Document zdoegbO45j3yXyerE170omoYz

FILE NAME: Asbestos Cement Pipe and Sheet (ACPS) DATE: 1986 Feb 25 DOC#: ACPS121 DOCUMENT DESCRIPTION: J-M Memo Response to Feb 18 Memo - Plant Workers Exposed to Asbestos Do Not Need to Wear Respirators Subject; RECEIVED pB 28 1986 INTERNAL RECOMMENDATION AND/OR AUTHBBlZJfflffll _________________________________________________________________________Page; NEED FOR RESPIRATORS E. E. WANG *S LETTER OF 2-18-86 Explanation: I very much disagree with the requirement that "all plant workers exposed to the asbestos environment (in our case, everyone), regardless of the current airborne asbestos concentration are required to wear their suitable respirators". First and foremost, the recommendation made by the California Air Resources Board was questioned by A1A/NA (copy attached) as well as the State of California. It Is my understanding that when thi-s proposal was reviewed by higher officials in California they also questioned some of the data and the Board was instructed to review pro cedures and "facts" and answer some questions prior to continued review of the proposal. 1 personally disagree with this assessment and requirement. It appears to be in line with the normal over-reaction of people who have not been well trained in the history and studies of asbestos fibre. One must first note that asbestos Is a natural element and in some areas exposure naturally exceeds our plant exposure levels, with no_ increase in asbestos-related disease. . If this is a Corporate decision, how do we enforce the rule? Denison has been to court several times to stop smoking on plant property, and as you know, we were only \ I able to restrict the smoking areas. Respirators are at best a very objectionable item to our employees. I feel that this rule would be challenged and without any factual reason to require respirators, we would lose. If we are going on the assumption that a threshhold exposure level must be established ! before any exposure can be allowed, we need to put everyone into a totally clean atmosphere. I do not know of a single item that has a truly known safe threshhold exposure level. If J-M A/C Corporation truly feels that this is a necessary requirement, they should not produce nor sell A/C pipe. Prepared By: T. E. Lohmanjl/ ; Supervisor or Manager: Department Manager: - -- -- 7 d ^ p re i^ e c ^ , r rf ! Vice President: i 1 Joe Chen l President: o C*'66 J SC-JMM-3125 f National Research Council and Ontario Royal Commission, as well as Dr. Nicholson who has performed risk assessments for both E?A and OSHA. In each of these assessments, the same issues of choice of epidemiology studies, conversion of historical measurements to today's monitored exposures, determination of the shape of the dose-response curve, and consideration of fiber types arise. "A detailed assessment of these issues was contained in Dr. Kennv 5. Crur.o 1s comments, on the OSHA/Nichoison risk as sessment. Dr. Crump is a recognized risk assessment"expert who has often worked for EPA and OSHA. As Dr. Crump em phasizes in his report, each of-the government risk assess ments, and for similar reasons California's new assessment, must be understood to be "upper limit assessments" because they: (1) Assume a linear dose-response relationship,- (2) Assume.the same potency for all forms of asbestos despite significant data indica ting lesser potency for chrysotile, parti cularly, with respect to mesothelioma; and (3) Include within the calculated risk the substantial portion of the lung cancer risk attributable to cigarette smoking." "In addition, because.the California risk assessment is intended to predict risks at much lower exposure lvels (0.001 fibers/cc and lower vs. 0.1 fibers/cc and higher)than the OSHA risk assessment, even greater uncertainty exists that such upper level limit assessments are appro priate. In extrapolating risks to even lower levels than OSHA_extrapolated, considerable likelihood exists that the linear dose-response relationship overestimates human risk." "We also caution the Board against over-reliance on the expo sure estimates set forth in the'draft report. As the draft report acknowledges, no long-term asbestos sampling data are available and no method has been developed to extrapolate long-term average concentrations from limited short-term observations. "Despite those limitations, it is significant to note that the 3card's extensive monitoring program in fact found very little, iz any, evidence that the identified emission sources contributed to ambient asbestos'levels. The very low. level of ambient asbestos found can be seen in two ways." "Accordingly, it would appear that the sampling study con firms that little reason should exist for concern about potential asbestos emission sources in California.^ Even short term measurements in areas where asbestos emitters D 002159 race 5 might be expected to be most likely to be contributing to ambient exposures have not identified any significant con tributions to asbestos levels." The Beard responded by letter of Nov. 6 to AIA/NA and ac knowledged the limitations of their exposure estimates based on the monitoring of local sites. However, the in tent, the Board asserts, was to document asbestos levels anc the monitoring study accomplished this from their point of view. The Board referred AIA/NA's questions about risk assessment to the~state Department of Health Services, which will issue a response at a later time. D 002160