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The Great American Asbestos Hoax Part two of two byRichard Baxter Preparation work is being done before the actual removal ofasbestos. 48 Editor's note: The followingis the conclusion of last month's article found on page 28. Studies conducted by the En vironmental Protection Agen cy (EPA) and private industry in dicate that airborne asbestos lev els inside buildings are low, and the difference between prevalent indoor and outdoor asbestos fiber concentrations is not significant from a public health perspective. There is, at present, not suffi cient information available to cor relate the relationship between potential exposure and actual in door concentrations of airborne asbestos fibers. Current lower fiber counts indicate that overall risk is low, and that the frequency of "episodic" releases are also low. The data base used to assess health risks associated with as bestos fiber exposure by federal agencies is based on studies, of occupational settings, and no data base exists for exposure of the general population to ordi nary and unconcentrated levels of exposure to asbestos fibers (harmful or otherwise). in Perspective From the summary of the interna tional "Symposium on Health As pects of Exposure to Asbestos in Buildings," conducted at the En ergy and Environmental Policy Center at the John F. Kennedy School of Government at Harvard University: "Deaths from ashestosis are observed only among indi viduals that have been occupa tionally exposed to high levels of asbestos. Present levels of as bestos in workplaces utilizing current control procedures are not expected to produce any mea surable impairment "Further, if asbestosis occurs, due to recent and much lower levels of asbestos exposure in workplaces, it has a slow progress sion and rarely results in serious disability or increased mortality. Consequently, there does not seem to be any evidence that asbestosis is a concern as a result of envi ronmental exposure." The occupational-related data February 1991 / Contractors Guide Photo courtesy of Lusa Anboslo* Ftamovat Co., Matm P*rtt, 11.1 BIRD 013028 base used by federal agencies to catch public attention included no essential information about the age of decedents or whether or not other causal factors (smok ing or exposure to other haz ardous materials) contributed to the deaths. The Wall Street Jour nal reported recently that approx imately 100,000 deaths had been attributed to asbestos exposure over the years -- no mention of how many years, the age of dece dents, other causal factors, etc. If one reflects on the number of deaths and disabilities that are at tributable to automobiles and smoking each year, the problems attributable to asbestos fade into the sunset But we don't see fed eral agencies clamoring for the banning of automobiles even though the best statistics indicate over 50,000 fatalities per year are attributable to the automobile. To their credit some federal agencies have addressed the smoking issue, hut not nearly as strongly as the asbestos issue. Perhaps if the tax revenue on as bestos fibers equaled the tax rev enue on tobacco, asbestos would be a much less harmful product The symposium summary at tempted to put the risk of death in the general population by as bestos exposure into perspective by comparing projected asbestos risks to other known risks. "Risk Models" developed using conser vative exposure levels of mixed asbestos fibers calculated from EPA measured exposures were used for-the projections of as bestos-related risk. Lifetime risks of cancer in duced by ambient air toxins in major metropolitan areas are 10 times greater than the potential for cancer caused by asbestos ex posure. Living with a smoker in creased the cancer-related risk by 200 to 400 times the risk of can cer from asbestos exposure. The figures shown in the chart are reproduced from the sympo sium summary, with lifetime risk of premature death per 100,000 indicated for various known and projected causes. It is absolutely unconscionable for a - government which subsi- Contractois Guide / February 1991 Various known and projected causes of premature death per 100,000- Smoking (all causes) Smoking (cancer only) Motor Vehicle Frequent Airline Passenger 21,900 8,800 1,600 Consuming Miami/New Orleans Drinking Water I dizes the growth of tobacco as a failure of brake and drive train farm crop (and therefore an in components will be listed in the dustry that produces substantial motor vehicle category and while health hazards) to ban a sub in fact, only the absence of as stance as useful as asbestos when bestos fibers will be the cause. the potential hazards from the Aside from the obvious eco use of tobacco and asbestos are nomic waste involved in removal objectively evaluated. of asbestos-containing materials I from buildings for no rationally Did You Know? justifiable reason, industry must When the fireproofing properties j deal with irrational bureaucratic of asbestos fibers are considered I decisions regulating the removal alone, asbestos has probably { of ACM in any form. Friable as saved more lives in the general j bestos, reducible to powder using population than been harmful. **" ! hand pressure, has been the tar The full economic and safety i get of most regulation by federal impact of the elimination of as- I and state agencies, but it is im bestos fibers from automotive j possible, in most instances, to get brakes and clutches remains to be : official differentiation between assessed. Brake pads and clutch i friable and non-friable asbestos- disks formed without asbestos containing materials. fibers tend to disintegrate after Non-friable and/or encapsulat only short periods of use and . ed asbestos materials have little, may cause loss of control of the i if any, propensity to release indi- vehicle. But deaths caused by : (more on next page) 49 BIRD 013029 ASBESTOS/conb'nuetfi vidual asbestos fibers even when disturbed. Virtually all asbestoscontaining roofing materials are encapsulated in asphalt, are not friable by federal definition, and do not constitute an airborne or respirable fiber hazard. More Data The National Roofing Contractors Association (NRCA) has been col lecting data during removal of roofing assemblies containing as bestos fibers for several years, contending that asbestos-contain ing roofing materials (ACRM) are not a particular hazard because asbestos fibers are essentially en capsulated in bituminous materi als and are non-friable by federal agency definition. Hundreds of samples have been collected from monitoring of roof removal work to indicate that removal of asbestos fibers en capsulated in bituminous materi als constitutes no particular health hazard to the remover or to the general population. In pri vate, federal officials have ac knowledged the evidence as valid, but officially, introduction of the evidence that Permissible Exposure Levels (PELs) are rarely, if ever, exceeded during roof re moval processes has resulted only in reduction of the PELs by regulating agencies. It seems that the original PELs once indicated as acceptable had no scientifically supportable foun- 50 datum. If an industry doesn't ex ceed the PELs established by a government agency, the PEL must be reduced until the prescribed individual protective measures are implemented by the removing contractor to justify the agency's regulations. As in the case of die originally imposed PELs, the sub sequently imposed lower PELs have even less foundation except for the additional stroke of the bureaucratic pen. The NRCA engaged the Stan ford Research Institute (SRI) to evaluate the data accumulated from air monitoring by NRCA members. Conclusions drawn by SRI were similar to those related in the Harvard symposium re garding the fallacies of phasecontrast microscopy (PCM) meth ods for evaluating airborne fiber exposure during removal of as bestos-containing roofing materi als, and the potential hazards as sociated with removal of ACRMs. SRI concluded that on most .general construction sites, a ran dom fiber counted by PCM will more likely be something other than asbestos, and that it is gener ally not possible to differentiate (reliably) between asbestos and non-asbestos fibers with the PCM. But SRI also provided the best, if somewhat illogical, excuse for OSHA relying on outdated and generally marginally reliable methods for evaluating airborne particle samples: " ... any change in the measurement method to determine compliance with the OSHA standard would, in effect, constitute a new standard and would require the same elaborate consensus-gathering effort, with public hearings and the like, as was required for the last standard setting effort in 1986,^ That reason alone appears suf ficient to continue to err in the eyes of the bureaucrats. And so OSHA, NIOSH and the EPA all have different definitions and standards for compliance with multiple and sometimes contra dictory rules - and the issue is even further clouded with inter pretations and unjustified tight ening of the criteria by equivalent state agencies. Some Agreement William K. Reilly, current admin istrator of the EPA, has recently admitted that the asbestos. risk has been miscommunicated; and that the current asbestos situation is a "good illustration of the law ofunintended results." He admits that most of the fed eral agency conclusions about human health risks are based an debatable assumptions and pro jections, which may or may not accurately predict human health effects, and that unnecessary re moval of ACM could pose a greater health risk than leaving the material alone so long as the material is undisturbed and un likely to be disturbed. Reilly contends that "If govern ment is going to sound the alarm about potential threats to public health and safety ... we must also state clearly just what these threats are, and how best to deal with them. And when appropri ate public reaction does occur, we have a responsibility to step up promptly and explain exactly what we know and don't know so the public can make an informed judgement of the situation." It certainly doesn't appear that his sentiments have been passed along to other self-serving federal agencies. And OSHA prepares to again reduce the PEL for asbestos (more on page 52) February 1991 / Contractors Guide BIRD 013030 * "i JointheEC! Builder Programand we^l helpyoubuildalarger customer base. Ifyou're not gettinginonthe dynamic growthoftoday'smetalroofingbusiness, youshould getinonthe groundfloorwithEGL OurbuUder program canhelpyourisetothetop. ECIgivesyouallthe technical, marketing, sales support, leads, and co-op advertisinghelp youneedto pullinthe metalroofingjobsyou've beenmissing.Andsince wesell metalsystems, notdealerships, you getagreat deal without front-loaded franchise orstart-upcosts. Plus; yougetoutstandingproducts likeompientedVeisaLQkstanding seamioofsystem, backedby superior customerwarranties, from.firnerica's leading metal roofing manufacturer. So, ifyou've beenoverlookinga marketwithvastpotential, look usoven WhenyouaddECImetalxoofingto yourproductline, weHhelpyouadd moreprofitto yourbottomline wECI BUILDING COMPONENTS.WC. Quality, AmericanStyle Officesandplants Houston, rX/AmaifflaTMendson,JUi/Lodi.CA/Tualatin.OR/Latetand, FL/ WiUamsbmg.MQ Write 224 on READER EXPRESS CARD customerbasa Pleasesendmemoro information ontheECIBrdlderProgram. Pleasehavearepreseittative call me Name: Company: Address: City:State_____ Zip: Phone ( ) Mailto: ECIBrnldingComponents, Inc. EO.Box968 Stafford(Houston),TX77497-0968 713/499*5611 wwimusn. Mac 910*8804435 Fax: (713)499-0809 assocwon I BIRD 013031 ASBESTOS/cont/nued' fiber exposure by another 50 per cent for no other apparent reason than die current PELs are not ex ceeded often enough during nor mal construction operations. And now that OSHA has re ceived a congressional mandate to levy increased penalties and fines to help reduce the federal budget deficit, they will be abso lutely uncontrollable. Congress, it seems, is counting on OSHA to contribute $1.2 billion dollars to the general fund over the next five years through its new power to fine and collect penalties for violations of their illogical and unjustifiable rules and PELs. Ob viously, the official positions of the EPA and OSHA are an abso lute dichotomy. Some early studies (1960s) on roof-related .asbestos exposure were conducted using old moni toring methods, the longest sam ple exposure being 3 hours with no time-weighted average for ex posure considered. All fibers were counted using the PCM concept, not just as bestos fibers. Some sampling was done during application of as bestos-containing roofing materi als, and some during the removal of asbestos-containing roofing materials. _ --' Ironically, concentrations of asbestos fibers were sometimes found to be higher upwind than downwind of the sample area, and none of the personal samples exceeded the 0.1 f/cm3 when cal culated as an eight-hour timeweighted average for comparison with file OSHA standard. Unfortunately, all of the sam ples collected during the early tests are suspect because of the lack of control of background contaminants or concurrent instal lation of other fibrous materials. Samples recently submitted to SRI by the NRCA were collected using currently acceptable sam pling techniques and evaluated by PCM. Most were taken during the time of removal of asbestoscontaining roofing materials, and most tests were conducted by cer tified industrial hygienists. Sam ples suspect, containing insuffi cient information, or illegible were discarded as invalid. All of Ihe 560 personal and 352 area sample results are below the Action Level (AL) (based on eight-hour time-weighted aver age); all were below the Short Term Excursion Limits (STEL). All of the samples above the Ac tion Limit were taken for time pe riods of less than 30 minutes, and should be more reasonably com pared to the STEL rather than the PELorAL. Some TEM data were included in the SRI report. The samples were reported as apparently hav ing been analyzed by competent laboratories, with no results at or above the action level reported. 52 More Findings Conclusions rendered by SRI fol lowing study and evaluation of NRCA-suppUed sample data were as follows: "On the basis of our review of these data, there appears to be no solid evidence that removal of ACRM yields exposures at or above the action level, the per missible exposure limit, or the excursion limit. A few of the data results were above the 0.1 fiber/cc for the given sampling duration, but information was not available for the remaining eighthour work shift. "They were below the OSHA action level when calculated as eight-hour time-weighted aver ages assuming zero exposure for the remaining shift There ap pears to be no pressing need for air monitoring at the start of each job, negative pressure enclosures or wetting. "However, the use of half-mask respirators is recommended until the source of the fibers in the few samples where concentrations were above 0.1 fibers/cc can be defined. Exposure to asbestos should be minimized until more (or better) information is avail able; the use of respirators seems a prudent compromise when working with uncharacterized and aged roofing materials. Further work should include analysis of additional samples by transmis sion electron microscopy (TEM), particularly when phase contrast microscopy (PCM) indicates high exposure levels, to distinguish between asbestos fibers and other fibers present in roofing removaL" The SRI study noted that there may be serious health risks asso ciated with working in protective clothing during hot weather, the use of respirators during work above the ground and with closed chambers and heat stress during roof removal projects; and as is the case with most evert' study, SRI indicated that the NRCA data could not be construed to be con clusive and that further study should he undertaken to evaluate other conditions. Those qualifica tions alone should be reason (more on page 54) February 1991 / Contractors Guide BIRD 013032 Roof Mouldings PAINTED ALUMINUM PART I -b-H DRIP EDGE STYLE D GUTTER SUPPLIERS, INC. 5353 Stickney Avenue Toledo, Ohio 43612 419-729-4691 PART NO. DE-2 DE-3 DlIMENSIONS A (in.) 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WFJ-5 Channel FR1-19 Channel 4" Fascia Cap 6" Fascia Cap 8" Fascia Cap 10' Fascia Cap .019 gauge Trim Coil 1-1/4" Trim Nails 2" Siding Nails 5" Gutter Guard 6' Gutter Guard 3" Ornamental Boxes 4" Ornamental Boxes Gutter Wedges Tile Adapters 3' Diverters 4" Diverters Roof Apron Hangers Pipe Cleats 5" K Style Gutter Write238 on READER EXPRESS CARD BIRD 013033 ASBESTOS/continued U.S. PAT. NO. 3913294 * Serves as a hip S ridge unit. * Hade of asphalt composition material. * Pre-creased at center, ready far easy installs lion. Save time and ladcr costs. * Approximately 3/4" thick at butt end. - * Looks FANTASTIC, homeowners love if. * Attention getting, draws leads. * Manufactured in 15 popular colors. * Reasonably priced. * Over 100.000 installations to date. * Algae resistant. ______ _ U.S. PAT. NO. 47G8318 * Serves as a roof edge Hashing & complete starter course. Includes a sell seal adhesive line. * Completely eliminates the need (cr metal edging and separate starter course. * Accomplish 3s!eps with one application-adds up to substantial savings in material and labor costs. * Made ol asphalt cot,position materia! with a granulated surlace. * Architecturally compatible with any type structure or rcoling material in texture and color. Homeowners love the warm, attractive, custom linish. * Available in 15 standard colors. 51 lineal fed per bundle. * Algae resistant Call or Write for Complete Information MANUFACTURING T1764SHELQQH STREET SUN VALLEY. CA31352 1818) 768-8014 FAX: |B18) 7B3-3048 enough for rejection of the evi dence by federal agencies. What appears to be the consen sus from respected institutions and individuals is that, although there are some dangers associated with some types of respirable as bestos fibers, there appears to be no immediate danger to the gen eral population caused by air borne asbestos fibers in buildings or in the environment. In feet, chrysolite fibers occur naturally in exposed rock forma tions and are regularly eroded by water and wind to become air borne asbestos fibers. Presum ably, man has lived with expo sure to airborne asbestos fibers since the days he began to walk upright and carry a club. Data bases used by federal agencies to determine the permis sible levels of airborne asbestos fiber exposure are not necessarily applicable to exposure of the gen eral population to environmental asbestos and are based almost en tirely on data collected from an industrial environment where workers were exposed to concen trated and prolonged doses of amphibole or mixed asbestos fibers in very confined areas. The exposure levels deter mined as being hazardous by fed eral agencies have little or no sci entific foundation with regards to the general population. No consideration was made, nor was data collected for, evalu ation of exposure to other con tributing hazards, such as smok ing, or the age of decedents. Methods dictated by federal regu lations to be used in evaluation of airborne fiber exposure are very likely to produce erroneous re sults because of their inherent in ability to differentiate between harmful and other fibers. The risks associated with re moval of asbestos-containing ma terials from building interiors ap pear to be much higher for build ing occupants and removal work ers than if the asbestos-contain ing materials were left in place. So the American public is once again the victim of misinforma tion perpetrated by those with a vested interest in justifying their 54 Write 233 on READER EXPRESS CARD existence. Does anyone remember saccharin? A synthetic sweetener product that made life more pleas ant for those with diabetes and tendencies toward obesity, even tually blasphemed by the Food and Drug Administration (FDA) which eventually forced its re moval from the market. Tune and research have proved the FDA was absolutely wrong in its evaluation of the effects of sac charin .on the health and welfare of the American public, but has the FDA ever extended an apolo gy or restitution for the damage caused to an industry to whom the agency originally conferred its blessing? The Canadian gov ernment has continued to ap prove saccharin while banning the cyclamates endorsed by U.S. federal agencies. It is not likely that OSHA and/or NIOSH will ever concede that empirical evidence should be considered to alter their rulemaking, or that the positives of asbestos outweigh the negatives. Nor will the agencies be pecu niarily responsible for their deci sions - right or wrongl The Damage Is Done The general population will never be provided with enough rational information to determine all the good asbestos has done for the public at large, nor to make educated decisions as to the long term effects of asbestos on their lives. Instead, the general population will continue to be bombarded with negative propaganda perpe trated by those" with a vested in terest in existence justification and economic gains in the re moval of asbestos-containing ma terials and the media which be comes an unwitting accomplice in the perpetration and embel lishment of misinformation. Those of us attempting to exist and make payrolls while attempt- ' mg to unravel the mystifying, contradictory government rules regarding asbestos removal and disposal could be accused of wrongdoing by one federal agen cy while complying with the rules of another federal or state Februaiy 1991 / Contractors Guide BIRD 013034 agency- And all the information we can gather to try to protect ourselves will only be used against us as justification by the rulemakers that their original SWAGs concerning exposure lev els were too high and must there fore be reduced to ensure that the rules are justified and enforceable regardless of the facts. Is the furor over asbestos really justified? After considering the minimal calculated risks present ed by experts in fiber exposure, is it worth deferring teachers' pay raises to provide funds for re moval of functional fireproofing or insulation from schools? Is it worth having otherwise function al facilities condemned because they contain innocuous quanti ties of asbestos-containing mate rials? Is it worth risking failure of friction components in vehicles because they no longer contain asbestos fibers? Should we suggest the encap sulation of all exposed natural rock formations to minimize the effects of natural wind and water erosion and therefore exposure of the general population to air- Exposure levels determined as being hazardous by federal agencies have little scientific foundation with regards to the general population. borne (and therefore respirable) asbestos fibers? Instead of re building deteriorated bridges, should we vacuum shoulders of major highways or install filtra tion devices at toll booths to min imize personal exposure to air borne asbestos filters? Only ifyou happen to be a tort attorney or de rive your income from a federal or state agency that has appoint ed itself responsible for adminis tering fear to American citizens. When evaluated against the other voluntary and involuntary risks encountered every day in the course of a normal life in the United States, the worry about as bestos exposure simply doesn't count. Given the apparent economic waste, the minimal effects of as bestos on the general population and the potential for hazards be cause of the absence of asbestos, this boondoggle should be laid directly onto Washington bureau crats. Write your elected repre sentatives who have most likely also been treated like mushrooms by the federal and state agencies. You should be mad as hell about the economic waste, misinforma tion and paranoia perpetrated by self-serving agencies. Revolutions have come about for less cause.CG ^SSSm. gj cuuue THE GARLAND COMPANY INC. A rapidly expanding muftHrrtSon dollar company in the roofing systems field requires INDUSTRIAL SALES The Garland Company is offering exceptional earn ings and growth opportunities to carefully selected experienced Roofing sales professionals. If You: Have a proven track record and a committment to a career in Roofing sales Are currently in the top 10% of your sales force Enjoy working on your own - Want to be compensated based upon your performance Then you're the type ofperson we are looking for. You'll also be working for a dynamic company comnimitted to long term growth. A company that will furnish you with all the necessary training and techno logical back-up to make the most of your skills. Garland - A company winning in the 90's Join the winning team. If you feel we have something to offer each other, send your resume in strict confidence to: Mr. A.V. 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