Document zzGavLZyxvNNxmZZ9O5qGKVBB

r t ASBESTOS UNION CARB10E CORPORATION METALS DIVISION P. 0. SOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 71S-278-3376 November 21, 1978 {see attached distribution list) Dear Enclosed are copies of the following items presented to the Standards Board in connection with the spraying of asbestos-containing materials: 1. Dr. Rhodes' oral testimony. 2. Additional testimony on H. B. Fuller test presented at the Hearing. 3. Additional testimony submitted under a 15-day extension of the Hearing. These items are in addition to the written testimony sent to you last month. The Hearing seemed to go well for the products containing wetted and encapsu lated fibers. Dr. Rhodes and Mr. Beemer are to be congratulated for their excellent oral presentations and handling of questions. I plan to meet with Dr. Ottoboni the week of December 4 to determine the potential action of the Board, who were reminded during the Hearing that a decision by early in 1979 would be appreciated. We will keep you informed of any activities concerning the issue, but don't hesitate to call if you have any questions. Harry will be out of town until the first of December. Very truly yours. *J6hn L. Myers (/ Marketing Manager 0LM:dal Enclosures CC: Dr. H. B. Rhodes UCC 013866 A Mr. Paul Beemer W. W. Henry Company 5131 Becket Street Huntington Park, CA 90058 Mrs. Stella Miller National Paint & Coatings Assoc. 1500 Rhode Island Ave. NW Washington, DC 20005 Mr. Herb Duckett, Executive Secretary Roofing Contractors Assoc, of So. Calif., Inc. 11401 East Valley Blvd. El Monte, CA 91731 213-579-1276 . Mr. B. J. Pigg Asbestos Information Assoc./NA 1745 Jefferson Davis Hwy. Crystal Square 4, Suite 509 Arlington, VA 22202 Mr. John T. Banister, Executive Director Associated Rocfirig Contractors of the Bay Area Counties, Inc. 8301 Edgewater Drive Oakland, CA 94621 Mr. Jim Hay The Flintkote Company 5500 S. Alameda Street Los Angeles, CA 90051 Mr. M. M. Golden Standard Brands Paint Co., Inc. 4300 W. 190th Street Torrance, CA 90509 Mr. R. C. Nunn Chevron Research Company 576 Standard Avenue Richmorid, CA 94802 415-237-4411 ext. 4139 Mr. Dimitry Poutiatine Johns-Manville Corporation Ken-Caryl Ranch Denver, CO 80217 Ms. Margo Parker General Motors Corporation Room 11-141 GM Building ` 3044 VI. Grand Blvd. Detroit, MI 48202 Mr. George Fay Carboline Company 350 Hanley Industrial Ct. St. Louis, M0 63144 Mr. Gordon Coates, President Calaveras Asbestos Limited P. 0. Box 127 Copperopolis, CA 95228 209-785-2201 Mr. Richard Carter Johns-Manville Corporation Ken-Caryl Ranch Denver, CO 80217 Mr. Bruce Radebough Mortell Company 401 Industrial Drive Plymouth, MI 48170 UCC 013867 4o '^4-- li. L. JZ&B&STOS UNION CARBIDE CORPORATION METALS DIVISION P. 0. BOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 716-278-3376 November 21, 1978 (See Attached Distribution List}. Dear Enclosed are copies of additional testimony submitted to the California Health and Standards Board in connection with the Hearing on SB-1591. Please let us know if you have any questions on the enclosed or on the testimony originally sent to you on October 23, 1978. Very truly yours, Joh^C.^yers^ Ma-fketing Manager *<.<!- JLM:dal Enclosures CC: Dr. H. B. Rhodes 1. Asbestos Fiber Exposure During the Destruction of Maintenance Coatings by Sandblasting, 2. Airborne Asbestos Concentrations from the Grinding of Thermoset Resins Containing 0.8-182 by Weight Chrysotile Asbestos 3. H. B. Fuller Company Presentation * 08389 UCC 013868 i Mr. George Borg Riverside Cement Company 1500 Rubidoux Blvd. Riverside, CA 92509 Mr. James Heacock California Dept, of Health 1449 West Temple Street No. 231 Los Angeles, CA 90026 . Mr. James Hecht Senator Marks' Office Room 2070 State Capitol Sacramento, CA 95814 Mr. James Mason California Dept, of Health 1449 West Temple Street No. 231 Los Angeles, CA 90026 Mr. Robert Locke W. R. Grace & Company 62 Whittemore Avenue Cambridge, MA 02140 Mr. Kurt Schwartz Senior Vice President Supradur Manufacturing Corp. 122 East 42nd Street New York, NY 10017 Mr. Forrest D. Simmerman Technical Director Texas Refinery Corporation One Refinery Place Fort Worth, TX 76101 Mr. David Townsend Senator Presley's Office Room 4076 State Capitol Sacramento, CA 95814 UCC 013869 * - ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD, NOVEMBER 8, 1978 Mr. Chairman, Members of the Standards Board. My name is Harrison Rhodes and I am employed by Union Carbide Corporation. The continued use of certain products wherein the asbestos fibers are wetted and encapsulated is extremely important to a large number of California manufacturers and users. They are represented here today by a number of experts who are prepared to answer any technical or business questionsyou may have. You have already received our written testimony and there is little point in reiterating it here today, although we can discuss it more thoroughly at your discretion. My intent is to show you some samples of the products so you can see what we are talking about. These samples show both the products in the form to be sprayed and the final product after cure. I will also summarize a spraying study which appears to be quite relevant and which came to my attention after the written testimony was prepared. A complete copy of this report was submitted to Mr. Rinaldi yesterday and may be in your folders. . Let me emphasize that we are discussing only products where the asbestos fibers are wetted and encapsulated from manufacture through final usage. These include the coating and laminating materials and both types of fibrated roof coatings, that is those manufactured from cold-process cut back asphalt and those from emulsified asphalt. We are not addressing the Portland cement plaster or the naturally occurring impurity portions of the hearing. A0839C UCC 013870 -2 As a frame of reference, let us first look at the asbestos-containing spray insulation material of the type that was the principal target of the 1974 legislation (60% mineral wool, 25% asbestos, 15% Portland cement.) This is the material as it was delivered to the construction site and this is what it looks like after application. Notice that I can pull it off with my fingers and crumble it to a powder. To use the Federal EPA definition it is friable. Excessive dust generation would be expected during field mixing and during renovation or removal. There are no objections to the banning of these materials and any like them. In contrast to this extremely friable material, all of the products for which we are requesting exemption must perform a protective or structural function which is defeated if they become friable. The first examples are a polyester laminating resin containing about three-quarters of one percent asbestos and a maintenance coating with about 2.5%. The laminating resin is used in conjunction with fiberglass to build up strong, rot-resistant structures such as boats. This is an example of one layer of the cured product. It is normally built up in layers to a thickness of a quarter of an inch or more. This is the finished maintenance coating containing 2.5% by weight asbestos. It is also hard and definitely not friable. Next are two examples of roof coatings. This one has an emulsified asphalt base and this one uses cutback. They contain about 9 and 7 weight percent asbestos after cure, respectively. Note that the cured coating is slightly flexible or resilient. These products must be formulated this way to allow for the effects of temperature change. A set of roofing product samples containing a much wider range of asbestos contents has been prepared by the W. W. Henry Company and will be described subsequently by Mr. Paul Beemer, A 08 3 3 1 the General Manager of that company. UCC 013871 -3- The spraying test I mentioned earlier, which was not included in our written testimony, was conducted by a consulting firm for the H. B. Fuller Company. This study was submitted by H. B. Fuller as part of their testimony on a proposed Federal EPA regulation on the spraying of asbestos-containing materials. The materials sprayed consisted of a series of mastics used to provide weather-barrier coatings over soft thermal insulation on tanks, roofs, lines, etc. Asbestos contents were 1.8, 6.6, and 14.3% by weight chrysotile and a mixture of 13.7% chrysotile and 34.9% of Asbestine Fiber #2 talc. It is important to note that although Asbestine Fiber #2 is talc, not asbestos, it does contain a substantial portion of mineral particulate which would have been counted as asbestos by the consultant making this study if it became airborne. The mastics were sprayed under two sets of conditions; in a closed 20x20 foot room to approximate the worst possible case, although the products are not normally used indoors; and in an outdoor application. The airborne fiber counts found are presented in this figure in the same manner as the other data in Figure 1, page 10, in the testimony. The fiber concentration in fiber/cc longer than 5 microns is shown on the vertical axis. The present DOSHA allowable limits of 10 fiber/cc ceiling, 2 fibers/cc TWA and the 1 fiber/cc maximum TWA set by SB-1591 are shown for reference. The four mastics are arranged in order of increasing mineral content from 1.8 to 48.6% by weight after cure. The solid circles show the operator breathing zone concentration. These are all in the Q.T -0.2 fiber/cc range. The bars show the maximum or ceiling values, the range, and the arithmetic mean for the area samples in the immediate vicinity of the spraying operation. The highest value found was about 0.5 fiber/cc for the non-typical interior spraying of the Hi Mastic. The remaining values were in the zero to 0.2 fiber/cc range. As an aadetr' UCC 013872 -4point of interest, the Gallo Company sprayed 40,000 gallons of the Monolar Mastic containing 6.621 asbestos to insulate the exterior surfaces of wine storage tanks located out-of-doors in Modesto. Air samples were collected on membrane filters. No airborne fibers were detected by microscopic examination. The important point to note in these data is that the airborne fiber concentrations are all very low with no clearly defined trends with mineral content in the material being sprayed up to a total mineral loading of 48.6% by weight after cure. This result is very similar to the spraying and product removal data given in Figure 1, page 10 of the written testimony, indicating quite conclusively that the airborne asbestos exposure does not change a measureable amount with the asbestos content as long as the fibers are thoroughly wetted and encapsulated. For these products to be commercially useful, they must be wetted and encapsulated. To conclude, the products with which we are concerned perform a useful and valid service for industry and for the general public. They contain wetted and encapsulated fibers which do not expose workers to fiber levels in excess of those established by DOSHA or SB-1591. We would not be here today if we were not convinced that the products could be used safely and within the confines of existing regulations. We request that continued use of these products be permitted by your action to modify Section 5208, Title 8, as suggested in our written testimony including a maximum allowable TWA exposure of one fiber/cc >5u- Thank you very much for the opportunity to express these views. With your permission, Mr. Paul Beemer would like to present the additional samples mentioned earlier. UCC 013873 aOQ3Q3 SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 2591Q AS PERMITTED BY SB-1591 Cal/OSHA and Union Carbide Sandblasting Comparison Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento, California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York A08394 UCC 013874 BACKGROUND During the hearings on the 1976 Presley Bill, Assemblyman Fenton asked the Department of Health to collect additional exposure data during the use of the products for Which temporary exemptions were granted. A cooperative government-industry effort ensued. The first portion of the data is contained in a letter of June 1, 1977 from Jerome A. Lackner, M.D. to Mr. Fenton. A copy of this letter is attached. These data have been submitted to the Standards Board as part of the record for this hearing. The initial two tests (see Location 1 and Location 2 in the Lackner letter) involved sandblasting of an asbestos-containing coating from a plaster or a stucco wall. When the results became available, they were higher than anticipated, i.e. 0.5-3 fibers per cc longer than 5y. The manu facturer of the paints asked Union Carbide to participate in a third test jointly with the DOH. This was quite acceptable to the DOH and a series of paired samples was collected at Location 3. A detailed Union Carbide report on this test is attached. DISCUSSION The samples collected in the third test were extremely difficult to count. They were heavily loaded with both fibrous and non-fibrous dust. A lot of particulate was present that met the dimensional criteria of a fiber, length greater than 5y, length to diameter ratio greater than three but was almost certainly not asbestos. Both counters were experienced and discussed the problem of evaluating filters of this type prior to counting. The results from the two laboratories are summarized and compared in the following table. The Cal/OSHA data ranged from 0.1 to 7.1 fibers/cc>5y and the UCC values from 0.0 to 3.3 fibers/cc >5y. .408386 UCC 013875 COMPARISON OF AIRBORNE ASBESTOS FIBER COUNTS DURING SANDBLASTING OF ASBESTOS-CONTAINING MAINTENANCE COATING Description of Operation Pretest Controls On fence, left side of area to be sand-blasted. "4 1/2* above ground. On fence,"100* from G-16. "S' above ground. Personal sample on observer '25* from fence and moving parallel to fence. Sample Data Time Total Ho. On Off Hin. G-16 10:35 10:56 21 F-44 10:42 10:59 17 A-86 10:39 10:52 13 Observer (During Sand-Blastinq) Personal sample on observer A-81 11:12 11:18 ~20-30* from fence and moving 11:25 11:27 parallel to fence. Same as A-81. J-89 12:26 12:52 Area sample on fence. 5* 6-3 above ground and -40' down wind. (In lieu of observer) 1:35 2:00 6 2 8 26 25 Helper (Durlnq Sand-Blastinq) Personal sample. Assisting with hoses. Operating sand feeding equipment. 6-48 11:10 11:18 B 11:24 11:26 2 Iff Same as 6-43. X-8 12:2S 12:48 23 Same as 6-48. Same as 6-43. C-15 X-4 1:08 1:36 1:22 14 1:58 22 Blasting Operator (During Sand-Blasting) Personal sample. Operator handling sand-blasting nozzle, standing"2' from fence. D-71 11:10 11:18 8 11:24 11:26 2 Same as D-71. X-14 12:25 12:36 11 Same as 0-71. 6-34 12:38 12:46 S Same as D-71 except Insfde of hood. Same as D-71. X-2 1:08 1:22 14 X-3 1:36 1:58 22 UCC 100 fields itss. Cal/OSHA f/cc Fiber Counts Asbestos UCC SEM (f/cc) Non-Asbestos Total Comments 2 0.1 0.3 00 0.1 2 0.1 0.2 1 0.1 0.1 1 0.03 0.2 3 Asbest 29 0.7 1.9 0.2 0.9 1.1 fibers i 25 field: 15 1.0 1.4 28) 45) 1.1 2.2 3 0.2 0.5 2 0.06 0.2 32 2.2 1.6 0.2 3.9 4.1 1 asbest: fiber in 25 field: 431 58) 3.2 7.1 38 3.3 6.6 34 1.7 2.1 0.0 1.1 1.1 0 asbestr fiber in 50 field: UCC 013876 a83qq -3- DISCUSSION (Continued) For the pretest controls and several of the samples collected on the observer and on the helper, only several fibers were found in the hundred fields examined under the microscope. Blank filters, i.e. those which have never been exposed, will read from 0 to 3-4 fibers per 100 fields, so these results are not significant. The remaining seven pairs ranged from about the same to Cal/OSHA counting about double. Considering that these counts are not from the same filter but from filters that were collected on opposite shoulders, both laboratories felt that the agreement was really excellent. The corresponding time-weighted averages for the two operators for the time period where sandblasting was actively in progress and for the entire eight-hour day are listed below. The two workers' actual TWA exposures for the particular day were all below 0.5 fibers/cc >5u. Time-Weighted Average Exposures (Fibers/cc>5y) During Active 8-Hour Day Operations Basis Cal/OSHA UCC Cal/OSHA UCC Helper 1.1 0.6 0.2 0.1 Operator 4.1 2.2 0.4 0.2 It appeared from the results that non-asbestos material was being included as asbestos in the counts reported. In order to check this further. Union Carbide examined three of the filters with a scanning electron microscope at 1000X. A total of only four chrysotile fibers was found in a hundred fields. ' 408387 UCC 013877 -4- When these results became available, the problem was discussed with Mr. Heacock at the DOH and it was agreed that another carefully planned large-scale test should be made. A copy of a letter to Mr. Heacock outlining the objectives and protocol for such a test is attached. The report of this test was appended to our written testimony and the results were described therein. CONCLUSIONS We believe that the fiber counts reported in Dr. Lackner's letter of June 1, 1977 include a great deal of material that is not asbestos. The subsequent large-scale test is more representative of potential exposure during sandblasting. UCC 013878 4o3Sg [415) S45-7IO!), Eit. " * Jw,<* * 1?77 ;^vcV=-.';. -;-5:'^;;::-'v: ;,*.* v. " - ' "- ' . ' -->4V ' .' ' * S-..- Kesorabler Jaefc &. Fenton, Gialrr-an .;..**- :-ry?-----V. - ~w -\- :- .--V ; -v-.rV'. ., -.1. ... . .. . . Subcossittco oft Occupational Safety ^ ` 'V:v;v.7- ` / .; ' . ' V ' ' sad Health ., ..., ;;Vv-. i r, V-vVV.:: -Vci -- Ststo Assembly _ . '.': ' Capitol ' *SV> f *.. -v',- '`.''.-V V/: -- -*: ' . ` 5aercaato, CA s:?K \ jd'V- ? ---v*--V v ~ r^rs'-z^ r V ' Dear Hr# Fanterv: :''V>'v';;,>r 7 . *'* \' ' .' - ' .: . ' * -' ` .* .. <*'+ - ' \' * ' ' - `Vy/..Tbi* report is in. response to the request by wcnbers of tbs Asscr&ly-Subcommittee y'C1 os Industrial Safety for wcesareronts of vortex ensures to asbestos during V7 , coristructios operations, ? ``..T , * . . .. ^ .... ' * . .1 .` . .4 ' ' . ' ' ' -' . - . .... . .. * \ ,'4 - *' " - *. - . *. ` -' v ' -j ^ ** . - VV Although' industry represent at ivs-s resair.eJ in closo contact vlth staff of tbo ' .V ...".JCfccitpational Uc-alth f-xancK tJiTCuphoirt the y-.ar, no orcortvnity arose to vitaerss ' .-''VftflO oval sate an actual iJestruction of a pnrriously-applied, eshastos-contairilni; \ product, oitber as paint or a stucco conposcnt. .,,- ; .. onclosei rrrort L? of vorber exposures tiuri.-j: stored sardlnj ani sandblastlr.f ifcr.oval of previously applied protective cnatlrr* containing asbestos. TTio re- :'-r'.-\ aovnl. vas conducted by industry representstIves at the direction of Oecartr.cnt of ' -IJcdtii eorleyces. Industry representstives havo since state-! the removal e'oes . . eot represent actual practice: health :o-ptrtcent representatives believe it docs, v As o result of this experience, when suppliers of portlaud cement plaster contain- ir.i: csbostes-could not identify a suitable buildiiie about to be demolished, and /offered to constr_.ct and then stasc the errolitioa of a strucvjrc^ their offer . was ackuovled^ed but rot.pursued. v --- h , V.\ : 1 feoi thet with tha Tccent ennctner.t of stringent rc-Kjrtir.- roqwiro-rfftrts cn the - tjso of usbestos in all places of csploy;tent in California, proper controls will '; /;bc developed and used for ell occupational exposures. _ n .. If vo can bo of further assistance to the Cosalttee, pi case do not hesitate to contact se* ..J-~ ' > i-..r .' " `.r i. - ~i_ * ' ' H. v Sincerely, ^ ^ *''s \&ii' ;s:vBpdD7-. j-roae A- Lac."'**i - - - - * '.. Woio'r'-rf .Situ 1. , ,. . * . . " s **' * . -; .`'h* m i.*4* ' ii*" ; * * . ji" 5-, Jarone A. Lacbr.er, 31. D. Director of liislth ^.; ,,t~.'*= :j-r?*-;4/. ,-m ** * + .-P=L V-1-' . .-v. - : , ."rr i.' ' ' 1 ^ , -'>*- . fnclosure v - .' . - , : ." j.-,4. .r ' ^ . , . ^* bcc; lien 1th aurnfcd-t Whcehlfaamre: Arv>r,cncy erislativc Liaison JHH:dfca Public Health Pivisio.n Occupational I'cilth r-ranch fred t. Ottobonl, Ph.D. - #. UCC 013879 Report of Employee Exposure to Asbestos During Destruction of Spray Coatings Previously Applied to Buildings or Structures INTRODUCTION . During 1976 the Occupational Health Branch of the Public Health Division of the California Department of Health agreed to conduct a series of self-initiated studies of worker exposures to asbestos during destruction of spray coatings. Exposures from two products were to be evaluated; portland cement plaster contain ing less than one half of 1 percent asbestos and exterior and interior coatings and laminating resins containing encapsulated asbestos fibers previously applied to a building or structure. Studies were made at three different locations to evaluate employee response to asbestos as follows: . ,' ' . ` 1. On August 31, 1976, a study was conducted at 4801 Exposition Boulevard, Los Angeles. A latex-based paint containing 1 percent Chrisotile asbestos, which had been applied to a plaster wall in an unventilated hallway five feet wide and eight feet long, was sanded for two hours with an electric hand sander. The operator was aware of the purpose of the study and at tempted to remove the paint without cutting into the plaster. 2. On November 16, 1976, a study was conducted at 950 South Broadway, Los Angeles. An alkyd-based paint containing about 4 percent' Chrysotile asbestos had been applied to a stucco wall. The test was conducted at ` the rear of the building in an alley, a 20-foot section of the wall was sandblasted to a height of five feet using a commercial sandblasting machine, .. . 3. On December 17, 1976, a study was conducted at Village Grove Park in the city of Corona. An epoxy-based paint containing 1 percent Chrysotile . asbestos had been applied to a metal fence. The test was conducted by sandblasting the fence using a commercial sandblasting machine. Samples were taken upwind, downwind, inside and outside the sandblasting hood, at the hosetenders location and in the general area. All of the airborne samples were evaluated using our Cal/OSHA method which is iden tical to the OSHA- and NIOSH-approved method specified in the asbestos standard. Material samples were also evaluated to determine the percentage of asbestos in the paint. The summary of the airborne concentration of asbestos during the sampling period is attached. ... The data shows that there is a definite exposure to asbestos when employees or workers sandblast or sand coatings containing asbestos and that this exposure is present in the immediate area. In this case, the immediate area referred to is within a 10-foot radius of the source in the non-windy condition and within a 40-foot radius downwind in windy conditions. :' UCC 013880 -2- In any case, at all three locations there was an employee exposure of at least 1 fiber/cc, and up to 4 fibers/cc as an average. The area samples also showed exposure into the 1 to 2 fiber/cc range. And finally the mixer-hosetender exposure range was from 0.5 to 2.0 fibers/cc. . DISCUSSION .* All of the samples collected were of short-term exposures of 10-to-20 minute duration. All showed that free asbestos fibers were released. Dry sanding and sandblasting using dry silica sand may not represent industry-wide practice, but have been witnessed by Health Department representatives at other sites, and with other coatings, frequently. No studies were made of destruction of portland cement plaster coatings contain ing asbestos as no buildings were located containing such a coating that were to be demolished. . . STANDARD ' ' ' The Cal/OSHA standard is: "The 8-hour time-weighted average concentration of airborne asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers, per cubic centimeter of air as determined by the membrane filter method using phase contrast illumination and 400 to 450X magnification. The ceiling or short time concentration to which employees are exposed shall not exceed 10 fibers, longer than 5 micrometers, per cubic centimeter of air." May 1977 UCC 013881 4 , Sunrrtary of Airborne Concentrations of Asbestos LOCATION 1 Material - Latex Base Paint (Vinyl-Acrylic) - 12 Chrysotile asbestos bound in matrix. Free fibers released with grinding abrasion. ' Sander f/cc* Area Samples f/cc* 1.7 0.3 Both samples simultaneously within 10 ft. of source 1.1 0.9 " 0.5 . 0.3 . 0.2 " - . v, .______________ "______________________________ ' LOCATION 2 Material - Alkyd Base - 3-52 Chrysotile asbestos. Free fibers released with sandblasting. ' Sandblaster f/cc*Mlxer-Hosetender f/cc* Area Samples f/cc* 1.5 (filter outside of hood) 3.5 __________________ 3.5 " 0.4 . 0.7lj2" 1.6 All 3 sampled simultaneously LOCATION 3 Material - Epoxy Base - 12 Chrysotile asbestos. Free fibers released with sandblasting. ` . ' Sandblaster f/cc* Mixer-Hosetender f/cc* Area Samples f/cc*_______ ____________ ' 0.3 (Stationary Background) Upwind . .- ' . .' ' Before 0.2 (Moving Background) Blasting 0.1 (Stationary Background) Uowinc 1.6 (Filter outside of hood) 1.4 0.1 (Moving during blasting) Never downwind 7.1 6.6 M VI 2.2(Upwind) 0.2 3.7 (Filter inside of hood) 0.5 " (Filter outside of hood) 0.2 " 1.9 (Stationary during blasting) Downwind . 4 CM *f/cc fibers per cubic centimeter of air greater than 5 microns in length NOTE: Horizontal lines denote samples collected in the same time iramimee U'a~. UCC 013882 AIRBORNE ASBESTOS COUNTS for Textured Coatings of America, Inc. (Village Grove Trailer Park, Lots 19 and 20) Corona, California Date Sampled: December 17, 1976 Date Reported: April 1, 1977 Samples Collected By: B. L, Ingalls Union Carbide Corporation Samples Analyzed By: B. L. Ingalls & G. J. Spencer Union Carbide Corporation Reported By: H. B. Rhodes Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013883 OBJECTIVE To measure the airborne asbestos fiber concentrations generated during the removal of an asbestos-containing maintenance coating from a sheet metal fence by sand-blasting. DESCRIPTION OF OPERATION The test was run at Village Grove Trailer Park, Lots 19 and 20 in Corona, California. The park was surrounded by a galvanized metal fence about 5' high that had been painted about five years previously. The metal was first primed and then painted with an alkyd-based maintenance coating containing about 5% asbestos. The paint also contained mica, talc (non-tremolitic), fiberglass, and perlite. The sandblasting was done with a portable unit consisting of a compressor and a blasting unit. The latter had a sand storage tank about 1' in diameter by 3 1/2' long which fed silica sand through a lever operated control device and a heavy hose to a blast nozzle, under the control of the operator. One man handled the blasting nozzle while the other operated the compressor, assisted with the hoses, but primarily operated a lever on the sand delivery unit to keep the sand flowing. The nozzle operator wore a conventional sand-blasting hood with air openings on the sides. During the blasting operation one man stood about 2' from the fence and moved the nozzle, held about 3-6 inches from the fence, in short arcs until the impinging sand removed the paint down to the base metal. Bonding was excellent and it took at least several passes of the blast to remove the paint. The material removed was finely pulverized. The bottom 1 1/2' of the fence was not hand-blasted to avoid raising extraneous dust from the dry ground at the base of the fence. The weather was clear and warm with a light, variable breeze blowing from left to right in approximately the same direction as the fence. SAMPLE COLLECTION The following types of samples were collected during the test: 1. Background samples prior to testing were collected at the fence, ~4 1/2' from the ground about 100' apart. (Spanned the section to be sand-blasted.) (G-16 & F-44) 2. A sample about 40' downwind, on the fence about 5' above the ground, during the last 25 minutes of sand-blasting.(G-3) 3. Personal samples on an observer in an area generally 25-35' from the blasting operation and approximately perpendicular to the blasting. (A-86, A-81, J-89) 4. Personal samples on both the helper and the sand-blastijfcL operator. All operator samples were external to the hooo^> except X-2. Helper - G-48, X-8, C-15, X-4 Operator - D-71, X-14, G-34, X-2, X-3 UCC 013884 COUNTING EQUIPMENT AND PROCEDURES All samples were collected with battery-powered air pumps (M.S.A.), calibrated to 2 liters per minute on Millipore membrane filters of 0.8y porosity. The samples were mounted and counted in accordance with the procedure of Bayer, Zumwalde, and Brown (Bureau of Occupational Safety and Health, February 1969). Counting was done with a Nikon microscope at 400X utilizing a Poton reticle with a 0.0062 mm2 field area. One hundred fields were counted for all samples. These samples proved to be particularly difficult to count. Out of the total of nine personal samples from the blast operator and the helper, six were loaded with dust to a level where filter areas were frequently obscured. When such an area occurred, the counter went on to another field. There is no way to tell how this may have influenced the results. Our normal practice in this situation is to resample, but considering the difficulties this would entail, the filters were used. In addition to this problem, the nature of the samples puts an extreme strain on the method. Thus: 1. Fiber concentrations were low with 0.58 fibers/field the maximum and 0.2 fibers/field more or less typical. This is well below the 1-5 fibers/field range recommended by NI0SH. 2. The fibers counted were in the 5-15y range so that the "5y decision" was a frequent requirement. 3. There were substantial concentrations of mica "chips" present. These can generally be recognized as not asbestos but certain shapes around 5y in length can become undistinguishable. These factors of low fiber concentration on the filter, filter size distribution, and potentially interfering "fibers" result in a high degree of operator discretion in the determination of the total number of asbestos fibers counted. When this possible variation is combined with the short sample times substantial variations can result. In view of these uncertainties, a modification was made in the procedure to report two categories of fiber: 1. Obvious chrysotile asbestos. Either long and curved, or distinctly thin and slightly curved in the 10-20y range. 2. Probable asbestos fiber: Particles which did not have obvious identifying asbestos features but met the L/D >3, >5y require ments and were dark and fiberlike under phase-contrast illumination. When there was any doubt about a fiber's identity it was included in category 1. Particles which were obviously not asbestos were not included. The total of 1 and 2 would be the value ordinarily reported as asbestos. UCC 013885 A RESULTS AND DISCUSSION A description of each sample and the respective fiber concentrations are shown in Table I. The data obtained by Counter A are presented graphically in Figure I. Where paired results are available Counter B was high six times and Counter A three times. The differences, without regard to sign ranged from 0.1 to 1.1 fibers/cc and averaged 0.3 fibers/cc. In view of the counting difficulties on these slides we consider this to be good agreement for operators in the same laboratory counting the same slides. . The operation of the sand-blasting equipment was too erratic to provide a. meaningful estimate of operator TWA exposure for normal day's oper ation. Using just the time periods during the actual blasting operations, the time-weighted averages would be: Operator - = - 2.2 fibers/cc >5y Helper - = 0.6 fibers/cc >5y The measured exposure for the full 8-hour day would be: Operator - =0.3 fibers/cc >5y Helper - 39.02 480 = 0.08 fibers/cc >5v UCC 013886 4 <0 e TABLE I SUMMARY OF AIRBORNE ASBESTOS_FjBEJt_COUNTS PUR[MG 5AM0-BUST1NG OF ASBEStOS-COflTAIHTHG MAINTENANCE COATING Descriotion of Operation Pretest Controls On fence, left side of area to be sand-blasted. "4 1/2' above ground. On fence,"100' from G-16. --S' above ground. Personal sangjle on observer "ZS1 from fence and moving parallel to fence. Sample Data Time Total Ho. On Off Min. G-16 10:35 10:56 21 F-44 10:42 10:59 17 A-86 10:39 10:52 13 Airborne Fiber Concentrations (Fibers/cc >5u) Operator "A" Operator ,,8,, Obvious Probable Total Total Chrvsotile fibers - Asbestos fibers Asbestos fibers Asbestos fibers 100 fields f/cc 100 fields f/cc 100 fields f/cc 100 fields f/cc 00 2 0.07 2 0.07 * * 00 00 00 00 2 0.08 2 o.n 2 0.11 4 0.21 Cpmnents Observer (During Sand-Blasting) Personal sample on observer A-Bl 11:12 11:1B "20-30' from fence and moving 11:25 11:27 parallel to fence. Same as A-81. J-09 12:26 12:52 Area sample on fence. 5' G-3 above ground and "40' down wind. (In lieu of observer) 1:35 2:00 6 2 8 26 25 00 1 00 1 7 0.19 22 0.09 1 0.03 0.61 1 29 0.09 0.03 0.7 21 0.6 Helper (Ourino Sand-Blastinq) Personal sample. Assisting with hoses. Operating sand feeding equipment. G-4B 11:10 11:18 8 11:24 11:26 2 Iff Same as G-48. X-B 12:25 12:48 23 Same as G-48. Same as G-48. C-15 X-4 1:08 1:36 1:22 14 1:58 22 1 0.07 14 10 0.30 13 1 0.05 00 2 2 0.97 IS 0.54 0.10 0.06 28 45 3 2 1.03 9 0.84 1.35 0.15 0.06 60 9 0.6 1.8 Heavily loaded; hard to count second slide 0.3 Blasting Operator (Ouring Sand-Blasting) Personal sample. Operator handling sand-blasting nozzle, standing--E' from fence. D-71 11:10 11:18 8 11:24 11:26 2 Same as D-71. X--14 12:25 12:36 11 Same as D-71. 6-34 12:38 12:4$ 3 Same as D-71 except inside of hood. Same as D-71. X-2 1:03 1:22 14 X-3 1:36 1:58 22 7 0.48 25 1.72 32 2.21 . 13 0.82 30 --- 5 0.43 33 3 0.39 26 21 0.66 35 1.88 - 2.84 1.28 1.10 43 58 38 34 56 2.70 3.64 3.28 1.68 1.76 _ 75 39 - 53 - Heavily loaded, hard to count. 4,70 3.36 - Heavily loaded; bard to count second slide Heavily loaded; bard to count. 1.66 UCC 013887 -4 08 4 07 AIRBORNE ASBESTOS FIBER COUNTS DURING SANDBLASTING Ou4 vi in C 'i UCC 013888 UNION CARBIDE CORPORATION METALS DIVISION P. 0, BOX 579 NIAGARA FALLS, N.Y. 14302 TEL: 716-278-3376 January 13, 1978 Mr. James Heacock Occupational Health Section California Department of Health 2151 Berkeley Way Berkeley, CA 94704 Dear Mr. Heacock: The suggested protocol for the cooperative test that we discussed in your office is attached. As you requested, it has been set up so that the Department does the actual sample collection. Plans are well along to conduct the test on one or more large tanks in the Trona area that have been coated with zinc-rich primer. The only hold up is satisfactory verification of composition of the primer. We would like to go ahead and plan to conduct this test during the week of January 23, 1978, preferably on Tuesday the 24th. Please let me know if this is satisfactory so we can finalize on a date and the other arrangements. In view of the time that has passed since the original hearings and the number of new people involved, it seems appropriate to comment on two questions relevant to the previous testing results reported in a letter of June 1, 1977 from Jerome A. Lockner, M.D. to the Honorable Jack R. Fenton, i.e.: 1. The appropriateness of sandblasting as a representative test method. 2. The accuracy of the previous counts. We have been informed by a large manufacturer of the high-performance mainten ance coatings of particular interest here that certain of these coatings are sandblasted as a routine procedure. Usually it is a light "brush" blasting to remove rust spots and loose coating but occasionally complete removal takes place. Sandblasting thus represents an extreme condition and should thus be a reasonable way to approximate the upper limits of exposure. UCC 013889 ao8 9 Mr. James Heacock -2- January 13, 1978 As we discussed several times, in the test where Cal/OSHA and Union Carbide collected side-by-side samples during a sandblasting operation, both laboratories found asbestos counts of several fibers/cc or more when counting by the routine NIOSH procedure. It is well recognized that the procedure has very serious limitations for dusts of the type generated during sandblasting. Subsequent examination by Union Carbide of several of the filters using scanning electron microscope techniques suggested that both laboratories may have counted substantial numbers of non-asbestos particles as asbestos and that free asbestos fibers were extremely rare. Over the past year the Federal OSHA Laboratory at Salt Lake City has adopted more sophisticated optical techniques to distinguish asbestos from other particulate matter and are quite possibly the most skilled laboratory in the country in this.area. I have discussed our problem with the Director, Mr. Floyd Madsen, and he is agreeable to count a reasonable number of samples. It will be appropriate for you to make a written request for this assistance at the time the samples are submitted. Please let me know if you have any problems with this proposal. We are looking forward to participating in what appears to be the first carefully defined test of asbestos exposure in this type of application. It was a pleasure meeting with you and the others in Berkeley. Very truly yours, /3, Harrison B. Rhodes Technology Manager HBR/rmm Attachment UCC 013890 TEST PROTOCOL OBJECTIVE The objective of this test is to measure the airborne concentration of asbestos fibers generated during the removal of a non-resilient maintenance coating by sandblasting. The site selection, test operation, sample collection, and sample analysis will be carefully planned in advance so that meaningful results are obtained. WORKING ARRANGEMENTS The selection of the test site and provision for the sandblasting operator and equipment are the responsibility of the Union Carbide Corporation with the choices subject to approval by the Department of Health. It is intended that the Department of Health and Union Carbide will each have at least one qualified person at the site to work out a mutually acceptable sample collection strategy in accordance with the general guidelines under "Sample Collection Strategy". Sample collection will be performed by the Department of Health. After collection is completed, a validated summary sheet of the collection data will be prepared with a copy for both participants. In order to expedite matters, the cassettes will be packaged and sent immediately by registered mail to: Mr. Floyd Madsen, Director OSHA Laboratory 390 Wakara Way Salt Lake City, Utah 84108 The Department will send a confirming letter to Hr. Madsen requesting them to analyze the samples. He has been alerted and is expecting to receive 10-30 samples. When analysis is complete, the OSHA Laboratory will provide both participants with a copy of the results. TEST SITE AND OPERATION CRITERIA The following criteria apply to test site selection: 1. Reasonably representative of a substantial commercial use of the product. 2. Large enough to allow for several hours of dust generation. 3. Reasonably unambiguous definition of the composition of the asbestos-containing material being handled and an asbestos content in the upper part of the range of contents of interest. 4. Sandblasting will be done with regular commercial equipment and materials by a professional operator in a manner that is accepted commercial practice. UCC 013891 / 2- - \ SAMPLE COLLECTION STRATEGY As noted previously, it is intended that the Cal/OSKA and Union Carbide representatives at the site work out the most appropriate sampling strategy with the following special provisions to be met: 1. Personal breathing zone samples will be taken on the operator and the helper {if present) that are subject to the highest exposures. In addition to samples collected during the actual operations, a reasonable number of samples will be collected before and after operation to permit an estimate of the 8-hour time-weighted average exposure. 2. Area samples upwind and downwind will be taken before, during and after the dust generation operation. ADDED NOTE The Union Carbide Corporation is participating in a national round-robin study of the NIOSH collection and analytical procedure. It has been agreed that we may have an observer wearing a pair of pumps moving in the immediate vicinity of the dust generation operation. Care will be taken that there is no interference with the test. These samples will be entered into the round-robin and since they will be counted by only the standard NIOSH procedure, the results are not relevant to the present tests. SAMPLE ANALYSIS . All sample cassettes will be shipped unopened to the Federal OSHA Compliance Laboratory at Salt Lake City. UCC 013892 4oe< r I' SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento. California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York ^ G8 4 1 3 UCC 013893 SUMMARY AIRBORNE FIBER CONCENTRATIONS SPRAYING OF MASTICS(1> 10 iSecti on S20 3, Tit le 3) S LACTONE Exterior MONOLAR HASTIC Interior Exterior -- HI MASTIC Interior Exterior ts 5 -J. Uu -- a Cl MASTIC -- Interior Exterior . No. of Samples t Asbestos by ut. After Cure - . Ar 1thmet ic Average UK * 14 1.8 1 ' allowa 3LE 8- iOUR T IME-WE IGHTEO ' AVERAGE EXPOSURE LIMIT ^ (Section S203, Title 3} ---------1--1-------- 1 1I11 MAXIMUM ALLOWABLE 8-HOUR TIME-WEIGHTED_ --;iVERAGE EXPOS URE LI MIT (S 8-1591 ) ^ 41 6.6 4 ' S 12 4 14.8 NOtl i Personal Samples JVM h ____ 12 14 12.7 Chrysotlle 34,9 Asbestine Fiber 12 30 (1) Source: Response of the H. 8. Fuller Company to "Changes in the Niitloitdl Emission Standards for Haiartlous Atr Pollutants* (40 CHI, Port 61) proposed by the PA (42 CFR No. 41t p. 12122, Harch 2, 1977). (2) Arithmetic averane of all samptes collected for each product group. Since these operations are generally fntetwlctant, the corresponding 3-hour time-weighted averages would he lower. A 08 4 14 UCC 013894 SUMMARY OF TABLE STEWART-TODD ASSOCIATES, INC. REPORT SPRAYINO OF MASTICS ru- a! 4a-1> C(1T3 E s_ sz at M > crti--avsij**- *x. ><01 1. a. t/CSl| US A Oo 0o) a<0n ! tA S_ -O <o ai Co f--a VsS- <o 0) 00 a. fQ s- +c0J1 oso(J= OcJ jso3_ 1. u '1-- 4-1 1 -C (a/>j 4-> tocn>--si('0Q<0=o4 S- 0C1T <0 s01 > <c Sa. <<uo (Si s <s- o Y-- s_ CD cto >--oi oos gE. Sa-i v1>0 a. CM IA O 4-> IA 4-1 ai 3 -O tA < 4-> U 3 a o s- a. vD o o VO o o 1 VO o o V vO o o V 1 co as c Y4-1 0 o o--- o oi r-. ct oo 4J 00 os--- 10 --1 o CM . o 1 CM o d os o d a o CM O I US o CO CO o p-- 4-1 vs 10 J --. to um >0 i r-- O O CO C---* o 31 CO o * oo >sf CM a o oo 1 CTl CM o o0 oo VV CM a Io V f-- VO o * oo as o o t US o oo V r>. o CM do v CO i-- a> f4O*-1 44C->- C=4MU vs >, iaas ^ ai S- J3 J3 O <. Ll- cn IM- OS * co CO o-- -- r-. 4-> O VS 1 0O 31 os i--t 3= (J*--* ?" VO +> CM \A 1 (C o s: to H o UCC 013895 to 03 C 10 IO (A 01 OS ns a. ----- 4-> <4- e o <o O us > >, 4-1 - 01 4-1 >-- -p- JO 01 01 - 4-> 4J i- 3 Oil- i- Q. C >----- - E 01 O a- ^ E w 01 p<J ^ s- p- c 4-> c: 4-1 10 Q 4-- 4-- 4" r-- 3. O 4-> 0 US CJ E c 01 SZ C <- IA i. is O-P O 4- UZ 4- US 44 4-> <- l/l 4- (A -O 01 O S-t- J3 01 -S 1/S IA 4-1 4-14-> -r- 10 c <o -C 3 01 s- 4-> (A o i- ai ns SOSj= 4-> <0 4J1/10 jo ai oi ai I-4J4J <0 OI S C 1- C 4-> 3 4J 4) <-- C O C r- 10 01 U 10 1A 4-> * ia ai tn <A 41 s- 1- (0 -O 01 Q. X 3 - > VS O 01 0) " S_ JZ c 10 S4-> +j S- uc o vs .a o S- j3 E-r- Cl O S1- 4- o >, +cJ (O Io--i 0 S- E vs E C (0Cl O 01 o u4- J- +J 4-> (10 <0 cXl fO 4-> S01- VI f3" +rtJ3 U +> T~ COJT+-CJ <0 S- 4-> 4-> Cl *-4 41 ? . -oCj. 4(-0* oi o ai 4i-/>i a4-1 0o1 4- U 0 - e(0 r-- -C LU 3 4-1 01 4s-1- OS 0 c (O oi s- e <o c-- CO <0 4- vs <jjj O p-- CM M 4-> Sa-i 4-> 4<a=i 0a5)0. ai <o - S- oi ai 41 E sa-i- U- lO O 4-> +-> ^ -- r-- p--4->4-1 S 4- Q <0 O 01 -- tA C- -- S- oi e , VS >, 3 c o &- o c Cl 4- P-- Cl 4-1 (0 4-> tA 4J vs i- tA C 01 01 01 01 01 V E -O Cl 4-> J3 E 0 vs c 4- (A 4- 4-- 10 4-- < < 0O 03 = V) CM C*0 4--' 4084!b Response of the H. B. Fuller Company to "Changes in the National Emission Standards for Hazardous Air Pollutants" {40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) UCC 013896 4 08 4 ] Q H B FULLER COM PENV ' International DIVISION -- Tnmirr. PRODUCTS TELE* 84-5141 PO 00X9395 * 43JS W.GIRAROAVENUE PHH>OElPHIA.PA 19131 TELEPHONE i2lSlflT&-8503 29 April 1977 U ir ; Emission Standards and Engineering Division Environmental Protection Agency Research Triangle Park North Carolina 27711 ' '` ' '' .[*** Attention; Mr. Don R. Goodwin .'v^- ' _ -'-V.-v:.~ i Gentlemen: :' ", ,'r- T^! ,iPursuant - to the announcement (42ER41) of proposed amendments to the Asbestos Standard C40CFR Part 61), we attach herewith, : in triplicate, factual information on the proposals, and our t. recommendations for changes. . ^ v 1 / > v-: -r .' 4Te urge strongly that action to ban spraying of all asbestos .. . containing materials not be taken; and that specific data be L v.vdeveloped on potential emissions hazards of each class or type of. such materials upon which to base emission controls. - -.1* . * - * ' p.- "*' * O- I - V.x.:'\'r 4 ^ . i . X;-vL-- ,, ' .V * \v :'V-V , . -T- - .''8!**.-, V' -'-V- / ny ; . : WpErebg rjv ;- ...* Yours very truly, -ig. , ^ r, H S FILLER COMPANY mm m \U7;v:$''V'"V^..:'v W. P. Ellis, Manager ?%':i "Foster Products International * ``-j ;*' ' . - * ' ' ' , ' , 'V .. . : r.A lr 4 . .. - - * " "' r< &K 'r* i -'- is 'i-H -Vr. * i. UCC 013897 A08 4 1 7 vlr. ; V/*, v ,'f * y .** . y y. ' .. (.,'.r4* ' v~. V;` -. .... ' *: <. -V , ' ? .* "* :> . . ' .V-' . ?* ,, .> . '`V. *.'r - STAT2i21T BI \. ** : '-vyyy^' y:- tbs h.b. fullzh. company -v \:^:r'^'v>:P.orBQX 9^95* ' PH3LADSLTHIA., PA 19131 :,v ':, /y *- -'3;-.*' 'concerning . v ' ' F^'taVkL?IPgKTS TO ASBESTOS STANDARD 40CFR PART 61 (42?Rbll ; -, n' . /: ' Section A . V Factual Infcreation on Specific Topics Cited in the Proposal 'Smsy-QH' 'titerials* i-' ' . . .. ' - Hie H*B* Pillar Company manufactures and sells several spray-on weather- -^barrier mastics (thick coatings) which contain more than asbestos +-y\ y' ' fiber* rcsi The. sung*' of asbestos td,37l^ by weight fiber content in these products extends . of the dry product after application. Attach! d are technical data sheets describing four such mastics (Attachment i; <Hy;c *yi'. y ,30-70, 60-26, 60-36, 90-0?)* , 7 ' .. . These prcductc ara applied by spraying over various forms of thermal insu- .-. laticn to protect, it from weather, water-vapor migration, mechanical or : ii- '1 '.'chemical damager and other exposures. Hey are not insulating materials of . t' ` * themselves- Our mastics generally are used at industrial plant site3, such as petrochemical plants and oil refineries, where they are applied on . : insulaad tanks, vessels, structures, structural members, pipes, and con duits. Sosa-of these are specific are-as of application which are subject to .' v.:. ' v**y. Vl %* ^ : : control in the proposed amendments. ' . \ ' w.V J1. .j Asbestos -Sobstitates. ' . , . ' - ' *" ; 1 I'tJ* ' t_--, ' V * The function of asbestos fiber in our mastics is to control flow during . application;: to prevent cracking during drying; to provide re-inforcamsnt, improved tansHe strength, fire resistance, outdoor durability, and package stability. Cur Philadelphia laboratory is, and has been, engaged in a pro *v ject to eliminate asbestos from products such as described-.above. After numerous axperimfints wa have not. yet found acceptable substitutes for asbes- V tea ia our prcducts , ; .. : .. . 3. Technical Tmtact. . : ' ' y--V' , , . An inportc-nt technical impact resulting from prohibiting the use of spray- on products containing more than 1^ asbestos, a3 proposed, would be the . ^ -withdrawal of weather-barrier mastics from the insulation protection market* /-.Bo suitable replacement protective materials at comparable cost are yet available to provide the vater-vaper barrier function which is essential to prevent water coadensatica within the insulation on low-tempera tore tanks, * * 'A j, , . vessels, piping and conduits. When under such adverse circumstances, thermal insulation becomes wet It loses its effectiveness* This loss increases sig nificantly the energy consumed to refrigerate process fluids and gases, and makes the control of process temperatures more difficult. S:r ' I.;/;,:;-: . . A084 ; 8 UCC 013898 H.8. Pullsr Ccepxny Statement fttgn 2 $ : 4. Sconoaic Ihcact. Uia economic impact of the amendments, if Imposed, would be to elia , ' inate the sola of weather-harrier nasties; an economic hardship to cur ` . ,company, and to other manufacturers of nasties* Salas of such nasties in V ^ -v amounted to more than one million dollars for our company alcna. 1- Another serious economic inpact would bo the increased energy consumption _ in the industrial plants concerned, because of decreased insulation effect-- ; iveness. There would be an increase in the cost of maintenance and repair r-.' of installed industrial insulation systans. Consequent to the elimination . ' of. the weather-barrier nasties production could be labor force reduction., ^ , . withdrawal of manufacturing units from service* and loss of tax ratables. r_V y;i" ' 5. l^agnitnde'of Potential Fbissions. . . - At our- Philadelphia laboratory we have-conducted a series of tests to ' -. detect and measure emissions of asbesto3 fiber during spraying of four " > typical weather-barrier mastics* The tests were monitored by Stevart-Todd . ' Associates of Vhyne, Pamnsylvania, an experienced firm of consulting : industrial hygienists and toxicologists* A copy of the Stewart-Tcdd report - is attached (Attachment 2)* The overall conclusion drawn from these tests ' " is that the eight-hour time-weighted concentrations of asbestos fiber did .. - -not exceed tha current standard of 2 fibers per cc or 10 fibers per cc . ceiling liatr during the spraying of the four mastics tested. ' Furthermore, more than 40,CC0 gallons of our Monolar has tic, which contains ;, ' 2.8 asbestos in the dry product, were applied by spraying, almost daily, - ' V over a parted of several months in 1976, by the 2. & J* Gallo Winery, ; " Jtodesto, California. 'Ihis mastic was applied .to the exterior insulated -" surfaces of wine-3 torage tunics located out-of-de-ors in Modesto, air quality . y . .. - was monitored by Gallo during the mastic spray application period. Gallo . deterained that no detactible airborne asbestos fiber was present. (See - . Attachment 3* Gallo letter dated April 20, 1977 which -we are authorised to include with this statement.) Ibis field experience from a large Indus trial installation confirms the conclusions from the laboratory study described" . in. Attachment 2. - ' - 6. Friability of Scrsv-on Materials. . Che of the criteria used in current regulations, and in the proposed -. amendments, is "friability4*, which is considered to give an indication of potential inhalation hazard of applied materials containing asbestSs. The 1 . definition cited in Paragraph 61.21(k) of the standard is inadequate in the technical sense because no standard method of test is referenced, by which the fhdxblar nature of a material can be determined with accuracy and uni formity* Vie believe an improved definition and a te3t method are needed. Concerning the weather-barrier mastics described above? at no time during -? application or during service life are they friable. The mastics are applied in a "vet state" from a semi-fluid or piste-like consistency. After appli. cation and drying by evaporation of volatile ingredients, the mastics have . the fora of thick, leather-like sheets or films which are not friable* . A 08 4 1 g UCC 013899 K.B. Fullor Company Btatemont fkga 3 Attached is a specimen of spray-applied Konolar Mastic (Exhibit I) which will demonstrate this point* 7* Renovation or Removal of Friable Asbestos Materials Because none of our asbestos-containing mastics is friable, there is no hazard associated with their removal where required. Section B Comments and Recommendations 1. We. do. endorse and support the intent of the standard and of the pro posed amendments- to minimize or prevent an asbestos inhalation hazard. However we believe is is not necessary to prohibit the spraying of all materials containing asbestos in excess of 1i> by weight as proposed, be cause it has not been shewn that all such materials do emit asbestos fibers to the atmosphere in unsafe concentrations incident to spraying. In fact, the results of the spray tests reported in Attachment!, together with the field application report of Attachment 3 show definitively that unsafe levels of asbestos `particulate matter are not produced during the spraying of the four products tested; one of which contains 37.1 asbestos fibers. Neither do we believe it is desirable to impose the the ban, for the reasons 'of adverse technical and economic impacts described in Section a 3 and 1. It is for all these reasons that we recommend deletion from the proposed amendments of the second sentence of Paragraph 61.22(e), which prohibits the use by spraying of products containing IJj or more asbestos. 2. Vfe recommend that the phrase "visible emissions'* be deleted from the present standard and from the proposed amendments wherever it appears ; and that it be replaced with "asbestos particulate matter", the latter phrase specifically identifies the nature of potentially hazardous emissions. "Visible emissions" may or may not be asbestos particulates. 3. We recommend that the first sentence of Ihragraph 61.22(e) of the pro posed amendments be revised to read: "There shall be no asbestos particulate natter emissions in excess of the levels established in OSHa Regulations (29CFR1910.1001) to the outside air from the spray-on applications of mater ials containing more than l asbestos on a dry weight basis; except as pro vided in paragraph (f) of this section." This proposed revision clearly protects the public health by limiting any asbestos emissions to acceptable concentrations. -. 7* 4. Concerning the term, friability, we recommend the development and adoption of a standard definition and a standard test method. Existing relevant standard tests are'ASTH C 36?, and ASTK C 421; but some modification of these standards is necessary to make them applicable to spray-on products. We suggest that either, or both, ASTM Committee E-6 on Performance of Building Constructions, and ASTH Committee 3-33 on Environmental Acoustics are technically qualified and able to develop suitable modifications of these consensus standards in cooperation with the Environmental Protection Agency* UCC 013900 A0842C H.B. Fuller Company Statement . E*K ** Ws suggest further that this work be coordinated by ASXh Committee 5-3^ on Occupational Health and Safety Aspects of Materials, Physical and Biolegleal Agents* because Committee S-3^ is presently deep into the preparation of a comprehensive asbestos standard, 5* Subpart B of Eh.rt 61 does not cite test protocols by which the presence and magnitude of airborne asbestos particulates from spraying operations ari be determined* We recommend that this omission be rectified, preferably by referencing current CShA-hlQSa procedures. 6* Finally, urge that restrictions on spraying materials containing asbestos not be based on asbestos content, but on emission of asbestos particulate- matter; whether in spray operations, or in service, or in renovation or removal, activities. 7* H.B* Puller'Company offers to work 'directly with S?a Snission Standards and Engineering division, or v/ith other qualified standards-writing bodies such as the American Society for Testing and materials (jLHTK), to implement the suggestions and recommendations made 'herein. Will we provide gladly any pertinent, non-confider.tial data on our products, and also the expertis of long experience with their spray application. . 29 April, 1977 -Prepared by W.P. Ellis UCC 013901 A842i me. AH EVALUATION OF POSSIBLE.AIRBORNE ASBESTOS - EXPOSURE FROM WEATHER-BARRIER MASTICS MANUFACTURED BY THE H, P. FULLER COMPANY, INC. Industrial Hygienist May, 1977 UCC 013902 c-rtc. TABLE OF CONTENTS 4 I. INTRODUCTION II. SUMMARY III. METHOD OF SURVEY IV. TEST RESULTS AND PHOTO MICROGRAPHS V. ANALYTICAL PROCEDURES VI. SURVEY PHOTOGRAPHS AND DIAGRAMS VII, TECHNICAL PRODUCT DATA SHEETS VIII. PRODUCT TECHNICAL INFORMATION IX. CURRICULUM VITAE 4 UCC 013903 ^~fYeta.ct C'Tte. I. INTRODUCTION Recent proposed standards by the EPA regarding airborne asbestos con centrations in materials containing more than one percent asbestos have caused a degree of concern to manufacturers of Weather-8arrier Mastics for insulation and -roofing materials. The standard as proposed, would preclude the use of these compounds if the material has more than one percent of asbestos. . In order to ascertain both environmental and occupational exposures from these materials where the concentration of asbestos anthroboles exceed one percent* a protocol was developed establishing methodology to determine airborne concentrations of asbestos fiber during the spraying application of four (4) representative H,B. Fuller Company Inc. Mastics. Four compounds with concentrations of asbestos varying from 1.B to 34% bound in asphalt hydrocarbons or vinyl acetate water base products were utilized. , Spraying of these materials was done under two sets of conditions; in ,a closed room simulating Interior usage and outside in the ambient 'air, simulating roof application or outdoor insulating techniques. The testing was accomplished on two separate days, April 19 and 20, 1977* 4A UCC 013904 irtc. Page 2 II. SUMMARY - 'm A total of 36 samples Including controls, were taken for determination of airborne asbestos fiber concentration. Sample times ranged from 10 to 42 minutes. Fiber concentrations were reported using standard laboratory techniques as established by NIOSH (see analytical procedures for detailed procedures used and calculations). Based upon the current occupational standard of 2 fibers/cc for an 8hour workday and a ceiling value of 10 fibers/cc for any 15-minute : concentration, all of the test spraying application were well below standard. Concentrations ranged from .5 to less than .002 fibers/cc and It should be noted that in many instances that fiber counts are In reality, below detectable limits. UCC 013905 A0842b <nc. Page-? % III. METHOD OF SURVEY Airborne asbestos samples were obtained utilizing Mine Safety Appliance Gravimetric Sampling Pumps and Mlllipore Cast Type Continuous Duty Pumps with appropriate critical orflces. Samples were taken on open faced mlllipore filter type AA, '0.08 micron, and pumps were calibrated before and after survey utilizing; a Universal Pump Calibrator in the case of the MSA Model G's and an NBS Certified Wet Test Meter for the Gast Type Pumps. Area and personal sampling was accomplished. The first day's data was obtained while spraying was performed on sheets of paper approximately 4x15 feet in length attached to the interior walls of a suitable workroom. Spraying was accomplished by utilizing normal industrially accepted practices as recommended by the manufacturer. Nozzle pressure averaged 2000 PSI. Area sampling was done at strategically located points in order to obtain maximum coverage and capture maximum concentrations of airborne contaminants. In addition, In each application, the operator's breathing zone was also sampled. ` ` Exterior environmental sampling was accomplished utilizing the same equipment; however, spraying was accomplished on three (3) 4x8 sheets of plywood, positioned against an exterior wall. In addition to the vertical characterization, a horizontal spraying operation was done on the ground. Paper was laid out In approximately 30 foot strips. Weather conditions for these tests were as follows: ambient temperature 64 degrees F. to 70 degrees F.; wind was from the North, 3-5 miles per hour. Area sampling was accomplished and all sampling stations down wind of the spray operations in order to obtain maximum fiber concen trations. 4 UCC 013906 me. IV. TEST RESULTS AND PHOTO MICROGRAPHS JT 4' UCC 013907 fc -* m V % . : V .. r-.V- r ... > : TV. \ ^* .:*>> .. VK'-' "}: ,i u .;. 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(MC0 4-VOp-- CO CO CO IN CO o in o o o 4 CO 4 4- 4 pm (0 C iQ IQ O (Q (/) mmajcjtl. t_ s- i_ . <*- 4) 4-> UI UI 4 C 4 -O O 3C 4-* U 4-1 U C IN O 4 4 HI In (J p-- VO > N. k. o- O CO *-- O 4) r-- c i o cm 4-i a. O O HIS X CL X VO'--4 Ui < .4.08 428 UCC 013908 Page 6 v. C to CO N CO (O ffl (O to O CM CO f-- OtOtAtOr* n r* f% r~. mm O tn in ^cof act <Tt CVJ CTl i-- CO n ntn rx in CM CM CM CM CM * b. . o oo o CO a% KO *T to CM <7> O co co co CM V \ ^ ' . '* '/ * N^N rA S3-*'** . ' _ , Q N vw 3- ikt Cv) (\jVj CJ> O O O O Q 0OO O a\a' a' '; : r i' . #* cm. rx, tnininmtn ooo oo p*f 1 t . i V v v* ' .. '//' /; <v id r-^ to co co ooo ** 4 ^ . `- ` .. T ' 4 co co co eo o ooo CO CO oo r" pTM CO o r-~ .. CO O . r-- XXXX CO O U3 ID ia ID 4* r*v X v </> v> <n cnj in t/> <n ui * 4) <D CJ <3J co r.r _ .- , r. ' ***. . .' ' . -v* , .-ir XX X CO CO O to to O to ^ XX <A <A in lO 1ft w 13 m * Q} CJ * (U r* r* r* ' (O CO CO o o o to ^ f* ^ * xxx VI CM tD CM V) * * *g CO CO r* . : r * *. ' . ' . : V- . * l- S ' f V ' ' '*,* ,v ... *i-`- . .2'- ^ j **.. . ' J*. .. t ' ID CO CJ PV rCO CO CO CO t> o o o o 'S* *4* 4- . ' -' ; . ;. rx. co co oo Ntn o o\ o ooo o o ^ ^ a* ^ t- ' .- co lo o% <y ^ vocoirsco^oooo o *r ^ ; . . . . - ' \ : ?Vv- .; : r. , . . '' i: ' ' Pi'J. . ' - . " , . b *' _ , *- f'w ' ' ' r,v- ` ' ..: ` _ a 'c o fl fl fl ^ 1/1 ffl d ai u i. S. S- - S_ <U t-t-cca. : . *. ' ' . ' V7 . . C O a <a a a in <u ai ai ai u i_ i- t_ u at < < < < Q. : ; . . <d cr o id id to it vi <U <U 4 41 U L s. t. u ai <<<<4 - 'f- . .. , . . . : . `H1. ' 7 \ ' \ ;, ' { .: ' -,1 : s .` :`v.i '' TP'1',-' .* ' ' ' , , v ' . jp' : '* i.-* * *"N 41 U) vi c r-- .a o o a* t- 1+j On +c* u o ** tj vi i r u to co *"*. > s_ -r- XetiOt- 4> f-- 1 CM O -MO. mo u> x a. tj VO ------------- 4> >a ' V >.: - r' . 41 ' C o 4i e M VI O o <o ia jo u+J _j rx o a c* at on. ai.) tj t- -r- 4J o -m O id V) S- x-- (J S 41 Uv 2: o -- *-0i a3Xv 0a. XOtvty q <o_> +<OJa ca as t/i a> 4o-> o I/) .t(aOn .acwrj co Ta(O3> (j <S/>- (/>* i-Haa--i --o<oCosj <Eo/> zCzD 4J a Ua> iC"O. it-- c^o O<J V>--. +a->) Ta3> i-t-- oa. s- OJ < - i 41 4 fe*2g UCC 013909 cc<x/*df C'TlCt Page 7 TABLE II Bulk Sample Asbestos Type and Percentage Analysis by X-ray D1 ffraction. m!" Cl Mastic 4^r* ee-w ^M L <3Wklc. HI Mastic 43r7 -60^- 38 chrysotile 345S amosite (anthopolfte) 13X chrysotile Monolar Mastic 60-36 No detectable asbestos. Small talc peak. Lagtone Coating W.-3* 3o-7* V. * . No detectable asbestos. Ctrrcc/>~* 6y *' ^ //,i "/V7* ^ ^ UCC 013910 40^3C H Ti fZ l O 2 SfVv.fi {tbits OtJTTtO^. S V $>& ggc*: UJ'iA i_L_ VjT^T'tf A l. UCC 013911 * . / \ < /l r Page f?b t ?*'.$ ;.. "?* :?-. 'v.*r Vi. r^'--' .;iv-., v<^i- 5 r ?'rf?u *... v/.i *. > ^*5 - r ,: - -f,- r v\ * * fig 1 and 2 (above) Samp! e 3538 (400X MagniMcati in) Fig 3 (below) Sample 4031 (400X Magnification) # UCC 013912 *e43 V/,ft/t <* i y t- iJU' /*f * . k*.': , > ; Page Pc Fig* 4 (above-left) Sample 4037 - 400X Magnification Fig. 5 (above-right) Sample 4057 - 400X Magnification Fig. 6 (below) Sample 4063 - 400X Magnification UCC 013913 464 Mist f / J * Jr.r/csslrJ, < n f'age 8d Fig. 7 (above-left) Sample 4075 - 400X Magnification Fig. 8 (above-right) Sample 4078 - 400X Magnification Fig. 9 (below) Sample 4038 - 400X Magnification UCC 013914 4s< $U<Z'n/-K^ac/cf t-rtG. Page 9 V. ANALYTICAL PROCEDURES Enumeration of Asbestos Dust on Membrane Filters Apparatus and Reagents 1. Mixture of Diethyl Oxalate + Dimethyl Phthalate; 50-50 mixture, mixed in a large graduated cylinder, 2. 0.14 grams of mlllipore filter type MF with pores >0,8y is used per 2 ml of solution. This produces a viscous solution having an index of refraction of 1.4? (slightly below that of asbestos fiber), ' ' r i'': v ;' Procedure ^ A drop of this mounting is placed on a microscope slide and a wedge of membrane-filter usually 1cm x 2 cm Is placed on the drop, and # 1.5 coverslip placed on top. This is allowed to stand 15 to 25 minutes, while the filter clears. All glassware used should be thoroughly rinsed in double-distilled water, and dried with low lint paper. All samples should be counted within 24 hours for uniformity, The fibers tend to migrate to the edges of the cover slip with time. . .. : ' .... :- . (1) Annals of Occupational Hygiene, Pergamon Press, Vol. II, 1968. UCC 013915 4 r, t.'fX.C, Page 10 Optical System Phase contrast microscope --------'4mm hidry acromatic lens and lOx ocular with a portion reticle mounted stationary left or right ocular, depen ding on the microscope, at the level the limiting diaphram should be used. The left half of the reticle should be calibrated according to the formula of: .. ' In microns: L x 2n n= porton dot number. Limits of visibility with this system are around 0.3 microns and the resolving power for differences Is about 0.5 microns, rt Is recommended that counting be done by categories according to the porton reticle with the number 1 dot usually being around 1 micron. Thus the category will include all fibers with diameters less than one micron rather than stating the exact diameter, e.g. 0.5 microns. The illumination for this system should be on a ribbon filament illuminator adjusted to Kohler illumination and a green filter with a neutral density of 0.9. Counting Technique At least 20 fields should be observed. All of the fibers longer than 5 microns counted. Because some clients may wish all the fibers to be counted it is wise to set up a category for total fibers, l.e,, all fibers having an aspect ratio of at least 3 to 1. After counting has been completed, the following formula is used to compute the fibers/cc concentration: . Fibers/cc 3 nr?n . LwnV where: itr^ * area of membrane area of microscopic field obtained by stage micrometer N numbers of fibers observed n number of fields observed V * volume of air In cc ^6 UCC 013916 i r V. /COATINGS i > SEALANTS j ' /ADHESIVES S PRODUCT DATA 30-70 31 -90 z:Jrs1 imo fs1E11S1 Ec iSs1 PROPERTIES FOSTER LAGTONE COATINGS COLORS (ASTM D1729-69) 30-70 White 31-90 Gray APPLICATION CONSISTENCY (ASTM D2507-70) Brush or spray WEIGHT PER U.S. GALLON (ASTM D1475-S0) 11.4 pounds (1.4 kg/liter) AVERAGE NON-VOLATILE (ASTM C461-64) 43% to 44% by volume (depending on color selected) THICKNESS AND COVERAGE (FSTM 71) Dry Thickness: 0.017 to 0.007 inch (.43 to .18mm) Equivalent Wet Coverage: G.Q32 inch to 0.016 inch (.81 to .41mm), 50 to 100 sq. ft. per gallon (1.2 to 2.5m2/liter) on smooth non-porous surfaces. Porous or rough surfaces may require higher galionage to attain required dry thickness. DRYING TIME (ASTM C461-64) Touch: 1 hour Through: 4 hours SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) Minus 50* F to 180F (minus 46C to 82sC) WATER VAPOR TRANSMISSION (ASTM E96^6) 3.0 perms at 0.028 in. dry thickness SAFETY * Wet Flammability (ASTM D93-72) Non-flammable Dry Flame Spread (ASTM E84-70) 30 on 1/4 in. Asbestos Cement Board (The flame spread may vary at different product thicknesses and/or when applied over surfaces other than asbestos cement board.) FOSTER LAGTONE COATING is an emulsion type poly meric protective coating. It forms a tough, flexible finish which can be used on ail types of thermal insulation, in cluding the expanded polystyrene and polyurethane foam insulations. Use LACTONE COATING as a combination adhesive and coating for cementing and sealing light weight factory ap plied fabrics such as 8 ounce canvas or muslin. Use LAGTONE COATING over hard asphalt weathercoats to provide color and additional weather resistance. Some flame spread resistance is added to an insulation system when LAGTONE COATING is applied in 2 coats with 20 X 20 whitedass cloth over existing asphalt weath er-coats. LAGTONE COATING is suitable for coating over asbestos-cement board and masonry to blend with ad jacent coated insulations. LAGTONE COATINGS are resistant to dilute acids and alkalies, solvents, and water. They have a mild odor during application. 30-70 and 31-90 comply with Rule 66 for Los Angeles County Air Pollution Control District. LIMITATIONS Protect from freezing. Do not apply below 40*F (4C) or above 100F (38*0). Do not apply oyer other paints. Cer tain soft asphalt mastics papers or fabrics saturated with asphalt may bleed. These products are classified by Underwriters' Laboratories, Inc. FSTM: Foetar Standard Teat Method Trademark 10/74-11-5M BFN-188; 8FO614/622; LFN-1113 H/ 8. FULLER COMPANY FOSTER PRODUCTS 5220 Mom Street N.E. Minneapolis, Minnesota 55421 UCC 013917 < a> UVPONTAKT--UWfTTO WAARMTTY -- The tfM rwlilMd Ift tMl bwflh ire nrnct te the Best pr rar mi testv. The /icdrnminojitgnf *a4 ^uitfonens tontatftM acksM at* mid* w.thdul fi...*j*<ee ition at 10 return Wt rKMi*w>tf thii aie4At# cast* b* nmi be Mi pwcRiief to dilermuie ii i product -s suinl r lor ip* irtie<j*a auroe'-r *m uu. Our only tfelifljhofl tmil be to r^vlete r pay far imirnit picrtetf deleciivo by aw lewW vtary mini* wr OLMihw j.kiI lift period. Beyond me piwemie price of auerufi lurpned by uv we j*u*m no lUONtfy far mate?** tf e/y tttnd iM me sur cccoett mi (N*Juel u it' mi miltovi eny oirief meunin?;. iierii?. j * impute. COA TINGS {f(3sdcBn\ SEALANTS ADHESIVES ` PRODUCT DATA 60-25/20/23 'ii i PROPERTIES . resTEJ c. i. casne* COLOR Black Fopter C. I. MASTIC is a tough, durable vspor barrier asphaltic APPLICATION CONSISTENCY 60-25 Trove1 ; 60-26 Spray ' 60-28 Spray(Low Temperature Grade) coating. Because of its flexibility and low vapor permeance. It la an ideal surface coating for low tem perature insulating applications where the insulation used is not VEIQHT PER U.S, GALLON(ASTH D1475-60) affected by mild solvents. ' 9.3 to 9.5 pounds (1.12 to 1.14 kg/litre) AVERAGE NON-VOLATILE (ASTH C461-60) 641 by volume (60-25 b 60-26) 581 by volume (60-23) C.I, HASTIC may be used on heated lines, vessels and equipment in intermittent or dual temperature service to prevent the entrance of THICKNESS & COVERAGE (FSTH 71) CSubJect to nature of material being coated). Ret coverages shown below are for smooth non-porous- surfaces. Porous or rough surfaces may require higher gallonage to attain required dry thickness. TACK COAT: 60-25, 60-26 water vapor into the insulation during off periods or on cold cycles Porous, dusty Insulation surfaces should be primed ^ith STACSFAS Concrete Curing Agent 51-06 prior to application of mastic. Insulation must be dry before mastic applica tion. Dry Thickness: 0.020 to 0.041 inch (0,5 to 1.0 mm) C.I. HASTTC la an effective protec tive coating for metal. Priming is Equivalent Ret Coverage: 0.031 to not necessary but adequate surface 0.0625 inch(0.8 to 1.6 =a), 2 to 4 .pre^paration Is alwa^ys desirable to gal. per 100 sq.ft.(0.3 to 1.6 liter/m1)obtain optimum results. A coat of on smooth non-porous surface.. as industrial oside-chromate primer FINISH COAT: 60-25, 60-26 will prevent spread of rust from Dry Thickness: 0.061 to 0.051 inch points of physical damage. Equivalent Ret Coverage: 0,094 to 0.125 incb(2.4 to 3,2 mm), 6 to 8 gal. per 100 sq.ft.(2.4 to 3.2 liter/a1) ^AST^C SO-25 may be used as ->ackets pip d dUct lnsulation. on smooth non-porous surface. MOTS; 60-28 Use ICS more material for equivalent dry thickness. C.I. MASTIC 60-25 meets the require ments for water proofing mastics in the TRI-SERVICE SPECIFICATION for PRYING TIMS (ASTH C461-64) Touch: 1/2 to 6 hours . UNDERGROUND HEAT DISTRIBUTION CON DUIT SYSTEMS. Through: 36 hours C.I. MASTICS 60-25 and 60-26 meet SERVICE TEMPERATURE LIMITS(FSTH 70) Military Specification UIL-C-82052. ^Temperature at coated, surface) LIMITATIONS Minus 20F to 200oF(-29C to 93C) Do not use in food storage applica RATER VAPOR TRANSHISSION(ASTH E96-66) 0.00 Perm at 1/8 inch dry film thickness (0.00 metric perm at 3.2 cm) HAZARD tions where odor might affect food flavors and tastes. Do not use on polystyrene foam. Allow at least 30 days curing before top coating with water baa* coatings. Ret Flammability (ASTH D93-73) Flash Point 100? (3SC) Surface Flame Snread(dry)(ASTM E162-67) FOR INDUSTRIAL USE ONLY BY TRAINED AND QUALIFIED CRAFTSMEN. 145 on 1/4 inch(0.63 ca) asbestos cement board. (The flame spread may vary at different product thicknesses and/or when applied A08438 over surfaces other them asbestos cement board.) , '',S Threshold_Llalt Value for solvent vapor (FSTU 73) T.L.V. 100 ppm UCC 013918 . FOSTER DIVISION AMCHEM PRODUCTS. INC. AMBLER, PA. 19002 Tl# IftfMMflM ud <'* MAfilMd **ni* if* bind m mwimli i"d t* N )***. n fuuHtH it mid* 1 Him iKvucy *d (ft# products waiM in wi( vMrMNV, u to tntic nil, iDdticaiiM ifilonninc*. lh* putgMiif uwr Mitll b*t <*** d*Ufi*N *N If Itith prodNIi (Of hit pwplsii *d ut* Mi sijrtiMiM ciflfii#d hoitm IMJI M tcruuii*4 aa *fl indcin*iiif ! Ilfrlnfl# ouiHnf piiMti. if 11 id if IN product* ol HFitf Rwvficunwv, IN {W,,W *** p4rt*imfn:i btikAH rmt viry tfipoadlN riutbrm* or poutify tl iwfici. iriucuian tcfntu iao ivki toddiilon* IN wtNd *M wdifiort* of loeilciiim {*r *hc *4 umsIm "t cwuH id H**ofU*t tacTitt m IN of pftdvttb. likiviii ciftibt iftfertt in miiiT0A4iiioi*b w* itiik* cUNifiind ift* ua# of m* |f*wcti. 1Nriir V| tufcl II | (MVI'MCNI of nil (hll ** *m flfldlr 'l*l|CI IHllMlI M '*(s**d IN pUftflM pM*l If IrtT p*v*4 bir *w libiNKonot la N difKtiwi *tu< W UH IfNi dita If N( tfut v* u*<a iu t? r PROPERTIES COLOR . 60-36 White (Spray! 60-29 Gray (Spray) 60-61 Black (Spray) Other colors available on special order FOSTER MONOLAR MASTICS JNI 'l P i ai ,.'I?vapmf'e!-A\*PaL m*<ui* )'in!, *id ' '-W r- `'TTTi'l'Tj. APPLICATION CONSISTENCY Rubber glove, trowel or spray ' WEIGHT PER U.S. GALLON (ASTM 01475-60) 9.3. to 9.7 pounds (1.11-1.16 kg/liter) AVERAGE NON-VOLATILE (ASTM 0461-04) 30% by volume THICKNESS AND COVERAGE (FSTM 71) (Subject to type of surface being coated) Total Dry Thickness: 0.030 inch (0.76 mm) minimum Equivalent Wet Coverage: 0.096 inch (2.4 mm) (6 gal,/100 ft3)* (2.44 liter/m1) on smooth, nonporous surface. Porous or rough surfaces may require higher gallonage to attain required dry thickness. See Guide Specification for detailed recommendations. DRYING TIME (ASTM C461-64) Touch: 3 hours Through: 2 days SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) Minus 20F to 250F (Minus 29C to 121C) FOSTER MONOLAR Mastic based on duPont Hypaion is a tough, flexible, fire-resistive finish for protection of thermal insulation. It is also used as a vapor barrier coating for fittings. It is excellent for indoor or outdoor use where chemical resistance and durability are required. SPRAYED POLYURETHANE FOAM INSULATION Foster MONOLAR Mastic provides outstanding weather barrier and vapor barrier protection for sprayed polyure thane foam in outdoor locations. It is a one-component high film strength product, usually applied in a single coat with standard airless spray equ^-ment Consult the MONQLAR Brochure and Guide Specifications for further information. APPROVALS: Underwriters' Laboratories, Inc., Classified, UL 732 & UL 790. ICSO Report No. 2763. LIMITATIONS Do not store over 100F (38C). Do not apply below 40F (4C) or above 1G0F (38C). Use within six months for best application properties. WATER VAPOR TRANSMISSION (ASTM E398-70) 0.08 perm at 30 mils dry (O.OS metric perm) HAZARD Wet Flammability (ASTM D93-73) Flash Point 100SF (38C) Dry Flame Spread (ASTM E 84-70) 20 on V* in. Asbestos Cement Board (The flame spread may vary at different product thicknesses, end/or when applied over surfaces other than asbestos cement board.) Threshold Limit Value for solvent vapor (FSTM 73) T.LV. 100 ppm Some plastic foams may be attacked by the solvent in this product. The user should establish by his own test that this will not occur. Wet or uncured MONOLAR Mastic may be discolored by sulphide atmospheres, but the discoloration will bleach aut after exposure to sunlight. Avoid crushing cellular glass when troweling on MONOLAR Mastic. FSTM: Potter Standard Tot Method ^Trademark of KB Fuller Co. 7/75-12 LFN 870/871 FOR INDUSTRIAL USE ONLY BY TRAINED AND QUALIFIED CRAFTSMEN '* H. -8. FULLER COMPANY FOSTER PRODUCTS 5220 Main Street N.E. Minneapolis, Minnesota 55421 800-129.7707 UCC 013919 408459 HfPMTJUfT--lIUITED WAAIW*TV -- Tin InlornuHt* and rtali co> talnod fMt bulKUA lit - tn#c ! m 6f of e,.< Um*:ec* and frill. Tin (tmmmamjali.m, and : uggnrnnj contatnrl ntm i tit iridt wrltietK sum< : or rrorntr.iJtion as to "ts.ln W* irtommoM mil atuquato tnu Ue otujo Ov th* ourclu-.w m cpwieiiu il a fwcitKl >h taWc Tor if- tmoeS Jurson nil. Out aiHy etilMjahen Mint us (s frfii or rtf tor ao> prove, defective by du* .neraiort wutiin eur put homJ jfie ` lit* pvuo4. Sevotid ih# purchase price ol mairuti suprieii by ui. wt isaime ao JiafriJily ' dJfypci et My k .4 if,2 in ostf eccepu ttii product " is1 uM tiihsul u-y other weriMilcY rifiiw -1 9r Implied, ,l COATINGS PRODUCT DATA -ibJTitenr. '^13 i ;[i ii f--v '-~r ) i-- - t j, SEALANTS ADHESIVES 3^ST,*T-----7*JfO*-w1J ,k MJ, liM!Wr*W-1W>--W<ulU*H*,KW''' grt: .^1w-*!u- .- TT*.-., 90-07 90-10 HJ _ I. HI. -I lijtlj . 4 w 1 # J 1 1 %. ; * * f k S'i I C-] * '--r -failteaw***^ =**= - *I u PROPERTIES FOSTER H. 1. MASTIC COLOR (FSTM 4) Black . APPLICATION CONSISTENCY Trowel or spray WEIGHT PER U. S. GALLON (ASTM D1475-60} 9.4 pounds (1.13 kg/liter) (Average) . AVERAGE NON-VOLATILE (ASTM C461-64) 40% to 45% by volume THICKNESS &. COVERAGE (FSTM 71) (Subject to nature of material being coated). Wet coverages shown below are for smooth non-porous surfaces. Porous or rough surfaces may require higher gailonage to artain required dry thickness. Dry Thickness: 0.080 to 0.106 inch (2.0 to 2.7 mm) Equivalent Wet Coverage: 0.19 in. to 0.250 in. (4.8 to 6.4 mm) (12 to 16 gallons per 100 sq. ft.) on smooth non-porous surface. Tack Coat: Dry Thickness: 0.040 to 0.053 inch Equivalent Wet Coverage: 0.094 in. to 0.125 in. (6 to 8 gallons per 100 sq. ft.) on smooth non-porous surface. Finish Coat: . Dry Thickness: 0.040 to 0.053 inch Equivalent Wet Coverage: 0.094 in. to 0.12S in. (6 to 8 gallons per 100 sq. ft.) on smooth non-porous surface. DRYING TIME (ASTM C461-64) 90:07: Toacht I hour at 73F (22.8C) Untight 8 hours at 73 F (22.8Q 90-10t Touch: 8 hours at 60F (I5.6aQ 24 hours at 20F (minus 6.7C) Through: 7 days at 20F (minus 6.7C) FOSTER II. I. MASTIC9 is a highly durable, protective weather coat for use over thermal insulation where an economical breathing mastic is required. H. I. MASTIC is a fibrated asphalt emulsion, made from a blend of prime asphaits, special colloidal day filler, and carefully selected asbestos fibers, which will not shrink or crack (particularly at the critical right angle bends) during curing, it has exceptional weathering stability and develops with its final set a firm, durable surface with good resistance to acids, alkalies, abrasion, and other abuses typical of outdoor industrial conditions. It has no heat flow, remaining hard and stable under ail normal operating temperatures. The following grades are available: 90-07 H. I. Mastic (Standard) 90-10 H. 1. Mastic, Low Temperature Grade U.S.D.A. (M.I.D.) chemically acceptable. 90-07 and 90-10 comply with Rule 66, Los Angeles Air Pollu tion Control District. LOW TEMPERATURE GRADE H, 1. MASTIC 90-10 may be applied during freezing weather when temperature is above 20F (minus 6.7C). LIMITATIONS (Standard Grade only)' Protect H. I. Mastic from freezing in storage. Exposure to severe freezing conditions during application, or between application and full cure, may cause cracks in the cured film. As with ail asphalt emulsion products, application over insulations containing soluble salts may show efflorescence or white salt deposits on the surface if water is present in tha insulation. Efflorescence may be removed by normal rainfall or washing after mastic is dry but may recur if water con tinues to be present in the insulation. ' SERVICE TEMPERATURE LIMITS (FSTM 70) (Temperature at coated surface) 0F to 200F (minus 17.8C to 93.3C) WATER VAPOR TRANSMISSION (ASTM E96-66) 3.0 perms (min.) at 1/8 in. dry ftim thickness (2.0 metric perms at 3.2 mm) HAZARD Wet Flammability (ASTM D93-73) No flash to boiling (2lOF, 99*0 Dry Flame Spread (ASTM El 62-67) 135 on V* in. Asbestos Cement Board (The flame spread may vary at different product thick nesses and/or when applied over surfaces other than asbestos cement board.) O Tndtmifk FSTU-Fomr Standard Tilt Mntiod Form No. 3155-270 4/76-12-6F-243, 268; BFO-953, 954 LFN-1110, 1112 FOR INDUSTRIAL USE ONLY BY TRAINED AND QUALIFIED CRAFTSMEN H.*B, FULLER COMPANY FOSTER PRODUCTS 5220 Main Street N.E. Minneapolis, Minnesota 5542! 800-328-7307 UCC 013920 IUF0TA*T--UUITTD wAMAttTY -- Ina lAfamurlaa tnd cwtti.'td In tilll bulletin irr :VT: Hit tril it tut bnewltdgt mt lisa. Tut iKginintnaali.'iif ind sugoMliem cpnUmtd n.ieia m wiitioul eiutc'et it rtprtui' mod ts la reiuits Wa itfSfflflitM lltai lieoutte tests lit nwt r, the purctucer in dilanaina H 1 unwind n I; .laal* Ipr me '"lenflad Jurpeia ant tit. Our unir aoimitian srun p to i-.ilut o> :jv lor ii*y m.it-eji prun* dettiuw by out 'isartienr *h-m( eur pu'j.rined mail lilt ptrlad- Utyeni uit purctusa price cl malanjJa auPuiitrt r u*. at iiinier no liMilll, In damage* aJ toy lu lot tut tut accapli IM pieluct "u is ' and wiltwat t><r tinar wanannei. itprtuta w Imsllad. Prmatd ia L'.i.t, E. & J. GALLO WINERY Modem, Califarnm April 20, 1977 Mr* Irving Steltz Foster Division H. B. Fuller Company P.0. Box 625 Spring House, PA 19477 ` * Dear Irv: . Attached is an outline of the asbestos`test which I described to you over the telephone on April 14. We could ngt find any airborne fibres using this method. Equipment Used: Bendix battery operated air pump. Procedure: 1. Set at 1.8 to 2 liters per minute. 2. Run for one hour. 3. Observe membrane under microscope using Light Field Technique. 4. Count glowing particles. ; Presently the Federal Regulation allows 2 fibres per cc of air; however, a new Regulation is pending which does not permit more than 0.5 fibres per cc of air. Sincerely yours. E. & 0. GALLO WINERY Donald C. Bettencourt Manager - Cellar Operations DC8:jp 7 ?5Aor'7 711S UCC 013921 SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN.THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY.SB-1591 Airborne Asbestos Concentrations from the Grinding of Thermoset Resins Containing 0.8-18% by Height Chrysotile Asbestos Prepared for the Occupational Safety and Health Standards Board Sacramento, California November 15, 1978 Prepared By Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013922 SUMMARY Union Carbide Corporation has published the results of a study of methods to detect chrysotile asbestos in the airborne dust generated during the grinding of thermosetting resins. As a part of this study, resin plaques containing 0.8 to 18% by weight of asbestos were abraided with a powered disc grinder. The operation was carried out in a closed, 8-1/2' x 8-1/2' x 8' room. Airborne dust samples were collected and counted by the standard NI0SH/0SHA procedure. The personal samples showed concentrations ranging from 0.0-0.7 fiber/cc >5y and the area samples varied from 0.0-1.2 fiber/cc >5y. There was no relation ship between the asbestos content of the plaque and the airborne asbestos content that resulted from grinding. These data are a small part of an extensive study, the balance of which is not related to the Standards Board hearing. In order to provide convenient reference, the relevant portions of the paper have been assembled on the following page. A complete copy of the paper is also attached. UCC 013923 A08443 `Defection of Chrysotile Asbestos in Airborne Dust from Thermosetting Resin Grinding REFERENCE: Fsulring, G. M., Forgeri*. W. D., Klfber, E. J,, tnd RKodei, H. B., "Detection of Chrysotlle Atbettos In Air borne Dust from Thermoaettlnfl Resin Grinding.'* Journal of Totting and Evaluation, JTEVA. Vol. 3, No. 6, Nov. 1975, pp. 482-490. Sample Preparation and Description Resin plaques containing 0.8 to 18% chrysolile were ground with a power-driven hand grinder equipped with a 7-in. (177.8 mm) diameter, 16-grit abrasive disk simulating the fabrication operations found in boat yards and the automobile industry. Compositions of the plaques are listed in Table 1. The grinding was carried out in a thoroughly cleaned, closed, 8Yi by 8H by 8-ft (2.6 by 2.6 by 2.4-m) room. The plaque, approximately J^in. (12.7-mm) thick by 1 by 2 ft (0.3 by 0.6 m), was clamped to a bench 30 in. (76.2 mm) from the floor approximately in the center of the room. The edge was ground for a period of 4-5 min with the grinder rotating in a direction to throw the heavy particles toward the floor. In addition, individual samples were collected before, during, and after each grinding operation by aspirating at the rale of 2 litres per min through Type AA membrane filters (0.8 #iin pore size). *TAQLE 1--CwBjMfliww of ehrysolilo-be&rintf pi&jtiu. Sample No. Rtain Weight, Typo % Chrysolite Fiber Lime Glass Sisal stone Weight, Weight, Weight, Weight, Type* % % % % 1 polyester 79.2 RG-244 0.8 20.0 2 polyester 99.2 RC-244 0.8 >* ,,t 3 polyester 98.0 RG-244 2.0 4 polyester 95.0 RG-244 4.0 .,. ft epoxy 75.0 ItC-144 4.0 20.0 moo polyester 35.0 RC-I10 5.0 10.0 10.0 40.0 7 polyester 35.0 RC-tlO 10.0 10.0 10.0 35.0 8 polyester 30.0 SC-200 18.0 s * - 2.0 50.0 Type* ItC-lU) nnJ HG-144 are opened fibers: SG-20O. pdlctlictl; RG-244, ailicu coaled (Union Carbide Corporation dcaiicnationa of re- ...fined California chryootilc, cummcrcml product*). before during during* No. fibers/cm* of air 0 0.01 0.01 0.01 0.00 0 0 0.03 00 00 0.2 0 1.2 0.7 0.1 0.1 1.2 0.5 00 0.9 0.3 ^ i *"*' * after 0 0 0.01 0.02 0.05 0.02 0 0.00 4 UCC 013924 TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Prepared for a Public Hearing Before the Occupational Safety and Health Standards Board on November 8, 1978 in Sacramento, California Prepared by Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013925 J SUMMARY AND CONCLUSIONS In 1974 a bill prohibiting the spraying, after July 1976, of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair was passed by the legislature. A single exception, for cold process cutback asphaltic roof coatings, was provided. A second-bill, enacted in 1976, provided a two-year exemption from the ban for Portland cement plaster containing less than one-half of one percent asbestos and for certain products similar to cold-process cutback asphaltic roof coatings which contained encapsulated asbestos fibers bound within the finished product from manufacture through application. Finally, a third bill (SB-1591) was adopted this year which directs the Occupational Safety and Health Standards Board to consider whether exemptions should be continued and, if so, to promulgate appropriate regulations. This presentation addresses only the questions in the Notice of Hearing which relate to asphaltic coatings and products with encapsulated fibers. The widespread uses and valuable contributions made by the products are described. Airborne asbestos fiber concentrations are presented from 34 locations covering spraying, removal, and abrasion operations for a variety of products. These data demonstrate that the ceiling concentrations are far below the 10 fiber/cc >5y allowed, and the time-weighted average concen trations are well below the more stringent maximum limit of 1 fiber/cc >5y . imposed by SB-1591. Documentation is presented that extensive and generally unsuccessful efforts have been made to find substitutes for asbestos. It is also shown that the value of the products affected is about $9,000,000 per year, so the economic impact of a ban would be substantial. On the basis that these products are useful and valuable to our society, that the potential worker exposures have been shown to be well within the limits specified by SB-1591 (as well as within the limits permitted for other nonsprayed asbestos-containing products under present DOSHA Asbestos Regulations), that there are no suitable substitutes generally available, and that the economic effect of a ban would be substantial, it is requested that the continued use of asphaltic-based coatings and other products containing encapsulated asbestos fibers be permitted. Specific wording suggesting a maximum allowable TWA exposure of 1 fiber/cc >5y and incorporating the other provisions of SB-1591 into Section 5208, Title 8 is presented for consideration by the Standards Board. UCC 013926 4o8 TABLE OF-CONTENTS Section_________________________________________________ A. BACKGROUND. . . ...................................................................................... 1 B. SCOPE OF THIS PRESENTATION......................... .... ............................. .... 2 C. PRODUCT USE INFORMATION......................... 3 a) Roof Coatings ........... .................................. 3 b) High-Performance and Specialty Industrial and Trade Coatings and Laminating Resins.................................. 4 D. AVAILABILITY OF SUBSTITUTE MATERIALS........................................... 5 E. WORKER EXPOSURE TO AIRBORNE ASBESTOSFIBERS ............................ 6 a) Sources of Exposure Data....................................................... .... 6 b) Presentation of Results ........................................... .... 7 c) Discussion of Results ................................................................ 7 F. BASIS FOR CONTINUED USE OF PRODUCTS........................................... 9 6. SUGGESTED CHANGES IN SECTION 5208, TITLE 8.................................... 11 Page ***** ______________________ Appendices TABLES I THROUGH VII ATTACHMENT I - Statements on Availability of Substitutes ITEM 1 - Excerpt from Response by the Johns-Manvilie Company to EPA proposal on spraying (42 CFR No. 41). ITEM 2 - Excerpt from response from the Texas Refinery Corporation to EPA proposal on spraying (42 CFR No. 41). ' ITEM 3 - Excerpt from EPA rulemaking on spraying (43 CFR No. 18), ITEM 4 - Statement by the Flintkote Company. ITEM 5 - Statement by Chevron Research Company. ATTACHMENT II - California Department of Health Report on Sandblasting of a Maintenance Coating Containing Asbestos UCC 013927 -1- A. BACKGROUND In 1974 a bill introduced by Senator Marks was enacted which prohibited, after July 1 , 1.976, the "spraying of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair." This bill was prompted by the spraying of asbestos building insulation materials in the San Francisco Bay area. For this type of application, dry asbestos mixed with other mineral ingre dients was delivered to the construction site in bags. It was then applied to the structure in two ways: 1. Sprayed in the dry form with a simultaneous spray of water so that it was deposited as a wet mat on the surface. 2. Premixed with water and sprayed as a thick slurry. By either method, the handling of the dry asbestos-containing materials produced clouds ofairborne dust in the immediate vicinity of the mixing operation and in the general area of the building being insulated. After the insulation material dried, it became friable, i.e,, could be reduced to a powder.by hand pressure. It is highly possible that substantial concen trations of airborne fiber would be released during maintenance, renovation or demolition operations of buildings and structures insulated in this manner. No one objected to the banning of this particular use of asbestos. Exposures were difficult to control, could be high, and under certain conditions, . could occur during the service life of the product. The Federal Environ mental Protection Agency promulgated a similar ban on the spraying of friable asbestos insulation materials in April of 1973. Manufacture of such products had generally ceased prior to the Federal action. The Marks bill was so broadly drawn that it banned not only this inappropriate use of asbestos but also a number of other important construction products wherein the asbestos fiber is wetted and encapsulated in a permanent binder or is present only in very small amounts. Fiber released during application and subsequent use of these latter types of products is non-existent or extremely small. It is worth noting that the Marks legislation contained one exception, cold process cutback asphalt roofing products, which is a typical example of the kind of products covered by this presentation. As more information showing very low worker exposure became available in 1975 and 1976 attempts were made in the legislature to modify the Marks bill to permit the continued use of these important products containing bound and encapsulated asbestos. In 1976 a bill introduced by Senator Presley was passed which provided a two-year exemption (until July 1978) from the ban for certain of these products and for Portland cement plaster that contained less than one-half of one percent asbestos. The two-year limit was a compromise to allow the manufacturers more time to search for substi tute materials and for the Department of Health and others to obtain more definitive exposure data. The manufacturers of the affected products agreed at that time to provide suitable sites for DOH testing of fiber.release. &08448 UCC 013928 -2- A. BACKGROUND (Cont'd.) The subject of exemptions was again addressed in the legislature in late 1977 and early 1978. It soon became evident that the legislature was a difficult place for objective consideration of this complex technical issue. The Standards Board, who has technical resources and capabilities, was clearly a more appropriate agency to act on the matter. A compromise bill, SB-1591, co-authored by Senators Marks, Gregorio, and Presley, was passed which transfers responsibility for the matter to the Standards Board, SB-1591 places certain specific limitations, beyond those already contained in Section 5208, Title 8, on regulations relating to exempted products, as follows: . 1. The maximum allowable 8-hour time-weighted average exposure cannot exceed one-half of the present level of 2 fibers/cc longer than 5 micrometers, i.e., 1 fiber/cc >5y. 2. The fiber concentration restriction applies not only to the spray application of the product but also throughout its use and disposal. B. SCOPE OF THIS PRESENTATION . SB-1591 relates to three different types of products: 1. Portland cement plaster containing less than one-half of one percent asbestos. 2. A variety of products where the asbestos is wetted and encapsulated in a permanent binder. These fall into ' two related groups: a. Interior and exterior coatings and laminating resins containing encapsulated asbestos fibers bound within the finished product from manufacture through application. b. Cold-process cutback and emulsified asphalt coatings. 3. Any substance which contains less than one-quarter of one percent asbestos which occurs solely as a result of naturally occurring impurities in the substance or its components. This presentation covers the encapsulated products in Item 2 above and will address questions 3, 4, and 5 in the Notice of Public Hearing dated August 8, 1978, as follows: UCC 013929 A 08 4 4 9 -3- B. SCOPE OF THIS PRESENTATION (Cont'd) "3, If exemptions for any substances containing asbestos are granted by the Board, at what level should the time-weighted average concentrations limits or ceiling concentration limits be set? (Section 25910(b)(3);(c)(3); and (d)(3).) 4. Upon what basis, if any, should products containing "encapsulated asbestos fibers" be exempt? (Section 25910(c)(1).) 5. Upon what basis, if any, should "cold-process asphalt roof coatings" be exempt? (Section 25910(c)(1).)" The applications, characteristics, and quantities of the various products of interest are described and the status of the search for substitute materials is shown. Airborne fiber exposure data collected at 34 locations are presented to demonstrate that the fiber counts are consistently below both those allowed for other asbestos-containing products under DOSHA regulations and the more stringent limitations imposed by SB-1591. On this basis, suggested changes to Section 5208, Title 3, to permit continued use of these products are presented. C. PRODUCT USE INFORMATION ` . a) Roof Coatings Many commercial and industrial buildings constructed today are topped with "built-up" asphaltic roofing. In the installation of these roofs a layer of hot tar or asphalt is mopped or brushed onto the roof and covered with a layer of building felt. The process is repeated until the required number of layers has been installed. The roof joints and flashings are sealed with thicker asphaltic-based "plastic cement" applied with a trowel. In this type of installation the asphaltic compound generally does not contain asbestos or other mineral additives. The building felt may or may not include asbestos, and the trowel able sealer will generally have asbestos as an important viscosity control additive. For proper application, the asphalt is heated to 450-500F and is then hauled to the roof in drums or pails. It is difficult and dangerous to handle and is too hazardous to spray. The heating is done in kettles which may emit smoke and fumes that are potentially harmful to the envi ronment. Environmentally acceptable kettles are expensive and difficult for the smaller contractors to obtain. As an alternative to heating, cold asphalt can be diluted or "cutback" with a solvent or emulsified with water to reduce the viscosity so that the material can be spread on the roof. Such products are termed "cutback" or emulsified asphalt coatings. These products require no heating and can be applied by spraying or rolling. They were used in the past mainly for maintenance and repair of existing roofs; but, with increased labor costs and improvements in spray equi4mng,^_l3iTa^ UCC 013930 -4- C. PRODUCT USE INFORMATION (Cont'd.) a) Roof Coatings (Cont'd.) are now finding much wider use in new construction. Spraying is about ten times as fast as hand application, gives a more uniform coating and permits pumping of material to the roof instead of using drums or pails of hot asphalt. The amounts of the various roofing products sold in California in 1975 are listed in the table below. Of the 8,042,000 gallons used, it is estimated that most of the black emulsions and cutbacks and about onehalf of the aluminized products contain asbestos, that is, about 4,300,000 gallons. Product value for this portion of the total is about $5,000,000 per year. Most of these materials are sprayed. Company Black Cutbacks A 214 B 412 C 160 0 150 E 67 Totals 1003 1975 SALES DATA*'1* (in thousands of gallons) B1 ack Emulsions Primers A1uminum Piamented Neg. 138 143 19 165 ' 291 1800 35 140 O 40 75 941 ___ 0 37 2879 237 708 Plastic Cements 33 737 290 250 127 1437 Other 1328 420 30 ___ 0 1778 "()) Consideration of Model Organic Solvent Rule Applicable to - Architectural Coatings, State of California Air Resources Board, June 1977, Table VI1-7, p-61. " The asbestos content of these products varies from 4-13% by weight. The base asphalt is in the form of an emulsion containing about 45% water or cutback which contains about 40% organic solvent. The water or solvent evaporate during cure to leave an asbestos content ranging from about 6-20% by weight in the cured coating. b) High-Performance and Specialty Industrial and Trade Coatings and Resins This broad group includes a wide variety of high-performance and/or corrosion resistant coatings generally applied to metal, concrete, or wood. High-build vinyl, epoxy, and epoxy-coal tar based coatings, zinc-rich primers and block and foundation coatings are typical of this group. Some typical formulations of high-performance industrial coatings are shown in Table I in the Appendix. These products are used in shipyards, power plants, oil refinery and building construction and maintenance, oil and gas storage tanks, barges, off-shore drilling rigs, and in general, on almost any A0845 ; UCC 013931 -5- C. PRODUCT USE INFORMATION (Cont'd.) b) High-Performance and Specialty.Industrial and Trade Coatings and Resins (Cont'd structure that is subject to corrosion or requires water resistance. In addition to the main types of sprayed materials just described, there are a variety of polyester resins used to provide such things as corrosion resistant linings for chemical process tanks and in the manufacture of fiberglass boats, tub-and-shower stalls, and similar glass-reinforced products. - Approximately $4,000,000 per year of asbestos-containing coatings of the type described are used in California each year. These coatings are generally applied by spraying due to the nature of the surfaces coated and the high labor costs for other application methods. Typical application rates are shown below and it is evident that the use of a brush results in a very substantial addition to the cost. > Conventional Air-Supported Spraying - Airless Spraying - ? 1000 ft. /hr. 2000 ft.^/hr. Brush - 200 ft.^/hr. The products described in this section contain 0.5-3% asbestos by C weight as sprayed and up to 5% by weight in the cured coating. D. AVAILABILITY OF SUBSTITUTE MATERIALS In developing regulations for the control of potentially harmful materials, an important consideration is the availability of substitutes. However, substitutes must be proven harmless {or clearly less harmful) and economically competitive, and must perform the functions of the original material and impart the desired properties to the final product. It is equally important that any substitute whose use is, in effect, mandated by regulation be generally available and be thoroughly demonstrated as practical in actual commercial operations. Asbestos consists of fine, hair-like fibers which, when dispersed in a liquid, form a loosely-connected network which could be described as a three-dimensional spiderweb. This network initially thickens the liquid; but, when the liquid is pumped through a spray nozzle, the network comes apart and the liquid is thin enough to pass easily through the nozzle. When the liquid spray reaches a solid surface, the fiber network immediately reforms and thickens the liquid to prevent sag or run-off. The asbestos fiber network in the sprayed product also provides a bridging effect over irregularities in the base surface, adds strength and toughness to the cured coating, and imparts a certain amount of fire resistance in some compounds.. There are no generally recognized and acceptable substitutes for asbestos fibers which so effectively perform the functions described above. A08ts2 UCC 013932 -6- D. AVAILABILITY OF SUBSTITUTE MATERIALS (Cont'd.) Since many fillers are less expensive than asbestos, the search for alternatives has been ongoing for many years, not necessarily prompted by the asbestos/health question or regulatory activity. However, these factors have clearly intensified the evaluation of substitutes in recent years. Some organic thickeners have been evaluated as asbestos replacements, but most work has been concentrated on other naturally-occurring fiber-like materials and man-made fibrous products such as fiberglass and mineral . wool. Efforts to replace asbestos have been largely unsuccessful because the substitutes usually cause a .substantial loss of functional properties and/or an increase in product or installation cost. Few manufacturers of the products under consideration desire to use asbestos in the present climate of concern over the asbestos/health relationship if a suitable substitute is available. An ashestos-free product with even approximately equivalent cost/performance would have a considerable advantage in the marketplace. The lack of such products is prime evidence that asbestos is an important and necessary raw material. ' Five specific statements on substitutes are provided in Attachment I. Three of these, including the conclusions of the Federal EPA, relate to a recent rulemaking on spraying of asbestos-containing materials and were obtained from the official record of the EPA proceedings. Two were prepared specifically for this hearing. ' E. WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS Exposure to asbestos in the workplace is measured in terms of the con centration of asbestos fibers longer than five micrometers per cubic . centimeter of air. To make the measurement, the fibers are collected on a filter and are counted with a microscope at 400 to 450X magnification. a) Sources of Exposure Data Data on worker exposure during spraying and renovation or demolition operations involving the products described herein are available from a variety of sources. These include: 1. Responses to a Federal Environmental Protection Agency proposal to modify spraying regulations (CFR-42, No. 41 Wednesday, March 2, 1977). 2. A paper presented to the Society of Plastics Engineers.^ 3. A cooperative Government-Industry study on sandblasting of a maintenance coating which was carried out by the California State Department of Health and is reported as Attachment II. (1) "Consumer Safety in Plastics Systems Containing Bound Asbestos Fibers," H. B. Rhodes, Union Carbide Corporation. Presented at the Society of Plastics Engineers, Inc., NATEC Meeting, Denver, Colorado, November 9, 1977. A UCC 013933 -7- E, WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS^ (uont d.) a) Sources of Exposure Data (Cont'd.) All of the data presented are results from personal samples collected in the worker's breathing zone, and most were obtained under routine commercial operations. , b) Presentation of Results, The airborne asbestos fiber counts for over 100 individual samples collected at 34 locations are listed in Tables II through VII and in Attachment II. These results are summarized in the table below and are shown graphically in Figure 1. For this summary, the data have been grouped by two main product types. Roofing Materials and Coatings and Resins. Each type is further subdivided by the operation being tested, i.e., spraying or tear-off or abrasion-of the cured products. The range of fiber counts and arithmetic average are shown for each product type. The arithmetic average represents actual exposures during equipment operation and would be the maximum exposure if the operation was performed by the same worker for an entire eight-hour shift. However, spraying, as an example, is a very rapid operation covering 1000 to 2000 square feet per hour. A worker would normally perform this operation for only a few hours, or less, in a working day. Therefore, a worker's actual TWA exposure would be reduced by whatever fraction of the day the equipment is not in operation. For purposes of this presentation, it was considered appropriate to use the arithmetic ' average (which would be the higher number) rather than calculate TWA's for the entire shift. c) Discussion of Results It is clearly evident from Figure 1 that none of the individual samples even remotely approach the allowable ceiling limit of 10 fibers/cc >5u. The highest value of 1.6 fiber/cc occurred during the sandblasting test and the next highest value was only 0.6 fibers/cc >5u, a factor of nearly 20 below the established limit. Similarly, the arithmetic average values were well below the 2 and 1 fiber/cc >5u limits prescribed by DOSHA and SB-1591 respectively. The sandblasting study reported in Attachment IT is particularly important to the present rulemaking since it represents an extreme test of the extent of fiber release from non-resi1 lent coatings.(1? The entire coating is removed and reduced to a powder by the highenergy action of the blasting. ' (1) Note: Sandblasting is not applicable to resilient materials such as roof coatings which must be removed by other means. . A UCC 013934 04 -8- SUMMARY AIRBORNE ASBESTOS FIBER CONCENTRATIONS - . SPRAYING AND ABRASION OF PRODUCTS CONTAINING WETTED AND BOUND ASBESTOS FIBERS ROOFING MATERIALS Spraying Cutback Asphalt Asphalt'Emulsion Weight Asbestos As Sprayed n?ter (Jure 5.8-7.7 9.7-12.8 z.a 5.1 Tearoff S Replacement Built-up Roofing 01 - 2.8-7.7 S.1-12.8 .Number of Locations Tested 3 2 8 13 Number of Samples Collected S 3 <13 <21+ Airborne Asbestos Concentration (Fibers/cc >5u) Arithmetic Ranoe Averaoe 0.003-0.03 0.04 0.01-0.3 0.1 0.0-0.6 0.0-0.6 0.1 Cata Reference Tables II 8 Table II Table IV COATINGS AND RESINS Spraying Epoxy and Epoxy-Coal Tar Coatings 1-1.5 Chemical Resistant Polyester Coatings 0.7-1.4 Alfcyd Solvent Coatings 6 Vinyl and Acrylic Latex Coatings 0.6-3.7 Polyester Laminating Resins 0.5 0.5-6.0 1.3-1.9 0.7-1.* 10 1.1-6.7 0.5 0.5-10 3 2 1 3 3 12 5 0.0-0.2 0.1 Table V 5 0.0-0.4 0.3 Table v 2 0.0-0.OS 0.03 Table V. 8 0.0-0.2 0.04 Table V 7 0.0-0.6 0.2 Table VI 27 0.0-0.6 0.15^ Abrasion Polyester Laminating Resins - Grinding Vinyl Latex Coatino - Sandino Epoxy Maintenance Coating - Sandblasting 0.5-3.0 0.6 0.6-3.O' 0.5-3.0 1.1 2.1 1.1-3.0 5 1 1 7 12 0.0-0.4 0.2 Table VII 4 0.0-0.3 0.1 Table VII 0.3-0.4 ,,, Attachment II 39 <0.1-1.6 (0.1-0.3)131 55 0.0-1.6 (1) Results Include both the tear-off of old roofing and replacement with the asphaltic materials applied by spraying techniques. (2) Overall average of 27 samples. (3) Eight-hour time-weighted averages. UCC 013935 -9- E. WORKER EXPOSURE TO AIRBORNE ASBESTOS FIBERS (Cont'd.) c) Discussion of Results (Cont'd.) The subject of this test was a 40 foot diameter by 25 foot high metal tank that was spray painted in 1973 with an epoxy-based primer containing 2A% by weight asbestos. The test was carried out in January 1978 so the coating was thoroughly cured. Two professional sandblast operators removed all of the paint on the vertical surfaces, one blasting for nearly six hours and the other for about two hours. They were assisted by a hose tender who kept the blasting equipment filled with sand and helped in the movement of the hoses. In accordance with California regulations, the two blasting operators wore respirators with an external air supply in addition to full protective hoods. Therefore, the data do not represent their actual asbestos exposure but only what it would have been without the required protective equipment. Even under these extreme conditions the maximum concentration found at any time was only 1.6 fibers/cc >5y. The arithmetic average concentrations were only 0.3 to 0.4 fibers/cc >5y and eight-hour time-weighted averages, which are more directly related to statutory requirements, were even lower at 0.1 to 0.3 fiber/cc. As might be expected, the values obtained in the other sanding and grinding ' operations, where the rate of energy input was lower, gave consider ably lower peak and average values. (0.4 ceiling, 0.1-0.2. arithmetic average.) The arithmetic average dust counts show a generally random variation between a virtually undetectable level and 0.4 fibers/cc >5y. There does not appear to be any trend with the amount of asbestos in the product, the type of product, of the type of operation. The asbestos content of the product does not appear to be critical as long as the asbestos is sufficiently wetted and is encapsulated. F. BASIS FOR CONTINUED USE OF PRODUCTS . As noted earlier, the Standards Board has specifically requested comments on what basis should be used for product exemption and, if exempted, appropriate ceiling and time-weighted average exposure limits. The air sampling data for a wide variety of products and operations show that these products consistently result in exposures that are both well below those allowed for non-sprayed asbestos-containing products by the present DOSHA Asbestos Regulations and also well below the more stringent requirements set by SB-1591. These data demonstrate that special regulations for these products are not needed. Extensive and generally unsuccessful attempts have been made to find substitutes for asbestos. Economic considerations are substantial in that about $9,000,000 per year of such products are manufactured and used in California. A UCC 013936 SUMMARY AIRBORNE ASBESTOS FIBER COI.'CFriTRATlONS - SPRAYING AND REMOVAL OF PRODUCTS CONTAINING VOTED AND BOUND ASBESTOS FIBERS SPRAYING^ |-REMOVAL- ~'-------SPRAYING ---------------- *-("*------ --ARRASION------ -- X Asbestos by Wt. As Sprayed 5,8 -7.7 3 After Cure 9.7 - 12.a 5 1 -1.5 0.7-1.4 0.7-1.4 0.7-1.4 6 0.6-3.7 10 1.1-6.7 0.5 0.5 0.5-3 0.5-3 0.6 1.1 2.1 0.5-7.7 0.5-12.8 (1.) Arithmetic averaqe of all samples collected for each product group. Since these operations are generally intermittant. the corresponding 8-hour time-weighted averogns would be lower. 4oe FIGURE 1 UCC 013937 -n- F. BASIS FOR CONTINUED USE OF PRODUCTS (Contld.) In answer to questions 3, 4, and 5 posed by the Standards Board, exemptions should be continued for the types of products discussed herein because: 1. They perform a valid and useful service. 2. They can be used at exposures well within those specified by the legislature. .. 3. No suitable substitutes are generally available, 4. Substantial economic considerations are involved. G. SUGGESTED CHANGES IN SECTION 5208, TITLE 3 A suggested format to incorporate the legislation contained in $8-1591 into the present asbestos regulations in Title 8 is presented in this section. This format is compatible with a similar treatment of the other two product categories under consideration in the manner indicated. Specific recommendations are confined to the product types covered in this presentation. . A new subparagraph (1) is added to Section 5208 as follows: (1) Spraying of Asbestos-Containing Materials. (l! Except as provided in subdivisions (2), (3) and (4) of this subparagraph, no person shall cause or permit the spraying of any substance containing any amount of asbestos in or upon a building or other structure during its construction, alteration or repair. (2) Insert 'wording to provide a specific exemption for Portland cement plaster {if the Board decides that such an exemption is appropriate.} (3) Exterior and interior coatings and laminating resins containing encapsulated asbestos fibers bound within the finished product from manufacture through application, and asphalt roof coatings, shall be exempt from the prohibitions of subdivision (!) of this paragraph. (4) Insert wording to provide a specific exemption for substances containing asbestos which occurs solely as a result of naturally occurring impurities in the substance or its components(if the Board decides that such-an exemption is pparopriate.) UCC 013938 -12- G. SUGGESTED CHANGES IN SECTION 5208, TITLE 8 (5) During any use, spraying, application, handling, storage, repair, disposal, processing, or transportation of such products, the person who causes or permits such acts pursuant to an exemption granted in sub divisions 2, 3 or 4 of this paragraph, shall comply - with the provisions of Section 5208, Title 8, California Administrative Code as it exists on the 'effective date of the amendments to this paragraph ' enacted by the Statues of 1978 or may, thereafter be amended. The time-weighted average concentration limits for employee exposure to airborne asbestos fibers arising from any use, spraying, application, handling, storage, repair, disposal processing, or transportation pursuant to exemptions granted under subsidivisons 2, 3, or 4 of this paragraph shall be no higher than the level contained in Subparagraph (A), paragraph (1), subdivision (g) of Section 5208, Title 8, California Administrative Code, as it exists on the effective date of the amendments to this section enacted by the Statutes of 1978 or as such regulations may, thereafter, be amended.- (. UCC 013939 408459 TABULAR DATA Tables I - VII ( UCC 013940 UCC 013941 * Asbestos - A fte r Cure 5.37 1.71 1.93 7.31 0.5Z 1.01 0 .8 1 TABLE II AIRBORNE ASBESTOS FIBER CONCENTRATIONS , SPRAYING OF FIBRATED ROOF COATINGS v'1)1 2 Date 9/25/74 Binder Cutback Asphalt . Approximate Wt. % Asbestos As Sprayed After Cure 7,7 ^12.8 Airborne Concentration (Fibers/cc >5u)_____ (2) From Total Background Sprayinq 0.023 0.02 0.003 0.026 0.02 0.006 10/9/74 Cutback Asphalt 7.7 a12.8 0.11 0.038 0.072 . 0.065 0.038 0.027 12/10/74 Asphalt Emulsion 2.8 ^5.1 0.16 0.15 0.01 0.17 0.15 0.02 5/19/76 Asphalt Emulsion 2.8 ^.1 0.80 0.50 0.3 (1) Data from a response by the Flintkote Company to "Changes in the National Emission Standards for Hazardous Air Pollutants" {40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977.. Commercial conditions simulated. (2) Background before start of spraying test. UCC 013942 Binder Cutback Asphalt Cutback Asphalt TABLE III AIRBORNE ASBESTOS CONCENTRATIONS SPRAYING OF CUTBACK ASPHALTIC*1 2 Weight % Asbestos As Sprayed ^5.8 ^5.8 Cured 9-. 7 9.7 Sample Time (Hours) ' 5.7(1) 7.2 Ai rborne Asbestos Concentrations (Fibers/cc 5 ) 0.09(^ 0.15^ (1) 260-265 gallons sprayed. (2) Sample possibly contaminated with background non-asbestos fibers from the roof. *Data from response by Texas Refinery Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants" (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977. 408463 UCC 013943 TABLE IV AIRBORNE ASBESTOS FIBER CONCENTRATIONS TEAR-OFF AND APPLICATION OF BUILTUP ROOFING^ Date 3/14/74 4/10/74 5/21/74 7/25/74 11/20/74 12/16/75 8/16/76 8/16/76 Location Wisconsin Indiana Pennsylvania Indiana Colorado Colorado Indiana Indiana Operation New Application Tear-off Tear-off and Replace Tear-off and Replace New Application New Application Tear-off and Replace New Application Airborne Asbestos Concentration (Fibers/cc >5p) 0.2 - 0.6 0.1 - 0.4 0.0 - 0.2 0.1 - 0.3 0.1 - 0.2 <0.1 0.0 0.0 (*) Data from response by the Johns-Manvilie Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants" (40 CFR, Part 61).proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977) 4 08 UCC 013944 c cn o in ot 1/1 A e o *0 O O t/iu i u *>* CM CM JZ -oj k t/> t- X 43 U U 43p- |A <c < C JO oo O uu. CM O O ai e6i--cl a> * 4n0 )h--t r> co ao ro <o L. V a o to a el! uj . ca! "i uji a- S[ O Q, a: = -- x s 43 a. > c ZJ u >1 to t. CL V>1 X s* ai at 4- U a- 3 3 o CO X 4) o -o U vn Q.< CL < L 4) u c cn r* S- >rtS% T<3u o OJ P *o Id -- * $- LA Or 4Q3. *3 J= Vi ul at s. < > X o a. LlI 0> C -X r- U > O "O T3 BJ L TJ a. >, c io u at T> Cl * U LA E O **- d S- L* Q l/l to L* L 4> E 4-> (DO O o CL't- !O wv a. TO 1 CTl O C -X O. *- o a- >i O o flO u u v> CL >i w LO -a 03 i- x O1*-1-- +v O t*o i- 01 = oj *o a Q.'p* U O 1 . ( . 1 . 1 1 . 1 . 1 1 OIVO cU ;p" 03 >.= 4-i o cn at i_ E Q-t*- to VI O "Q S- u o o-- +J r- 04 O t- r*. 1_ CJ a> -*-* TJ l c: c O 'r- to o 43 O & CL l/l * T3 UC *- *0 <5 CO CO to *o3 o + >> X oa. LU 434-3 r* id CM O PfwU4L>-. f4CotU*o3gQ 35 CC*T GU(JJ CL 1 1 1 * 3 1 1 1 1 *.uoXG *>lo_> oc> C*o-J0* 43 Q. a. io cn o tol <c* a. a tn6Os vccr i/i 4f < *4 O i m D i yz UCC 013945 a o o a| ,I i in ^ m to cm . i >,co +J fO CM c L. 43 CL CT o (A C to 4p **> O *-3 T3 to *J o to g > E vi o o a* -- 4-t *- e at o 3 -t- Lu <0 JZ T3 at L3 C Q_ o IT) 1J o m E E to 03 1_ CTl A C H- C CL>-- C 3: JO L Vt L. O i-- Cl +J 43 LA o u U "O u a> c ID cl to 43 OE c U^ Cl-*-* la <L- . co o- . c ^ 1 rts l E 4^ 3 -P o 1 7 JCl . O to |1 i| r--* -o 43 i ou 1 id JZ ia oi c* **- X >. O rO O i- T3 Q. > V) L. TJ U oc *J r- U p-- 43 i-- CL 3 O J= s o CL Cl 03 3i/i * S. < t IS *rs--_ cfO <* r-* Oa r*. r- C <0 to U *-> f HI C E *- *- U V) HI .c ai at c_> S- t- ! J? co co 43 a. fl 3Irt >* o +-t PlU (jj i U L_ I- '-'O 03 3 c a u. 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"> Q } ^ <; L. 0 or +> x ^3 M C (-> 3o </J X 4 a. sC S- ** a. to ia.> o a >* o o -- o <#0- +J oLfl.j *Ur Sctocswo E *3- O^ OX cfQl -3a uk r0a->*-oMrledO *cC7-1 vt -a >1 i u o a. ex 3 CO to CO o dd 10 d <t r-->, X<y 5S r-. c* co r* cn o t, cco +* *o i- C^ V qOC a, otou, cco kCTp--3 L0* fl 3 X a, o v CO CM X aj *r* >> '''s. o o o <x -o c (4 >% i-- 19 K, 0 CO I UCC 013946 I (A c 01 T3 0> O __ ^ f-UQi Vk<S <J4oQM-3l MsUCs* -Ctik*o^f4) c3O 0wJ x CO c *- M * oo enT u O I/I CO uiro- Uv **- O (U >illI>)>0 or V) *f oM o0"o0 >uM* iO Xfl r*--9 -<CU rO- & + O fiCi* 4- 5- >1*0 Qi -*- or > L*m.a*O-.ttakH/) IQc4J1 ^t, Sa,os 3 X -rv 0> +J cQ 4a. oHri o o_ s to. 10> 2 >0 .0 or ou o T43> u i. oo 466 AIRBORNE ASBESTOS FIBER COUNTS SPRAYING OF LAMINATING RESIN- 3 O LO T- A tn1 J CO 0 U U 4J t- U O lA 4-J .Q lA S_ O IP- lA L> OP c < C XI O *r- u Lb so o 1 o 1 1 1 1 0- o 1 oO 1 rt O Oo , * Q. E .E iohs: to CM C o 4-1 "3 J01 CL, o 1 >i 1 flJ'O L L C 01 i9 - LA f C 4- W -*- iA -O 4- qj iq w a vi U Cl o*l cn o 0 ac^- O *- on so LA dr i >v 1 njTD L L. C CL <0 jC (A < 4- *- *- O 1T3 4-> fl3 U Cl i/l 1- CL LA tn o i0 Cl JC -- Of U cn 2 X LA n so IA to rt 1* > >i fl ^ (A L C V) ao v> *-- < O* Wf L trt 4-* -O 0 b *- S- 4-- cn Cl O O ST _ s > 3 > *9 Cl to ** t* 01 01 S-. 4-> IA 4- 3 s o <t o +J lA x oo L. iA tA S' CL< Q. < s- < -o 4-> U o a. Ci. b V) O. 1 uo . <w lO o so * o 4- So CL CL 3 (A CL i CL wo f JC *a: u so o to o i- ia <A C Q. U 3 i- Cl U -a *-- -M 10 (A S_ 03 >* r-- o . <VI r- 4O4J r-. <9 D Cm C 0 - 4-> 0 1- U o <J c L. 3 +J L> <0 <*3 C 10 E 4-* >9 O to c o 0> +* r-- 0 CL EiQ *bi LO tA 01 o <n so IA *i-- (A CL L. S13 CL t1 i-- +J l <0 IA V. >s f1 O Cl 1 1 1 1 r^. t fmm c*i 1 O r" 1 1 U \3 4-* JO >o 1 43 1 flj 1 5: 1 4- 0 1 cc 1 I n 1 1 1 --s a4 (A (A U l Ii < to | o --s 5-- 1 to *| o 1 1 c 1 (A f- lA 1 CL LL 13 al \ -s r-- *4 \ 0' tA 5- 1 >* 1 O O Cl 1 ii \ 1 IA 1 a-- CO 1 o 1 \ \ L. I3 4-1 1D 0 -- 8 1 4- 3 1 0 ( J 0 -- lO CO 1 1 1 eo O | y CM 1 <o r In i 2? % t 2S 1 1 -- Ss S8 22 82 o CM dr i1 as V V <9 Q lob $ U tao i Q00.,-W<01>7 O sf -OS Ai!0a1 co u- co I/I IoA iu(MA 0S- :c (A >> <- *c3 fr9-*1.. O r** 9 t. +J OS-B LA >O e as +j * LL>OA.-D0Uo i(/J> ro-* 4(<p-A0>* U a. ai > -a 01 (0/> *-M*- ueoM<A H<zoUe.i ^08457 UCC 013947 TABLE VII AiHORAE ASBESTOS FIBER COLI.TT5GRINDING AND SAN TING Or POLYESTER RE S1N-BASF0 systems contain;:.:, asbestos Sarnie 3sicnation Conrorciai Application Date Type Asbestos Approx., Ltu i As After Sprayed Cure Operation 1. THCSr SET RESIN (Polyester} 1929-82-3 1929-82-4 Fabrication of reinforceo fiberglass pipe. * 1929-82-5 * 2/27/73 RG-144 2-3 2-3 Operator pulls pipe along line. Sans off end with circular saw. ft a 2-3 2-3 Same operation as 1929-82-3. a 2-3 2-3 Operator removing end of pipe with scarfing macnine. 1-13 1-6 It 6/13/74 RG-244 1.4 N ft 1.4 1.4 Operator shaping end of pipe with bell A spigot machine. 1.4 Operator cutting off piDe end and light grinding on exterior surface. 1-26 6-8 V. r-jQ Fabrication of FRP tanks and pipe. " it 8/13/74 * RG-244 a 1.5 l.S 1.5 1.5 Operator grinding inside of 13' i.D. x 26' tank. 1.5 Continuation of same opera tion as 1-26. 1.5 Operatnr crindinq edges of miscellaneous small parts. 1929-84-4 1923-84-5 Production of artificial bricks. " 3/8/73 " RG-244 2.0 ft 2.0 2.0 Operator cutting with sabre $aw. 2.0 Operator triming with sabre saw. 3-20 N-25 Production of fiber glass boats. 11/26/74 RG-244 0.5 0.5 0.5 Operator grinding inside of boat hull. 0.5 Operator grinding. Sample Time (Min.) 19 49 45 16 17 16 5 25 44 39 11 4 B. V1NTL LAT EX RESIh^l J-33 Sanding of vinyl latex paint. R-43 3/8/77 a T-135 - 0.6 0.6 1.1 Operator handsanding overhead panel. 1.1 ft 12 n J-35 a 0.6 1.1 Operator handsanding wall panel 16 J-4 a a O.S 1.1 ft 16 Possible Airaorne Asbestos Fiber Concentrat'd (Fibers/cc -5.) 0.1 0.1 0.04 0.3 0.2 0.4 0.3 0.3 0.1 0.2 0.0 0.0 0,3 0.06 0.1' 0.0 . (1) Consumer Sarirty in Plastics Systems Containing Bound-Asbestos Fibers,* paper presented at the Society of Plastics Engineers, Inc. NATEC Meeting, Denver, Colorado, November 8-10, 1977 by Harrison B. Rhodes, (2) Commercial conditions simulated. a >0sHa UCC 013948 ATTACHMENT I Statements on the Availability of Substitutes for Asbestos UCC 013949 69 ITEM I Excerpts from response by the Johns-Manville Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants (40 CFRS Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977): "Asbestos is used in asphalt coatings for three reasons. First, to add body or enhance the rheology of the coating, especially the thixotropic characteristics. Other fibers, such as fibrous glass, do not have sufficient bulk to serve as an adequate substitute. Second, since many of the applications for asphalt coatings involve outdoor exposure, the fibrous nature of asbestos provides superior weather resistant characteristics. Third, the low cost of asbestos in relation to the value added is superior to other mineral fillers, and essential in the manufacture of asphalt coatings, which are generally low cost products. A J-M Technical Bulletin describing the use of asbestos fiber in asphalt coatings has been provided as Attachment I. " UCC 013950 Ao^o ITEM I Cont'd V, V. J Gha'V/ SO Iil-lr{ Asbestos Fiber dirysotiS M u*.--j?^ .-aciw&icai Hi tfi&rJi n Asphalt Coatings Asphafl coatings represent a line of products which have a variety of end uses in the industrial, automotive and con struction industries. They are produced for such varied uses as protective coatings tor metals and tanks, insulation for pipes and tanks, sound deadenecs, sealants and undercoat ings for automobiles and roof coatings, flashing cements and tile cements in construction. One type is made from an asphalt cut back with kerosene or mineral spirits used as a solvent and the other with an asphalt emulsion in water. Purpose of Asbestos The primary purpose of asbestos in coatings is to enhance the rheology of the system and especially the thixotropic characteristics. Since many of the uses involve outdoor exposure the excellent weathering resistance imparted to the coating by asbestos is essential and its fibrous nature provides the desired viscosity characteristics. The low cost of asbestos in relation to the value added is essential in these low cost products. Aluminum paste is added to give a reflective coaling; granu lated cork for insulation Manufacturing Process The manufacturing process consists of mixing and packag ing and the sophistication will depend on !he size of the operation. Mixing is accomplished in horizontal mixers of the helical type or vertical or horizontal mixers with paddle blades. Most of the lime the dry ingredients are added to the cutback asphalt and mixing is continued until a homoge neous mix is obtained. In some cases the order of mixing may be reversed or only some of the dry ingredients mixed initially. When mixing is complete the unit is emptied into packages which may vary from one and five gallon pails to barrels. Some products, especially those used in airless spray oper ations, require straining before packaging. Recommended Fiber Grades Formulations 7M05 7RF02 Because of the variety of products and the number of pro ducers there are unlimited formulations. The major compo nents are: 7R05 7T05 7MF5 7TF1 7TF02 ( Cutback Products Cutback Asphalt --30-80% CAUTION Asbestos --10-15% Contains Asbestos Fibers -- Avoid Creating Dust -- Limestone or Slate Fluor --15-30% Breathing Asbestos Dust May Cause Serious Bodily Dispersant -- 1% Harm Emuls ion Products Emulsion Asphalt Asbestos Limestone Dispersant --55-80% --10-15% -- 5-15% -- 1% The physical (or chemical) properties ol Johns-M.wWIc Chrysolite Asbestos f ibt;r repieseni typical average values obtained in accordance viih accepted test mdhuiis .v><J ore <osub fee I to normal manufacturing variations They arc sus-dLuo os a techructii service jod are subject to change without notice. Check (he Johns-Mjnvitte Ji-sinct office iv,uic Co I rent information. ATTACHMENT I Aq e UCC 013951 5 302 7 303 0-1000Asbestos Fiber Sale* P O Bo* lM * Denver. Colo I ( f ?? Canadian Johns-Mam-tHe Co . HQ A^nesloi Fiber OtvtstoA * PO Op* 1500 * Ab*Hoe< Or/ebec, Canada JlT 3N2 (lU9i 979-S433 ITEM 2 . Excerpts from the response by Texas Refinery Corporation to "Changes in the National Emission Standards for Hazardous Air Pollutants" - (40 CFR, Part 61) proposed by the EPA (42 CFR No. 41, p. 12122, March 2, 1977): "These coatings are used in spray applications because of convenience, safety and the ability to get a uniform coating. Spray application of these coatings is conven ient since the containers of coatings are left on ground level and pumped through hoses to the spray nozzle on the roof. It takes fewer persons to spray a roof than to apply it by hand in the same time period, and containers do not have to be lifted to the roof, emptied by hand and the empty containers lowered from the roof along with other equipment necessary to apply by hand. Spray applications are safer due to the fact, as mentioned previously, that the only appratus needed to be raised to the roof is the spray hose and nozzle while the heavy containers of coatings are left on ground level; not as many workers are needed up bn the roof and therefore are not taking risks of falling; and less waste is generated since no rags or brushes are used. Also,most roofs develop low spots during aging which will result in a heavier deposit of. coating in the low spots than in the high spots when the coatings are applied by hand. These heavier deposits will cause problems with the efficiency of the roof which will result in workers having to return to the roof for patching work. This in turn results in add ed expense and re-exposure of workers to safety hazards. A spray application usually results in a uniform layer of coating over the roof regardless of any indentions or low spots on that roof. . Our company has investigated several types of asbestos substitutes for use in these coatings and found none to be satisfactory. Several types of clay thickeners, includ ing Attapulgite, ground cork, styrofoam, ground rubber, vermiculite and Feldspar have been investigated and found to lack the characteristics necessary to impart strength to the coating .polyethylene fiberous powders were tried and found to dissolve in the solvent system and/or not to impart fire resistance or strength necessary to the coat ing. Hemp and other organic fibers were investigated and found not to impart bio logical resistance necessary to prevent attack of the coating or fire resistance. A ceramic fiber was tested and found to give strength, fire resistance and biological resistance to the coatings. However, a problem with settling of the coatings over a period of time was noted; the ceramic fiber is not widely available and is very ex pensive. The ceramic fiber we have tested from Babcock and Wilcox is selling for $0.80 per pound in carloads while asbestos is obtained in carloads at $0.0955 per pound. Also, since this branched, soft, fairly long ceramic fiber has only been found available from the one supplier, it is doubtful whether or not supply would be adequate for complete substitution - industry wide. Substituting the ceramic fiber for up to 10.5% asbestos used in these coatings, cost increase to these products would be substantial. If the coating materials which we produce have to be deleted from the line due to no acceptable asbestos replacement, figures-from fiscal year 197 6 show that 5 >588 million dollars in revenue will be lost annually by our company." UCC 013952 A08472 ITEM 3 Excerpts from "Amendments to Asbestos Standard" (40 CFR, Part 61) promulgated by the EPA (43 CFR, No. 118, p. 26372, 26373, June 19, 1978): "Several commenters, however, requested that EPA exempt from the spraying restrictions certain bituminous- and resinousbased asbestos-containing coatings. These coatings are typically used as roofing compounds, waterproofing of insulation exposed to the weather, automobile undercoatings, and industrial maintenance coatings. Based on information supplied by the commenters, there are no acceptable substitutes available for these uses of asbestos. Among the most likely substitutes which have been investigated are glass, cotton, wood cellulose, mineral wool, hemp, and other types of inorganic and organic fibers; gelling and thickening agents; clay thickeners, including attap'ulgite; ground cork; styro foam; ground rubber; vermiculite; feldspar; polyeth ylene fibrous powders; and ceramic fibers. Generally, these substitutes have been found to be unacceptable because of unsatisfactory durability; insufficient bulk; unsatisfactory qualities related to fibrous reinforcing, homogeneity, and adhesiveness; agglomeration during spray ing; and settlement in the container over time. Further more, if asbestos fibers are released during application of the coatings, during their service life, or during demolition or renovation, the fibers will not remain airborne because they are encapsulated by droplets of the binder and are too heavy to remain suspended. Because there do not appear to be acceptable substitutes available and any beneficial environmental impact resulting from the prohibition of this use of asbestos would be negli gible, the spraying of materials in which the asbestos fibers are encapsulated by a bituminous or resinous binder and which are not friable after drying is exempt from the provisions of 61.22 (e) of the promulgated amendments." UCC 013953 *08473 mHTXQTz: TO Mr. Jim Hay INTER-OFFICE CORRESPONDENCE ITEM 4 DATE March 8, 1978 FROM John Tamanen subject C-13-C4 WITH & WITHOUT ASBESTOS Asbestos is used in asphalt emulsions to provide reinforcement and aid in fire retardancy. Asbestos has high water or oil absorption, does not melt and will not burn or contribute to a fire, Organic fibers such as cellulose, polyethy lene, nylon or polyester as well as fiber glass or mineral wool, can be used to make fibrous asphalt emulsion products. They can be used in combinations or alone, but none have the same characteristics as asbestos. Organic and some mineral fibers will melt or burn at elevated temperatures, generally have a low water or oil absorbancy and can contribute as fuel to a fire. We have made- a few samples of C-13-C4 using blends of fiber glass and organic fibers. They do show some promise as far as manufacturing procedures and workability are involved. Further work is needed to determine storage stability, weathering characteristics and fire retardancy. JT :rb cc: Mr, W. Bradley A FORM 62 M UCC 013954 Chevron L'-'-'J ^j Chevron Research Company A Standard Oil Company of California Subsidiary 576 Standard Avenue, Richmond, CA 94802 J. H. Macpherson Vice-President ITEM 5 September 19, 1978 Mr. Harrison B. Rhodes Union Carbide Corporation Metals Division P.O. Box 579 Niagara Falls, New York 14302 Dear Mr. Rhodes: We understand that you plan to testify at the November 8, 1978, public hearing of the Occupational Safety and Health Standards Board relating to asbestos-containing products. In response to your request for information on substitutes . for asbestos, we have the following comments: For several years now we have been actively searching for an asbestos replacement in our asphalt-based coatings. We have evaluated a variety of materials, but so far have found none that has the same cost/performance effectiveness as asbestos in our products. Asbestos fibers serve two purposes in our coatings: 1. It gives the freshly applied coating a thixotropic consistency that allows the buildup of a thick film without sagging. 2. It reduces the alligatoring of the asphalt film. We have tried various pigments and gelling agents. Pigments, such as mica, talc, slate flour, and carbon black, by them selves do not provide the thixotropic characteristics desired. Thickening agents do impart thixotropic structure to the liquid; but they do not give the same sag resistance and film build. Polyethylene and polypropylene fibers also have been evaluated. These are advertised as asbestos substitutes. However, some of them could not be mixed into the coatings because of inconroatibility. Others did not have the required ' . 4847V UCC 013955 Mr. Harrison B. Rhodes -2- ITEM 5 Cont'd September 19, 1978 sag resistance. The storage stability of the coatings made with these materials was also a problem. Due to cost and application problems, asphalt-polymer combinations have been eliminated as practical coatings. We expect to continue the evaluation of various materials as asbestos substitutes. However, at present we have no practical substitute for asbestos in our coatings. Very truly yours. c UCC 013956 oa(?e ATTACHMENT II California Department of Health Report on Sandblasting of a Maintenance Coating Containing Asbestos ( UCC 013957 A84?? Due to logistics problems the final version of this report was not received in time to be included. It will be submitted directly to the Executive Officer of the Standards Board for attachment to this report. ( UCC 013958 4 w" SUPPLEMENTAL INFORMATION FOR TESTIMONY CONCERNING POSSIBLE CHANGES IN THE HEALTH AND SAFETY CODE SECTION 25910 AS PERMITTED BY SB-1591 Asbestos Fiber Exposure During The Destruction of Maintenance Coatings By Sandblasting Prepared for the Occupational Safety and Health Standards Board Sacramento, California November 15, 1978 Prepared By Union Carbide Corporation Metals Division Niagara Falls, New York UCC 013959 SUMMARY AND CONCLUSIONS The air monitoring test during sandblasting at Corona, California that was reported in the October 30, 1978 DOSHA letter to the Standards Board was a cooperative study wherein Union Carbide Corporation and DOSHA collected simultaneous paired samples on the workers. A report of the Union Carbide results is provided herein. The UCC counts ranged from about the same to about one-half of those found by DOSHA. Considering the nature of the samples, both laboratories were in accord that the differences were due to the normal random errors in the sample collection and counting procedure and did not represent a significant difference between the laboratories. The critical problem with these samples was the presence of large amounts of mineral particulate that met the criteria for a countable fiber, but in all probability were only very rarely asbestos. An examination of three of the filters by scanning electron microscopy was carried out by Union Carbide. This study confirmed that free asbestos was rare and made up very roughly one countable fiber out of fourteen. This information led to a further cooperative, large-scale sandblasting test at Trona, California wherein the samples were collected by DOSHA and counted by the Federal OSHA Compliance Laboratory in Salt Lake City. The Federal laboratory has considerable experience with this type of difficult sample and uses a combination of sophisticated optical techniques and electron microsopy to aid in the identification of non-asbestos particulate. The results of this study showed a ceiling concentration of 1.6 fiber/cc >5y and 8-hour TWAs in the 0.1 to 0.4 fiber/cc >5y range. We believe that these levels, which may still be conservative (high), are more representative of asbestos fiber release from maintenance coatings during sandblasting than the data that either participating laboratory obtained at the earlier test at Corona. UCC 013960 os TABLE OF CONTENTS Section________________________________________ A. BACKGROUND. . ...................................................................................... 1 B. RESULTS AND DISCUSSION 1. Fiber Counts by the Optical Phase - Contrast Method ... 1 2. Fiber Analysis byScanning Electron Microscopy.......................... 2 C. COMMERCIAL SANDBLASTING TEST....................................................................4 D. CONCLUSIONS.......................................... 6 E. FIGURES 1-12.................................................. 7 F. ATTACHMENT I 1. DOSHA letter of October 30, 1978 to the Occupational Safety and Health Standards Board....................19 2. Appendix B of October 30, 1978 DOSHA Letter (Village Grove Park, Corona, California Test) .................... 21 3. Appendix C of October 30, 1978 DOSHA letter (Kerr-McGee Test, Trona, California)........................................25 G. ATTACHMENT II (Union Carbide Report of Cooperative Air Monitoring Test at Village Grove Park, Corona, California . . . . .32 H. ATTACHMENT III (Protocol of Cooperative Air Monitoring Test at Kerr-McGee, Trona, California)............................................... 38 Page UCC 013961 ^Og A. BACKGROUND During the hearings on the 1976 Presley Bill, Assemblyman Fenton asked the Department of Health to collect additional exposure data during the use of the products for which temporary exemptions were eventually granted. A cooperative government-industry effort ensued. The data obtained were submitted to the Standards Board by Mr. James H. Heacock of DOSHA in a letter dated October 30, 1978 (Attachment I). Appendix A of this letter covered tests of Portland cement plaster. Appendices B and C related to sandblasting of maintenance coatings. This discussion is limited to maintenance coatings, the plaster applications will not be covered. The initial two sandblasting tests (Location 1 and Location 2, Appendix B in the DOSHA letter) involved the removal of an asbestos-containing coating from a plaster or a stucco.wall. When the results became available, they were higher than anticipated, i.e. 0.5-3 fibers per cc longer than 5y. The manu facturer of the paints then asked Union Carbide to participate in a third test jointly with the DOH. This was acceptable to the DOH and the Village Grove Park location in Corona was selected as the site. In this test the blasting operator, helper, and observer each wore two pumps and simultaneous samples were collected in the breathing zone with filter cassettes positioned on opposite shoulders. Paired background and area samples were also collected. A detailed report of the Union Carbide results is provided in Attachment II. For easy reference the corresponding DOSHA report has also been included in Attachment I as Appendix B. Only the key points of these reports will be summarized here. B. RESULTS AND DISCUSSION 1. Fiber Counts by the Optical Phase - Contrast Method The samples collected in the test at Village Grove Park, Corona were extremely difficult to count. They were heavily loaded with both fibrous and non-fibrous dust. Considerable particulates were present that met the dimensional criteria of a fiber, i.e. length greater than 5y, length to diameter ratio greater than three, but they were clearly not asbestos. Both counters were experienced and discussed the problem of evaluating filters of this type prior to counting. In an attempt to assess the impact of the asbestos fiber recognition problem. Union Carbide divided the fibers counted into two classes, "obvious chrysotile asbestos" and "possible asbestos fiber." When there was any doubt about a fiber's identity it was included in the count. The total of both classes would be the value ordinarily reported as asbestos. Particles which were obviously not asbestos were not counted. This Included such things as unbroken fiberglass, mineral flakes with non-parallel sides, and particulate that appeared bright under phase contrast. It should be noted that the only known source of asbestos of any type was the 5% by weight chrysotile that was added by the manufacturer. (Note that the 2% asbestos figure reported by DOSHA in Appendix B is in error.) -1- UCC 013962 The Union Carbide results ranged from 0 to 0.8 fibers/cc >5y of "obvious chrysotile" and from 0 to 3.6 fiber/cc >5u for total asbestos. (See Attachment II.) These total values are compared with the DOSHA results for each paired sample collected on the opposite shoulder of the workers in Table 1. These values range from 0.1 to 7.1 fiber/cc >5y. Examination of Table I shows that the pretest controls and several of the samples collected on the observer and on the helper resulted in the detection of only several fibers in the hundred fields examined under the microscope. Blank filters, i.e. those which have never been exposed, will read from zero to several fibers per 100 fields, so these results really are not distinguishable fro#background. The remaining eight pairs ranged from about the same to a Cal/OSHA counting of abbot double that of UCC, 7.1 vs 3.2. Considering that these counts are not'from the same filter but from filters that were collected on opposite shoulders, teSth laboratories were in agreement that the differences were probably the result of random errors in the sampling and counting method and did not represent a significant difference between the laboratories* The time-weighted averages for the two operators for the time period where sandblasting was actively.in progress and for the entire eight-hour day were calculated for each set of total asbestos count data and are listed below. The two workers' actual TWA exposures for the particular day were all below 0.5 fiber/cc >5y. The highest value reported by either . laboratory, 7.1 fiber/cc >5y is still below the ceiling limit of 10 fiber/cc >5y. Time-Weighted Average Exposures (Fibers/cc >5y) During Active Operations Cal/OSHA UCC 8-Hour Day Basis Cal/OSHA UCC Helper 1.1 0.6 : : ^ 0.2 0.1 Operator 4.1 2.2 , 0.2 ^ . iff5'5 0.2 : 2. Fiber Analysis by Scanning Electron Microscopy ^ It was evident from the results that non-asbestos material was being included as asbestos in the counts reported. In order to check this further. Union Carbide examined three of the filters with a scanning electron micro scope. A small square from each of three filters was exposed to acetone vapor under conditions that had previously been determined to collapse the filter to a smooth surface but did not allow the particles to sink into the filter. Shrinkage in area was measured and found to be about 45%. The samples were then gold-coated and mounted for microscopic examination in the normal manner. A 08 48 3 -2- UCC 013963 TABLE I COMPARISON OF AIRBORNE ASBESTOS FIBER COUNTS DURING SANDBLASTING OF ASBESTOS CONTAINING MAINTENANCE COATING Sample Data Description of Operation Total Ho. On Off Hin. Pretest Controls On fence, left side of tree to be sand-blasted. -4 1/Z" above ground. G-16 10:35 10:55 21 On fence,"1001 from G-16. ^5' above ground. F-44 10:42. 10:59 17 Personal sample on observer "25* from fence and moving -parallel to fence. A-86 10:39 10:52 13 Observer (During Sand-Blasting) Personal sample on observer A-81 11:12 11:18 "20-3O1 from fence and moving 11:25 11:27 parallel to fence. Same as A-81. J-89 12:26 12:52 Area sample on fence. 5` G-3 above ground and j4Q' down wind. (In lieu of observer) 1:35 2:00 6 2 8 26 25 Helper (During Sard-Blasting) Personal sample. Assisting with hoses. Operating sand feeding equipment. Same as G-48. G-48 11 :!0 11:12 8 11:24 11:26 2 Iff 1-8 12:25 12:48 23 Same as G-48. Same as S-48. C-1S W 1:08 1:36 1:22 14 1:58 22 Blasting Operator (Curing Sand-S lasti.'l) Personal sample, Operator handling sand-blasting nozzle, standing~2" from fence. Same as D-71. 0-71 11:10 11:18 3 11:24 11:26 2 x-u 12:25 12:35 It Same as D-71. G-34 12:38 12:46 8 Same as D-71 except inside of hood. Same as D-71. X-2 1:08 1:22 14 X-3 1:36 1:53 22 UCC 110 fields f/cc Fiber Counts Cal/OSHA UCC sYnTf/Tc) f/cc Asbestos Non-Asbestos Total Concents 2 0.1 0.3 00 0.1 2 0.1 0.2 1 0.1 0.1 1 0.03 0.2 3 Asbestos 29 0.7 1.9 0.3 1.0 1.3 fibers in 25 fields IS 1.0 28) 45) 1.1 3 . 0.2 2 0.06 n 2.2 1.4 2.2 0.5 0.2 1.6 43) 58) 3.2 7.1 38 3.3 6.6 34 1.7 3.7 56 1.8 2.1 0.3 0.0 1.5 1.8 3 asbestos fibers in 25 fields 0 asbestos 1.0 1.0 fiber In 75 fields -3- UCC 013964 Random fields were then selected and examined for particulate matter which met the "fiber" criteria, i.e. L >5u, L/D >3. Magnification was 1500X and the defined field area used was 0.0048mm2, This is similar to the optical counts where the field was G.0062mm2. whenever a fiber was found it was analyzed by Edex in the spot mode for chemical composition. Detailed results are listed in Table II and Figures 1 through 10, and are summarized below. Sample No. X-3 G-3 D-- 71 Total Fields Counted 75 25 25 125 Fibers Found^ Chrysoti1e Non-Asbestos 0 34 3 2(2) 11 19 5 64 Total 34 14 20 69 (1) Length greater than 5y, length/diamer greater than 3. (2) Does not include a non-fibrous asbestos "clump". These data demonstrate that free asbestos fiber in the generated dust is both rare and a small fraction of the total fibrous particulates, in this case about one fiber in fourteen. The potential for erroneously high counts by the ordinary phase-contrast optical method is obvious. The number of fields examined for each filter and number of fibers found were too small for a reliable estimate of airborne concentration. As a point of interest, however, the fibers per cc values corresponding to the numbers of fibers found have been shown in Table 1 and positively identified chrysotile asbestos ranged from 0 to 0.4 -Hber/cc >5y. These would be ceiling, not TWA values. C. COMMERCIAL SANDBLASTING TEST When these results became avilable, the problem was discussed with Mr. Heacock of the DOH and it was agreed that a carefully-planned, large-scale test using professional operators and equipment should be made. Samples would be collected by DOSHA and counted by the Federal OSHA Compliance Laboratory in Salt Lake City. This laboratory has had considerable experience with the type of highly contaminated samples expected and utilizes a combination of sophisti cated optical techniques and electron microsocpy to provide more reliable counts. A -4- UCC 013965 S ISOOX TABLE II SAMPLE ANALYSIS BY SCANNING ELECTRON MICROSCOPE Chemical Composition by EDEX Field Area 0.Q04&ra^ 7t*u * 1 t1I4I 1970 11 12 1U3 IS IS 1107 1* 30 21 2232 2H4 2270 2190 31 32 33 34 3399 37 30 39 40 41 42 43 49 44 47 40 4590 . r ffow 00040000200900111 2 t 3 0011 Appro*, LMt JiL S S 7.9 *J ID ,i 11952 10 12 4 lOlbm ami no. 1-1 -XlXXI-X--3I3X-X- - i-Astesto* (PTwttt 1 3 i) X-XX3-XX-- lon-Jbbettot {Pheiftt.l X I*) ' ] J | J ' ] ' ' * tfltli lOB-XlbfltM ---I-I---- jitt ..111.... . (HU| 3 1 3l) * " C ! I..........................tDtft Hon-takntoi ----IIIIXI-----*--*-----*11 I --IXX--*-- - - - I............................. I Asbntn 14 InHUbnW ffuM we. M. f fiber* inw. Lenptft S*L t1 21 9 i1 40 S i1 S 0 70 00 9 1 10 10 2 7 7 H1 S ii 0 ii 0 14 0 IS t 19 0 17 0 It 1 9 19 1 8 20 0 21 l 1* 22 a 23 0 24 0 a0 it 0 27 9 SB 0 If 0 3d 0 31 1 i 32 0 a 1 11 34 0 80 39 0 ML 1 It 30 0 39 0 40 3 It 14 41 0 <2 0 43 0 44 0 0 44 2 14 . 14 <7 0 43 1 90 IS I---ii -a. t-i 111 Ma l il 51. t & fit a. Ii Tl^ Ttaitffltitlai - iX V 1 lp*Athstot ftftft-AibestM M--bbtn 1 M hthiitw - X X 1 X - - - X Kftft-AUcttat m X ---- m Beth Ban-Asbestos m.-X1 a* Afhsstw ion Aibeitas ten *ifitft --iIX bon Asbestos H0ft-Asb*t0S boo-Asbe*to* All lee-Aibeito* loth Keft-Asbesto* oft-AibestH Xntm m Cl) SMMllTf idjKfH f1*14* CMMt*4. 0 Mnto* 20 MM-AibastM Dtlt -Sfc-r 1 I 9 4 * ii * 9 M 11 11 13 U K 17 M 20 ii a a M Ho* of FI ben i 3 0 0 2 9 2 0 0 0 0 0 0 1 1 a 1 0 1 a Approx. it*?;* _iij_ 27 19 1 10 10 4 5 1 7 j t% w SAtflt MO. 4-3 - 3-1---- - - i idyitificitiow u i mil - - - 3 -........................Oil OoiMcbatM ---I------ --III--- 3 3 140 llw *lbO|f - ....3 1 - - Msocstoi : - XZX-- --1-13---- on Uitoitu It laHUHtM 5 smi 30. 0-7! 71t4 n*.a r 2 3 4 t 4 7 9 10 11 11 u 14 IS 11 17 11 19 10 n It 23 34 to Id. 47 fibers 1 2 t 0 0 4 1 1 2 0 0 0 1 1 I 1 0 1 Uflftfe Cm3 .a 14 nw 12 t4 t4 10 20 30 7 t t IS 7 14 0 9 to VI f* Om SiSliiSlJtClCuFtTnXl I4nt1f1cstl4 *I -- 1I X-3 I -X13 X*- - lUKAsbtstet loth Non-Asbeitas loth R4ft-Ab*t$ --X( I --XI 1 -X-X0X11- " X * l 2 1 Alt X - - 3 I Asbestos IPhotw 5 0 5aT7 k - - AaftevtaSi VhVtos*4~i4* -111..... Hon-OllM^tOt - 1 I I I ... . Dttt4iw"T7n4tot 7 *nt'ur ft twOlsp obulsM (burnout). *ei toufti#* aimsui ft itadlif obtftfuo* (hnmt}, dot Count** it Atbettft* 311---- - fton-AsOeitoi banA;b*stos X-X--3-- ihthesM'. diuop" 33X--X-- %gn-A*eeVtDV photos' II"i^ - ino-ftiMiTiri I Photo* 12 9 1 **-- 3 Miitn fibers 1 ClMft 17 *-**bf*tw UCC 013966 The protocol for this study is appended as Attachment III and the DOSHA Report (Appendix C of their October 30, 1978 submission to the Board) of the study is also given for reference. The DOSHA report covers the test very well although it should be noted that the Federal OSHA counter included any fiber of doubtful identity as asbestos so the results presented would be conservative (high). It is also appropriate to acknowlege that the test site was provided through the courtesy of Kerr-McGee Company at Trona, California. Figures 11 and 12 show photographs of the test which give a clear illustration of the nature and scope of the operation. CONCLUSIONS The fiber counts reported in Appendix B of the DOSHA letter of October 30, 1978 as well as the Union Carbide counts of the simultaneous counts include a great deal of material that is not asbestos. The subsequent large-scale test although possibly still conservative (high), is more representative of exposure during sandblasting. 6 UCC 013967 Photo 1 - Sample X-3 @ 10,OOOX Photo 1A - Spot Mode of Particle Show Above A8^88 UCC 013968 FIGURE 1 \1 Photo 2 - Sample X-3'@ 1500X~ Photo 3 - Sample X-3@ 1500X Photo 3A - Spot Mode of Particle Shown Above AOg UCC 013970 FIGURE 1 i Photo 6 - Sample D-7.1 @ 1500X Photo 6A - Spot Mode of Particle Shown Above -10 ! O84 9 UCC 013971 FIG4U* RE 4 Photo 5 - Sample D71 @ 1500X_ -11- UCC 013972 FIGURE 5 Photo 7 - Sample D-71 @ 15,OOOX Photo 8 - Sample 0-71 .0 1500X Photo 7A - Spot Mode on Particle Shown in Phojfasin 7 and 8 -12- UCC 013973 FIGURE 6 Photo 10 - Sample D-71 @ 5000X -13- UCC 013974 FIGURE 7 Photo 11 - Sample D-7T @ 1500X Sample 11A - Spot Mode of Particle Circled Above A QQ ^ UCC 013975 FIGURE 8 Photo 12 - Sample D-71 @ 20.000X Photo 12A - Spot Mode of Fiber Particle Shown Above UCC 013976 tQe FIGURE 9 Photo 14 - Sample G-3 @ 1500X y Photo 14A - Spot Mode of Particle Circled Above >4 4.o v? ! -16- UCC 013977 FIGURE 10 COMMERCIAL SANDBLASTING TEST KERR-MC GEE CORPORATION - TRONA, CALIFORNIA UCC 013978 LunncnuittL jriMuoLnj i ijiu i u^i KERR-MC~6EF CORPORATION - TRONA, CALIFORNIA Operator on Manlift Sandblasting Top Portion of Tank A84gg DOSHA Representative Collecting Samples and Recording Data to I ` UCC 013979 FIGURE 12 STATE OF CALIFORNIA DEPARTMENT OF INDUSTRIAL RELATIONS DIVISION OF OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 144? WEST TEMPLE 103 ANGELES, CA 90026 _________ *^ EDMUND O. SHOWN JR.. Cowrtr ADDRESS REPLY TO: 144S WEST TEMPLE LOS ANGELES. CA SODAS October 30, 1978 T 61978 Occupational Safety and Health Standards Beard 1006 Fourth Street Sacramento, CA 95814 <SS;^uoWa, Gentlemen Subject: Public Hearing November 8, 1978 Asbestos Products in Buildings'and Structures The Occupational Health Branch of the California Department of Health evaluated employee exposures to asbestos during the destruction of building materials in an industry-government cooperative consultation program. Results of those tests have bearing on all items of the hear ing and specific information on Items 1, 2 and S. Previously applied sprayed materials containing asbestos were removed by sanding or sandblasting, or the structure demolished. The employees doing the work were sampled and results analyzed in the same manner as any other compliance or consultation GSHA samples would be handled. (In one study, samples were analyzed by the Federal GSHA Laboratory in Salt Lake City in the hopes that advanced analysis might be available. They repeated the California 0SHA Laboratory and NIGSH methods.] Regarding Public Hearing Questions 1 and 2, the report of employee exposures to airborne asbestos during demolition of a portion of an apartment building previously damanged and burned by a light airplane is attached as Appendix A. The stucco was identified as having been sprayed, and as having contained less than one-half of 1 percent asbestos. In summary, employee exposures during demolition were determined to range from 0.25 to 0.33 fibers longer than 5 microns in length per cubic centimeter of air. Regarding Public Hearing Question 3, if any exemptions should be granted by the Eoard, it is recommended that employee exposures be limited to, and employee protection be the same as, that specified in Title 8, CAC 5208 Asbestos. -19- A85Qq UCC 013980 Occupational Safety and Health Standards Board Page 2 October 30, 1978 Question 5. Regarding exemptions for products containing "encapsulated fibers," tests conducted by the Health Department indicate that the fibers are not all "encapsulated" during destructive removal, such as sanding or sandblasting, but rather are also found as free fibers. Four studies were conducted, with reports forming Appendices 3 (consolidated report of three studies) and C. In all studies, employees were exposed to asbestos fibers, with a range of 0.1 to 7.1 fibers/cm3 (greater than 5 microns in length). James H. Heacock Supervising Industrial Hygiene Engineer JHI/cs enc -20- UCC 013981 APPENDIX B TEXTUEED COATr.TS OF AMEHICA, INC. Because of'Legislature concern with regard to future worker exposure to the asbestos cor. a aired. in asbestos coatings being spray applied, the Occupational Healcn Branon conducted industrial hygiene osterminations of worker siC2csure ao asbestos released from substances (these materials covered by the exempt!,cns introduced by SB 1596), previously applied and aged, curing build.ing renoYsticn/rspair and demolition eperatiens. Hr. P. Tillisch cf Texrtursd Coatings cf America (TCA) agreed to provide appropriate opportunities for such determinations during typical in dustrial eperatiens. This.study involved intermittent sampling and analytical determinations over a period of several months. On three different occasions, the Department of Health, Occupational Health Branch and TCA conducted tests: (1). August 3-t 1976 at L.S01 Exposition Blvd., Lcs Angeles, . for building interior coatings ` (2). November 16, 1976 at 950.S. Broadway, Los Angeles, for building exterior coatings and (3)* December 17, 1976 at Village Grove Park in the city of Corona for e coatings. * METHOD At all three locations sanding or sandblasting was used to simulate building renovation. ., . At the first location, 1=01 Exposition Blvd., Lcs Angeles, the tests for asbestos were conducted inside the building at the end of a hallway which had been partitioned off from the rest of the building (to keen oust to a nine. The enclosed area was approximately 5 it wide, 12 ft long and 3 ft high. Inside the partitioned area an "employee" did the actual sanding, The "employ was Scott Tillisch, an employee of TCA. He was observed by Mr. J. He acock and Mr. L. Beck-of the Occupational Health Branch (CHB) and Mr. M. Ordanik of the Southern California Laboratory Section. The sanding was done with a portable electric hand sender which the operator usea on the wall for apprcxir.ately 2 hours. . Samples were collected in three ways. The first was in the operators breathir *one. (CBZ). The second type was an area sample. The area sample utilized the same type of pump and filter-cassette am the CBZ sample but were located A -21 UCC 013982 *22# H532I/S"V77M APPENDIX B -2- * 2/23/77 on an " observer'1 who valued back and forth throughout the test area. The third type c; mimsi-xu cvai-scaem, were "material" osmpiei. These were collected frsm the setsivi dust miter the sanding operation cy chipping material ad: ad the sandpaper dace, or from the material odd cd the wail before sanding. At the seccr.d "location, 950 So. Brsodwuy, Los Angeles, the asbestos test was conducted in the alley behind the building using a ccmm.srcsal sar.d-f blasting machine, An er.encr wall approximately IQ deet long was selected and blasted dor nest of its length to a height od about 5 feet. Again the three types of samples were collected. Operator Breathing Zone, area, and material sample. A second OEZ sample on the nan running the sand mixer for the sandblaster was also collected. The area sample -was again collected on an observer walling back and forth through the blasting area, both upwind and downwind ex' the operation, "Material'' samples were drcm settled sand-dust or drom building surface chips, . The people involved were Vs*. Scott Tillisch as sandblaster (TCA), Mr. Ron Mich as mixer-hose tender (TCA), Mr* J. Heaccck. (CHS), Mr. L. Beck (CHE) and Mr. M. Crdanik (3c. Cal. Lab) all as observers. The area samples were collected cn Mr. Beck as he observed the operation, Hie third location, Village Grove Park, Corona, utilized the same sandblasting equipment as the second location. This time a der.ee was sandblasted. The fence surrounded a nooil home development, samples -were taken in the vacant lots (#'s 19 and 20) cn the worth side of the development approximately 30 feet fren the Mcrthwest end of the fence. The two lots were approximately 50* x 150* combined. Hind cut cf the west 3 10 mph. Samples were collected at the sandblasters 03Z, mixer-hose tender's OEZ and area samples upwind and downwind, both stationary and ncbil. At this third location Mr. H. Rhodes and Mr. 3. Ingalls of Union Carbide (New York) represented TCA as consultants and Industrial Hygienists and collected samples along with the Occupational Health Branch. It was mutually agreed that Carbide and the Occupational 3l. fcT** Branch would collect samples side by side. -- People present were Mr. Paul Tillisch, 7.P. of TCA; Scott Tillisch as hese- tender-mixer; Hen Schorr as sandblaster; Mm1. Pieces and Mr. Ingalls of Union Carbide; and Mr. J. Hinton and. Mr, L. Beck of the Occupational ne alth Branch. . Again the air in the sandblaster and rixsr-fc.esetar.der*s GEZ's was sampled. Area samples included fixed location samples cn the fence post upwind and downwind, and roving samples cn Mr. Rhodes who walked back and forth through the area, settled dust was again collected as a material sample -after the sandblasting cesosc. For all three locations sample "Blanks'* were kept for analytical comparison. . Laboratory analysis utilised CSKA and HICSii ancroved methods. A 0 P c- ,, S03 -22- UCC 013983 APPENDIX B , , -- ilt ksj 21/023/77:* . -3 February 23, 1977 Data: LOCATION I 1501 Scopes iticn m Lg3 Angeles ' Sander Area Fibers/cc 5 Microns in length 1.7 1.1 0.5 0.3 Both samples simultaneously* within 10 ft ox* sr 0.9 * * 0.3 n 9 ' 0.2 Material - Chrysatile tcur.d in matrix: Free fibers released with grinding abrasion t LOCATION 2 - Latex Base Paint (Vinyl-Acrylic) " * 950 South Broadway, Los Angeles Sandblaster Area Fibers/cc 5 Microns 1.5 (filter outside of hood) 3.5 " 0.4 0.7 1.6 All 3 sampled simultaneously*' 1.2 " Material - Aldyd Base; 3-5>S Chrysotile Asbestos Within 15 to 20 fees of source . * LOCATION 3 Tillage Grove Park (Lot:s 19 and 20)", Corona Sandblaster Mire?2? Area . ................... - ----------- - T- - -- J----.Tr.- i : Before Blasting 0*3 (Stationary Eackgrcu Up wind 0.2 (Moving Background) Fibers/cc 0.1 (Stationary Backgrcu Unwind* 5 Microns 1.6 (Filter outside of hood) 1.4 0.1 (Moving during blase 7.1 " 6.6 " - - (Filter inside **' of Hoo-0 _ * (Filter outside Z#J- of Hood) 2.2 (% wind) * 0.5 " 0.2 " n n f n t? tt 1.9 (Stationary during b1 e s t in r) I -r. .r/. :i- Material - IT' ChrysctiTLe Epoxy case? ~23_ Within 20 to 10 feet cf UCC 013984 ^^^04 .APPENDIX B H# H532l/^3/77:-! *4 February 23, 1977 * Horizontal line3 distinguish those samples collected -in the sane time frame and/or simultaneously. Variables: ALL LOCATIC:" Several varieties were not accounted for in the study concerning all three locations. First the sanding red ium was not analyzed for asbestos. At location I, this would have teen the sard? tper used and, at locations 2 and 3, the sand used" far sandblasting. Secondly the building material on 'which the textured coating had beer, applied was net analyzed fer astestes content. At the first location this would have been the wall plaster, the second location, a stucco wall reinforced v;ith wood, and tha third location a metal fence. Thirdly, the area s angle z varied in die tance from the source and were not constant with regard to wind direction except in a few instances. Finally, no "before" and "after" air 3ancles were cellscte d to establish an ancient asbestos con- ' centraticn, extent at the third 1ocaticn. Ambient air samples at the third location revealed that there is asbestos from unknown sources ccr.tandnating the air which right be the subject of an environmental study. However, in view of these variables, we feel the results 'would be changed insignificantly ad they been accounted fer, The bag was labeled "ICOri sand'*; the sandblasting went only to the surface of the plaster, stucco and metal; and the cherdst ho analyzed the samples is an experienced expert in the field of asbestos date rdnatiens. ' H5SULTS The data shows that there is a definite exposure to asbestos when employees or workers sandblast or sand coatings containing asbestos and that this exposure is present in the immediate are a. In this case, the immediate area referred to is within a 10 foot radius of the source in a nan-windy condition, and with in a AO foot radios downwind in, windy conditions. In any case, at =11 three locations there was an employee exposure of at least 1 fiber/cc, and up to L fiber/cs as an average. The area samples also shewed exposure into the 1 to 2 fiber/cc range. And finally the mixer-hose tender exposure range was from 0.5 to 2.0 fibers/cc, discussion . The current standard for asbestos is 2 fibsrs/cc greater than 5 microns in length. However, medical monitoring is required at 1 fiber/cc on an d hr. time weighted basis. : Since the results indicate employes exposure to 1 fiber/cc and greater, we conclude that there is a high possibility of harmful expeusres to employees during building renovation. -24- UCC 013985 APPENDIX C ASBESTOS SAMPLING DURING COATING DESTRUCTION Many questions have been raised regarding the levels of asbestos fibers released during the removal of paint type coatings containing asbestos. In this investigation, air samples were collected during the destruction of a high performance coating containing 2.1$ asbestos. A k0 foot diameter, 25 foot high steel tank spray coated in 1973 was sandblasted to bare metal. Since sandblasting represents an extreme condition, it provides an estimate of the highest employee or community exposure to asbestos. METHOD '' . Air samples were collected in the breathing zones of workmen using personal sampling equipment. Open face filter cassettes containing 37 mm Millipore AA filters on a cellulose backing pad were attached to the employee's respirator straps or lapel. MSA Model G portable sampling pumps were used to maintain a flow rate of 1.5 liters per minute. Flow rates were calibrated in the field with a Brooks type 1355-01A1AAA rotameter. Sampling times varied from 5 to 15 minutes. Thirty minute background samples were collected before sandblasting. Unexposed blanks were also submitted. Samples were collected on the three workmen, two sandblasters and one pot tender. Sandblasters wore airline respirators to protect them from silica exposure. ANALYSIS Asbestos sample filter cassettes were sealed in the field, packaged and forwarded to the U. S. Department of Labor, OSHA Laboratory in Salt Lake City for analysis. Samples were analyzed by phase contrast microscopy. Selected samples were also analyzed by dispersion staining and electron microscopy. Results of the laboratory analysis were forwarded as soon as they became available. The optical microscopic results are summarized in Table 1. Asbestos fibers were counted by the standard NIOSH method. ELank sample cassettes submitted with the asbestos samples were 05 optical methods. -25- UCC 013986 6 APPENDIX C . Three unused filter cassettes were submitted. No fibers were detected on two filters, one filter was reported to have 0.01 fiber/field (100 fields counted). Background samples collected before sandblasting were reported below the detection limits for asbestos. In addition, JK-32, collected during sandblasting of a section * of the tank sandblasted to bare metal earlier in the day was also reported as below the detection limit for asbestos. To gain additional information about the fibers present, filters were further analyzed by dispersion staining. In a study of sample JK-3* by dispersion staining, 16 of HO fibers were identified as chrysotile asbestos. Other samples were stained. The fibers present were found similar to JK-3The nonasbestos fibers were identified as plant fibers and fiber glass. RESULT Time weighted average concentrations were calculated from the optical microscopic analysis. Exposures to the workmen are listed in Table 2. Sandblaster TWA exposures were calculated * to be 0.2 and 0.3 fiber/cm^. The pot tender's average was 0.1 fiber/cm^, greater than 5 jx in length. DISCUSSION " ' " """ <3 Unployee exposures were within the present Cal/OSHA standard of 2 fibers/cm , greater than five microns in length. In addition, workers with the greatest asbestos exposure were protected by the airline respirators worn to prevent silica exposure. Sandblaster #1 did not sandblast all day. His calculated time weighted av erage, 0.2 fibers/cm , represents a partial day of sandblasting. Sand blaster #1 was not used between 13:15 and 15:30. Asbestos fiber counts of mixtures of air contaminants containing asbestos are slow and tedious. The standard phase contrast optical microscopic -26 408507 UCC 013987 APPENDIX C method was relied upon to determine worker exposures. In this method of analysis, the procedure allows for information gained through additional, testing to be used to more precisely identify countable fibers. The analyst may reject fibers identified as not being asbestos. Dispersion staining and the use of cross polarizing filters, or a first order red retardation plate, give additional information regarding the nature of the fibers. Fibers without the correct morphology or other characteristics, recognized as not asbestos, are not counted. Fibers of doubtful identity are included with the asbestos count. The results of electron microscopic analysis and dispersion staining quantify the proportion of the total fibers which are actually asbestos. These percentages were between 12 and 11$* Although the percentages are small, it is important to note that free asbestos is released. Analysis of blank samples ruled out the possibility of significant contamination from either the blasting sand or desert air. /flw 10/19/78 -27UCC 013988 6508 ATTUN'DIX C Table 1 SAMPLE # OPERATOR TIME ON JK-1 Sandblaster-l 3:21 JK-2 Pot Tender 8:21 JK-3 JK-4 JK-5 JK-6 JK-7 JE-8 Sandblaster-1 8:54 Pot Tender 8:54 Sandblaster-2 9:09 Sandblaster-1 9:14 Sandblaster-2 9:20 Pot Tender 9:26 JK-9 JS-10 JB-11 JK-12 JK-13 JK-14 JK-15 JK-l6 JK-17 JK-18 JS-19 JK-20 JX-21 JK-22 JK-23 JK-24 JX-25 Pot Tender 9:46 Blank MV Sandblaster-2 9:36 Sandblaster-2 9*41 Sandblaster-2 9:47 Sandblaster-2 9:55 Sandblaster-2 9:55 Pot Tender 9:58 Sandblaster-2 10:01 Sandblaster-2 10:07 5andblaster-2 10:13 Pot Tender 10:20 Sandblaster-2 10:24. Sandblaster-2 10:34 Pot Tender 10:43 Sandblaster-1 10:47 Blank TOTAL TIME (MINUTES) 27 27 4 20 32 U 17 16 20 12 -- 5 6 5 6 12 22 6 7 10 22 10 18 16 16 FIBERS/CC COMMENT ^ D.L. Background (Desert Air) Sample before sand blasting ^ D.L. Background (Desert Air) Sample before sandblasting 0.49 0.35 Membrane marred 0.57 0.31 No membrane in cassette Under Blasting Hood. Two Sand Blasters working Blasting at ground level On Scaffold Ground Level Two Blasters working * <D.L. Two Blasters working None 0.63 0.71 1.4 1.6 Ground Level Ground Level Ground Level Ground Level - Overlap JK-15 0.75 0.17 < D.L. 1.3 0.3 0.24 0.32 Hole In filter - Overlap JKGround Level Blasting -5- of sample r 11 minutes break Entire sample break 0.91 1.02 On man lift 1.27 None to ground i -28- UCC 013989 / ^ 0S509 APPENDIX C Table 1~(Continued) SAMPLE # OPERATOR JK-26 Sandblaster-2 JK-27 Sandblaster-1 JK-28 Pot Tender JE-29 Sandblaster-1 JX-30 Sandblaster-2 JX-31 JK-32 Pot Tender Sandblaster-2 JK-33 JK-3U JK-35 JK-36 Sandblaster-2 Sandblaster-1 Sandblaster-2 Sandblaster-2 JK-37 JK-38 Sandblaster-2 Sandblaster-2 JK-39 Sandblast er-2 JK-40 Sandblaster-2 TIME ON 10:52 11:01 11:00 11:0? 11:09 11:18 12:50 13:04 13:09 13:17 13:24 13:34 13:48 14:06 14:17 JK-41 JZ-A2 Sandblaster-2 Sandblaster-2 14:35 15:00 JE-43 JK-44 Sandblaster-2 Blank 15:21 TOTAL TIME (MINUTES) FIBERS/CC COMMENT ' ' 16 4 D.L. On lift above #1 6 0.38 #2 above on lift 17 0,40 11 0.67 #2 still above 14 0.45 Blasting time: 9 min 8 < D.L. 5 4 D.L. Blasting Bare Metal Area. 11 < D.L. Man lift 5 0.95 7 . 0.60 Ground On man lift Blasting time 6 min 9 0.66 On lift 14 4 D.L On lift 7 min blasting 17 0.32 Lift 11 min blasting 11 0*19 %17 0.40 Lift Lift Blasting over operator's head. (cat walk) 25 0.23 Lift 15 min blasting 21 No count possible Lift 11 min blasting 15 0.46 Lift 0.01 fibers/field (100 fields) D.L. * Detection Limit m samples Operator Breathing Zone -29UCC 013990 4o5tc t, APPENDIX C Table 2. Pot Tender SAMPLE JK-2 JK-4 JK-8 , JK-9 JZ-16 JK-20 JK-23 JK-28 JK-31 Unsampled TIME(Min.) 27 37 20 12 22 22 17 18 8 182 ' Time Weighted Average Asbestos Exposure. C3 PIBERS/CMJ 0 0.35 Wo count 0 0.17 0.24 1.02 0.40 0 0.28* CALCULATIONS * Average Exposure * CT = concentration tT of unsampled. TWA = JCT 480 = 97.5 480 = 0.20 3 0.2 fibers/cm , >5 H 3 C s fibers/cm , T e Time (minutes) Sandblaster. #1 Partial day time weighted average. SAMPLE JX-1 JK-5 JK-6 JK-24 JK-27 JZ-29 JZ-34 TIME (Min.) 3 PIBERS/CIT CALCULATIONS * 27 0 No exposure between JX-6 and JK-24-. 20 0.49 17 0.57 TWA 4CT = 57.2 = 0.1 t/cm5. 16 1.27 480 480 ^ 6 0.88 C m flbers/enr 11 0.67 5 0.95 T - Time (minutes) -30- UCC 013991 4035)7 APPENDIX C Table 2.""""fCcntinued) Sandblaster 2. Time Weighted Average Asbestos Exposure. SAMPLE TIME (Min.) JK-5 JK-7 JK-11 IK-12 JK-13 JK-14 JK-15 JK-17 JK-18 JX-19 JK-21 JK-22 JK-26 , JK-30 JK-32 JK-33 JK-35 JK-36 IK-37 JK-38 JX-39 JK--40 JX-41 JK-42 JK-43 Unsampled . 11 16 5 6 8 Overlap 12 Overlap 7 10 11 18 16 17 5 11 9 9 15 17 12 17 12 17 25 52 . * Average Exposure 0 PIBERS/CM3 CALCULATION Marred 0.31 0.63 0.71 1.4 Jit--lb 0 JK-15 1.3 0.3 0.32 0.91 0 0.45 0 0 0.6 0.66 0 0.32 0.19 0.40 0.23 Mo count 0.46 0.38* * Average exposure = tCT = concentration f T of unsampled TWA = CT 480 = 130.4 = 0.27 480 - 3 0.3 fibers/ca , >5 At C a Concentration (fibers/ca3) T = Time (minutes) . *' - 4 0&5 j 2 -31UCC 013992 AIRBORNE ASBESTOS COUNTS for Textured Coatings of America, Inc. (Village Grove Trailer Park, Lots 19 and 20) Corona,,California Date Sampled: December 17, 1976 Date Reported: April 1, 1977 Samples Collected By: B. L. Ingalls Union Carbide Corporation Samples Analyzed By: B. L. Ingalls & G. J. Spencer Union Carbide Corporation Reported By: H. B. Rhodes Union Carbide Corporation Union Carbide Corporation Metals Division Niagara Falls, New York -32- UCC 013993 ti 3 OBJECTIVE -1- To measure the airborne asbestos fiber concentrations generated during the removal of an asbestos-containing maintenance coating from a sheet metal fence by sand-blasting. DESCRIPTION OF OPERATION The test was run at Village'Grove Trailer Park, Lots 19 and 20 in Corona, California. The park was surrounded by a galvanized metal fence about 5' high that had been painted about five years previously. The metal was first primed and then painted with an alkyd-based maintenance coating containing about 5% asbestos. The paint also contained mica, talc (non-tremolitic), fiberglass, and perlite. The sandblasting was done with a portable unit consisting of a compressor and a blasting unit. The latter had a sand storage tank about V in diameter by 3 1/2' long which fed silica sand through a lever operated control device and a heavy hose to a blast nozzle, under the control of the operator. One man handled the blasting nozzle while the other operated the compressor, assisted with the hoses, but primarily operated a lever on the sand delivery unit to keep the sand flowing. The nozzle operator wore a conventional sand-blasting hood with air openings on the sides. During the blasting operation one man stood about 2' from the fence and moved the nozzle, held about 3-6 inches from the fence, in short arcs until the impinging sand removed the paint down to the base metal. Bonding was excellent and it took at least several passes of the blast to remove the paint. The material removed was finely pulverized. The bottom 1 1/2' of the fence was not hand-blasted to avoid raising extraneous dust from the dry ground at the base of the fence. The weather was clear and warm with a light, variable breeze blowing from left to right in approximately the same direction as the fence. SAMPLE COLLECTION The following types of samples were collected during the test: 1. Background samples prior to testing were collected at the fence, *-4 1/2' from the ground about 100' apart. (Spanned the section to be sand-blasted.) (G-16 & F-44) 2. A sample about 40' downwind, on the fence about 5` above the ground, during the last 25 minutes of sand-blasting.(G-3) 3. Personal samples on an observer in an area generally 25-35' from the blasting operation and approximately perpendicular to the blasting. (A-86, A-81, J-89) 4. Personal samples on both the helper and the sand-blasting operator. All operator samples were external to the hood except X-2. Helper - G-48, X-8, C-15, X-4 Operator - D-71, X-14, G-34, X-2, X-3 A Op cr * *4 -33- UCC 013994 2- - COUNTING EQUIPMENT AND PROCEDURES All samples were collected with battery-powered air pumps (M.S.A.), calibrated to 2 liters per minute on Millipore membrane filters of 0.8u porosity. The samples were mounted and counted in accordance with the procedure of Bayer, Zumwalde, and Brown (Bureau of Occupational Safety and Health, February 1969). Counting was done with a Nikon microscope at 400X utilizing a Poton reticle with a 0.0062 mm2 field area. One hundred fields were counted for all samples. These samples proved to be particularly difficult to count. Out of the total of nine personal samples from the blast operator and the helper, six were loaded with dust to a level where filter areas were frequently obscured. When such an area occurred, the counter went on to another field. There is no way to tell how this may have influenced the results. Our normal practice in this situation is to resample, but considering the difficulties this would entail, the filters were used. In addition to this problem, the nature of the samples puts an extreme strain on the method. Thus: 1. Fiber concentrations were loyt with 0.38 fibers/field the maximum and 0.2 fibers/field more or less typical. This is well below the 1-5 fibers/field range recommended by NIOSH. 2. The fibers counted were in the 5-15y range so that the "5y decision11 was a frequent requirement. 3. There were substantial concentrations of mica "chips" present. These can generally be recognized as not asbestos but certain shapes around 5y in length can become undistinguishable. These factors of low fiber concentration on the filter, filter size distribution, and potentially interfering "fibers" result in a high degree of operator discretion in the determination of the total number of asbestos fibers counted. When this possible variation is combined with the short sample times substantial variations can result. In view of these uncertainties, a modification was made in the procedure to report two categories of fiber: 1. Obvious chrysotile asbestos. Either long and curved, or distinctly thin and slightly curved in the 10-20y range. 2. Possible asbestos fiber: Particles which did not have obvious identifying asbestos features but met the L/D >3, >5y require ments and were dark and fiberlike under phase-contrast illumination. When there was any doubt about a fiber's'identity, it was included in the appropriate class. The total of both classes would be the value ordinarily reported as asbestos. Particles which were obviously not asbestos were not counted. This would include such things as unbroken fiberglass, mineral flocks with non-parallel sides, and particulate that appeared bright under phase contrast. It should be noted that the only known source of asbestos in this formulation was the 5% by weight chrysotile. (Note that the 2% asbestos figure reported by DOSHA in Appendix B is in error.) 6 -34- UCC 013995 -3- RESULTS AND DISCUSSION A description of each sample and the respective fiber concentrations are shown in Table I. The data obtained by Counter A are presented graphically in Figure I. Where paired results are available Counter B was high six times and Counter A three times. The differences, without regard to sign ranged from 0.1 to 1.1 fibers/cc and averaged 0.3 fibers/cc. In view of the counting difficulties on these slides we consider this to be good agreement for operators in the same laboratory counting the same slides. A The operation of the sand-blasting equipment was too erratic to provide a meaningful estimate of operator TWA exposure for normal oper ation. Using just the time periods during the actual blasting operations, the time-weighted averages were: Onerator O0)(Z-2Hn)(3.2H8](3.28) + (14)(l-6BH22)(1 .76} Operator -> " *--1 (io)+(ll )+(8)+(14)+(22) ` 14^'68- 2.2 fibers/cc >5u Helper - (10)n.03}+(23)(l.l} + (14)(0.15} + (22}(0.06) _ 39.02 _ ,, * __ _ c ^------- (10 +(23)i(14)+(22) ' M------- L - ST- - -6 flberS/CC >5V The measured TWA exposure for this particular 8-hour day would then be: Operator - 4qq^8 = 0*3 fibers/cc >5y Helper - 39^02 = QQ8 fibers/cc >5y -35- UCC 013996 .A 6 4 TABLE 1 SUWABT OF AIRBORNE ASBESTOS FlHfR COUNTS DURING SAND-BLASTING Of' ASBESTUS-CWTAIHINJ' KMNTEKAfICE'COAT 1 NO Description of Operation Pretest Controls On fence, left side of area to be sand-blasted. ""4 1/2' above ground. On fence,^100' from G-16. -rS' above ground. Personal sample on observer WE" from fence and moving parallel to fence. Samole Data Time Total No. On Off Min. G-16 10:35 10:56 21 F-44 10:42 10:59 17 A-86 10:39 10:52 13 Airborne Fiber Concentrations {Fibers/cc >5u) Obvious Chrvsotile fibers 100 fields f/ec Operator "A- Possible Asbestos fibers 100 fields f/ct Total ___ AsbCStpS fibers ~ 100 fields f/ec Operator *a* Total Asbestos fibers ' 100 fields f/ec 00 2 0.07 2 0.07 - - 00 00 00 00 2 o.os 2 0.11 2 0.11 4 0.21 CotnnentS Observer (During Sand-Blasting) Personal sample on observer A-81 11:12 11:18 --20-30' from fence and moving 11:25 11:27 parallel to fence. 6 2 8 Sane as A-81. J-89 12:26 12:52 26 Area sample on fence. S' G-3 above ground and -'40' down wind. (In lieu of observer) 1:35 2:00 25 00 1 00 1 7 0.19 22 0.09 1 0.03 0.61 1 29 0.09 0.03 0.7 21 0.6 Helper (Durino Sand-Blasting) Personal sample. Assisting with hoses. Operating sand feeding equipment. G-4B 11:10 11:18 8 11:24 11:26 2 Iff Same as G-48. . x-s 12:25 12:43 23 Sane as G-48. Same as G-48. C-1S 1:08 1:22 14 X-4 1:36 1:58 22 1 0.07 14 10 0.30 18 - *- 1 0.05 2 00 2 0.97 15 0.54 * 0.10 0.06 28 45 3 2 1.03 9 0.84 1.35 0.15 0.06 60 9 0.6 1.8 Heavily toaoed; ha to count second si 0.3 81astino Operator (During Sand-Blasting) Personal sample. Operator handling sand-blasting nozzle, standing--2' from fence. D-71 11:10 11:18 8 11:24 11:26 2 Same as 0-71. X-14 12:25 12:36 11 Same as D-71. G-34 12:38 12:46 8 Same as 0-71 except Inside of hood. Same as D-71. 1-2 1:08 1:22 14 1-3 1:36 1:58 22 7 0.48 25 1.72 32 2.21 13 0.82 30 - S 0.43 33 8 0.39 26 21 0.66 35 1.88 - 2.84 43 58 38 1.28 34 1.10 . 56 2.70 3.64 3.28 1.68 1.76 75 39 S3 Heavily loaded, ha to count. 4.70 3.36 - Heavily loaded; ha to count second si Heavily loaded; ha to count. K* 1.66 4 -36- UCC 013997 OF ASBESTOS-CONTAINING MAINTENANCE COATING UNION CARBIDE CORPORATION - METALS DIVISION P. 0. BOX 579 . NIAGARA FALLS, N.Y. 14302 * TEL: 716-278-3376 January 13, 1978 Mr. James Heacock Occupational Health Section California Department of Health 2151 Berkeley Way Berkeley, CA 94704 Dear Hr. Heacock: The suggested protocol for the cooperative test that we discussed in your office is attached. As you requested, it has been set up so that the Department does the actual sample collection. Plans are well along to conduct the test on one or more large tanks in the Trona area that have been coated with zinc-rich primer. The only hold up Is satisfactory verification of composition of the primer. We would like to go ahead and plan to conduct this test during the week of January 23, 1978, preferably on Tuesday the 24th. Please let me know if this is satisfactory so we can finalize on a date and the other arrangements. In view of the time that has passed since the original hearings and the number of new people involved, it seems appropriate to comment on two questions relevant to the previous testing results reported in a letter of June 1, 1977 from Jerome A. Lockner, M.D. to the Honorable Jack R. Fenton, i.e.: 1. The appropriateness of sandblasting as a representative test method. . 2, The accuracy of the previous counts. We have been informed by a large manufacturer of the high-performance mainten ance coatings of particular interest here that certain of these coatings are sandblasted as a routine procedure. Usually it is a light "brush" blasting to remove rust spots and loose coating but occasionally complete removal takes place. Sandblasting thus represents an extreme condition and should thus be a reasonable way to approximate the upper limits of exposure. A -38- UCC 013999 Hr. James Heacock -2- January 13, 1978 As we discussed several times, in the test where Cal/OSHA and Union Carbide collected side-by-side samples during a sandblasting operation, both laboratories found asbestos counts of several fibers/cc or more when counting by the routine NIOSH procedure. It is well recognized that the procedure has very serious limitations for dusts of the type generated during sandblasting. Subsequent examination by Union Carbide of several of the filters using scanning electron microscope techniques suggested that both laboratories may have counted substantial numbers of non-asbestos particles as asbestos and that free asbestos fibers were extremely rare. Over the past year the Federal OSHA Laboratory at Salt Lake City has adopted more sophisticated optical techniques to distinguish asbestos from other particulate matter and are quite possibly the most skilled laboratory in the country in this, area. I have discussed our problem with the Director, Hr. Floyd Madsen, and he is agreeable to count a reasonable number of samples. It will be appropriate for you to make a written request for this assistance at the time the samples are submitted. Please let me know if you have any problems with this proposal. We are looking forward to participating in what appears to be the first carefully defined test of asbestos exposure in this type of application. It was a pleasure meeting with you and the others in Berkeley. Very truly yours, *~)i - /3. flJfurztJ-? Harrison B. Rhodes Technology Manager HBR/rmm Attachment 40852c -39- UCC 014000 TEST PROTOCOL OBJECTIVE The objective of this test is to measure the airborne concentration of asbestos fibers generated during the removal of a non-resilient maintenance coating by sandblasting. The site selection, test operation, sample collection, and sample analysis will be carefully planned in advance so that meaningful results are obtained. WORKING ARRANGEMENTS The selection of the test site and provision for the sandblasting operator and equipment are the responsibility of the Union Carbide Corporation with the choices subject to approval by the Department of Health. It is intended that the Department of Health and Union Carbide will each have at least one qualified person at the site to work out a mutually acceptable sample collection strategy in accordance with the general guidelines under "Sample Collection Strategy". Sample collection will be performed by the Department of Health. After collection is completed, a validated summary sheet of the collection data will be prepared with a copy for both participants. In order to expedite matters, the cassettes will be packaged and sent immediately by registered mail to: Mr. Floyd Madsen, Director OSHA Laboratory 390 Wakara Way Salt Lake City, Utah 84108 The Department will send a confirming letter to Mr. Madsen requesting them to analyze the samples. He has been alerted and is expecting to receive 10-30 samples. When analysis is complete, the OSHA Laboratory will provide both participants with a copy of the results. TEST SITE AND OPERATION CRITERIA The following criteria apply to test site selection: 1. Reasonably representative of a substantial commercial use of the product. 2. Large enough to allow for several hours of dust generation. 3. Reasonably unambiguous definition of the composition of the asbestos-containing material being handled and an asbestos content in the upper part of the range of contents of interest. 4, Sandblasting will be done with regular commercial equipment and materials by a professional operator in a manner that is commercial practice. --...3 < -40- P UCC 014001 ^\ -2- SAMPLE COLLECTION STRATEGY As noted previously, it is intended that the Cal/OSHA and Union Carbide representatives at the site work out the most appropriate sampling strategy with the following special provisions to be met: 1, Personal breathing zone samples will be taken on the operator and the helper (if present) that are subject to the highest exposures. In addition to samples collected during the actual operations, a reasonable number of samples will be collected before and after operation to permit an estimate of the 8-hour time-weighted average exposure. 2. Area samples upwind and downwind will be taken before, during and after the dust generation operation. ADQED NOTE The Union Carbide Corporation is participating in a national round-robin study of the KIOSK collection and analytical procedure. It has been agreed that we may have an observer wearing a pair of pumps moving in the immediate vicinity of the dust generation operation. Care will be taken that there is no interference with the test. These samples will be entered into the round-robin and since they will be counted by only the standard NIOSH procedure, the results are not relevant to the present tests. SAMPLE ANALYSIS All sample cassettes will be shipped unopened to the Federal OSHA Compliance Laboratory at Salt Lake City. 4 8S2'> -41- UCC 014002 IZreM G{ PREPARED TEXT ORAL PRESENTATION BEFORE THE CALIFORNIA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD AUGUST 30, 1979 TITLE 8: GENERAL INDUSTRY SAFETY ORDERS (Asbestos) Held in San Diego, California on August 30, 1979 Union Carbide Corporation Metals Division Niagara Falls, NY 14302 UCC 014003 A08523 Introduction My name is John L. Myers and I am employed by Union Carbide Corporatic as Marketing Manager for its "Calidria" asbestos products. Union Carbide pro duces about 30,000' tons per year of asbestos fiber from a mine and mill located in the King City area of California. The operation employes approximately 70 people with an annual payroll of nearly $2,000,000 and is the largest industrial employer in a radius of about 50 miles. We produce and market raw asbestos fibers for industrial use but do not manufacture finished asbestos-containing products. Our plant has had complete air monitoring and medical surveillance programs since operations were initiated in 1963. Our interest in the proposals to change the "action level" for monitoring and medical examinations is because these changes can have a massive impact on the users of asbestos-containing products with, we believe, little or no gain in worker protection. _ Changes in Section (8) - Monitoring and Recordkeeping The staff proposes to reduce the level in paragraph (g)(1)(A) at which monitoring is required from 1 fiber/cc >5y to 0.1 fiber/cc >5y. The question of the appropriate "action level" to trigger monitoring and also medical examinations was discussed at the standards Board hearing on April 26, 1979. At that time, there was general agreement among labor, industry, and even state governmental representatives that a level of 0.5 fibers/cc longer than 5y was reasonable. This level was based on considerations of worker protection, ability to measure, and an efficient allocation of professional resources. This level was adopted unanimously by the Board. UCC 014004 A08524 -2- Subsequent to this action, on May 10, 1979, the Federal OSHA Regional Administrator, Mr. Gabe Gillotti, informed Mr. Don Vial by letter that this action by the Board was "unacceptable . . .Your asbestos exposure language will need to be identical to Federal OSHA" and quoted OSHA Program Directive #300-16 as the basis for this requirement. Mr. Gillotti's letter was a surprise since California has a state plan which has been fully approved "as effective as" the Federal regulation in accordance with Section 18(e) of the OSHA Act and under Part 1902 of the imple mentation regulations. There has been no change in the Federal -Regulations.' 19CFR 1910.100 1 {j)(2), (3) or (4) which would require their incorporation into the State Regulations in accordance with Section 18 of the OSHA Act. We discussed this with John W, Whittlesey, Esq. a Union Carbide . Counsel specializing in OSHA matters. He has authorized the following opinion and will be glad to provide a written confirmation if the Board desires one. 1. Program Directive #300-16 is an administrative interpretation only. As such it does not have any regulatory or statutory authority. 2. California may elect to modify their regulations to conform but are under no statutory requirement to do so. 3. Failure to conform to such an Administrative interpretation does not provide the "substantial evidence" required under Section 18(g) of the OSHA Act to sustain a withdrawal of certification. 4. The authority delegated to the Regional Administrator under paragraph 1953.4 (a)(2) relates to inconsistent interpretations of standards as they exist. It does not require standards which have been certified "as effective as" to be modified to conform identically. UCC 014005 A0852b -3- California is not required to change their present regulations to conform to the Federal wording. The choice is up to the Standards Board. There are at least two reasons wljy the Board should retain the present action level of 1 fiber/cc or at most lower it to 0.5 fibers/cc. 1. The very large burden on resources to comply with (and enforce) a 0.1 fiber/cc level. 2. The inability to measure the airborne concentration at this very low level. Significant releases of asbestos fiber must take place before the 1 fiber/cc >5y current action level is exceeded. It is fairly easy to ascertain where initial monitoring does not need to be conducted and unnecessary action can be minimized. If, on the other hand, the California Asbestos Standard is changed to require monitoring at a level of 0.1 fiber/cc, virtually every place of employment where asbestos is present in any form must be monitored at least once, - Brake repair shops provide a specific example of the scope of the problem. Molded brake linings contain asbestos. Airborne fibers can be re leased when they are sanded, machined, or when the drum is blown out with com pressed air. It has been shown that airborne asbestos concentrations can be controlled to low levels by careful handling, proper work practices and the use of vacuum cleaners to remove dust. There are over 20,000 brake repair shops in California, the majority of which are service stations. A survey of 100 shops was made by CAL/0SHA some months ago and it is our understanding that it was found that a low level of airborne fiber is common but exposures above one fiber per cc are rare. Generally, the higher levels occured at the large truck repair shops where such things are blowing and sanding have been practiced without proper dust control. If the proposed action level is adopted, all of these shops, which are generally small businesses, would be required to monitor at least once ' A 08 52 6 UCC 014006 -4- We recently asked two industrial hygiene consulting laboratories the cost to conduct a basic "initial monitoring" for a relatively simple opera tion like a brake shop. Both gave a range of $300-$500 per test. These figures do not include travel and living expenses or provide for any significant extra technician travel time to the test site which can occur frequently. Applying a representative value of $400 to the approximately 20,000 registered brake shops gives a cost of $8,000,000 added to the operating expense of this industry to comply with the new regulation. Each inspection would also use up about two man-days of the time of trained personnel. If we assume 200 man-days as equivalent to a working year, it would take the full-time activity of 200 trained technicians to carry out the monitoring in a year. We doubt if this quantity of people and equipment is available. The main information obtained from such a massive test program would be that exposures are generally above zero, and below one fiber/cc, which is already quite well established. This discussion has emphasized brake shops because they are a well defined entity, already registered and identifiable. The same problem exists for the widespread low exposure in the less well defined construction industry. There is also an additional compounding factor in construction in that the "place of employment" changes a number of times a year so that continuous moni toring at frequent intervals would be required. The brake shops may really be only the tip of a very large iceberg. Changing the initial monitoring action level to 0.1 fiber/cc would place a very heavy cost burden on the employer, require a massive use of limited technical resources in an area of low exposure and consequently low risk, and give a very questionable return in terms of worker protection. We recommend that your present standard be retained. UCC 014007 A 08527 -5- The second reason not to change to a 0.1 fiber/cc action level regards the ability to measure this concentration and I would like to ask my colleague. Dr. Rhodes, to discuss this aspect. (j) Medical Examinations The staff has proposed that the requirements for medical examinations be changed from the present one fiber/cc TWA "action level" to 0.1 fibers/cc >5u as an eight-hour time-weighted average. It is instructive to continue with the brake shops as an example of the potential impact of the proposed regulations on this small-business oriented industry. It has been our obser vation that a local filling station is likely to have a couple of young mechanics who handle the brake repairs along with other general repair work. The larger franchise type shops may have a dozen or more people who repair brakes with some frequency. For estimating purposes, it will be assumed that there will be two persons per shop for a total of 40,000 persons requiring pre-employment and annual medical examinations under the new proposed regulations. This does not allow for employee turnover. Dr. Clark Cooper, who supervises the joint union-employer medical surveillance program for Western Department of the Asbestos Workers Union, has provided an estimate of $60-75 per man for a minimum physical examination to satisfy 0SHA requirements. This is on a large-scale contract basis conducted by well qualified personnel. Examinations of an individual or small groups, as would probably be the case for brake repair shops, would increase the costs to approximately $100 each. These costs do not include time spent away from the job to obtain the examination. At a conservative $50 each, the medical examinations could cost $2,000,000 annually and, obviously, double this to $4,000,000 annually at the UCC 014008 Aes28 -6- higher unit cost. This discussion, as with monitoring, emphasizes the brake shops. The less well defined construction industry is faced with the addi tional complications of a transient workforce and moving workplaces. Although this is clearly a very large cost burden, the fundamental question is not the cost per se, but what is accomplished in terms of worker protection. Although it is admittedly controversial as to what exposure level is "significant", we believe that the present California level of one fiber/cc TWA, or some level in that general vicinity, such as 0.5 fibers/cc is reasonable and meets the California objective of a standard which is enforceable and makes a positive contribution to worker health. The lowering of this level to 0.1 fiber/cc would require a large new investment in time, money, and .people by both the employer and the state compliance operation for which we see little if any return in terms of worker protection. Vie urge you not to make this change. General Comments 1 - Why are the proposed changes a unique problem in California? It has been noted several times that the proposed changes would make the California standard the same as the Federal standard which is administered by the Federal Government in 26 states. The very legitimate question has been asked as to why a standard which has been in effect for seven years will present a serious problem if it is now adopted in California. The answer is basically very simple; although the Standard has been in effect for seven years there has been almost no Federal enforcement in the asbestos product user areas that would be most seriously impacted by the 0.1 fiber/cc A UCC 014009 -7- action level. This would no longer be the case in the more comprehensive California state industrial health activities, so we believe that the compliance and enforcement problems described earlier would soon become clearly evident. The statement on Federal enforcement is based on a computer printout of all Federal asbestos inspections over a 30 month period from October 1976 through January 1979 that was supplied by OSHA to the Asbestos Information Association/North America. Details are included in Attachment I. In this 30-month time period there was a total of 17 inspections, of brake repair operations basically on large auto dealerships, relative to asbestos. There are about 250,000 brake shops in the country with roughly half estimated to be in states where Federal CSHA is the primary compliance enforcement. The construction industry has also been mentioned in connection with enforcement and potential impact. The U.S. Department of Commerce published a census of the construction industry for 1972 which showed a total of about 430,000 construction establishments with an employment of about 3,500,000 construction workers. It is not well defined how many of these establishments use asbestoscontaining materials and at how many locations per year they work. Considering that over 60% of the asbestos used in the U.S. is in construction products, the number of both people and work locations could be substantial. The printout mentioned earlier shows a total of 173 asbestos-related inspections in the construction industry in the 30-month period. Considerably more time has been spent in the construction industry than in brake shops to make general inspec tions but it is clear that only a minute fraction of possible asbestos containing locations has been inspected. It should be emphasized that the information presented is not intended to be a criticism of the Federal activities or the allocation of the resources UCC 014010 . A8S3c -8- that have been made available to them. OSHA has statutory priorities to consider. It is provided to document the fact that regardless of the reason, the brake repair industry has been subject to virtually no enforcement of the 0.1 fiber/cc action level requirement for monitoring and medical examin ations, and the situation is little different in the construction industry. There is no evidence that these provisions are reasonable and workable in the states under Federal administration since they have not been actively enforced on a wide basis. In contrast to this, the State of California has supplemented their OSHA activities with the Carcinogenic Substances Control Act, a registration provision, a Carcinogens Control Unit, an active consultation program and an experimental voluntary labor-industry joint program. We believe that the incorporation of a 0.1 fiber/cc triggering level into this comprehensive compliance program would soon reveal the gross impracticality of such a level and urge that it not be done. Concluding Statement In conclusion, we wish to make certain that the Board has not been left with the impression that Union Carbide is opposed to monitoring and medical surveillance. Union Carbide strongly supports the need for both of these acti vities where significant asbestos exposures occur. Our plant employees have been provided with regular medical examinations since the plant opened in 1963. Although it is admittedly controversial as to what exposure is "significant" we believe that the present California level of one fiber/cc TWA, or some level in that general vicinity, such as the 0.5 fiber/cc level adopted by the Board at the April 26, 1979 hearing, is reasonable and meets the California objective of a standard which is enforceable and makes a positive contribution to employee health. To lower this level to the extreme of 0.1 fiber/cc TWA will A08531 UCC 014011 -9- extend monitoring and medical examination requirements to about 20,000 ,, brake shops and quite probably an even larger number of construction sites where exposures are generally low. The return, in terms of worker health, on the large new investment of time, money and people by both the employer and the state com pliance operation is very questionable and limited technical resources are diverted from more urgent higher risk situations. We urge you to retain your present well written standards for asbestos and not to make the proposed changes that would return them to an outdated Federal requirement. Thank you for the opportunity to express our concerns. /dal 8/27/79 UCC 014012 A April 9, 1976 Docket Officer Docket H-033 U.S. Department of Labor Room N - 3620 200 Constitution Avenue, N.W. Washington, DC 20210 SUBJECT: OCCUPATIONAL EXPOSURE TO ASBESTOS Gentlemen: Reference is made to the proposed rules on this subject published in the Federal Register V. 40, No. 197, PG. 47652, which states that interested persons are invited to comment on or before December 8, 1975 which comment period was subsequently extended to April 9, 1976. Union Carbide is involved in the mining, milling and marketing of asbestos and we believe that the proposed rules will have a significant negative impact on our business. The attached presentation documents our position on the proposed revisions to the Occupational Standard on Airborne Asbestos. Our recommendations focus on the issue of insuring that the small or intermittent user of asbestos fiber is able to provide a safe work place for his employees without being unduly burdened by administrative or monitoring procedures. * This presentation submitted this date also incorporates by reference the position expressed in the presentation by the Asbestos Information Associa tion/North America to the Occupational Safety and Health Administration, United States Department of Labor entitled: Notice of Proposed Rulemaking Occupational Exposure to Asbestos 29 CFR Part 1910 Federal Register, Vol. 40, No. 197, October 9, 1975 t * Asbestos Industry Response. . 9 April, 1975 in which the name of Union Carbide Corporation appears as an endorser. We reserve the right to provide additional comments at any public hearing which may be scheduled relative to this rulemaking. Very truly yours. WCT:dal "Tt/- C.. 7 (H.'St) W. C. Thurber Business Manager-Asbestos bcc: Messrs. G. G. Gabrielson, Jr. - AIA/NA Task Force Chairman J. J. Kenney R.F.X.Fusaro D. M. Mintzes Dr. H. B. Rhodes'-' n T f\ /M A A08533 UCC 014013 PRESENTATION TO THE OCCUPATIONAL SAFETY AND HEALTH ADMINSITRATION UNITED STATES DEPARTMENT OF LABOR IN REGARD TO THE NOTICE OF PROPOSED RULEMAKING OCCUPATIONAL EXPOSURE TO ASBESTOS 29 CFR Part 1910 Federal Register, Vol. 40, No. 197, October 9, 1975 On behalf of UNION CARBIDE CORPORATION Date Submitted April 9, 1976 UCC 014014 A 08 5 3 4 -1- INTRODUCTION Union Carbide Corporation has been actively engaged since 1962 in the mining and milling of asbestos ore at facilities in central California. This asbestos is marketed throughout the United States and in many foreign countries. Union Carbide is a substantial supplier of short-fiber asbestos, similar to Canadian Grade 7, for the manufacture of floor tile, for tape joint compounds used in drywall finishing, and for oil-well drilling muds. We also supply highly refined asbestos fiber to about three hundred manufacturers of caulks, sealants, coatings, adhesives, mastics and similar materials that are widely used in the construction and automotive industries. We do not supply the longer fiber asbestos used for cement, fireproofing, or insulation products nor do we manufacture any asbestos-containing products. The great majority of our customers are small businessmen in the secondary and consumer asbestos industries who have limited technical capa bilities and resources. We are greatly concerned with the impact of the Proposed Rulemaking on these moderate sized but numerous users of asbestos. OSHA has recognized that this is a serious problem by the exclusion of the Construction Industry from the Proposed Rulemaking and the request for sug gestions for appropriate provision for other industries with similar problems as contained on page 47657 in the Preamble to this rulemaking; vis.: "While the proposal does not address itself to specific alternatives, OSHA invites comments concerning options which would both provide full protection to affected employees and at the same time would minimize the admin istrative and economic burden on affected employers especially those with small numbers of employees, non-fixed work places, or highly transient work forces." The main purpose of this presentation is to discuss the specific alternatives requested. Certain portions of the Proposed Rulemaking which we feel are inconsistent with the mandate given to OSHA in the Occupational Safety and Health Act (hereinafter referred to as the Act) are also discussed. The Proposed Rulemaking as well as the Asbestos Standard promulgated in 1972 are written to be applicable to conditions which normally occur in large, fixed places of employment, i.e., stable work forces who handle asbestos or asbestos^containinq products for a major portion of most workdays throughout their working life, the application of such regulations to conditions where there is significantly less exposure is unnecessary and inequitable. It appears to be well within the scope of the Act to make allowances for this condition. The Act also makes a clear distinction between monitoring, medical surveillance and the attendant recordkeeping requirements that are intended to protect today's worker and those which are intended for research. Unfor tunately, the Proposed Rulemaking does not reflect this distinction and con sequently the entire industry would be required to operate as a closelycontrolled epidemiological research experiment. This will result in a tremen dous expenditure of scarce industrial hygiene and medical resources as well as money to amass vast amounts of information of which only a miniscule fraction will ever be used. It is this portion of the Proposed Rulemaking UCC 014015 40853b -2- which is extremely burdensome to the large asbestos users, that becomes over whelming when applied to the smaller and infrequent users. Union Carbide believes that the Proposed Rulemaking should be modi fied to recognize the large gradation in exposure and the corresponding large gradation in hazard that exists in the working population to be covered. Research requirements should be defined and treated in a specific way, not imposed broadside on the entire industry. If this is done, the main diffi culties for most employers with small numbers of employees, non-fixed work places, or highly transient work forces that are noted by OSHA would be solved in a realistic and equitable fashion without decreasing worker protection or imposing large, unnecessary costs on the employer. It also seems inappropriate that OSHA should proceed with new rulemaking without making specific provisions for the serious problems of small businesses, non-fixed work places, or highly transient work forces that are known to exist in the present standard. GENERAL COMMENTS - PROPOSED RULEMAKING It was suggested in the previous section that the Proposed Rulemaking should be modified to allow for differences in the overall level of exposure experienced by different workers during their working lifetimes. This sug gestion is in accord with the provisions in paragraphs 6104 and 6114 of the Act. Section 3, Definitions, paragraph 6104 states: "(8) The term "occupational safety and health standard" means a standard which requires conditions, or the adop tion and use of one or more practices, means, methods operations or processes, reasonably, necessary, or appro priate to provide safe or healthful employment and places of employment." {Emphasis added.) Section 6, paragraph 6114, Criteria for Standards, states: "(5) The Secretary, in promulgating standards dealing with toxic materials or harmful physical agents under this subsection, shall set the standard which most ade quately assures, to the extent feasible, on the basis of the best available evidence, that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working 1ife." {Emphasis added.1 The key words here are "... reasonably necessary and appropriate" and "... regular exposure... for the period of his working life." A standard which is reasonably necessary for a worker who has regular exposure for the period of his working life is not reasonably necessary and may not be feasible for work situations of irregular exposure for periods considerably less than a working life. It is certainly appropriate to recognize this difference in the health standard. o v 3 UCC 014015a It was also suggested in the previous section that the Proposed Rulemaking does not make any distinction between monitoring, medical exam inations, and the attendant recordkeeping requirements needed to protect the worker and enforce the Act and those that are mainly for research purposes. The basis that such a distinction should be made is found in Sections 6, 8 and 20 of the Act. With regard to monitoring. Section 6, Labels, Warnings-Protective Equipment, states in paragraph 6116: "(7) ... Where appropriate, such standard... shall provide for monitoring or measuring employee exposure at such lo cations and intervals, and in such manner as may be neces sary for the protection of employees.11 {Emphasis added.) Section 20, Research and Related Activi ties ^states in paragraph 6190: " (5) The Secretary... ijn order to develop needed infor mation-----may prescribe regulations requiring employers to measure, record, and make reports on the exposure of employees...(Emphasis added.) "Upon the request of any employer who is required to measure and record exposure of employees... as provided under this subsection... the Secretary... shall furnish full financial or other assistance.for the purpose of defraying any additional expense incurred by him in carrying out the measuring and recording as provided in this section." (Emphasis added.) With regard to medical examinations. Section 6, paragraph 6116 states: "... where appropriate, any such standard shall prescribe the type and frequency of medical examinations and other tests... in order to most effectively determine whether the health of such employees is adversely affected by such exposure. In the event such medical examinations are in the nature of research... such examinations may be furnished at the expense of the Secretary of Health, Educati on: and Welfare." (Emphasis added.) Section 20, Research and Related Activities, states in paragraph 6190: "The Secretary... also is authorized to establish such programs of medical examinations and tests as may be necessary for determining the incidence of occupational illnesses and the susceptibility of employees to such illnesses." With regard to recordkeeping. Section 8y in paragraph 6128, Accident and Illness Records, states: - J: UCC 014016 -4- "(C) (1) Each employer shall make, keep and preserve ... such records regarding his activities relating to this Act as the Secretary___ may prescribe___ as necessary or appropriate for the enforcement of the Act or for developing of information regarding the causes and prevention of occupational accidents and illnesses." (Emphasis added.) ' It has already been noted that Section 20 provides for financial assistance for monitoring records obtained and retained for research purposes; Finally, the extent of recordkeeping which can be required by the Secretary is clearly limited by Section 8, paragraph 6130, which states: "(d) Any information obtained by the Secretary.... under this Act, shall be obtained with a minimum burden upon employers especially those operating small businesses. Unnecessary duplication of efforts in obtaining information shall be reduced to the maximum extent feasible." (Emphasis added.) The key point to note in these quotations is that Congress, in writ ing the Act, made a clear and repeated distinction between monitoring, medical examinations and recordkeeping that were intended to protect the employee and those which constituted research. One.of.the major shortcomings of the Proposed Rulemaking is the failure to incorporate this distinction into the regulations. Every employer, large and small, is required to prepare the same very detailed records and store them for 40 years or more. The Preamble to the Proposed Rulemaking discusses the concept of the "technical feasibility" of the suggested new rules but does not clarify what is meant by this term. In fact, the crucial words "to the extent feasible" are omitted when the relevant section of the Act is quoted on page 47053, Column 3 in the Preamble. In view of the extremely low allowable exposure levels proposed by OSHA and the possible differences in what is feasible in various occupational situations, it is particularly important to establish the meaning of these words in the context of the Act. The phrase, "... to the extent feasible" was an amendment to the Act offered by Senator Javits. The Senator explained the rationale of the amende ment as follows: A HP'S 3 8 "As a result of this amendment, the Secretary, in setting standards, is expressly required to consider feasibility of proposed standards. This is an improve ment over the Daniels Bill, which might be interpreted to require absolute health and safety in all cases, regardless of feasibility, and the administration bill, which contains no criteria for standards at all." S. Rep. No. 91-1282, 91st Cong., 2d Sess., at p. 58; Legis. Hist, at p. 97. In Industrial Union Department, AFL-CIQ, et. al, vs. Hodgson, 499 F. 2d 467, (C.A.D.C., 1974) (Appeal on First Asbestos Standard) the Court con cluded that economic factors as well as technological factors are integral components in the concept and determination of feasibility. UCC 014016a -5- The Court states at p. 477 in this decision: ' "There can be no question that OSHA represented a decision to require safeguards for thefhealth of employees even if such measures substantially in crease production costs. This is not* however, the same thing as saying that Congress intended to re quire immediate implementation of all protective measures technologically achieveable without regard to their economic impact." (Emphasis added.) and at p. 478: "Congress does not appear to have intended to protect employees by putting their employers out of business-either by requiring protective devices unavailable under existing technology or by making financial liability generally impossible." (Emphasis added.) It is evident from these passages that the basic objective of the Act is to protect the health and safety of the worker to the extent that is technologically and economically feasible. This distinction becomes parti cularly relevant when the medical examination and recordkeeping provisions of the Proposed Rulemaking are applied to small businesses, transient work places, and transient work forces. ............. SPECIFIC COMMENTS - PROPOSED RULEMAKING Sections 1910.1001 (a) Scope and Application and (e) (1) Monitoring, Initial With the exception of the construction industry, which will be covered separately, the Scope and Application section is virtually universal. It not only covers products where commercial asbestos is deliberately intro duced but also where even minute quantities are present as impurities in any of the raw materials. This is expanded greatly by the inclusion of tremolite, a frequent impurity in talcs, in the definition of asbestos without any dis tinction between the asbestiform and non-asbestiform varieties of this mineral. Finally, the use of the word "stored" brings under the regulation every place where a product containing asbestos is present whether or not it is even re moved from the package. This universal definition of Scope and Application is combined in the Proposed Rulemaking with paragraph (e) Monitoring, which requires an initial monitoring at- "... every place of employment where asbestos fibers may be released". At least a second monitoring, must also be made regardless of the initial results. This differs substantially from the present regula tions where the initial monitoring is needed only at places where asbestos fibers are released and in many situations further monitoring is not required. A08539 UCC 014017 -6- It has been estimated^^that there are approximately 258,000 places of employment in the secondary asbestos industries and 140,000 places in the asbestos consumer industries. Under a literal interpretation of the proposed regulation, it could be construed that fibers "may be released" at all of these locations. This is so, even though by the very nature of these opera tions a substantial portion are already in compliance with the proposed 0,5 fiber TWA standard. A monitoring requirement of staggering proportions results. At the present time there are 90 laboratories participating in the NI0SH PAT Program to demonstrate competence to count airborne asbestos fibers. Approximately 70 of these are large company laboratories or are operated by states for compliance purposes and are not available for outside counting, A dust count by a consulting laboratory costs about $400. At this rate it would cost $320,000,000 to provide the 800,000 surveys that would be mandated by the Proposed Rulemaking. Due to geographical limitations and the need to collect sufficient samples to calculate an 8-hour time-weighted average it is estimated that each of the 20 laboratories could sample about two locations per day. At this rate it would take about 80 years to carry out this initial screening. It is recognized that some laboratories can handle more than two locations per day and more people are entering the field, but it must also be remembered that asbestos is only one of about 400 substances to be regulated. The same pool of trained personnel will be needed to provide similar services for these other materials. It is clearly impossible for industry to comply with this provision of the proposed standard. We feel that this sweeping monitoring program mandated without regard to the potential hazard that actually exists at the places to be mon itored is not "... reasonably necessary or appropriate to provide safe or healthful employment and places of employment." In addition, it is not "... necessary or appropriate for the enforcement of the Act or for the develop ment of information..." or for research. It is a grossly unreasonable fin ancial burden on the employer and a poor and inefficient use of limited indus trial hygiene resources. As such it detracts from rather than adds to the protection of the workers. Finally, the words "may be released" without any qualification as to quantity, frequency or even probability that such an event will actually occur are too vague to be enforceable and are inappropriate in a regulation of this sort. It would also appear that they do not meet the requirements of the Criteria for Standards expressed in paragraph 6114 of the Act: "Whenever practicable, the standard promulgated shall be expressed in terms of objective criteria and of the performance desired." It is suggested that the difficulties can be corrected within the provisions of the Act if an initial assessment of the hazard potential based on available information is required. Where suitable information for a rea sonably reliable assessment is lacking it would need to be obtained. Monitor ing would only be required where such an assessment could not be made or where there was a reasonable possibility that either of the allowable limits would be exceeded. Such an approach is well accepted industrial hygiene practice. (1 ]U|echnological Feasibility and Economic Impact of 0SHA Proposed Revision bo the Asbestos Standard. Prepared by Roy H. Weston, Inc., March 29, 1976, UCC 014017a 8540 -7- As an alternative, the exception for bound fibers now used in the Proposed Rulemaking in connection with Danger Labels, paragraph (1) (2) could also be applied to monitoring. A suitable wording would be: "Monitoring is not required for asbestos or asbestos containing products.where asbestos fibers have been modified by a bonding, agent, coating, binder, or other material so that during any reasonably forseeable use, handling* storage, disposal* processing, or transpor- ' tation no airborne concentrations in excess of either of the limits specified in paragraph (c) of this sectionare released." This second wording has an advantage that this type of provision was adopted by the Construction Industry OSHA Advisory Committee at their meeting on September 17-18, 1975. It would remove one of the major problems in the application of the Proposed Rulemaking to the construction industry and the other problem areas that are the subject of this discussion. Paragraph (c) Permissible Exposure to Airborne Concentrations of Asbestos Fibers In arriving at the proposed 0.5 fiber/cc standard, OSHA has stated in the Preamble to the Proposed Rulemaking: "OSHA recognizes that there is no assurance of a safe exposure for a substance with known carcino genic property, in this case asbestos, and thus there should be no detectable concentrations." And: "While some level, below which exposure to a car cinogen does not cause cancer, may conceivably exist for any one individual, other individuals in the working population may have cancer induced by doses so low as ta be effectively zero." In taking this position OSHA has embraced the new "one-hit" hypothesis that is speculative and unproven. We feel that at this time, this theory does not meet the "... on the best available evidence..." requirement stated in paragraph 6114 of the Act. It is also questioned"whether it is suitable under the "... with respect to questions of fact, if supported by substantial evi dence on the record considered as a whole, shall be conclusive..." provisions of paragraph 6142, Judicial Review. A0854 1 Paragraph (d). Regulated Areas This paragraph introduces a new concept to the asbestos regulations wherein "any work area where, a person may be exposed to airborne concentrations of asbestos fibers in excess of either of"the limits shalT be designated as a regulated area." The existence of such an area in a plant triggers very substantial additional compliance obifgations of prohibited .entrance by other UCC 014018 - 8- - persons, warning signs, rosters, change rooms, lavatories, hygiene programs, prohibited activities in such areas and an employee training program. In many cases compliance can only be achieved by extensive relocation of equipment. The basic concept of the regulated area is certainly a means to limit exposure to as few people as practicable but the use of the ''may be exposed** wording is so vague that almost any place where unbound asbestos fiber is used can be construed to be a regulated area. We feel that regulated areas should be clearly defined as places where there is actual regular exposure of levels over the allowable limit. The speculative phrase, "may be exposed" is too vague to be enforceable and is inappropriate language for a regulation. This change would reduce the number of regulated areas to those places where a hazard exists and greatly reduce the burden for all industry and particularly those for the occasional or short term user and for non-fixed work places. Paragraph (d) also provides for a daily roster of all persons entering a regulated area. This is clearly an attempt to obtain very detailed work history records for research. The corresponding exposure data would only be measured once a month, would not match the roster in`detail, and would thus negate the value of such a roster. The same information, to the degree of detail that could possibly be needed for research, can easily be obtained from employee assignment records. The roster requirement is thus in conflict with paragraph 6130, Obtaining Information, in the Act which requires that information be obtained with a minimum burden upon employers. This portion* of paragraph (d) should be deleted. Paragraph (f), Methods of Compliance The Proposed Rulemaking requires that engineering controls be installed, "except to thet extent that such controls are not feasible", whether or not such controls will' reduce exposure to allowable levels. Work practice controls must be used to supplement engineering controls where needed and, finally, respirators are permitted as a last means of compliance. Engineering controls and work practices both protect the employee by reducing his exposure. Neither method is absolutely reliable and both are subject to mechanical and human failure. We feel that making engineering controls pre-eminent exceeds the "reasonably necessary or appropriate" pro vision of paragraph 6104, Section (3) subpart 8 of the Act and that engineer ing controls and work practices should be equally acceptable procedures to achieve compliance. In addition. Union Carbide takes strong exception to the apparent attempt to place the burden of disproving the existence of feasible engineering controls on the employer. The burden of proof has been shifted from the regulator to the regulated whereby the latter would, in effect be required to prove a negative to establish his innocence. This is contrary to the intent of the Act and repugnant to basic regulatory principles and the tradition of due process. As noted previously. Section 6, paragraph 6114 of the Act, Criteria for Standards includes the words: "... even if such employee has regular exposure to the hazard dealt with by such standard for the period of his working life." (Emphasis added.) O UCC 014018a _g. It is certainly appropriate that OSHA provide a standard which meets these criteria for protection of the employee with regular exposure for the period of his working life. In view of the "to the extent feasible" wording in this same paragraph and the subsequent court ruling, IUD, AFL-CIO vs. Hodgson, on this subject that was discussed previously, it is questioned whether it is "reasonably necessary or appropriate" to apply this same standard to employees with irregular exposures or who are regularly exposed for only a moderate frac tion of their working life. ' This problem is exemplified by a worker who, although at a fixed place of employment, dumps a few bags of asbestos into a process vessel once a day. This situation is widespread, for example, in the great multiplicity of small businesses where adhesive and specialty coatings are manufactured as a small part of a broader line of products. In many cases engineering controls that would only be used intermittently for short periods would impose a pro hibitive financial burden. We feel that it is appropriate and within the scope of the Act to permit the use of respirators with suitable limitations on the time they may be worn in any shift, as the primary means of compliance when asbestos is used' only intermittently or occasionally. This would also facilitate compliance in many norr-fixed work places, or small businesses which would have great difficulty in complying with the proposed regulations. Paragraph (g) (3) (iv) The Proposed Rulemaking moves further than the present standard in it's requirements for the transfer to other employment of any employee who is found to be unsuitable to wear a respirator. Further, in the Preamble, page 47658, OSHA states: "If warranted, OSHA may consider job reassignment based on medical unsuitability, per se, as the subject for a , separate rulemaking procedure." There is no authority in the Act for OSHA to include this subject in any regulation promulgated thereunder. It is a complex subject impinging on labor relations, workmen's compensation, and other existing legislation. It is suggested that- this is a more fitting subject for collective bargaining. Paragraph (i). Hygiene Facilities and Practices Subsection (4) of this paragraph states: "Clothes lockers and shower facilities shall be arranged so as to separate regulated areas and uncontaminated areas." [Emphasis added.) Subsection (5) states: "Lavatory and toilet facilities which are located in regulated areas shall be arranged so: that no^ ^ access is ava liable from therm to uncontami nated areas.11 (Emphasis added.) *08543 UCC 014019 -10- The meaning of these provisions is not entirely clear but it would appear that OSHA envisions that each regulated area will be segregated physi cally by a fence or other means and that the only entrance and exit will be through shower and change rooms. There is no provision for raw materials to enter or products to leave except through the shower and change room. If this is OSHA's intent it clearly exceeds the "reasonably necessary or appropriate" criteria for standards and when applied to small businesses and non-fixed places of employment is generally not feasible. Locker rooms and shower facilities are already subject to the allowable levels prescribed in the reg ulations and regulated areas are set off by warning signs. These additional provisions are confusing, unnecessary, and unworkable, and should be deleted. This section of the Proposed Rulemaking also states that: "... employees....shal1 be required to shower before leaving at the end of the work shift." And: "Employees... shall be required to wash hands, face, and forearms prior to eating, drinking, or smoking." There is no question that these are very desirable personal hygiene procedures but to make it a citable offense for the employer if the employee refuses to follow them is unreasonable. The employer can only provide the facilities, educate the employee on the need and desirability to use them, and encourage him to do so. Actually, the Act is quite clear on the responsibility in this case. Paragraph 6103, Enumerated Purpose, states: "(2) By providing that employers and employees have separate but dependent responsibilities and rights with respect to achieving safe and healthful working conditions;" This point, is emphasized in the general duty provisions of Section 5 (b) which states: r - "(b) Each employee shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are appli cable to his own actions and conduct." (Emphasis added.) We feel that OSHA has exceeded the mandate granted in the Act by proposing to make employers responsible for the personal hygiene of their employees and has failed to comply with a clear-cut intent in the Act by not making each employee directly responsible for compliance with rules applicable to his own conduct. Paragraph (j). Medical Surveillance and (n) Recordkeeping The present asbestos regulations require an annual medical examination for every employee in any occupation exposed to "airborne concentrations of asbestos fibers." A recent review commission decision found that this was not A08544 UCC 014019a -n- * limited to exposure levels over the allowable limits but to any level whatsoever. The Proposed Rulemaking continues this provision and increases the time that the employer must store the medical records. It is also proposed that monitoring records be kept for the same extensive period of 40 years or more. It is in these provisions that OSHA has failed to distinguish properly between employee protection and research. As a result, the proposed regulations place an extreme and unnecessary burden on all employers and an even greater and more unnecessary burden on employers whose employees are not regularly exposed for the period of their working lives. The Weston study cited previously estimates that about 15 million workers will be required to have annual medical examinations under the Proposed Rulemaking. This does not include an estimated 3-5 million additional workers engaged in the construction and shipyard industries. It also obviously does not include-workers covered by similar OSHA standards now in effect or being promulgated under the'standards completion programs who would be obtaining examinations from the same "pool" of medical practitioners. At the present time there are approximately 350,000 licensed physicians in the United States. Estimates of the number who have a registered specialty in industrial medicine or have acquired special knowledge in this area as a result of their particular practices vary from 2000-5000. For 5000 physicians to give ,20 000,000 examinations annually in accordance with the Proposed Rulemaking would require an average of 4000 examinations per year per physician, an obvious impossibility. To use this limited resource most effi ciently medical examinations should be required only for those workers exposed to levels over the allowable limits. It is well documented in medical research that there is typically a 20 year latent period before the appearance of asbestos, related disease and that this period generally increases as the exposure level goes down. On this basis, annual examinations for at least the first 10 years of exposure do not contribute to the-protection of the worker or provide research information. A tremendous decrease can be made in the medical examination burden without de tracting from worker protection by reducing the examination period to once every 5 years for the first 10 years of employment. This would also make the regu lation more reasonable for transient work force conditions and reduce the recordkeeping load. t It is clear from the Act that OSHA has a research responsibility to fulfill. The Proposed Rulemaking does this by adding to the universal medical examination requirements, universal provisions for keeping all of the medical and the corresponding monitoring records for 40 years or more. Successors to the business must keep such records and only in the case of a complete shut down can the records be sent to the Secretary. We question the need for a 100? cohort of about 20,000,000 workers to obtain valid epidemiological conclusions. What is the real possibility that any future study will examine the history of more than a very small fractioi) af this overwhelming mass of data? This is especially true if the reg ulations which have been adopted result in the elimination of asbestos related disease as expected. The motivation and funds to analyze these data will neither be available nor required. Union Carbide believes that the require ments that such records be kept 40 years or more by all employers is not "necessary or appropriate" for the orotection of the worker and grossly A08545 UCC 014020 -12- . exceeds any reasonable requirements for "determining the incidence of occu pational illnesses." It is also in conflict with the "minimum burden" provisions of the Act. . Instead of this impractical, cumbersome, and grossly excessive approach it is suggested that the research requirements of the Act can most effectively be met if OSHA will set up a planned research protocol with realistically sized cohorts for the range of exposure conditions to be studied. The workers covered would be designated and their records sent to OSHA at 5 year intervals. This would remove the necessity for long term storage of millions of records and employers would be permitted to discard such records after a 5 year period. SUMMARY # Union Carbide believes that the Proposed Rulemaking which has been written to protect workers who are regularly exposed to the asbestos hazard for their entire working lifetime, is excessively burdensome and is not "rea sonably necessary or appropriate" for the majority of workers who have a lesser degree of exposure. There is good basis in the Act to consider this gradation of exposure. Union Carbide also believes that the treatment of the entire industry as a large epidemiological experiment far exceeds the provisions of the Act for both worker protection and for research. The following suggestions are offered to make the regulations more appropriate both for large fixed places of employment and for the particular problems encountered by employers with small businesses, non-fixed work places, transient labor or intermittent exposure. 1. Limit medical examinations to those workers regularly exposed to levels over the allowable limits. Such examinations would be at 5 year intervals for employees with less than 10 year exposure. 2. Define realistically-sized cohorts of workers who's medical history will be followed extensively to satisfy the research requirements of the Act. Records for these workers would be sent to the Secretary at 5 year intervals. Mandatory storage of records by employers would be limited to 5 years. 3. Narrow the definition of regulated areas to include only those places where the allowable levels are regularly exceeded. 4. Not require initial monitoring at those places where there is no reasonably foreseeable possibility that the allowable limits will be exceeded. 5. Make engineering controls and work practices co-equal methods to achieve compliance. Allow limited use of respirators as the pri mary means to achieve compliance for intermittent and short-term exposure conditions and for small businesses. 6. Delete the. special requirements relative to the location and arrangement of change rooms and shower facilities and operate such facilities under the regular provisions of the Act. UCC 014020a ''O S 5 4 e ORAL PRESENTATION BEFORE THE CALI FORM IA STATE OCCUPATIONAL SAFETY AND HEALTH STANDARDS BOARD, NOVEMBER 8, 1978 Mr. Chairman, Members of the Standards Board. My name is Harrison Rhodes and I am employed by Union Carbide Corporation. The continued use of certain products wherein the asbestos fibers are wetted and encapsulated is extremely important to a large number of California manufacturers and users. They are represented here today by a number of experts who are prepared to answer any technical or business questionsyou may have. You have already received our written testimony and there is little point in reiterating it here today, although we can discuss it more thoroughly at your discretion. My intent is to show you some samples of the products so you can see what we are talking about. These samples show both the products in the form to be sprayed and the final product after cure. I will also summarize a spraying study which appears to be quite relevant and which came to my attention after the written testimony was prepared. A complete copy of this report was submitted to Mr. Rinaldi yesterday and may be in your folders. Let me emphasize that we are discussing only products where the asbestos fibers are wetted and encapsulated from manufacture through final usage. These include the coating and laminating materials and both types of fibrated roof coatings, that is those manufactured from cold-process cut back asphalt and those from emulsified asphalt. We are not addressing the Portland cement plaster or the naturally occurring impurity portions of the hearing. __________ A 0 8 5 4.7 UCC 014021 -2- As a frame of reference, let us first look at the asbestos-containing spray insulation material of the type that was the principal target of the 1974 legislation (60% mineral wool, 25% asbestos, 15% Portland cement.) This is the material as it was delivered to the construction site and this is what it looks like after application. Notice that I can pull it off with my fingers and crumble it to a powder. To use the Federal EPA definition it is friable. Excessive dust generation would be expected during field mixing and during renovation or removal. There are no objections to the banning of these materials and any like them. In contrast to this extremely friable material, all of the products for which we are requesting exemption must perform a protective or structural function which is defeated if they become friable. The first examples are a polyester laminating resin containing about three-quarters of one percent asbestos and a maintenance coating with about 2.5%. The laminating resin is used in conjunction with fiberglass to build up strong, rot-resistant structures such as boats. This is an example of one layer of the cured product. It is normally built up in layers to a thickness of a quarter of an inch or more. This is the finished maintenance coating containing 2.5% by weight asbestos. It is also hard and definitely not friable. Next are two examples of roof coatings. This one has an emulsified asphalt base and this one uses cutback. They contain about 9 and 7 weight percent asbestos after cure, respectively. Note that the cured coating is slightly flexible or resilient. These products must be formulated this way to allow for the effects of temperature change. A set of roofing product samples containing a much wider range of asbestos contents has been prepared by the W. W. Henry Company and will be described subsequently by Mr. Paul Beemer, the General Manager of that company. A08548 UCC 014022 -3- The spraying test I mentioned earlier, which was not included in our written testimony,-was conducted by a consulting firm for the H. B. Fuller Company. This study was submitted by H. B. Fuller as part of their testimony on a proposed Federal EPA regulation on the spraying of asbestos-containing materials. The materials sprayed consisted of a series of mastics used to provide weather-barrier coatings over soft thermal insulation on tanks, roofs, lines, etc. Asbestos contents were 1.8, 6.6, and 14.3% by weight chrysotile and a mixture of 13.7% chrysotile and 34.9% of Asbestine Fiber #2 talc. It is important to note that although Asbestine Fiber #2 is talc, not asbestos, it does contain a substantial portion of mineral particulate which would have been counted as asbestos by the consultant making this study if it became , airborne. The mastics were sprayed under two sets of conditions; in a closed 20x20 foot room to approximate the worst possible case, although the products are not normally used indoors; and in an outdoor application. The airborne fiber counts found are presented in this figure in the same manner as the other data in Figure 1, page 10, in the testimony. The fiber concentration in fiber/cc longer than 5 microns is shown on the vertical axis. The present DOSHA allowable limits of 10 fiber/cc ceiling, 2 fibers/cc TWA and the 1 fiber/cc maximum TWA set by SB-1591 are shown for reference. The four mastics are arranged in order of increasing mineral content from 1.8 to 48.6% by weight after cure. A 08 54 9 The solid circles show the operator breathing zone concentration. These are all in the 0,1 -0.2 fiber/cc range. The bars show the maximum or ceiling values, the range, and the arithmetic mean for the area samples in the immediate vicinity of the spraying operation. The highest value found was about 0.5 fiber/cc for the non-typical interior spraying of the Hi Mastic. The remaining values were in the zero to 0.2 fiber/cc range. As an added UCC 014023 -4point of interest, the Gallo Company sprayed 40,000 gallons of the Monolar Mastic containing 6.6% asbestos to insulate the exterior surfaces of wine storage tanks located out-of-doors in Modesto. Air samples were collected on membrane filters. No airborne fibers were detected by microscopic examination. The important point to note in these data is that the airborne fiber concentrations are all very low with no clearly defined trends with mineral content in the material being sprayed up to a total mineral loading of 48.6% by weight after cure. This result is very similar to the spraying and product removal data given in Figure 1, page 10 of the written testimony, indicating quite conclusively that the airborne asbestos exposure does not change a measureable amount with the asbestos content as long as the fibers are thoroughly wetted and encapsulated. For these products to be commercially useful, they must be wetted and encapsulated. To conclude, the products with which we are concerned perform a useful and valid service for industry and for the general public. They contain wetted and encapsulated fibers which do not expose workers to fiber levels in excess of those established by DOSHA or SB-1591. We would not be here today if we were not convinced that the products could be used safely and within the confines of existing regulations. We request that continued use of these products be permitted by your action to modify Section 5208, Title 8, as suggested in our written testimony including a maximum allowable TWA exposure of one fiber/cc >5y. Thank you very much for the opportunity to express these views. With your permission, Mr. Paul Beemer would like to present the additional samples mentioned earlier. M3855C UCC 014024 Union Carbide Corporation Metals Division Niagara Falls, NY 14302 November 30, 1976 M E M 0 R AN DUH To: J. L. Myers F rom; Copies: H. B. Rhodes R. E. Byrne, Jr. T. P. Norris R. L. Schult W. C. Thurber*^ File SECE/vEo t, |S/6 Subject: Status of Denver Drywall Asbestos Problem Denver Drywall is the drywall contractor for the Johns-Manville World Headquarters in Denver. They were using a mud manufactured by a UCC customer, Drywall Supply, as the first coat in a three-coat finishing procedure. This mud contained about 1% SG-210. The mud used for the other two coats contained no asbestos. By a communications mix up, Denver Drywall was under the impres sion that the Drywall Supply mud also did not contain asbestos and had so certified to Turner Brothers, Inc. the prime contractor on the job. On July 15, 1976, the site was inspected by Colorado State OSHA in response to an employee dust complaint. Denver Drywall received asbestos related citations for lack of monitoring and lack of medical examinations. Turner Brothers received a citation^for lack of medical examinations. Following the citations, UCC collected and analyzed dust samples at the J/M site (where no asbestos was now being used) and at another site where the previous system, i.e. base coat only contained asbestos, were in use. Our results indicated that asbestos exposures were so low that it was unlikely that they could be proven to be different from background levels. Denver Drywall filed notice of opposition and an informal conference was scheduled. Denver Drywall pushed the position that OSHA had not adequately demonstrated exposure, and if there was exposure it had not come from their wet mud. OSHA which was obviously in a weak position offered as a compromise to remove all fines and accept the offer to the employees of one physical examina tion by Denver Drywall and 4-5 by Turner as meeting compliance. Mr. Mitchell, the president of Denver Drywall, was seeking our comments on the desirability of not accepting this compromise and going on to the review commission as a matter of principle and to help with the overall battle with OSHA. The UCC involvement would be, at the least, the provision of expert testi mony on monitoring results and procedures. I told Mr. Mitchell that I felt that the technical merits of his position were solid but that this did not look to me like a good place to do battle on the monitoring reliability question. The strong appreciation of both UCC and the AIA/NA for his willingness to help was expressed. UCC 014025 jV 0 8 5 o 1 I 1 Memo: 0. L. Myers 2- - November 30, 1976 At the present time Mr. Mitchell is extremely annoyed at Drywall Supply for misleading him and is not using any asbestos-containing muds. If a realistic set of construction regulations can be obtained from the current negotiations with OSHA he is a likely cqndidate to go back to such muds. He is one of the largest drywall contractors in the Rocky Mountain area and is quite influential in the national affairs of the contractors association. H. B. Rhodes HBR:dal UCC 014026