<* FROM: Lewis & Gilman, Inc. 1700 Market Street Philadelphia, PA 19103 FOR: A/C Pipe Producers Association For Client Approval ACPPA AND AIA/NA OPPOSE EPA AMBIENT WATER QUALITY CRITERIA FOR ASBESTOS The A/C Pipe Producers Association (ACPPA) and the Asbestos Information Association/North America (AIA/NA) have stated that water quality criteria should not be used as guidance in promulgating drinking water standards.

the Asbestos Information Association/ reasonably*be expected to .exceed the North America, Ex. 328).

Pigg, the head of the 'Asbestos Information Association, the industry group which sued to block the emergency rule, said: "We have no plans for further litigation

The Asbestos Information Association (AIA) is coordinating the preparation of an industry response to the proposed 0.5 fiber/cc (TWA) standard.

Although the Agency did not propose mandating a specific monitoring procedure at that time, the proposal discussed the desirability of adopting, verbatim or with modification, procedures recommended by the Asbestos Information Association (AIA) (Ex. 86002), Chatfield (Ex. 84-319). the British government.

Through the efforts of the Asbestos Information Association, the membership of MSI is now represented at a series of informal off-the-record meetings between industry and SPA ruleraakers.

Although we currently envision others (eg. the Asbestos Information Association) will take the lead in rulemaking pro ceedings -- particularly as they relate to risk assessments, analytical capabilities etc., some possible Cl inputs might be appropriate.

., LAST 210 ROUTE A, PARAMUS, NJ 07652 BULLETIN NO. 776 October 25, 1983 EijVlROifliENTAL PROTECTION AGENCY ASBESTOS POLICY At the September meeting of the Asbestos Information Association (AIA) and in an article in the WALL STREET JOURNAL earlier this month, Enviroraental Protection Agency (SPA) plans on asbestos were discussed.

(Ex. 330) The appropriateness of promulgating a separate standard for.the substantially different exposure and work conditions in construction and general industry, was supported.by a wide spectrum of rulemaking participants: BCTD, OSHA's Advisory Committee for Construction Safety and Health (CACOSH) the Asbestos Information Association of North America (AIA/NA), and the Associated General Contractors of America (AGC).

JU>J 193 1 F CAPCO JEN 0032765 * * 'k ASBESTOS HATER CRITERIA BASED ON INADEQUATE DATA, A/CPPA CHARGES Drinking water standards should not he based on Environmental Protection Ager.cv water quality criteria for asbestos, according to the Asbestos/Cenent Pipe Producers Association and the Asbestos Information Association/K'orth America.

The foregoing is for your information.

Warren, representing the Asbestos Information Association/North America (AIA/NA). stated: 'AIA/NA agrees that the monitoring requirements of the present [existing) . standard should be revised to increase the coverage and frequency of routine exposure nionjtoring.

Asbestos Information Association.

suggested by the Advisory Committee In the April notice (49 FR14116-14145). for Construction Safety and Health OSHA solicited comments on whether the existing medical surveillance provisions for asbestos-exposed employees should be modified in any (CACOSH), the Building and Construction Trades Department of the AFL-CIO (BCTD), the Asbestos Information Association (A1A). and by new rulemaking undertaken to revise other affected organizations specifically OSHA's existing asbestos standard.

Although the Agency did not propose mandating a specific monitoring procedure at that time, the proposal discussed the desirability of adopting, verbatim or with modification, procedures recommended by the Asbestos Information Association (A1A) (Ex. 86002), Chatfield (Ex. 84-319), the British government.