Court of Appeals for the Fifth Circuit Nov. 23 pending a decision on a challenge to the rule by the Asbestos Information Associ ation (Current Report, Nov. 10,1983, p. 587; Dec. 1, 1983, p. 691).

One has in fact been presented to the Construction Advisory Committee by the Asbestos Information Association. 7.

- 'The Asbestos Information Association has estimated that there are upwards of 3,000 discrete uses of asbestos.

Because several studies (Exs. 2-5; 84-190; 84-47) were cited in the November proposal as evidence of a multiplicative effect of asbestos exposure and cigarette smoking with regard to producing increased lung cancer risk, several commenters, including the Asbestos Information Association (Ex. 328), argued that OSHA overstated the risk of lung cancer in its qualitative risk assessment by failing to distinguish between the lung cancer risks for asbestos-exposed smokers and nonsmokers.

Support for a separate OSHA standard for construction came from all . interested parties in this rulemaking, including the Building and Construction Trades Department (BCTD) of the AFLCIO (Ex 87-2); CACOSH (Ex. 84-424); the Asbestos Information Association (EX. 84-307); the Associated General Contractors of America (ACC) (Ex. 844$7): The Safe State Program.

t Chemical, and Atomic Workers Union j ' (Tr. 6/26, p. 9), and the Asbestos. ( Information Association of North . i America (Tr. 7/6, p. 10). 123-A), and A1A lEx. 328) did not believe thst the scientific evidence warranted this approach.

Jean Gaudry (Jean Francoise) Vice President - Sales Marketing ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA Mr.

Performance-oriented rules allow an employer to design and implement a method of compliance which allows innovation and adaptation to the particular circumstances submissions by the Asbestos Information Association (AIA)), which indicate that local-exhaust ventilation is inadequate to routinely control exposures to below 0.2 f/cc because of the standard also requires fhe development and implementation of a written compliance program where the employer has employees exposed to asbestos above the PEL, without regard presented in a workplace, and permits an the volume of asbestos dust generated to the use of respiratory protection.

Warren, representing the Asbestos Information Association/North America (AIA/NA), stated: A1A/NA agrees that the monitoring requirements of the present (existing) . standard should be revised to increase the coverage and frequency of routine exposure monitoring.

You can contact the Asbestos Information Association, the asbestos industry lobby organization, by calling 703/979-1150. 36 ROOFING SPEC BIRD 012238

We understand that OSHA will be reviewing the current asbestos standard within the near future, and that the Asbestos * Information Association has provided OSHA with a suggested non-fixed worksite asbestos standard.

(ORC) (Ex. 12:i-A) and the Asbestos Information Association of North America, (AIA/NA) (Ex. 328), argued that'OSHA overstated the risk of disease from asbestos exposure.

Pigg, executive director of tbe Asbestos Information Association, said in a telephone interview that the indus try considered an emergency tempo rary standard for permissible exposure to asbestos fibers "unneeded and un warranted."

AIA - "The Asbestos Information Association/North America" AIA - "Asbestos and Health Questions and Answers" ^4.

m ASBESTOS INFORMATION ASSOCIATION 1745 jellerson Davis highway.