Document ybkB840b4NwrO6mLXVpjGLqoX

\f r' % CAMBIUDGI3 06044S35 TO: John F. Morphy FROM: Peter Kostic CC: J. D. Kinrery J. F. Murphy, Jr DATE: I-3.rch 29, ISoo At the request cf Jach Stover, I have reviewed the file relative to the Zonolite dust premiers. In order that ell concerned ere familiar vith the background, following is e chronological sunenry cf correspondence and reports'releting to the problem; 1-23-59 v Report of examination of employee Walter Me Cueen, age 69, vho complained of shortness of breath on exertion for several years, vhich had worsened the past year or two, indicated that the can had extensive cystic disease of the lungs vith decrease in lung function, end recommended that he be put on light vork. His condition vas due to chronic bronchitis vhich did not appear to be produced by irritating dust. 6-22-59 Report of examination at the Western Montana Clinic of an employee (Wagner), vho complained of shortness of breath and fast heart stated "he vas suffering from Pulmonary Emphysema (loss of elasticity of lung.tissue)," and recommended that he stop smoking. Ko mention vas made of exposure to or inhalation of dust. 2-14-64- Report of examination of employee Eitel Ludvig, vho complained of chronic cough, heavy feeling in the chest and shortness of breath on exertion, indicated that he had Pulmonary Fibrosis end recom mended that'he avoid exposure to dust as much as possible. The lung condition, the report stated, vas due te inhalation of dust particles, almost certainly frem the asbestos content of the dust. May-June, 1964 Respirator;.- function tests made cm l4o men at Libby, Eccults cf the teszs shoved that their resgir; tor*-- function vas belov standard, that a serious hazard from. Fn umo-coniosis (lung condition resulting fren inhalation of dusn p .rticles) exists to employees at Libby. it reccmended that the analysis ta em plcted, and that further studies be carriei c it to quantitate the irritative properties cf the dust unices, cf course, inhalation of the same dust can te completely avoided. 22-5-64 Letter fron L. Fthat approved re > I--_<--- w-w uC* ^ tc ^ -v *CC i# Is -; - #1 ** j -v urge a I John F. Murphy 06<MK27tf -2- torch 2?, 19^-5 12-10-64 Letter from A. toe Arthur to C. R. Babb advised that it is an established company policy that all employees raking niiccd products as vail as those employees er.gagod in tocsins Perlite, oust at all tines wear a respirator, and ashed that people at their Atlanta plant he advised accordingly. 12-21-64 Letter frem F. Hupp to L. Park stated that the Maryland Casualty inspector covering the Wilders plant proaised to rake recommendation regarding approved respirator, hut Tailed to do so until called for the information. 12-29-64 Letter frea L. Pari to ?. Rupp recommended procedures for identifying, testing and caring for respirators, and a program of training of nev employees. 12-30-64 % Letter froa R. A. Bleich to J. A. Kelley explained the dust situation at the different operations at Libby, the control measures that have "been taken or will he taken, and some that vere under consideration. 1-2-65 Letter from E. D. Lovick to J. A. Kelley described the increase in the dust problem with the expansion of operation at Libby over the years, and the various medical studies that have been conducted on employees. Although X-rays showed lung disease in a number of employees (plus 20/j) a panel of five doctors "felt that they could not come up with any conclusion es to whether our mill operation presented an above-normal occurrence of respiratory trouble." 1-7-65 1-11-65 Letter from J. A. Kelley to G. W. Blackwood explained that arrangements had been made to transfer X-ray pictures end related information from Dr. Kelson, Libby plant physician, to Dr. Chenowith of Maryland .Casualty, for purposes of study and analysis. Kelley further stated that phasing out of the dry milling operation, which had been scheduled, would have to be done within the next year or two. He also indicated that the dust count of the mill dees not meet M.ontar.a standards. Letter from L. park to ?. Rupp reiterated the importance of providing approval respirator;r protaction and enforcement of wearing of such equipment at Wilders, cut pointed out that res pirators are not to be considered a substitute for engineering improvement of dust control. 1-13-65 Letter from J. A. Kelley to G. W. Blackwood reported that the situation at Libby is not as good as it should be as far as the State of Montana is concerned; that phasing out of the dry mill operations creating the major dust problem would bo expedited with soma definite plan by 9-1-65J and that the problem of physical condition, of employees ma'Jy be a long term problem. John F. Murphy 06046277 -3- torch 30, lfX-5 3-2-65 Letter fren J. A. Kelley to G. W. Blackvcsd, had no an attachment, A report of analysis and study of X-rays, breathing tests and other pertinent data relating to employeso at Libby, by a Dr. Spicer, a recognised lung specialist of the University of Maryland. Sore of the things Dr. Spicer had to say: 1. The tests dene by Dr. Kelson at Libby, end the data received by Spicer iron Kelscn vas inccrplete and unsatisfactory. 2. His (Spicer's) findings vere inconclusive. 3. He reeonnended e:rtensive and costly studies of employees, and a control group, to be repeated in 2-3 years. He pointed cut that the U. S. public Health Service night support such study. 3^-65 % Letter fren 7. II. Rupp to L. Park asked for Park's co--ents re garding Br. Spicer's report, and suggested that Maryland Casualty, as part of their service, proceed with the study. 3-5-65 Letter fron J. A. Kelley to G. W. Blackwood advised that an asbestos rider had been included in their vorknen's condensation insurance coverage. 3-23-65 Letter of transmittal fron F. U. Rupp to G. \1. Blackwood covered a letter fron L. Park to Rupp in which Park stated that "it vas not anticipated that Maryland Casualty was responsible for or should initiate the studies reconhenied by Dr. Spicer. He further pointed out that representatives of Maryland Casualty would take air samples at Libby on 3-21-65, for dust count and laboratory analysis. 5-5-65 Letter fron J. A. Kelley to G. W. 31ackvood advised "We are now getting nsst of our dust counts under 20 pen, and in fact, had one in Aoril that vas over 20 pen. The addition of -.he rest of the equipnen; should clean up this natter so that vs a under -.he run. Montana State originally required a re 50 p?n." (Xostic's content: PPM means parts per million par-.s of air by voiune. This torn is normally used to empress quancities of vapors or gases in the air. Mineral dust counts are erroressei as nppcf - million particles per cubic focj of air. I presume Kelley means 20 nppcf). 11-3-65 Letter from J. A. Kelley to G. W. Biackveo in dust collection at Libby and stated thr. processing, which will cut dm the dust, An attached report of dust counts in seven a range between U nppcf and 9 rpptf. The that the nanism allowable concentration escribed. progress --seev-n"NT*bew:ha-n0g*s1iTin^ ^ , fferenc arr23 3hc*.;ed s*r.' 10 nppcf John F. Murphy 0604S278 -h ltorch 30, 1966 12-23-65 Letter from L. Park to ?. W. Hupp recognized that progress in dust control vat baing rads at Libby, and explained hov and by whom maximum allowable concentrations are established, end the purpose of ouch standards. Ee stated further that "it is believed possible and practical that positive control of certain dusty operations '.rill establish and maintain the dust concentration below the maximum allowable concentration." 1- 25-66 % 2- 15-66 Letter from R. A. 31eich to ?. W. Rupp expressed dissatisfaction with Maryland Casualty's air sampling, communications, and general handling of the dust situation. Ee explained that although the mayi mm allo*.rable concentration for asbestos is 5 eppef, the Montana State Board of Eealth had, after an analysis of the dust, set their maximum for all dust at 20 nppcf, but because the air borne dust is 40$ asbestos, Libby has voluntarily set their standard at 10 nppcf. Letter from L. Park to P. Kostic stated that air samples are taken by Zoaolite on a regular basis (assured to bermnthly), and that the maximum allowable concentration used is that of the State of Montana, which he indicated as 5 nppcf. An attached report indicated that dust count samples froa seven different areas on 10-12-65 showed readings ranging froa U Eppef to 9* 3 nppcf. Five of the seven readings were above the 5 a level, it further stated that "Management at Libby seemed to feel that the total dust count is shown to a level that is as good as present equipment can maintain. As to a total concen tration of 5 nppcf; there seers to be a discrepancy in our thinking' on this figure." The inspector who wrote the report questioned as to which was the proper figure. COMMENTS I note there are scr.e conflicting remarks in the correspondence. Lovick states in a letter to Kelley, 1-2-55, "Montana has had for rar.y years an Industrial Accident Lav, but it vas not until 1?59 that they passed an industrial disease law. This lav specified certain specific industrial diseases for which emplo;-ers would be responsible. The only specified disease which ve felt would apply to us was Silicosis." Then he vent on to say further, "We have never had a known case of Silicosis areng our employees. Silicosis is caused by free Silca. The minerals ve process ere Silicates and do not cause Silicosis." On this point he is correct, Silicosis is caused by inhalation of free Silca over a number of years. It should be noted, however, that other lung diseases are caused by in halation of Silicates such as Asbestos, Mica, Soapstone, Talc and Porfani John F. Kurphy -5- Karcb 30, 1'/S' 0601S279 Another big difference expressed in the correspondence is in the naxinua allowable esneentration. L Park of Maryland Casualty specifies, as does the recognised authority (American Conference of Governmental Industrial Hygienists), that the MAC for asbestos is 5 In a letter - to F. W. Rupp fron 3. A. 31eich, 1-25-66, Bleich states "He have two distinct differences free vhat Mr. Park has indicated. Our dust contains Trenolite, not the asbestos type referred to, and cur dust is not all Trenolite. In Mr. Ben Hake's report of 5-23-63, Montana State Board of Health, the maxima allowable ccncentration for us is 20 mppsf total dust and 5 nppcf for asbestos. He explains that the asbestos concentration is calculated on the basis of our air-borae dust being 4C$ asbestos, in April, 1963# Mr* Wake had 6 samples analyzed by the U. S. Public Health Service which identified the mineral as Trenolite-Actinolite in concen tration varying fron 6.2$ to 22.5$. Hote the use of Trenolite instead of asbestos and the high of 22.5$ instead of 40$. However, this did not change the naxinun allowable concentration of 20 nppcf and 5 apoef. The 20 nppcf total multiplied by 40$ gives 8 nppcf instead of the allowable 5 nppc for Trenolite. Mr. Hake explained that the 20 crapcf total was acceptable because the 5 =ppcf for Trenolite was not an exact dividing line between a safe end unsafe condition, but a range at which control should be set. These Units were referred to in Mr. Hake's report of 10-2-64 end to our knowledge are still valid es far as the Montana State Board of Health is concerned. He have not been inspected since that tine. For our own purposes, ve have voluntarily set our standards at 10 nppcf total dust." Frankly, this letter confuses ns. Regarding the elaborate studies and tests recommended by Dr. Spicer, I feel that they would be of greater- value to the medical and health professions than to us. The fact that employees had contracted lung conditions is not as important now as determining if there is a health exposure (by scheduled air samplings and analysis), and applying . proper controls. Although there have been no workmen's compensation claims for chest disease since Maryland Casualty took over the risk in 19=3, it should be expected that there will be as tine goes by. I agree with L. Park of Maryland Casualty fshould not be con ilderei a substitute for prccer en Respirators are fine for short periods of time, but to one eight hours a day is next to impossible. a tors ols. SUI-SiARY It is ay recommendation that consideration bo given to the following: 1. Include chest X-rays in the pre-emoioyr.ent physical examination.;. 2. Reach an agreement as to what the maximum, allcvoble ccm.ccr.trr.ti -n should be, and use that as a standard. John F. Murphy 0604(^88 -6- March 30, 1966 3. Set up a schedule of monthly air samplings and laboratory analysis. If after a tire, the dust count is consistently below acceptable limits, the tests could be done on a quarterly basis. k. If analysis of the dust content in the air show3 that it is above the maxima limit, improve or add `to t*16 existing ventilating and/or dust collecting equipment. FK:gp % Signed in his absence QJja. Q7rJ Peter Kostic