Document ypOng6OE4vkv2DJq4LLo6NBad

Asbestos Information Association/North America, 22 East 40th Street New York, N. Y. 10016 212--689-3378 October 24, 1972 TO: AIA/NA Executive Committee r Gentlemen: Attached is the first draft of a proposed AIA/NA "Employee Safety & Health Guide" on asbestos. The purpose of the Guide, which would be printed in booklet form, is to inform asbestos industry employees of the basic facts about asbestoshealth and also about employer responsibilities under the l. OSHA resulations. The main reasons why I am proposing such a booklet at this time are as follows: 1. The IUD is launching a program (the Mount Sinai seminar in late November is the first step) to inform employees throughout the industry of the health hazards of asbestos and how to best use OSHA to assure compliance with the standards. There is little doubt that the IUD will paint a very black picture of the health situation and of the industry's supposed lack of concern for its employees, and will encourage local unions to constantly search out even minor infractions of the regulations for reporting to OSHA, as well as to press for strict observance I l of all employee health rights granted under the l. law. In my op~n~on, it is essential that we get to our employees first with the facts about asbestoshealth, and about OSHA, rather than to permit the IUD to present its highly distorted, anti-~ndustry "information" unchallenged. 2. .....-"' :, .. t ............. ~.. -~-.; ... Ill One of the major arguments voiced by both Tony Mazzochi and Dr. Selikoff at the Lyon . conference for greater union participation in medical and other meetings on asbestos-health was that the industry was .takin'g ive s e s EXHIBIT r:!1 c. -2- to inform its employees of the hazards of asbestos and was, in fact, trying to keep these facts hidden from its workers. Thus, in principle, a booklet of this nature would have the support of the IUD and of Dr. Selikoff. It would also be an effective ~ refutation of their charges that the industry is doing nothing to inform its employees. 3. OSHA has on more than one occasion voiced its contention that industry should provide employees with as much information as possible on occupational health hazards, and that OSHA would look favorably on any industry that did so. In my opinion, it would be a serious error on our part to continue to hold the belief that our employees are, for the most part, unaware of the asbestos-health problem and are not i \.. going to find out about it unless we tell them. I think we must face up to the fact that employees in all areas of the asbestos industry are becoming increasingly aware of the situation and are going to become better and better informed as the IUD and other medical-labor informational programs get into full swing. The point is simple: If we don't inform our employees, somebody else will! I am fully aware that one of the major industry fears with regard to providing employees with facts on asbestos-health is that this would result in a great increase in workman's compensation claims. t-."hile there may be some validity in this argument, think for a moment how many claims there would be if the IUD and Dr. Selikoff were permitted to present their estimate of the health situation to employees without any refutation by the industry. One of the major problems that can be anticipated in any industry sponsored informational program for employees is the question of credibility. Will employees believe what we tell them? or will they consider the contents of the booklet to be nothing but a pack of industry lies and misinformation? Because of this credibility problem, it is essential that the booklet not be a propaganda piece, but it must be as factual and irrefutable as we can possibly ~~ke it. For this reason, for example, I have-eliminated all but a passing reference to industry efforts in controlling dust levels and have instead concentrated on the industry's responsibilities to its employees under OSHA. Hopefully, the employees will come to the conclusion that if the industry is willing-"to tell .them what the law requires, the industry is, in fact, planning to obey the law. 000182 -3- As another example, I have avoided the subject of what is a safe dust level by en.phasizing that the reduction of dust exposures to as low a level as is technically possible is universally accepted as the best way of preventing disease. To argue about dust levels would give the impression that the industry wants to do as little as possible, and is looking for excuses to avoid doing more. To have this booklet be credible to the majority of workmen, it is essential that we avoid points of controversy with the IUD and Dr. Selikoff as much as possible, and also that it contain information of value and use to the employee. You will notice in the draft that considerable attention is paid to the use of finished asbestos-containing products. As we are all aware, there is much misinformation being circulated as to the safety of such products. This booklet ean, hopefully, also be used by our customers to help allay the fears of their workers. Because the IUD-Mount Sinai seminar is a mere five weeks away, I believe it is essential that we proceed as rapidly as possible with the production and distribution of this booklet. Of course, no member company has to make use of this booklet if, in its opinion, the disadvantages of using it outweigh the advantages. Nevertheless, for those companies that will find it useful, speed is essential. I would appreciate, therefore, receiving your comments on it as soon as possible. Once the Executive Committee has agreed on a final draft, we will then send it out to the member companies for final approval. Sincerely, Matthew M. Swetonic Executive Secretary , Enclosure .. ,--.; ._..:. " " " .. :w"t !. ......_.._ .:.. -"" .... ' ....... ~~ 000183 !!Ployee Safety & Health Guide Introduction I! 7ou are an emplo,-ee engaged in the ird ng, aanu!acturl.ng, or ha.ndl.ing and !a.brication of ubesto.s and a.sbe.sto.s-conta.i.n.i.ng produet!S., there are cert.a.i.n !acte concerning the potential health b.a.z.a.rd.s e! ubeets and vhat to do about them tha.t ,.ou should knov.. t i' !'he purpose er thia booklet i.e t.o protide yu with i.n.!ormation en what these ha.za.rds are, vhether ,..ur job ie affected, vhat lave exist t. protect vorkmen, and what ,.ou can dQ to prote,ct ,.our ovn heal.th and that o! your fellow e!tployee!! . l. t r r ................. Health Facts About Asbe~to~ It i.e a generally accepted fact that the iDhalation f excessiTe quantitie.s ! !ree asbestos fiber can increase a11 employee's risk o! deTeloping certain cli8ea.ses ! the lung, :including asbestosis, bronchogenic cancer and mesothelioma. Because it takes .any ,.ears !or ubest~related i.l.lnese to tshov up in an indirldua:l, the di.eea.ee being found td.a:r among long-term asbestu indW!Itr,. empl.o;rees 1a a result ef conditions that e:x:i.sted 20 or 30 ,-ears age, at a time vhen neither the .edical profession nor the indu.str,. knev ert much about the health e!!ect.s of .ubeetos or the proper means for their control. While there are differences ef opinion within the medical profession eonce~ !IIB.n1 IU!Ipects ef this problem, it i.a uniers.Ul:r accepted that du.st leTels in the verkpl.aee ehould. be k~pt as lQv as modern technology can possibly achieve .. At the present time, the reduction ~~ dust levels ia the onJ..1 ~ovn method ef preTenting these d.iseasee a.mong expoeed workmen.. ExPerience ha.s ahevn that vhen dust leve~ are lv, the ~~idenci:e .r theee diseases drops ~" 000 1~ 4 :. . -..,.............._........._....... ....... r ' ( l' L L i \. .f r ' -...- It hu alu been proven that heavy ubestes exposun greatly increues the risk e! lung cancer from eiga.l"ette SliOking, but that a.sbestos ind~tr,. vorkmen vhe cte ~smoke cigarettes haTe no ~ater risk e! lung cancer than the aTerage a:n-c:n-the-street vhe does not 11:110ke. Ie M:r Jeb H.azardeu.s7 M a general rule" mest employees eDgaged in the mning and milling o! ubeeha tiber, er in the aanu!acturing o! ubestoa-cont-":S ning products:- rill be exposed te some quantity o! airborne a.sbestoe tiber in their jobs. In prcperl:r contrelled pl&.nts and mines, these leTels vill be extremely J.ov .. In i.rrproperly or uncontrolled operations, the leTels may be dangerously high. Most uanu!acturing plants in the industry are nov er soon vil1 be properlJ' controlled.. er!he installation application f ~ finished asbestos-containing products will .ruu, produce dust levels high enough to be o! concern. In products such u Tinyl-asbestos fior tile and asbestos-cement aheets and pipe, the ill!bestoe ~ olidly lecked into the product vith cement~ plastic er ther binders in aueh a ISB.nller that the. ~iber i.s not easily released during nenw.J. handling and application. Some a.sbestos-conu.:i!'ing products,. hewever, such as unsaturated textiles and most asbestos insulations, can releee potential.l.y hazard.o\1.1!:- amounts ef a.abestes duri.ng handlXng or fabrication. !he tea.r-.ut or removal. ! ld ubestee...eont&i.ning j.nsuJ.ations can like~ be a -nr,. dW!ty operation. lfhese products 111W5t, therefre,. be handled vith cautio~ using approTed ~~ethods e! duet auppreasion and control to wdtl'imi u the generation e! airborne fiber. Fortunatel\y; nly a Ter:f esal.1 percentage o! the asbeetos-Centa.ining preduets produced ~ the United Sta.tee each ,-ear are capable ! releasing aizea.ble qll.antitiee of dust during handl.ing er application. "00185 . . ,. .. . . .. ."'t .... , .,. ._ .. ~,. ~~'1...._ ~.. a....~. ~:. r It ,.ou are un.sure whether the product ,-eu are using iJ capable e! producing potentially haz.a.rdews aliOunts e! ubestee dwst,. c~k tM carten er bag in vhieh the product vas ashipped. Kanu!aeturere are required bt lav to place a caution l.abel en .:U ubetstoe-cont:.aini:ng products that read.i.l.,- releue high levelts e! tiber du.r:1..zlg h.a.n~ or applie&tien. '.!!he label ha15 been placed there tor your protection. Look !or it i ! ,.ou are U%18ure . ~ U ,-ou do net vork d..U-ectly vith ubestoe or ubetste&-cent..ining producta,. but [ vork in close proxi..mit:r te tlwae wh.e d.o, aueh a.t!E en a conatruction ite where ( l ubeste&-eontaining insul.ationa are being applied, :rou ah(,uld check to do.termine :1! these products are being handl.ed properly. It the:r are,. it is Mghl:r tmJikel:r L tha.t :rou viJ.l be exposed to potent~ unsafe leTels e! ubestos. I ! proper precautions a.re net being taken by ether workmen on the job aite, thi!l sheuld be reported to :your employer or wti.on representative. ! Regulations On Asbestos : l On J.tme ? 19729 the Occupational Sa.fet:r and Bealth Adm n1 etn.tion (OSRA) e! the United StateB Department e! Laber i.saued occupational etanda.rd.a !or exposure t. ubeastoe clwst. ~ae astan.d.ard.a baTe ene aa.jer purpose - to protect :rou from xpo~ to potentially htu:a.rdous amounte et u"bestes dust in ,-our vork. '1'he r ubestos astandards, u they a.re commonly called, contain mey detailed requirements, howeTer9. the basic ebligatiens placed on the employer under the tandards can be aslll'l!lmed up as !oUows: 1. The employer shall aa.iJlta.in a healthy vorkplaee by ~ auroe that no emple,-ee its exposed tb concentrations: e! airborne ubel!ltos fiber in excess e! eastablished l.i.raits.. : 000186 llmt 'l'he current .OSHA to~ eXposure to aabestolS i.8 5 fiberlS fi.Te tderon.s in ._l.ength or l.onger. per cubic centimeter (cc) e! air u averaged over an ~hour workday. At no time ma:y an employee'a exposure exceed 10 !ibera per cc. I.rr.l976, the 8-hour aTerage its scheduled to be reduced to .tve fibers pe:rr c:a. A mi.eren is &'Pf.lroximately l/25,000th e! an inch~ and a ~bic centime_ter is ~ppro:x::i..t:mtel'y z. Where erpotsU.re l.illr:ite are exceeded., the e~rplo)"H ahall be neti!ied in vriting e! the situa.tien bt his emploter a.n.cl ab&ll be Weraed e! the correetiTe measures being undertaken te reduce hia expoeure ttl a JUde leTel. 3 Wb.Ue corrective mei!Urures are being instituted, the employee sbal.l 'be preteeted by other mee.n.e., .ueh A!l by the vea.ring c! an apprond reepirator pr.vided by his employe%! or by ahi!t rotation.. 4. E:ngi.neer:Lng contrcla and the inatitution o! aa.te verk pra.ctieee are the approTed methode et correc::tion.. 5. !be use of respirators or ahift rotation to aehieTe control is ~ permitted except (a;) during the t~ neeezse.a.%7 U3 i.Mtall L engi..neering controls er to institute aa.!e work praeticea;,, (b) in situations vhere auch controls or praeticee are n.ot techniee.J.ly feuible, er (d in emergencies... I. ( 6. lie empl.o;ree ahall be assigned to a taak requiring the wse e! a ,. reapirater i ! hie most recent ,.early .edieal ex:urination indicates I that he voul.d be unable to :f'unc'tion properl,. vhlle wearing ene, or if' the wearing e! a respinter would ha%&rd the e~~ple,.ees health 7 Special, proteetiTe clothing, change ro.ma and eeparate clothee 1ockenr shal.l ~ provided !er employees in cmrtain eituationzs.. a. PersonaJ. and enTironmental 'IIOnitori.n.g ! workplace ai.r 8hall be conducted b,. the employer to a.aaure th&t thtE etand.ard.s are being aet .. Employees 8hall bATe aceeaeo to the reaultes of the monitoring . e! their job. 9 Warning .signs. shall be ~!lted .ili areaJS vhere the dU!It leTel its in excess of the ata.ndard. 000187 . . . ...... . ..::.# ;. ... : ' - ..... .,. "':. ~ , .. ,. ~.._ .... -5- 10. Caution l.abels llha1l be plAced en produet.a "that are l.ikely te releue tree aabestee fiber in excess ef t.he standard duri..ng he.ndHns, application or fabrication.. ll. 'rhe employer shall protide yearly Mdieal ennd :natiou fer empl.oyeftE exposed te concentration.e ef &ISbestes dust. Pre-emplo,--nt and terainatien -.edical exalM are al.so required. 1.2. At his request, an employee's medical records. can be made ava.ila.ble Vh.ile the entire set of &ISbestos regul.a.tion.e covens nearl,. Jt~ large pages ef ~ pr:i.l'lt, the Twelve Key Points listed abeve are the 110st illportant aa; far u ,.ou,. the employee,. i.e concerned:. Standing behilld the vork:ing man, ready ta nforee these regulAtions, is the OccupationAl Safety and Health Adm;nietrationr vith inspectors a.nd offices all acroes the country. If the ta.ndards are not being ~, any employee has the right to compl.a.i.n to OSHA and request a geverM~ent b.spection teas to investigate the situation.. E=ployera; who fall te ebe,- the regulations are subject to heaTY fines. It i.e in ~ur best interest te lc:n<Df. ,-eur rights under the lav and vha.t ebl.iga.tion.s; -your empleyer bQ tolla.rd you. ~ 'l'velve Key Points l.isted abeve aheuld help.. What Can I De? Industrial aa!e1ey' and health cal\ never be onl.y one person's responsibility.. Both .employer est emplo;reee auat werk tegether te proTide a aa.fe ud heLLthy verld..ng enrlronment.. In cmrta:i.Ii aegments e! the coMtruction industry, for exa.mple, Tery detailed vork practices W!ill baTe to be instituted to assure ce~ce with the regulations. lOIS an ell"ployee,. it vill be ,-our duty t fellev thee work p:racticee at all. times, and no~ take a~rt euta that ~ enda.llger your ovn health .............. ud that of ether workmen en the jeb aJ! well &IS possibly irubject ,.our eapleyer.- .. ...... - . ~:uoo1.as . ....,.,.;.,... ... ~ -...i ,"-41. . . . . . . . . . . . '--.~ .;.._,:_ ~ ~........... .........~,.._, ... ,~~,- .. ~. :~.:-'~~-:.j,i1f"~~ld_r'i~~~: to an unnecesaa.ry fine .. Fer another exaaple,. 1! .,..u eee: a potential b.uard that ,-our employer u:y have enrlooked,. point it out to him !or correctieu. Only i! he continuou.ely ~ores ebrlously hu:llrtiou.e situations er refuses to con:l!ct the ahould :rou reportt the Tiolation to OSHA. Remember.- eO.rpl..ian~ vith the regulations vi1l be extremely difficult and very expensive in ma.ny eegaent!l ot the indust%'1' In the interest o! aTi.ng jobs a.a ve:ll as: uauring a heal.thy- workplace, indu..str;r and l.ab.r IIUSt work tegether to solve their IIUtu.al probleliB .. Aebeetos and Smold.ng On page 2 of thia bceklet,. ~t vu pointed eut that noking c~ttes greatly increa.se!!3 the risk e! lung ~eer a.ong employeel!: expesed to exceuiTe quantities f aJSbestos dU8t. Statistics Bhov that len.g term, hea.vil.y expoeed ubestee insulation vorkens vhe smoke cigarettes have a 92 times greater risk of denloping lung cancer than their fell._. vorkens whe do net amoke. In !act, if ,-ou do not amoke cigarette.e, even if yeu have been exposed to ex.eessiTe concentra.tiorus e! ubestos dust or 20 or re years,. ,-ou have n. ~a.ter chance e! ~tting lung cancer than the &Tera.ge man-en-the-street vho does not smoke. !he advice o! 8edieal. apecial.i.ets on thie matter 1!1 simple:: I! :rou vork with r ubestos and smoke cigarettes, quitl- I! ,-ou vork with asbestos and do not aaoke, don't atart. SUJ!Il!':ar1 000189 Aabeetes can be a ha.zardeus subetanee i! :inhaled in euf!icient quantitiee. There 18 a Hcognized need to keep duet level.B -., low ..,., poseible for expoeed workere. ;he &JSbe.etos i.ndustr,r ia verk:i.n.g hard :to achieve control.. lfb.e nat aajority of fi.Jd.shed asbes~os-eonta.i.l'l.ing products are not ba.zardeW. to U.ee or handle. '!'he Occupational Safety and HeAlth Administration has iasued. regul.atio.~. to prote~t American vorkmen frem exposure to heaTY concentratioll!l a! ubestos dust. lfe lUke these regul.atierus vork properly, the cooperation o! both ell'pl.o,.er and e.:ployee is essential .. Aabestes werkera hould not .-moke c~ttes .. 7er Additional or More Detailed I:U"orsation Or For Additional. Copies o! Thi.e Booklet Contact '!'he A.sbe5toe In!orma.tion A.eaeciatiozv'North Americ:al. Su:it.e l6ll 22 Eut 4oth Street !lev York, N.Y. 10016 PHONE: (212) 689-3378 I \. ~:.! r 000190 . .