Brook Chles*o Cleveland, Iwltf 3 Psreonal Balias Dstroll White lead Works Houston Minneapolis Newark Oakland 0. 5.

<uJLu A = RRCIATE rQijR CONFIRMATION THAT WEEK 48 IS ACCEPTABLE AS /c Ntgj RELATIVELY LONG LEAD TIME TO MAKE APPOINTMENTS *:.GAnins r 3 ,,am QOMRUPG BFGOUDRICH CHEMICAL EUROPE TO REPLY BY MAILGRAM MESSAGE.

The importance of this action by Delaware is that the states may take the lead in regulating the prevention of chemical plant incidents rather than the federal government.

It was therefore suggested that the reaction of chlorophenol with chlorobenzene could lead to polychlorinated diphenyl ethers (PCDPEs) which are known to form PCOFs upon pyrolysis.

In addition lowcost substitutes exist for products in the millboard and the specialty paper categories Therefore available evidence suggests that suitable substitutes should be available for most applications by the effective date of the Stage 3 ban The total costs of the actions taken in this rule for these product categories are set forth in the following Table XXIV TABLE -COST OF THE Rule for ASBESTOS PAPER PRODUCTS Product Total cost in $ million discounted at 3 percent 3.73 The paper product categories were proposed for either a Stage 3 ban or a ban via the operation of a permit system Many of these products are no longer used in the U.S. and suitable substitutes are rapidly being developed although the development of reasonably substitutes for some specialty uses might take a number of years EPA is also concerned that consumers may be subject to uncontrolled exposures during _ installation maintenance repair and removal of products such as millboard In addition many of these paper products are very similar in form and bans would be difficult to enforce were the products in this grouping banned at different times EPA has concluded that a Stage 3 ban is appropriate for these product categories for the following reasons 1 Relatively high quantifiable exposure and individual risk levels exist for these products 2 these products pose a high potential for ambient release during a number of life cycle stages 3 consumers and workers are potentially subject to uncontrolled exposures especially during installation maintenance repair and removal of these products 4 the cost of taking these actions is reasonable because several of these products are no longer produced or imported in the U.S. and because suitable substitutes are i expected exist for all of these | products by the time of the ban and 5 banning while the quantified benefits of these products are relatively small compared to other product categories banned by this rule these products are likely both lead number 4\ serious exposures that could \ readily quantified for this rule and \ contribute significantly to environmental loading One asbestos paper product category grade electrical paper is not included within the rule's bans

(a) For Air Contaminants Generically 1910.134 1910.1000 1990.157 Respiratory Protection (For compliance with PEL's) Carcinogen Policy Model Standard LAM 004442 DPMC-10515 2 Specifically 1910.1001 Asbestos 1910.1017 Vinyl chloride 1910.1018 Inorganic arsenic 1910.1025 Lead 1910.1028 Benzene (overturned, for other reasons) 1910.1029 Coke oven emissions 1910.1043 Cotton dust 1910.1044 DBCP 1910.1045 Acrylonitrile 1910.1003 thru 1910.1016 - Thirteen carcinogens, with specific control requirements, backed up with respirators.

Attach substantiation form to this submission.) 1.2 CAS# 00 77 8 2 | --1 51 0 1 -j 5 (Use leading zeros if CAS number does not fUl space provided.)

*M tabolic acidosis = altered acidity of body fluids which mav lead to effects in organs such as the kidney, liver and heart DO A 0 1 9 5 3 6 O O N F T D F N T T A l.

Our data must support analysis that is not only convincing but sufficient to over power analyses of data that lead to other conclusions.

The case of the 24 Dow workers in Texas illustrates how much time, effort and money are consumed in epidemiological studies, and how the inherent imprecision can lead two groups to draw different conclusions in a single situation.

Thus, as diagramed below, the interaction of the reactive VC metabolite with cellular macromolecules may not always result in a mutation leading to cancer.

., mg/m of lead as a TWA, ceiling, etc.

For example, the levels set for asbestos and lead are 100 fibers inhaled per day and 0.5 micrograms per day, respectively.

Overestimating a decrease development of mesoiheliomas in people may lead policymakers to decrease vital exposed to asbestos dust,31 would appre funding for drug treatment for pregnant ciate an opportunity to try to clarify the and other women using cocaine.

Monsanto voluntarily stopped sell* mg KBs for "open uses" that could lead to human exposure in 1971.