Document xzGqkqneVbrjnewjGbdpg9w0G

FILE NAME Quebec Asbestos Mining Association QAMA DATE 1977 June 1 DOC QAMA131 DOCUMENT DESCRIPTION Submission of the QAMA to the Office of Hazardous Materials Operations with Cover Letter to AIA BYERS CASGRAIN MCNALLY DINGLE BENN & LEFEBVRE BARRISTERS AND SOLICITORS File DO.T. POST OFFICE 90 27 PLACE URIA QUE MONTREAL DONALD N. SYERS PAUL FOISE C. JEAN BAZIN PAUL R. MAR^ ~AND COATRE RICHEA RUSSELL MERIFIELD CLAUDE CLAUDE LAPORTE SYLVAN SYLVAN SESLAURIERS PHILIPPE CASGRAI Q.N G. VINCENT F. LEFEBVRE LEFEBVRE ROBERT S CARSWELL PIERRE FOURNIER JOHN F. LEMIEULEMXIEUX ALLAN A VASS MICHEA SOULEY SOULEY PIERRE CHEVERRY HERBERT B. MENALLY OC FREDERICK W. BENN RAY E. LAWSON JEAN DUPER^ PIERRE LANGLOIS ALAN RUBIN JAMES LEAVY DANIELLE WILLIAMS June 1st 1977 24TH FLOOR STOCK EXCHANGE TOWER TELEPHONE TELEPHONE TELEPHONE AND TELECOR TELECOR ER 514 878-3711 TELEX 05-24 CABLE tw MAG MA EGEEE R.H. Mereness Executive Director Asbestos Information Association- North America 1835 K Street N.W. Washington U.S.A. D.C. 20006 Dear Sir On instructions from the QAMA I enclosing herewith submission of the QAMA to Office of Hazardous Materials Operations in Washington am the I would appreciate appreciate your comments Casgra / Philippe Philippe Casgra PC Encl c.c Paul Filteau Maurice E. Taschereau Marcel Dorais J.R.M. Hutcheson Mike Prus M.J. Messel Roland Gagnon Dr. Michel Lesage 2 15047 JHM BYERS CASGRAIN MCNALLY DINGLE BENN & LEFEBVRE BARRISTERS AND SOLICITORS DONALD N BYERS C. PAUL F DINGLE C. JEAN BAZIN PAUL R. MARCHANO CLAIRE RICHER RUSSELL MERIFIELD P. CLAUDE LAPORTE LAPORTE SYLVAIN OESLAUR.ERS OESLAUR.ERS OESLAUR.ERS PHILIPPE CASGRAI Q.N C. VINCENT F. LEFEBVRE ROBERT 5. CARSWELL PIERRE FOURNIER JOHN F. LEMIEUX ALLAN A MASS MICHELA MICHELA COULET PIERRE ETCHEVERAY HERBERT 8. MCNALL0Y .C. FREDERICK W. BENN RAY E LAWSON JEAN DUP^ R^ PIERRE LANGLOIS ALAN RUBIN JAMES LEAVT DANIELLE WILLIAMS June 1st 1977 POST OFFICE BOX 27 PLACE VICTORIA QUE MONTREAL K42 A6 24TH FLOOR STOCK EXCHANGE TOWER TELEPHONE AND TELECOPIER 514 878-3711 TELEX 05-24195 CABLE MAGEE Docket Section Office of Hazardous Materials Department of Transportation Washington D.C. 20590 U.S.A. Operations Dear Sirs Re Docket No. HM - 145 We represent the Quebec Asbestos Mining Association the Association which consists of all the major producers of asbestos in the Province of Quebec We have noted the Advance Notice of Proposed Rulemaking the advance Notice which the Materials Transportation Bureau of the Department of Transportation issued on December 6 1976 and published in the Federal Register on December 9 1976 dealing with the transport- ation of hazardous substances This Advance Notice re- quested comment on its proposals by interested parties and in particular on matters listed in paragraphs 1 to 10 of the section of the Notice entitled Request for Comment wishes to In response to this submit the following request the Association points for your consideration 1 We note that the proposed rules concerning transportation of hazardous materials are designed to meet the concerns expressed in various quarters about the transportation of materials whose potential release during or incident to transportation may result in unreasonable risk to property the environment or to human health and JHM 15048 ... glue locking paper and rubber inflatable dunnage bags pallets lift trucks shrink wrap and stretch wrap techniques The industry has also evaluated different types of transportation equipment such as containers in the Export market and to a lesser degree to the U.S. Some fibre is shipped to the U.S. and Canada by truck where it is economically feasible The primary method of transportation to the U.S.A. is by rail The industry is presently negotiating with the railways for assigned DFB carS Three the present time 3 types of bags are in wide use at 1. Woven and plain polyethylene 2 3 ply unsized Kraft paper 3 3 ply sized Kraft paper Woven and plain poly is recommended to all customers where the bag is not consumed in the mix because of its strength and resistance to damage This bag must be disposed of after it is opened and the contents removed 3 ply unsized Kraft paper bags are requested by users who place bags and content into a wet mix process In this case the bags are not opened and are consumed along with the fibre in the mix This eliminates a potential dust problem and the necessity of disposing of the bag It is imperative that this method of packaging be retained until a suitable alternative can be developed The industry is at this time conducting experiments with respect to various possible improvements including the production and shipping of asbestos fibre in high density block form 3 The possible biological hazards resulting from inhalation of asbestos fibres are totally different from that resulting from most other substances mentioned in the Advance Notices as being hazardous such as sulphuric acid whose effects are immediate and violent 6 The Association does not believe that it is necessary in the interest of health and safety to place health warning notices on rail cars or trucks carrying asbestos fibre since such notices conforming to OSHA requirements already exist on the bags containing such fibre However the Association believes that notices could appear on bag or where this is impractical that notices could be placed inside rail cars or trucks carrying asbestos fibre instructing that in case of an accident involving the breakage of bags of fibre such bags should be sprayed with water to avoid creation of dust In addition re iratory protective devices could be provided to those having to deal with transloading or accidental spillage of fibre Respirators are widely available which have been tested and approved by experts of McGill University Montreal under the auspices of the Institute of Occupational and Environmental Health 7 The asbestos and asbestos products industries have been the victims not only of inflation and of the general recession in economic activity but also of much unfavourable publicity in recent years and now face increasing competition in their traditional outlets from substitute materials In these circumstances the sale and marketing of asbestos is becoming more difficult and the imposition of regulations over and above those necessary to protect against any real dangers to health and safety in the transportation of asbestos fibre would have substantial and unfavourable consequences on the industry We shall be glad to answer have concerning the above comments and way you deem appropriate any questions to assist you you may in any Yours truly BYERS MCNALLY DINGLE PC lippe Casgrain Q.Z. Q.Z. JHM 15052