Document zdz1Jx2YXYd4wxVEDM9y02zL7

DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE PUBLIC HEALTH SERVICE FOOD AND DRUG ADMINISTRATION June 8, 1972 AO DRESS REPLY TO. BUREAU OF PRODUCT SAFETY 5401 WES rSARD AVENUE ) BETHESDA. MARYLAND 20016 Standard Oil Co. of California 225 Bush Street San Francisco, California 94104 Attention: to. D. H. Barber Gentlemen: This is in response to your letter concerning asbestos-containing garments for general use. If the gloves you mention are to protect your company personnel only, and are not intended for use by the general public, they would not be affected by this proposed regulation. The proposed action is taken under the provisions of the Federal Hazardous Substances Act and therefore would apply only to articles intended or suitable for use in or around the household. It does not cover articles used strictly for industrial or commercial applications. We hope this clarifies the matter. If you have any further questions, please let us know. Sincerely yours. Dale C. Miller, Chief Compliance Guidance Staff Bureau of Product Safety CHEV BB 010472 P.15. PftVv. t WN' f.V'?. c:r / - * ""!> V GPC > * AMS V ` ' :____________ ___ i AU 1 I KMH* JPS 1 < MV.- "H/IS. HFAITH t A`, | > `IK.: f ..OC 1 1 JMA I ! slo kn 1 ; J.F ; 1 H 1 LBL 1 Return i Cir. ; ' Te-.ft | Hsl i **-i ft : April 24, 1972 ASBESTOS-COSTAHilirG GABMEOTS FOR GENERAL USE Mr. Charles C. Edvards Commissioner of Food & Drugs Department of Health, Education and Welfare Roan 6-68, 56OO Fishers lane Rockville, Maryland 20852 Attn: Hearing Clerk Dear Sir: Re Federal Register, Vol 37, Ho. 34 dated February 18, 1972 (21 CFR Part 191) in which you propose to order a ban on Asbestos-Containing Garments for General Use and limit them to "garments having a bona fide application for firefighting purposes", ve wish to go cm record as opposing and protesting such limitation. For sane twenty years now ire have furnished cor Company personnel . a cotton canvas sandwich asbestos glove to protect them from radiator burns on automotive pressure cooling systems. We hare no reports in our medical records to shew that asbestos from protective garments ever has caused a pul monary problem. We have other situations in refineries where welders and laborers working in high temperature atmospheres require protection of aluminized asbestos suits and hoods and we have no records of disabilities due to asbestos. We believe it legally and morally wrong to deprive employees the protection and to subject them to greater hazards because we cannot furnish them with this protective equipment simply because they are not fighting a fire. DEL:mc bcc-Mr. J. H. Gibson (IMC) Mr.,?. G. McKellar Mr. E. C. O'Relly Mr. F. M. Russell (GO) Mr. G. C. Smith Sincerely yours, Origin.'! D. H. 2<<* D. H. Barber CHEV BB 010473 September 26, 1972 'MEMO TO TF 110.$ ASBESTOS: S. L. Dryden talked with Ron Ott, Industrial Hygienist for the local OSHA Region today in order to clarify the monitoring requirements for asbestos under OSHA (29 CFR 1910.93a-). The standard merely states that samples are to be analyzed by "the membrane filter method at 400-^5CX.. .with phase contrast illumination." No reference is made to any guideline document. OSHA uses Appendix I of the UIOSH Criteria Document (CD) as their guideline, but it carries no legal clout. My specific questions related to the number of fields (or fibers) which must be counted and the minimum sampling time for statistical validity. The CD recommends inspecting as many fields as 'are necessary to count at least 100 fibers (generally 20 to 100 fields). Mr. Ott indicated that the counting procedure is a matter of professional judgement and following the CD is not essential for compliance with the monitoring requirements of the standard. In terms of sampling short-term operations, Mr. Ott felt that the wording of the standard ("No employee shall be exposed at any time to airborne concentrations.....in excess of 10 fibers/cc..") precludes the use of the CD recommendation of a 15 minimum sampling time for operations that take less than 15 minutes. That is, the sampling period should approximate the length of exposure in short-term operations, and additional sampling time which would dilute the sample cannot be tacked on. cc: R. W. Ader S. L. DHTDEN CHEV BB 010474 PROPOSED RULE MAKING 3G13 lerk. Department of Health. Educn- a new subparagraph (C) be added to changed in the light of comments c;;. and 'welfj.re. Room 6-T.8, 5600 5191-IKa.', as follows: received. ,rhfrs Lane. Rockville, McL 20C52, and isr be accomj.ar.icd by a memorandum r 'brief In support thereof. Received sa'J-.cnt"- may be roen in the alxrvc office using working hours. Monday through ridar. Dated: February 2. 1072. Virgil O. Wodicka. Director, Bureau of Foods. ITS. Doc.72-2467 Filed 2-17-72:8:47 ami 191.9 Banned h.-tj'jrdwii* >uffilan<w<. The official docket will be available for examination by interested persons at (r.) Under the authority of section 2', the Office of the Regional Ccuv-ti. (q) (1) (B) of the act, the Commissioner j Southwest Region, Federal Aviation Ad declares as banned hazardous substances; ministration. Fort Worth. Tex. An in the following articles because they pos formal docket will also be available for sess such ?. degree or nature cf hazard examination at lhe Office of the Chief. that adequate cautionary labeling can Air Traffic Division. not be written and the public health and It is proposed to amend Part 71 c the safety can bo served only by keeping such Federal Aviation Regulations as herein articles out of interstate commerce: I after set forth. ` In f 71.181 (27 FH. 2143), the Johnson I 21 CFR Pert 191 ] (6) General-use garments containing as City. Tex., transition area is amended bestos (other dtan such garments having a to read: bona fide application fer freighting JounjoN- Crrv, Trx. iSBESTOS-CONTA'NiNG GARMENTS FOR GENERAL USE Proposed Classification cs Banned Hazardous Subslence Inhalation of asbestos fibers for as Tite as 3 months has been reported as susing lung: cancer, mesothelioma, and mg fibrosis. To provide an emergency ztndard dealing with the exposure of nployees to asbestos dust, the Oecupacnal Safety and Health Administration 1 the Department of Labor promulgated 3 CFR 1910 .93 a in the Federal Eecister 1 December 7, 1971 (35 F.R. 23208), hich reads In. part "The 8-hour timeeighted averape airborne concentration f asbestos dust to winch employees are aposed shall rJbt exceed 5 fibers per milliter greater jfcan 5 microns in length, purposes). Interested persons may, within 60 days after publication hereof in the Federal Register, file with the Hearing Clerk, Department of Health. Education, and Welfare, Room 6-S8, 5500 Fishers Lane, Rockville, Md. 20852, written comments (preferably in quintuplicate) regarding this proposal. Comments may be ac companied by a memorandum or brief in support thereof. Received comments may be seen in the above office during work ing hours, Monday through Friday. Dated: February 12, 1372. Charles C. Edwards, Commissioner of Food and Drus/s.. (FB Doc.72-2457 FUed 2-17-72:8:45 am) That airspace extending upward frent 7C0 fees above tbe surface wimin a 10.5-uu!e ra dius of Joimrsc City P.2N uiUtv.de 30*:2'22" N.. longitude 98'3T03" \7.1 ar.d within 2.3 miles each side of the 173* bearing (ICS* magnetic) from the RDM t.vreadli'g from the :0.S-milc radius area to lli milts south of the BBN. In. addition to providing controlled air space for the instrument approach pro cedure serving Johnson City Airport, this proposed alteration will also accommo date an approach procedure for Shepherd Farm Airport Stonewall. Tex. This amendment is proposed under the ' authority of section 307ia) of the Fed eral Aviation Act of 1958 (49 U.S.C. 1348 and of section 6(c) of the Depart ment of. Transportation Act C49 U.S.C. 1655(c)). s determined by the membrane -filter >.ethcd at 400--ISO x magnification (4 Issued in Fcrt Worth, Tex., on Febru ary 10,1972. dfiimeter obicciive) phase contrast rumination." | R. V. Revxoles. Acting Director, Southwest Region. Said promulgation was based on recent mdies by the Matronal Institute for Oc- FetJercl' Aviation Administration . [FE. Doc.72-2473 Filed 2-17-72;B;46 am) upationnl Safety and Health, rtccmr.endations by the American Conference I 14 CrR Fart 71 ] I 14 CPU Part 71 ] f Governmental Industrial Hygienists, ud other relevant material. On the basis of reports and investiga (Airspace Docket Mo. 72-SIY-9] TRANSITION AREA [Airspace Docket Xo. 71-WD-52] TRANSITION AREA tors. the Ccmrr.issicner of Food and mugs learned that certain garments cada from an imported fabric contain- ng S percent of asbestos have been mar.etad. An ad hoc committee of five ex erts in the field of asbesros toxicity was Froposed Alteration The Federal Aviation. Administration is considering amending Part 71 of the Federal Aviation Regulations to alter the Johnson City, Tex., 700-foct transition Proposed Alteration The Federal Aviation Administration tFAA) is considering an amendment to Part 71 of tbe Federal Aviation Regula tions that would alter the Fortune, ppotated to evaluate the health signifi- area. Calif., transition area. ar.ee of asbestos in such garments. The . Interested persons may submit such Interested persons may participate in emmittee concluded that the use cf as written data, views, or arguments as they the proposed rule making by submitting bestos in garments for the.general pub- may desire. Communications should be such written data, views, cr arguments :o was inappioprlifte and presented an submitted in triplicate to Chief, Airspace as they may desire. Communications hiwarranted ha sard of toxicity.' and Procedures Branch, Southwest should identify the airspace docket num Xocorcincly, the Commissioner finds' Region, Federal Aviation Administra ber and be submitted in triplicate to the hat asbestos-containing garments mar- tion, Post Office Box 1633, Fort Worth. Director, Western Region. Attention: :eted for general use. other than thosej TX 7G101. All communications received' Chief, Air Traffic Division. Federal Avia laving a bona fide application for fire- within 30 days after publication of this tion Administration, 5051 Wess Man ighting, are hazardous substances, that! notice in the Federal Eecisiex will be chester Avenue, Post Office Bex 32007. :autionai-y Libeling is inadequate to pro-. considered before action is taken on the V/orldway Festal Center. Lcs Angeles. (set the public healih and safety, and! proposed amendment. Mo public hearing CA 9C009. AR communications received therefore, that such articles should bet is contemplated at ' this time, but within 30 days after publication of tins tept from interstate commerce. Therefore, pursuant to provisions cf :kc Federal Hazardous Substances Act 'sec. 2<0.1 (11 (3). (2), 74 Stat. 374. as amended SO Stat. 13C-1-5; 15 U.S.C. 1201) rad of the Federal Food. Drug and Cos meric Act (sec., 701 <c), 12 Sint. 1055, as amended; 21 77.S.C. 371'c)>, and under authority d-.-le-rated to him (21 Cl'S 2.1201, the Commissioner proposes that arrangements for informal conferences with Federal Aviation Administration officials may be made by contacting the Chief, Airspace and Procedures Branch. Any data, views, or arguments presented during tuch conferences must also be submitted in writing in accordance with this notice in order to become part of the record for coLrlder&tionl The pro posal contained in this notice may be notice in the Federal F.zgistee will be considered before action is taken on the proposed amendment. The proposal ccutaiaed in tliis notice may be changed in the light of comments received. An official docket will bo available fnr examination by interested persona at the Federal Aviation Administration. Office cf tlso General CctwueL Attention: Rules Docket, 800 Independence Avenue d*-V,, FEOtRAl REGISTER, VOL 37, NO. 3---FRIDAY, KSRUARr is. 1?72 CHEV BB 010475 PROCEDURE FOR COLLECTION OF ASBESTOS AND FREE SIRICA SAMPLES ON MEMBRANE FILTERS Asbestos Fibers It is recommended that a system manufactured by C. F. Casella and Co., Inc.. Electro-Neui ronics, Inc., Mine Safety Appliances Co. , Radiation Detection Equipment, Inc. , or National Environmental Instruments, Inc. be used. Each of these systems consists of a rechargeable battery powered-pump which operates at about 2 liters per minute. A Millipore Monitor (Cat. No. MAWP 0 37 0A) which includes a Type AA filter having 0, Sfi pores is used to collect the sample. This is a 3 piece monitor. The face cap should be removed and the monitor used open-face during sampling. In order to obtain concentrations of fibers'on the filters which are not too large for counting, the following guidelines are presented: Recommended Sampling Times Areas Sampled 5 min. Very dusty cloud with some fallout as viewed away from direct sunlight 10 min. Medium dusty cloud 15 min. to S hours Slight cloud, plus knowledge that some asbestos fibers arc- suspended in the air. For determining the 8-hour time-weighted average airborne concentration of asbestos, sampling times of 1.5 to 8 hours are usually appropriate. The maximum short term concentration should be evaluated over periods of at least 15 minutes and preferably 30 minutes. 'Free Silica When collecting a sample on Millipore for Free Silica or Quartz analysis, the same systems are used as described for collecting asbestos-fibers. The monitor is preceded by a cyclone having a 10/x cutoff in order to collect a respiratory, sample on the filter. A National Environmental Ins.tr aments, Inc., Model 2.8 cyclone with the Monitor Cat. No. M000 037 FO with 37 mm Type 00 AA plain white filters with 0.8 [x pores and 37 mm 37 mm diameter pads bene?.th the filters is recommended. It is suggested that 1 to 8 milligrams of dust be collected in each filter. This amount can usually be collected in 4 to 8 hours.' Wll/kc BB 010476