Document wr2Nb2ygjvDbdQKgDYZOd28V6
FILE NAME Talc TALC
DATE 1973
DOC TALC309
DOCUMENT DESCRIPTION Senate Hearings for the Toxic Substances Control Act of 1973 CSPI comment BC Notes Center for Science in the Public Interest Oct. 4 1972 calls on government to revoke Generally Recognized As Safe status of talc largely because of asbestos pp 179-180
Barry Castleman Comments - Center for Science in the Public Interest Oct. 4 1972 calls on government to revoke Generally Recognized As Safe status of talc largely because of asbestos
pp 179-180
occupational \ occupational
dozen
ocupational
dozen
past =
oc upational
CONTROL ACT TOXIC SUBSTANCES
ee
OF 1973
HEARINGS
BEFORE THE
ENVIRONMENT SUBCOMMITTEE
OF THE
COMMITTEE ON COMMERCE
UNITED STATES SENATE
NINETY CONGRESS
FIRST SESSION
ON
S. 426 and Amendments 1 8 and 9
TO REGULATE INTERSTATE COMMERCE BY REQUIRING PRE-
MARKET TESTING OF NEW CHEMICAL SUBSTANCES AND TO PROVIDE FOR SCREENING OF THE RESULTS OF SUCH TEST-
ING PRIOR TO COMMERCIAL PRODUCTION TO REQUIRE TESTING OF CERTAIN EXISTING CHEMICAL SUBSTANCES TO
AUTHORIZE THE REGULATION OF THE USE AND DIS-
TRIBUTION OF CHEMICAL SUBSTANCES AND FOR OTHER
PURPOSES
S. 888
TO BE KNOWN AS THE TOXIC SUBSTANCES CONTROL
ACT OF 1973
FEBRUARY 23 26 AND MARCH 21 1973
Serial No. 93-18
|
Printed for the use of the Committee on Commerce
94-872 O
a
U.S. GOVERNMENT GOVERNMENT
PRINTING OFFICE WASHINGTON : 1978
JUNE Washington
potential caling patleentniounms practice consequent
urban and nonurban consequent
1,171 D.C.
is
in
in
reply
reply
ttoo your
MMaarrcchh
29
letter
GENTLEMEN This
new
calling
spaces in new buildings as returnreturn
using ceiling of introducing asbestos fire
hazard
protection to
about airborne asbestos fibers protection fibers and
concerned the initial list of
On
hazardous in
air
as Air Act amended Federal hazardous
pollutants regulations polutants
pollutant ambient air of any
pol utant the
1972. During the past year
so
listed
control control
listed
March 3f1or asbestos in some fifty have
20 program analyzed at a rate of about
are being
arta
These sampling San pilot studyto NevertheCloelsusmbusconcentratio questioninssidseoobunildings California exploratory initiate samples
month
your letter
whether the EnvironmentalEnvironmental
that
authority
to
require
modifications
in
building
has
Agency
contamination of indoor
potentialpotential
been made
buildings in
have already
Clara
York and in Berkeley
measure asbestos Our
buildings as ent plans aoruetsitdoe public buildings buildings as
as a competent
concentratio
contractor inside and
can
can
say that we welcome the continued efforts of
found me again Law to help us identify problems of the Center fr
environment Study of Responsive
to deal with such problems
environment
develop effective programs
Sincerely yours
WILLIAM D. RUCKELSHAUS
APPENDIX 1c
AdminiAsdmtirniasttraotorr Adminstrator
respond to your letter of
also I believe I covered
It fully December discusion sumary
In
in sum ary summary
This materials containing spraying containg promulgated standards construction
eliminatefuture situations asbestos asbetos Contrary Indoor the construction construction
magnitude discussion discussion
:
summary
standards for hhaazardzous ardous pollutants
standards standards
spraying
emission
spraying
construction buildings This should should eliminate
of problem
or
just don't exist
Racke to Mr.
pointspoints Mr. Racke rarisaedised
your
containing
be
over
promulgated
promulgated
in
measurements earlier our the sampling program has been limited to EPA's asbestos buildings plenum chambers in
indica
air indica
regulations from successful promulgation of the
the
appropriate potential intointo
the
outdoor
air
it
seems
ap ropriate
asbestos resources into programs to define the
formalization indoor our also in keeping with a recent
formalization in concern pollutants We will initiate a modest sampling relate on asbestos in indoor air and attempt program data base
is a potential to
at this time
of of
to
relate it to pastpast
datqauestion such regulations advisability considerations need whether construction However ambiguous until a
develop
practices
of the
advisability
for and
of control
regulations
construction
at this time
and
are all
authority authority
determine
we
we have a problemproblem and we will
until discussion on
a later date
monitoring to develop a monitoring study and keep you informed
begin
Robert Neligan and Data Mr.
Director Monitoring
prog
andoreuAspornnsibalely- presumed make schedules of Air Quality Planning and Standards will be responsible responsible
Office
I have
on your knowledge and interest
assured
program
to
would be willing
recommendations to him and
discus- you
of sampling sites and be available for additional
on selection
sions problem Sincerely sions
on the
with you andandhope we can continue the exchange
enjoyed talking
enjoyed yours
B. J. STEIGERWALD
Air
Quality
Director
Director Air Quality Planning and Standards
CENTER FOR SCIENCE IN THE PUBLIC INTEREST
APPENDIX 2
15 Washington D.C. December 1972 1972
Mr. WILLIAM RUCKELSHAUS
Protection
Environmental Protection Agency
Administrator mentioned Washington D.C.
I sent a letter to you on March 24 1971 eall
DEAR
MR
RUCKELSHAUS hazards
arising
from
ciculation
of
air
in buildings
your attention to asbestos
interior surfaces It was requested
through areas with exposed asbestos on
to what extent these plenums
that you embark upon a program to determine
1971 you
are contaminated by asbestos In your reply of June 1
inside
concentrations having plans to initiate a pilot study to measure asbestos
seriously o
and outside public buildings After an 18 month lapse we are
require authority
cerned about your findings
has the authority to
require It is evident from your letter that your agency
potential contamination modifications in building design in order to control
s have been initiated
indoor air I would like to know what corrective actions
correspondence published the result of the above study One final request May I have permission to use our
appendix to a report on asbestos which is to be
corespondence in
1973
in January
prompt reply would be deeply appreciated
Thank you for considering these requests
Sincerely yours
FRITSCH Ph
ALBERT J. FRITSCH
APPENDIX 1D
AGENCY
Washington PROTECTION today Science ENVIRONMENTAL January AND OFFICE OF AIR QUALITY PLANNING N.O. Research Triangle Park
Dr. ALBERT J. FRITSCH
Center for Science FRITSCH
in the Public Interest convceornsvaetrisoantion
Washington FRITSCH conversation comerc the problem DEAR
This is to confirm our telephone selected
of asbestos concentrations in indoor air of
CENTER FOR SCIENCE IN THE PUBLIC INTEREST Washington D.C. October , 1972
HEARING
CLERK
of Health
Education
and
Welfare
DeNAingperedimnawts rotYnmoegrnkt knownsubstantial sanctionofrelahtaiznmagartedrsialwsegrreeoaxsntpaemropstlatleeehdesseofcom- substantpiraolposed miners insulation different observed 40 Rockville Md
to comment on the
new regu-
DEAR SIR OR MADAM We are writing
to sanctioned food
lations Federal Register August 12
tale
ingredients and a change in the prior sanction sanction for
fractions
fractions
tre-
has long been that many taleasnacloynzteadin51 of
molite asbestos Schultz and Williams
in
mercial
tale
and
found
tremolite
asbestos present
study
miners
amounts of 17. Kleinfeld et substantial performed a mortality The tale work- these
excess lung cancer
and found a
handled contained 25 to 35 tremolite.3
in Seli-
asbestos workers even more severe
these men
investigations investigations 4 of mortality of
of the
gheannddeleradatla containing ascbomepsettioncgsompetingveexrpsoussure Gastreoxpiecntetdtehescdatnceeiranatlchancer dhanedlaedth occupational have numbecarusse Hygiene who
and amosite
deaths chrysotile
asbestos
expected based
cancer
attributable to
versus11.2 expected
was was the
Mortalitwyas datacaaunsde moafldiegantahntinme3s7otchaesleisoma ofthexetrempeelyritoextremenly erumare cause of of
in an additional 14. This latter is an
In the
certainly would
larger
risks of
and
cases
population There
competing expected
66
the above categories were it not for (
none
versus
asbestosis
8.9
expected
pleural
mesothelioma
asbestosisasbestosis 27 versus none expected
24 75 1942
R. Z. and C. R. Williams J. Industrial 663 1967 International .
3
Castleman International PrivatePrivate
Comunication
M.
et
Com unication
Arch
Environ
Health
B.
Castleman
Castleman
August
the International
Johan esburg p Sellkoff Communication M. Kleinfeld to Proceedings 180
et al
Press
Pneumoconiosis JohannesburgJohanesburg 1969 Capetown Oxford University
ConferencConeference
deCOV
181
the National for
the literature
Air Polution
stated fiber not authors that Polution Pollution In review
asbestos determined tration than one enjoy malignat more
safe There compositions more tale Taalc have been are
has
by
to induce
been Control
tale will continue to in
concerned There is
strong similarity
particles have
malignant
the
tumot malignant detrmineddetrmined
tumot
found compositions number patients compsitons silicates silicates
tiformtiform
from a
of patients
taken tisstuissuee particles
were found
in
these with
epidemiological epidemiological tumors ovarian of workers studies within
asbestos of
workers
epidemiolgical epidemiological of rerson
epidemiological
with pure
epidemiological know etc. cancerknow foods
vaginal sprays
aWlse thbeegining overdue We puorn easbestiform foods foods we tale preerpfourtmsedwe concludeadoption beginning conclude that ban
tale
safe for
above
The presently proposed proposed ban of
safe
view of
overdue
overdue
ban
favor its
beginning
tee
acaleilviivliileises
adoption
faa sur
the urge urge
-
beginning ifs
a
parenteral Food parenteral the '
tales items items
of
filtering
such items yours,
filtering
beer whiskey and
parenteral drugs Food Food
ALBERT MICHAEL
FJR.ITSCH
FRITSCH
MICHAEL
and
Ph.D.
MICHAEL FRITSCH Ph.D. AAPPPPENEDINXDIX 3
BABBY CASTLEMAN JACOBSON
CASTLEMAN JACOBSON
Ph.D.
CASTLEMAN
Ph.D. Ph.D.
SCIENCE CENTER CENTER
FOR
SCIENCE
IN THE
7s,
D.C. PUBLIC galWashington galWashington
November D.
RUCKELSHAUS
Environmental
Protection
Protection
Agency
INTEREST
D.C. November
9 1972
1972
Adminstrao AdminstratorAdministratorD.C.
Washington National We have been followi for so
.
.
Lo
StandardsStandards National Emission
hazardous
tapnrotgrses toward proposed hazardous air progres hazrdous asbestos pollu particularly concerned which about proposed
hazardous
We are contaminant in our environment standards
pollu air
is a major
.
for
Our of the proposed Standard for Hazardous
center
approval has asbestos Pollutants copies
sent to you for final
Baltimore Mercury approval Beryllium and of the Baltimore County Health the comments
: received Further
CountyHealth Department Asbestoshave There is no need to repeat the
Department
seen on this with all the contents of
Department letter
November 6th We concur
and docu immediate consideration
that letter letter
should be given
it Standard Overall our impression is that the watered
ANG think
version of
to regulation it the approval sent you for
is not really a regulation
is a
Standard
tbhuesiFneedsesraals RegiussutalerAlolf sDiexcseemcbtieorns7of19th7e1 Shtaavnedabreden as originally proposed operate
be n proposed completely We remind you that under the law the weakened
proposed
discarded
| of must be regulated by the EnvironmentalEnvironmental emissionhazhazaardrousdous
pollutants air margin
ProtectiProotnection
Agency provide an ample margin of safety to protect the public health
the Balti makes embarasing more County letter
clear you will be put in an
As
visible embarasing position | embarrassing to explain how the sanctioning of
asbest asbest
callecaflde romdemolition or any source is protective of the emissions of
is
health public There little need to remind you of the voluminousvoluminous medical literature on
We | asbestos We are all familiar with manymany reported malignant lioma of the pleura and peritoneumperitoneum a disease
population quite
cases of
poulation populationbut common workemrisneraasrbeestos per mental that
quite common
among asbestos
.
disease whose only knownknown exposure to
lived or worked near a
on mesothe
malignant
general
in the a per 4 numberof was was
plant or
fabrication have cancer men who are
occupationallaymongamong is 100 times as common as
eee
where asbestos was handled
manufacturing
Lung exposed to asbestos and smoke cigarettes among
handle among men who neither smoke nornor handle
asbestos
asbestos
@ mf ens
5
common as among men who
simultaneously
but dodo \
smoke simultaneously simultaneously subjected simultaneously 7 simultaneously
times simultaneously
subjected to
competing
not
competing not risks work simultaneously asbestosis.od
not mesotheliomamesothelioma simultaneously estimate | were strointestinal
impossible asbestos poulation
impos ible
the level a of
asbestos
can be continuously continuously
exposed
whic the
with
cigarette mesothelioma population which exposure stroinestal
poulation population smoking which population
of which cancer, smoking
population
poulation population sothelloma contly Enblishea risk ine
sotheloma Gocum, exposed i to Age
WAS ere is iney Heb diseases in
ent
re
went
risks
with
of
sa
mesothelioma
increased to
can be of ent exposed
other than one
omit of 2strentomnalignthaonntooeatpaS. more one induce malignant sotheloma induce necessary At1 fibe@efroe. iist ia statted that
than
fiber is necessary to
y
to
)
a subject
than of
- In the P ted
; It malignant
tumor
malignant malignant a
tab.
tr Pot. ined
protection subject public resgtulaantdiaornd The tumor and occupational for gone ritual criterion whether
the
protection protectionprotection of the public public health
only
Labor
criterion
accept-
the protection
the ritual
promulgating a
promulgating promulgating of
for occupational
occupational
has
ant is the
1
asbestos
construction
occupational
exposure
vicinity
asbestos construction
exposure which
throughthrough materials strongly through
the
vicinityvicinPirottyection Protection
Agency
to
adopt
a
much
materials We
tougher
strongly
which
urge
Environmental Environmental Protection Protection 80 at the earliest poasip le tougher
on
Environmental yours FRITSCH Ph.Da.sbestos SiEnnvirocnmenetalrelSinycerelySincerely
ALBERT J.
Occupational Safety BARRY CASTLEMAN
toto Mr. E.C. GuentherGuenther
CASTLEMAN
Letter
Appendix
DirectoDrirector
M.S.E.
and Health
Administration
Administration
APPENDIX 4
TER FOR SCIENCE IN THE PUBLIC INTERST
WashingtonWashington D.D.C. C. IJNuTlEyR1E7ST1972
SGeUcEreNtTaHrEyR Mr.
E.
C.
Asitan
of Labor
Administration
Safety and Health Administration
peMOSsrotAeacubssnlccibtsruheiedIpbsetadotsiRonal limit developing authoritUiension Environmental Occupational Occupational Safety
bail
We deplore your recently promulgated Standard for
Dust
Federal
Register
Vol
37
No.
June 7
to
1972 It is well
in the medical literature that workers exposed to the conditions
established a greatly enhanced risk of
fatal asbestos diseases
established a centime- prescribed
face
followed
pleas
by
the
AFL
for
a
one
fiber
per cubic
action
Oil Chemical and
Your action
cc
limit
limit and
by
the
Oil
Chemical
and
Atomic
Workers
for a
ter 1
exposure
as well as statements by recognized
the
Sinai
Sciences Laboratory to the effect that 40 of
Mount deaths
of
insulation
workers
in
this
country
whose
timeweighted
exposure
to
asbestos is 3 cc are attributable to occupational asbestos exposure This fact
was revealed at the March 1972 Hearings
Oc upational
The the Criteria document prepared byby the NationalNational Institute Ocupational
Ocupational Asbestos makes it clear that Safety and Health Ocupational clear that while a
cc level cannot
Ocupational Exposure Exposure
be declared safe, it is undoubtedly less hazardous
made to reach that level
industrywide
reviewing on asbestos
Tabershaw and If isshouldsalitefraturee literature natural 1967 compared asbestos to radiation there a
be exposed large human populations can
above natural background background to which
with no enhanced risk to developing
not government's certain diseases, tthhisis threshold is not known it will not soon be known and it
quite be appears toto be
appears
low We are perplexed and alarma ed beey. e the e gn radia radia