ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA 1835 K Street, N.W., Washington, D.C. 20006 (202) 223-4885 27 April 1977 Memorandum For: R.

EWIRO^IENTAL PROTECTION AGENCY February 4, 1976 Asbestos Information Association North America 1660 L Street, N.

-/ *9 Discussion of the Technological Feasibility of Attaining a 0.5 Fiber/Cubic Centimeter Time-Weighted Average Airborne Concentration of Asbestos Fiber in the Workplace as Proposed by OSHA in the Federal Register of Thursday, October 9, 1975 by Johns-Manville Corporation April, 1976 DUP U52470 DU 061785 C- / INDEX Title Page Summary & Conclusions ----- -----------------i Johns-Manville's Involvement in the Asbestos Industry - - 4 Plant Data (Table A) - .5 Major Problem Areas - -- -- -- -- -- -- 7 Fiber Introduction -------------7 Bag Opening Stations Fiber Handling Product Finishing -- - -- -- -- -- -- -8 Machining Sanding Case History 1 - Asbestos Bag Opening Stations - - - - 10 Process Descriptions ---------- Asbestos-Cement Pipe ---------Case History 2 - Reduction of Asbestos Fiber Exposures in Asbestos Cement Pipe Plants Case History 3 - Waukegan Pipe Plant - - Asbestos-Containing Boards ------ - - - - 22 Asbestos-Cement Asbestos/Calcium-Silicate -' Case History 4 - Billerica Plant - - Roofing - -- -- -- -- - - - _

Medical Removal Protection; (Z), Employee Information and Training; (m), Signs; (n), Recordkeeping; (o), Observation of Monitoring; (p), Effective Date; (q).

ste ee APPENDIX A - OSHA ASBESTOS STANDARD 1910.93a APPENDIX B - VACUUM CLEANING STATIONS SKETCHES 3 Page 1 Page 2 Pages 3-7 Pages 8-10 Page 11 Page 12-19 Page 13 Page 14 Page 15 Page 16 Pages 17-18 Page 19 Page 20-43 Pages 21-30 Pages 31-37 Pages 33-42 Page 43 Pages 44-45 INTRODUCTION The Occupational Safety and Health Act was signed into law on December 29 1970 and became effective on April 28 1971 The Act has the stated objective of assuring every American worker a safe and healthy workplace On December 7 1971 the Secretary of Labor issued an emergencytemporary standard for exposure to asbestos dust As required by the Act a permanent standard for asbestos exposure was promulgated six months later on Asbestos Standard discussed in June this 7 1972. booklet The present OSHA became effective on July 7 1972 The work practices on the following pages have been prepared by the Standards and Technical Committee of the Asbestos Information Association America They are intended as general guidance for safe and clean workplace conditions in keeping with the spirit and intent of the OSHA Standard for Occupational Exposure to Asbestos Dust These practices have consultation and are been developed recommended as through careful good procedure study and It is recognized that manufacturing conditions vary Implementation of the practices contained herein cannot be considered as a guarantee of OSHA compliance of compliance OSHA personnel Where should there may be a be consulted question Thorough understanding of the OSHA Asbestos Standard is important to management of any company utilizing asbestos in its manufacturing or processing operations The proposed revised standard contained in the Federal Register of Thursday October 9 1975 Vol 40 No. 197 Part II will not be a subject of discussion in this manual since it is a proposal without an effective date When the final revisions are promulgated this manual will be dated PRODUCTS AND OPERATIONS Types of asbestos sheet products covered by these work practices are Flat asbestos sheets - plain and pigmented - press produced Corrugated asbestos sheets - press produced Flat asbestos sheets - plain and pigmented - wet machine produced Corrugated asbestos sheets - wet machine produced Asbestos sheets and shapes - extruded Flat asbestos calcium silicate sheets - press produced Structural sandwich panels - sheets with insulating core flat asbestos Operations to which these work practices may apply are Handling and warehousing Drilling General Housekeeping including waste disposal Shaping Sawing Sanding PRODUCED JM PRODUCED SUMMARY OF THE REQUIREMENTS OF THE OSHA ASBESTOS STANDARD 1910.93a General Comments After extensive public hearings OSHA published a Standard for Exposure to Asbestos Dust in the Federal Register Volume 37 No. 110 dated Wednesday June 7 1972.

Testimony will be presented by several companies and the Asbestos Information Association.

N W WASHINGTON, 0 C. 244-354 FOR THE ASBESTOS INFORMATION ASSOCIATION PLAINTIFF'S 6 EXHIBIT | 'j SB.C..A-- 5...0-5-1--- |x PROGRAM ABC News Closeup s ta tio n WJLA-TV A8C Network DATE July W , 197 8 10:00 PM CITY Washington, D.C.

Testimony will be presented by several companies and the Asbestos Information Association.

Testimony will be presented by several companies and the Asbestos Information Association.

ENVIRONMENTAL PROTECTION AGENCY February 4, 1976 Asbestos Information Association North America 1660 L Street, N.

Testimony will be presented by several companies and the Asbestos Information Association.

RDIO TV REPORTS, inc. } 31.185 435 WISCONSIN AVENUE, N.W WASHINGTON, D C. 244-3S- -- \ 'FOR THE ASBESTOS INFORMATION ASSOCIATION PLAINTIFF'S fc EXHIBIT I 1SBCA..50.5.1.. 125 program ABC News Closeup STATION WJL A - T V A8C Network DATE Ju ly It, 1978 10:00 PM city Washington, D.C.

- International Talc - Union Carbide Corporation - Asbestos Information Association America - Institute of Occupational and Environmental Health R.

Specifically, no "new information has been forthcoming on the toxic effects of asbestos," since June 1972, that justify the substantial modifications being proposed by OSHA. in fact, new information not referred to by OSHA strongly suggest that 2 or perhaps more- fibers/cc is not associated with an excess incidence of pulmonary cancer.

Testimony will be presented by several companies and the Asbestos Information Association.