1. 26 consecutive autopsies of patients with asbestosis, and
      2. found four mesotheliomas of the pleura and three of the peritoneum.
      3. can be recycled under optimal economic conditions. Johns—Manville
      4. in Waukegan claims to re-use “most” of the filtered short fibers.
ILLINOIS
POLLUTION
CONTROL
BOARD
January
6,
1971
In
the
Matter
of:
)
)
#R71—16
ASBESTOS
REGULATIONS
)
OPINION
OF
THE
BOARD
ON
ADOPTION
OF
REGULATIONS
(BY
MR.
LAWTON):
Proposed
regulations
relating
to
asbestos
and
spray
insula-
tion were published in Newsletter #24 dated
June
14, 1971.
Hearings
on these regulations were held in Granite City on October 6, in
Chicago on October 15, and in
Waukegan
on October 19, 1971.
Notice
of the proposed final draft, together with the form of regulation
proposed
for
adoption,
~,
published on
December
5, 1971 in News-
letter #37.
Written coimnents were invited
and
a
small
nanber
have
been received.
We adopt the
regulations
today
in the form as
pub-
lished
in
Newsletter
$37, modified by some minor clarifying lan-
guage.
Our
principal
concern
in
these
regulations
is
to
prevent
or
limit
the
emissions
into
the
atmosphere
resulting
from
the
use
of
asbestos
and
asbestos-bearing
products
and
the
resulting
disas-
trous
pathological
consequences
resulting
from
ingestion
and
inhalation of this mineral.
This Opinion will consider the source
and
types
of
asbestos,
the
uses
of
asbestos
and
asbestos
bearing
products,
the
cause
of
asbestos
emissions
and
their
demonstrated
impact
upon
the
health
of
the
conmiunity,
the
measurement
and
monitor-
ing
of
asbestos
fibers
and
the
means
available
for
emission
abatement
and
control.
The
modifications
made
in
the
substative
provisions
of
the
regulations,
between
their
original
proposal
and
ultimate
adoption, will likewise be discussed.
The term Nasbestosu is a
name
given to a variety of natural
occurring mined silicates of a virtually indestructible character.
The major asbestos minerals
are
chrysotile,
crocidolite,
amosite
and anthophyllite.
Of lesser importance are tremolite and actino-
lite.
These minerals differ in their metallic
elemental
content,
range
of
fiber
diameter,
flexibility
and
harshness, tensile strength,
surface
properties
and
other
attributes
that
determine
their
indus-
trial
uses
and which,
in
turn,
affect
their
respirability,
retention
and
biologic
reactivity.
Over
90
of
what
is
mined
and
commercially
used
as
asbestos
is
chrysotile,
sometimes
referred
to
as
“serpentineTM
asbestos
•
The
remaining
minerals
are
collectively
referred
to
as
amphiboles.
The
United
States
uses
about
one—fcurth
of
the
world
production
of
this
substance,
most
of
which
is imported
from
Canada
and
Africa.
(Ex.
3,
Air
Pollution Moects of Asbe~toi~,
U.
S.
Department
of HEW,Septeniber,1969,
Litton
Report.
•Ex
19,
Airborne Asbestos, National Academy of Sciences, 1971.)
Asbestod
deposits
of
comnercial
value
in
the
United
States
are
located prin-
cipally
in
Vermont,
California,
Arizona
and
North
Carolina.
No
3—437
conrnercially viable sources
of asbestos are
found in Illinois,
a
fact
which might otherwise invoke
a far more comprehensive set
of regulations.
The
uniqueness and industrial usefulness of the
mineral
is
a consequence
of
its flexibility, tensile strength, non-
inflammability and its resistance to acids,
alkalies
and electricity.
Some asbestos
fibers
get into the atmosphere from non-industrial
sources.
See Asbestos Air Pollution Control,
Institute for Environ-
mental Quality, prepared by Cohn
F, Harwood,
Ex.
20.
These range
from rock outcrops,
farming
and excavation
for construction purposes
to
the
use
of
talcum
powder.
Emissions from
rock. outcrops occur
as
a
consequence
of
natural
eroding
processes
such
as
earthquakes,
temperature,
wind
and
rain.
Farming
of soils
in areas containing
asbestos
rock
will
likewise
cause
emission
of
these fibers.
Con-
struction
requiring
excavation
in
asbestos
containing
rock
for
housing,
pipe—laying
and
road
construction
constitute
~
source
of
asbestos
emission into the atmosphere.
Recent research indicates that talcum
powder,
while basically
a mineral rock
dust,
does contain fibrous
material,
and represents
a threat of asbestos bodies.
Obviously,
the th~ustof the regulations does not
seek to
control asbestos emissions
from these sources.
Further,
the absence
of
asbestos mining in Illinois eliminates
this activity
as
a source
of
danger.
It
is
the
processing
of
asbestos
in
manufacturing
and
the
use
and
fabrication
of asbestos
and asbestos
and fiber containing
products
to
which
the
regulations
are
principally
directed.
The
health
dangers
inherent
in
asbestos
inhalation
arise
at
the
start
of the asbestos processing cycle
and include the loading and storage
of
milled
asbestos,
the
transporting
of
bagged
asbestos
to
the
open-
ing area,
fluffing of compacted fibers and the mixing bf asbestos
fibers with other materials.
(Ex.
20, Harwood, Page
7.)
Principal
user
of
all
grades
and
varieties
of
asbestos
fibers
is the asbestos-cement industry producing asbestos-cement pipe
used
to
convey
water,
sewage,
industrial
and
gaseous
products
and
serving
as
conduits
for
electrical
and
telephone
cables.
Other
asbestos-cement
industry
products
include
roofing
shingles,
building
boards,
marine
board
and
laboratory
bench
tops.
To
manufacture
these
products
willowed
fibers
are dry-mixed with fine-ground silica,
and
a
slurry
formed
by
addition
of
water.
The
end
products
of
these
industries
require
finishing
steps which again generate asbestos
emissions.
These
include
sawing,
turning,
drilling
and
sanding,
each
producing
large
quantities
of asbestos-laden dust,
and some
clinging to the surface
of the items being worked upon,
again
becoming
a potential emission source.
A second major
use of asbestos fibers
is in the manufacture
of asbestos vinyl floor
tile and asbestos asphalt road paving com-
pounds.
Here
again,
emissions result from the manufacture
of these
products
and to
a lesser degree from the use and ultimate processing
3—438
and
fabrication.
Asbestos
papers
represent
a
great
variety
of
products used for roofing,
insulation,
linings, heat and chemical
resistant insulation for pipes and automotive exhaust insulation.
Pre—processing of asbestos
fibers
and the mixing of asbestos
paper ingredients constitute
an emission source.
Again,
the ulti-
mate cutting and processing represents
a further source
of asbestos
emissions
into the atmosphere.
Asbestos paint
and coating fillers
utilize
asbestos
“shorts”
recovered from the milling process
where
their
relative
indestructi-
bility increases
the density
or opaqueness of paint.
Where asbestos
bearing paint is used in the spraying operation,
the potential
for
emissions
is substantial.
Likewise,
the wearing
and aging of
the
paint uecomes an additional source of emissions.
Asbestos friction materials
and gaskets represent
a wide
use
of these minerals.
Emissions result from the fabrication, molding
and trimming of these products.
Asbestos
is also used in
the pro-
duction of textile products.
The
term “roving” refers
to the finished
textile product,
from which yarns
are produced.
Blended fibers are
carded in
machines
where
the
operation
is
essentially
open,
pre-
senting
a serious emission source due to the combing action of the
machine.
Both
the
production
of
this
product
and
its
ultimate
use
present substantial sources
of emission.
The
spraying
of
asbestos
for
insulation
Constitutes
one
of
the
widest
uses
of
the
product
arid,
undoubtedly,
one
with
the
greatest
danger potential,
not only
to the health of the workers involved but
to the public
at large.
Prepared asbestos cement slurry
is pumped to
the nozzle of
a gun
and sprayed directly
to
the surface,
or alterna-
tively
a dry mixture of asbestos cement
is pumped to the gun and
mixed with water during the spraying operation.
The material comprisinc
the asbestos insulation
is formed by combining
asbestos,
cement,
and
rock wool
in proportions of
30,
15
and
55,
respectively.
The
mineral most commonly used is amosite, possessing superior thermal
properties.
If color
is required,
crocidolite or chrystotile fibers
are used.
Among the unique properties associated with asbestos cement
insulation
are low thermal conductivity
and inflammability and high
strength,
together with good acoustic features,
low cost, easy thick-
ness control
and application.
Initial cause
of emissions from this
product results from dry mixing of the
soestos cement and mineral
wool components.
Care must
also be exercised during the storage
and transportation of the bag mixture to prevent further emissions.
At the construction site,
the bags are open and
the dry material
emptied into hoppers where further emissions
occur.
The most signi-
ficant source of emissions,
of course,
is in the spraying operation
itself,
High dust concentrations can be seen and measured at con-
struction sites utilizing asbestos spraying methods.
Our regulations
impose an outright ban on this activity and impose stringent house-
keeping
requirements
on
all
spraying
of
non-asbestos
fibrous
materials.
—
439
Additional emission of asbestos results from the use of
pre-formed
asbestos
sections
or
blocks
for
insulation
of
pipes
and
boilers,
and in the use of materials applied in
a wet or slurry
state.
Asbestos
cement
products
including
roofing
shingles,
building
boards
and
drain
pipes
have
sealed
surfaces
and
do
not
dust
easily.
However,
emissions may result from their cutting or breaking.
Other
asbestos products used in construction and industry are asbestos
paper, blankets,
rope
and sealing compounds.
Emissions resulting
from the use
of these products depend on the type
of material being
fabricated,
the amount and character of fabrication required, the
location and nature of
the
site and
the quantity çf
material
being
pro-
cessed.
Tightly bonded composites will have
less
potential for
emissions than those loosely bound.
See R.l16
and following testi-
mony
of Pundsack; Thompson,
Ex.
5, Asbestos
as an Urban Air Contam-
inant;
Ex.
4, Selikoff, Asbestos,
“Environment”, March,
1969.
Twenty-
seven industrial concerns
in Illinois manufacture products using
asbestos.
Exhibit
20, Harwood,
p.
56.
Asbestos products
are used
in virtually
all building construction
and utility installation.
A particularly obnoxious source of asbestos emission with
extreme difficulty
of control is the demolition of existing struc-
tures.
Asbestos insu1a~tionand products present in demolished struc-
tures generate substantial emissions into the atmosphere where control
is difficult and the impact on persons in the vicinity, both workers
and residents,
is extreme.
For years,
asbestos has been incorporated in building materials.
In some forms of insulation and wallboard,
the amount present is less
than 20
of
the total, but other materials consist principally
or
entirely
of asbestos.
When
a building is demolished,
areas
of
loosened asbestos
are open to
the ambient air
and fibers are emitted.
In general,
single—family residential structures contain relatively
small amounts
of asbestos insulation.
Demolition of industrial
and
commercial buildings that have been fireproofed with asbestos-containing
materials will prove to be
an emission source
in the future,
requiring
control measures.
Asbestos
is emitted into
the atmosphere from brake linings and
clutches.
While these are unquestionably substantial sources of as-
bestos emissions
in the ambient air, the character and potential of
these sources have not been sufficiently documented
to
a point where
we feel they
can properly be
the subject of regulatory action and
control
at the present time.
Harwood,
Ex.
20,
p.
22 through 28.
See Ex.
8 “Brake Lining Decomposition Products”, Lynch, Journal of
the Air Pollution Control Association, December
19,
1968.
Having described the principal sources of asbestos emissions
we next consider their pathological implications.
The Litton Report
states,
Ex.
3,
p.
40:
3
--
440
“Asbestos is an air pollutant which carries with
it
the
potential
for
national
or
worldwide
epidemic
of
lung
cancer
or
mesothelioma
of
the
pleura
or
pen—
toneum.
Asbestos bodies have been observed in random
autopsies
of
one-fourth
to
one-half
of
the
population
of
Pittsburgh,
Miami
and
San
Francisco
and
will
probably
be
found
in
the
people
of
every
large
city.
..
.the
effects
of
the
asbestos
being
inhaled
today
may
not
be
reflected
in
the
general
health
of
the
population
until
the
1990’s
or the next century.”
The objective of the regulations must be two-fold,
first,
to
protect
those
who
by
occupational
activity
or
physical
contiguity,
either to the asbestos
use or
the
asbestos
user
become
the
potential
victims of
this pollutant,
in other words, to protect
those with both
occupational
and environmental orientation;
and secondly,
to provide
measures that will protect the ambient air against an asbestos
build-up that will have adverse effect upon the general public
beyond those occupationally or environmentally orientated
at the source.
As stated by Thompson;
(Ex.
5),
“Because asbestos is virtually indestructible
and so
many of the asbestos containing products
are used
in towns,
the average urban dweller is theoretically exposed to the
inhalation
of asbestos fibers on
a residential basis,”
After reviewing the incidence of death among asbestos workers, ex-
posed to asbestos dust, over
a 20—year period,
Selikoff,
Ex.
4,
states:
“These experiences highlight one portion of the current
spectrum of asbestos disease.
It is now recognized that
direct occupational exposure to asbestos results in
a
hazard much more significant than formerly appreciated.
In
the last several years, however,
additional problems have
been recognized which add another dimension:
the possibility
that
the
utilization
of
asbestos
is
associated
with
a
much
wider
risk,
perhaps
one
of
the
community
at
large.
This
is
less well defined, much less well documented,
but because
of its potential importance,
of considerable concern.
It
is
in this context that our regulations must be structured.
The
onset
of
morbidity
and
lethal
diseases
have
been
attri-
buted
to asbestos inhalation and ingestion.
Asbestosis, pleural
calcification, lung
cancer,
and mesotheliomas
are known to result
from exposure to asbestos.
Surveys
of people living or working
near asbestos mines
and factories have revealed that many nonoccupa—
tional
cases of asbestosis and mesothelioma have occurred either
from asbestos in the polluted
air or from asbestos carried home on
the clothing of workers.
3— 441
The
fate
of.
the
asbestos
fiber
once
IL
is
inhaled
and
de-
posited
in
the
~ung
is
still
cuestionahile,
The
short
fibers,
less
than
.5
microns
in
length,
have
in
the
past
been
ignored,
probably
because
they
are
much
too
narrow
to
be
visible
under
a
light
micro—
scope.
The longer fibers
are encrusted in an iron-bearing protein
form termed’ashestos bodies’ which are more easily visible.
Amone
asbestos
workers, evidence
of
pulmonary
asbescosis,
also
known
as
ashes totic
pneum000niosis,
an
asbestos
induced
scar-
ring
of
the
lungs,
is
common.
This
condition
results
in
a
titfuso
fibrosis,usua~
an
toe
1o~ior
Lobes
o~ toe
Lun~
PL1iOO~L~
asbestosis
nas
neen called
a monosymptomatlc disease,
characterized
by
painful breathing and lung disorder.
See Nicholson statement,
Ex,
21, R.35
and
following.
Littnn Ex,
3,
p.
4
and following.
Asbestosis
usually
develops
after
lonu
exposure
to
high
concentrations
of
asbestos
dust,
the
risk
varyino
directly
~nth
toe
length
of
exposure
and
the
dust
concentration.
Following
continued
exposure
to
high
concentrations
of
dust,
asbestosis
may
develop
fully
in
7
to
9
years
and
may
cause
death
as
early
as
13
years
after
the
onset
of
exposure.
The
common
exposure
period
before
recogni-
tion
of
asbestosis
as
observed
among
asbestos
workers
is
20
to
40
years,
with
death
following
about
2
to
10
years
later.
Once
established,
asbestosis
progresses even
after the exposure
to dust
ceases:
illness
or
death
can
occur
long
after
exposure
to
concen-
trations
not
producing
inroeth ate
effects,
The
prolonged
latency
period
between
exposure
and
the
first
signs
of
ashestosis
makes
it difficult
to
establish
dose—time
rela-
tionships.
In
1946,
700
cases
of
asbestosis
were
found
in
Germany
among
a
total
of
approximately
8,000 employees
in the asbestos industry
125
cases
of
asbestosis
of
the
lung
in
X-ray
examinations
of
476 as-
bestos workers were found in one company in Finland,
The occurrence
of asbestosis in members of
this
worker
group
appears
to
rise
with the duration of the employment:
A morbidity of
80 percent
among English asbestos workers with
over
20
years
of
employment
has
been reported.
Selikoff
and others investigated 1,522 asbestos
insulation
workers
in
the
New
York—New
Jersey
metropolitan
area.
Among
392
i~~dividuals
examined
more
than
20
years
from
the
onset
of
exposure,
X—Ray
evidence
of
asbestosis
was
found
in
339.
In
half
of
these,
the
asbestosis
was
moderate
or
extensive.
In
individuals
with
less
than
20
years
of
exposure,
radiological
evidence
of
asbes-
tosis
was
less
frequent
and
when
present,
less
likely
to
be
extensive.
3
—
442
The
most
common
complication
of
asbestosis
is
cancer of the
loon.
However,
cancer
of
the
lung
aeparently
induced
by
asbestos
~cay
anpear
unaccompanied
by
asbestos
is.
The
association
of
lung
cancer
with
exposure
to
asbestos
dust
has been
the
subject
of
many
investigations
in
recent
years
and
extensively
documented
in
the
literature,
See
Ex,
3, Litton;
Ex,
19
Nat’l
Acad.
and
a
nnrrelati~n
between
asbestosis
and
lung
cancer
appears
definite.
It
is
recognized
that
cancer
of
the
lung
produced
by
asbestos
needs further study.
The
latent
period
between
exposure
and
evidence
of
carcinoma
nay
be
even
longer
than
for
asbestosis.
Little
is
known
about the
dose--time
relationship.
Cases
of
lung
cancer
have
been
observod
when
only
a
very
short
exposure
or
no
exposure
-to
asbestos
was
known.
Furthermore,
the
low
number
of
“asbestos
bodies”
ob-
served in
one-fourth
to
one-half
of
the
urban
population
may
be
sufficient
to
cause
cancer.
Because
the
long
“asbestos
bodies”
re-
main
in the
lungs,
a
person
who
has
inhaled
asbestos
may
carry
the
ootential
for
the
rest
of
his
life
to
develop
carcinoma
of
the
lung.
Moreover,
it
has
not
been
determined
whether
more
than
one
fiber
is
necessary
to
induce
a
malignant
tumor.
It
has
been
suggested
that
the
orobaibility
of
cancer
induction
is
proportional
to
the
number
of
asbestos
fibers,
number
of
susceptible
cells,
the
concentration
of
carcinogens
on
the
fibers,
and
the
time
from
exposure.
Why
asbestos
is
carcinogenic
is
not
clearly
understood.
At
least
three
hypotheses
have
been
advanced:
1.
That
the
fibers
act
as
a
physical
irritant
which
after
20
to
30
years
of
constant
irritation
induces
a
tumor.
2.
That
the
fibers
contain
small
amounts
of
carcinogens,
such
as benzo(a)eyrene,
nickel,
and chromium
which are
eluted
from
the
fibers
by
the
serum
in
the
lungs.
3.
That the fibers accumulate
in the lung
and are immobilized
as
“asbestos bodies” which disintegrate after
20
to 40
years.
The resulting
free particles
cause asbestosis
or carcinoma of the
lung.
Primary
tumors
of
the
pleura
and
peritoneum
are
so
rare
that
for years
they were considered
to be pathologic curiosities.
In
1960 the first large series of cases
of diffuse mesothelioma were
reported,
in South Africa.
In trying
to explain this mysterious
epidemic,
“asbestos bodies” were found in the lungs
of some of
these
patients.
An
association
with
exposure
to
the
Cape
of
Good
Hope asbestos
fields,
or
-the industrial
use of asbestos, was estab-
lished in
32 of
33 patients with histologically proved pleural meso—
thelioma.
The
majority
of these patients had not actually worked
with asbestos
but. had lived in the vicinity of the mines
and mills,
--
443
and
some
had
left
these
areas
of
exposure
as
young
children.
The
average
period
between
exposure
and
development
of
the
tumor
was
20
to
40
years
•
Later
studies
verified
this
interrelationship
between
asbestos
exposure
and
mesothelioma.
See
Litton
Report,
Ex
•
19,
p.
12; Nicholson, Ex.
21; Selikoff, Ex. 4.
In
an
attempt
to
determine
whether mesothelioma of
the
serosal
surfaces
was
related
in
any
way
to
asbestos
ax~osurein
the
United
States, Selikoff studied 307 consecutive deaths among asbestos in-
sulation
workers
in
the
Northeasten
United
States.
They
found
10
deaths
caused
by
four
pleural
and
six
peritoneal
mosotheliomas.
In addition, these workers had thigh death rate attributed to cancer
of
the
stomach,
colon,
and
rectum.
Of
the
307
deaths,
40.4
percent
were
attributed
to
cancer,
5.5
percent
to
asbestosis,
and
54.1
percent
to cther
causes
•
In
a
second
study,
the
investigators
re-
viewed
26
consecutive
autopsies
of
patients
with
asbestosis,
and
found
four
mesotheliomas
of
the
pleura
and
three
of
the
peritoneum.
Mesothelioma is
now
considered
a
frequent
cause of
death
among
asbestos
workers.
No
attempt
has
been
made
to
summarize
the
reports
of
mesothelioma,
since
they
appear
almost
weekly
in
the
current
liter-
ature.
So
far,
however,
there
appear
to
be
few
cases
among
the
gener-
al
population.
Selikoff reviewed 31,652 deaths among the general
population
of
over
1,048,183
in
the
United
States
and
found
only
three cases of mesothelioma.
Moreover, he points out that asbes-
tos
is
not
the
only
cause
of
mesothelioma;
it has also been produced
by
silica
and
polyurethane.
While
the
exact
cause
of
lung
cancer
or
pleural
periotoneal
nesothelioma
induced
by
asbestos
is
not
known,
air
pollution
by
other
pollutants
may
accelerate
the
morbidity.
One
form of
air
pollution
which
is
easily studied in individuals is smoking.
Seli-
koff recently studied the mortality of 370 asbestos insulation work-
ers
•
In
this
group,
24
men
died
of
lung
cancer
and
all
had
a
history
of
smoking.
See
Weiss,
Ex.
15,
“cigarette
Smoking,
Asbestos,
and
Pulmonary Fibrosis”, American Review of
Respiratory
Disease,
Vol.
104,
1971.
This rate was eight times greater than the expected mortality
rate,
with
age
and
smoking
habits
taken
into
account.
The
recent
finding
of
“asbestos
bodies”
in
one—fourth
to
one—
half
of
the
urban
population
has
added
new
impetus
to
the
examination
of asbestos as a general
air
pollutant.
~
~
body”
has
been defined as “an elongated
golden
or
reddish-brown
structure
usually
with
clubbed
ends.
The
shaft,
which
often
shows
a
segmented
or
beaded
appearance,
is
usually
straight,
but
sometimes
curvilinear
with
a
tendency
toward
symmetry.
Usually
it
is
from
3
to
5
microns
in
diameter
and
20
to
100 microns in length.
The coating contains iron demonstrable by
3—444
Perle~s
stain
(Prussian
blue
reaction)
,
and probably composed
of
ferritin or ferritin-like material. It may
cover the structure
commletely,
masking
the
central
fiber
from
direct
view,
or
may
be
incomplete
in
the
central
portion
of
the
shaft
or
in
the
interstices
of the body,
revealing
an expanse of naked
fiber.
There
is no doubt
that the “asbestos bodies” formed in the
lungs
of
the asbestos
workers
contain
asbestos,
and
it is probable
that
some
are
contained
in
those
found
in
the
lungs of the general
ponulation.
Evidence
that
persons
other
than
those
working
directly
with
asbestos
minerals
are
being exposed
to asbestos is of
several
types.
Asbestos
fibers
can
be
demonstrated
in
the
lungs
of
persons
not occutationally exposed.
In
a few geographic areas, pathologic
changes regarded
as
representing
a reaction to asbestos
such
as
pleural
calcification
have
been
found
in
populations
with
no
history
of
occupational
exposure.
Asbestos
fibers
have
been
demonstrated
in
ambient
air.
Structures
that
appear
to be
fibers coated with
a pigmented
material
were
described
in
lung
tissue
as
early
as
1907.
These
structures
were
actually
fibers
c~ted
with
hemosiderin.
Because
those who work with asbestos
exhibit
them
a
few
months
after
starting
work,
it
was
recognized
that
they
were
evidence
of
exposure,
but
not
of
asbestosis.
The
term
“asbestos
body”
came
to
be
the
preferred
designation.
As
long
as
the
coated
fibers
were
found
in
persons
known
to
have
been
occupationally
exposed
to
asbestos,
the
identity
of
the
central fiber was
seldom
questioned,
although
from
time
to
time
similar
objects
were
found
in
persons
with
no
known
exposure
to
asbestos.
Identification
of
-the
core
fibers
has
proved
to
be
a
formidable
technical
task.
Without
fiber—ny-fiber
analysis,
all
that can be
said
is that coated fibers resembling those
in
asbestos
workers
are
present in most persons
in
our
urban
centers.
Stripping
the
coating
and,
analyzing the cores by various techniques
can sometimes
demon-
strate that
the
cores
are
asbestos,
but
the
process
is tediot~sand
often inconclusive.
A more
appropriate
term
is
“ferrugineous
body”,
Attention
is
now
being
directed
toward
study,
not
of
the
ferruginous
bodies
alone,
but
of
the
total
fiber
content
of
the
lungs,
whether
such
fibers
are
coated
or
uncoated.
Evidence
is
strong
that
most
human
lungs
harbor
thousands
or
millions
of
fibers.
some
of
these
are
chrysotile
asbestos,
and
other
types
oa
asbestos
minerals
are
probably
there.
In
most
persons
not
occuoationallv exposea
to
asbestos,
the
numbers
of
fibers
are
rela—
tive.1~
small,
compared
with
the
numbers
found
in
the
occupationally
exoosed.
Tte sos tematic
application
of
quantitative
techniques~
3
—445
measuring both coated and uncoated
fibers,
is needed to define
a
gradient of accumulated fibers
for correlation with incidence
of
disease,
on the one hand,
and history of environmental exoosure,
on
the other.
Although there appears
no doubt that asbestos
fibers
are
sent in many human
lungs,
there are sources
of airborne fibers
other than asbestos.
Some
are probably derived from the hurninc
of leaves
and’ plant products,
such
as paper, wood
and coal.
Man-
made
(mostly vitreous)
fibers have also been identified in the
sediment isolated from~.human
lungs.
Talc,
often used oenerously
as
a dusting powder, may contain
a significant amount of trenolite
asbestos
fibers.
Information
is
sparse
concerning
possible
increase
of
fibers
in lungs with increasing use
of asbestos
and concerning the exis-
tence
of
significant
differences
between
urban
and
rural
populations.
Selikeff
and
Hammond
compared
lung
tissues
obtained
in
1934
and
1967
ano
found
no
sign’
ficant
_ncrease
in
tie
r~
rrinn
coitainin~
ferruginous
bodies.
This
suoc’ested
that,
despite increasing use of
asbestos
in New York
City between
1934
and 1967.
fibers of
a tyoe
producing
ferruginous bodies had not been increasino
at
a correspond--
ing
rate.
Other commentators,
however,
have ~ot~d. an incrense
over
each
decade
in
asbestos
bodies
in
song los
ci
i~enos
iro~”oar—
sons who died in London
in
1936,
1946,
1956
and
1966.
A review of the literature related to ol-aucal calcifi cation
and
asbestos
exposure
strongly suggests
an
associctaon bet-nato
pleural calcification and nonoccunational
exnosures
to asbostos.
See Nat’l. Acad.,
Ex.
19,
c.
14.
Industrial experience has shown that orolongod inhalation
of
asbestos
can
increase
the
risk
of necolastic
(tumor nroiucin’~)
disease.
Examination of lung
tissue has made
it
apparent
that
a
much
larger
proportion
of
the
general
public
nas
inhaled:
and
.cataincd
asbestos
fibers
than had formerly been realized;
in
fact,
most
-acban
dwellers
have
some
such
fibers
in
their boos.
The basic
issue
is
whether the general public,
as well
as persons working near cocoon--
tional
sources,
living
in the
households
of asbestos workers,
living in the neighborhoods of asbestos
olants,
or having occasional
random exposures, have
a detectably increased risk of mali’maanm:
or other disease because of airborne asbestos.
What
information
there
is
to
answer
these
questions
comes
either
from
direct
epidemio-
logic studies of groups with various levels of nonoccunational
0000-
sure
or
by
extrapolation
from
the
experience
of industrial
~o~u1~titnS
with
direct
or
indirect
asbestos
exposures.
3
—
448
Two general indices
of asbestos exposure
are available
for
use
in direct epidemiologic studies
of
groups not known to be
occupationally exposed to asbestos.
The first
is
based
on
knowledge
of
each
member’s
place
of
work
and
place
of residence. Because of
the long latent periods
of
asbestos-related
disease,
this
knowledge
must cover each person’s whole lifetime.
The second is
a quantita-
tive estimate of each member’s lung content
of asbestos fibers.
There
are
few such direct epidemiologic studies,
and they are
inade-
quate to answer the questions at issue.
Of
42
persons
with
mesotheliomas
reported
in Pennsylvania,
10
had
worked
in
asbestos
olants,
8
lived
or
worked
close
to
an
asbes-
tos
industry,
and
3
were
members
of
families
that
included
asbestos
workers;
in
11,
no history of exposure could be obtained, and the
re-
maining
10
had
questionable
random
exposures.
On
165
fatal
malignant
mesotheliomas
known
to
pathologists
in Canada
between
1959
and
1968,
an association was
confirmed
with
occupational
exposure
to
asbestos,
but
suggests
that
the
excess
was
in
the
manufacture
and
industrial
application
of
asbestos,
rather
than
in
mining
and
milling,
It
is
apparent
that
no
quantitative
conclusions
were
possible
from
these
studies,
which
present
serious
methodologic
problems
to
the
epidemiologist.
They
suggest
a
risk
in
household contacts and
in
residence
in
the
immediate
neighborhood
of
asbestos
plants.
There
appear
to
be
different
levels
of
risk
in
different
types
of
occupa-
tional
exposures,
and
some
of
these
may
be
reflected
in
corresponding
household
and
neighborhood
experience.
Another
source
of
evidence
of
the
relative
risks
associated
with
iithaling
moderate
or
small
numbers
of
asbestos
fibers
is
the
exper-
ience
of
persons
who
have
had
occupational
exposures
below
those
known
to
he
definitely
hazardous,
The
maximal
airborne
fiber
con-
centrations
recommended
for
prevention
of
asbestosis
are
much
higher
than
any
likely
to
be
encountered
in
nonoccupational
situations,
Occupation—related
asbestosis
can
be
effectively
controlled
with
air-
borne fiber concentrations much higher than are likely to be encoun-
tered in non-occupational situations.
It is important to determine
whether
workers
whose
exposures
have
been
reduced
to
levels
that
prevent
or
greatly
delay
asbestosis,
as
well
as
others
whose
expo-
sures
are
indirect,
have
a
lower
risk
of
lung
cancer
than
those
with
higher
and
more
direct
exposures.
Most
series
of
case
reports
of
mesothelioma
include
some
persons
who
have
worked
in
the
construction
or
shipbuilding
industries,
but
in
trades
not
involving
direct
contact
with
asbestos,
~Suc)a
persons
as
plumbers,
electricians,
and
metal
workers
often
have
more
ferru—
ginous
bodies
in
their
lungs
than
do
white-collar
workers,
A
study
of
occupational
groups
in
California
revealed
an
excess
of
deaths
from lung cancer in
insulation-workers,
but found no excess lung—
cancer deaths in
other construction trades.
There may be
a definable
gradient
of
effect
within
the
construction
trades,
More
thorough
studies
of
groups
with
indirect
exposures
are
certainly
needed,
3
—
447
The mbrtality experience
of those who are di~r~ctl~
aI3d in~jre~t-
ly exposed
to asbestos
in their employment is
not- directly aenlicable
to
the general public who have had moderate or
slight
exposures
from ambient
air.
The
evidence suggests
a gradient of effect
from direct occupational,
to indirect occupational,
to family and
neighborhood situations,
in all of which dust concentrations are
probably high by comparison with most community
air.
This suggests
that there may be levels of asbestos exposure that will
not be asso-
ciated with
any detectable
risk.
What those levels are
is
not known.
However,
if we eliminate the known occupational, household and
neighborhood exposures, we drastically decrease th~potential
for
this risk.
For this reason our regulations must be directed to
emission sources and limitations imposed at the origin as distin-
guished from an effort to establish air ~quality standards
as we have
done with regard to other air pollutants of demonstrated adverse
health effects.
Having considered the health impact inherent in asbestos emissions,
we no~examine the avai1a~1emeasurement and abatement procedures.
Sampling of asbestos fiber seeks to obtain a representative
sample of the tota~air ufass in sufficient quantity to make quantita-
tive assessments statistically significant.
Methods employed in
asbestos sampling and the possible sources of error are discussed
at length in Ex.
20, Harwood,
p.
42 and following.
Of the several techniques available
for emission sampling, the
membrane filter recommended by
the U.
S.
Public HealtXi Service,
has
become
the standard technique for environmental asbestos emission
sampling.
Air is drawn through
a cellulose membrane filter where the
particles
are entrained.
Although the effective pore size of the
filter
(0.45 microns to 0.8 microns)
is larger than the diameter of
many
of the asbestos
fibers,
the surface charge properties
of the
filter and the asbestos fibers,
plus
the circuitous path through the
filter,
result in collection
of virtually all of the particles and
fibers to which the filter is exposed.
The collected fibers must be analyzed.
This may be accomplished
by using
a microscopic, photographic or electronic technique
to count
the fibers resulting from a known volume of air.
The fibers which
are counted are seen at
a given magnification and the number will
vary.
The standard practice
in industrial hygiene is to use
a
phase contrast microscope at anagnification of X430.
The fibers
counted are those having
a length of greater than
5 microns with
the
ratio of length to breadth at least
3:1.
The
use of an electron microscope would allow all the parti-
cles to be counted,
However,
the expense,
time and expertise neces-
3
—
448
sary
to
count
all
the
particles
makes
this
procedure
impractical.
In understanding control techniques
and their efficiencies,
it
is important not to confuse efficiencies quoted on
a weight
basis with those based on
a particle count.
Considering
efficiency
based
on
a
weight
basis,
it is relatively easy to get
a very high efficiency with parti-
cles whose size is in excess of
5 microns with
a variety of con-
trol devices.
However,
the efficiency does drop off considerably
with decrease
of particle size.
Dr. Harwood,
in his
study,
considers what
a collection
efficiency
as high as 99.999
(the percentage of the total weight
of the particulate matter which will be collected by the filter)
actually means in terms of
the
number
qf fibers collected.
(Ex.20
,
p.47
)
.
He concludes that 10’ fibers actually will pass
through the collecting filter for every
1 gram of material impinging
upon
it.
This is
a situation not frequently brought out, but is very
significant when exposure levels are monitored in terms
of fibers
per cubic centimeter.
Thus, quoting of efficiency in terms of mass
efficiency is
a statement that tends
to be deceptive.
It bears no
obvious
relation to the number of fibers being emitted.
However, based on tests which actually measure
the number of
fibers being emitted, it would seem that both fabric filters and
high efficiency wet scrubbers are capable of reducing the fiber
counts to acceptable levels.
British experience
is that 0.2
f/cc
is routine and Johns Manville finds that
1 f/cc is an acceptable
value when the results
are averaged over
a time period.
We adopt the two fibers per cubic centimeter and the over
five
micron standards becaoise
of the facility
of both abatement
and measure-
ment utilizing these numbers
and because they furnish
a sound indi-
cation of asbestos content in the air.
However,
recognition that
particles
of smal1er~size may have adverse health consequences of
equal
or greater magnitude will require the Board to review this
subject periodically
in consideration of the available measurement
technology.
See Ex.
6, Lynch, Ayer and Johnson,
“The Interrelation-
ships
of Selected Asbestos Exposure Indices,”American Industrial Hy-
giene Association Journal,
September—October,
1970,
p.
598.
(The
direct index of asbestos fiber
exposure
proved
to
be
the
concentra-
tion
of
fibers longer than
5
microns.
See
Ex.
27,
Edwards
and
Lynch,
“The
Method
Used
by
the
U.
S.
Public
Health
Service
for
Enumera-
tion
of
Asbestos
Dust
on
Membrane
Filters,”
U.
S.
Department
of
HEW.
3
—
449
Consideration
must
be
given
to
available
control
techniques,
the
fabrication
and
use
of
asbestos
containing
products
and
exposure
resulting
from
activities
involving
asbestos
emission
potential.
Because of the demonstrated alternatives
to asbestos spraying,
our regulations will flatly outlaw this activity.
Spraying of
non—asbestos materials are permitted subject to stringent protec-
tive measures.
Air ventilation systems can be employed
to mjnimize emission
during the mixing of fibrous fireproofing and insulation materials.
Hoods
can be provided at bag-opening and emptying
areas.
The mixing
area,
if
not
totally
enclosed,
should
be
ventilated.
Conveying
equipment,
to
and
from
the
mixer,
can
be
enclosed,
Bagging
of
the
mixed material should be done under suction hoods.
On-site controls needed include enclosing the area to be sprayed
and employing good housekeeping procedures both before and following
the spray operation.
The filling of the spray machine hopper must
be
done carefully to minimize dust.
When the machine
is not
in use,
the hopper should be cov~redto prevent the material from being
blown about.
Several states
and manufacturing
associations have published
guidelines for emission control.
The
recommendations
include
the
following
1.
All areas used
for opening bags containing fibrous
insulating materials
and charging of hoppers should
be enclosed.
Empty bags should be properly disposed
of.
2.
Floor
areas
should
be
swept
broom
clean
before
spray--
ing
operations
begin.
All
unnecessary
object~~n
the
spray
area
should
be
removed
or
covered
with
plastic
or
plastic
coated
tarpaulins.
3.
The
entire
area
to
be
sprayed
should
be
enclosed
with
plastic or plastic coated tarpaulins.
An enclosure
will be considered satisfactory only if visible
insulating material cannot escape from the closure.
4.
Fibrous—containing material that
falls
to the floor
should
be
swept
up
immediately
and
placed
in
approved
disposable
containers.
5.
When spraying is completed in an area,
the entire
work
area and the materials used to form the enclosure
should be thoroughly vacuumed.
The vacuum cleaner
should contain
a
strong,
single—service,
disposal inner
bag which shall be removed from the vacuum cleaner and
sealed.
Disposal is the same as for other bagged
waste
materials.
3
—
450
6.
Any
plenum
or other structure coated with asbestos-
containing
insulation
and
intended for circulation
of
air in
the
building
must be thoroughly cleaned
of
debris
and
waste.
Fibrous
insulation
in
a
duct
or
plenum
must
be
coated
with
a
sealer
to
preclude
erosion
of
the
insulation
by
circulating
air.
Our
regulations
embody
the
essential
features
of
these
suggestions
-
Asbestos emissions
are likely in any process in which asbestos
fiber is handled or asbestos-containing materials are
cut, drilled,
or trimmed.
The quantity
of asbestos dust generated by these oper-
ations
can be quite large.
Since it is impractical to completely
seal
a
factory
or
a
work
area,
industry
has
adopted
an
arrest—at—
the-source
technique
for
capturing
this
dust
utilizing
a
complex
ventilation system comprised of capture hoods,
ductwork,
fans and
filters.
Benefits received from this system include:
1.
Reduced atmospheric emission when plant is open
to
ambient
conditions
(i.e.,
doors
and
windows
open).
2.
Reduced external emission from fibers being carried
outside
on
work
clothing
and
manufactured
products.
3.
Greater efficiency in plant operation because of reduced
internal housekeeping
chores (vacuuming,
etc.)
4.
Better personnel attitudes.
The ventilation system
may eliminate the need for personal respirator units
which limit efficiency and are generally disliked by
workers.
The
air ventilation system is
an integral part
of the emi~sion
control
program
and
the
components
of
various
systems
in
operation
will
be
considered.
Two
types of ventilation systems
are employed for dust emission
control;
low volume,
high velocity;
and high volume,
low velçcity.
Each
requires
a
specific
type
of
hood
design.
The low volume, high velocity systems induce an extremely
high captive air velocity,
10,000 to 12,000 ft/mm,,
at the dust
source.
The air volume, however, averages only 10—250
cfni.
With
this
system
it
is
essential
that
the
feed
particles
be
carried
by
the
air stream.
The entrainment force must exceed the gravitational or
projectional force.
Low velocity, high volume air ventilation systems,
on the
other
hand,
are utilized
for operations where localized capture is
not possible.
For such hoods
to be effective,
the air velocity
to the ducted area must be at least 150
ft/mm
and should be such
that the
air flow direction
is always toward the collection
system.
A considerable amount of ductwork is required for a large
plant having
a central collection point.
Circular ducts, having
no sharp bends, are recommended,
Inspection ports should be
provided
near
bends.
Several types
of collectors have been ntilized by
the asbestos
industry
for dust control.
Baghouses represent the most frequently
used
filtering
system.
Wet
scrubbers
are
also
used.
Cyclone
pre—
cipitators
may
be
used
as
primary
collectors
preceding
baghouse
filters.
Electrostatic precipitators
tried by
the asbestos industry
have several deficiencies.
Asbestos is
an insulator and builds
upon the electrodes reducing efficiency.
Installation
costs are
higher than for baghouses.
An electrical failure would remove all
emission control.
The most commonly used filter system is the fabric filter,
This device is found in
a wide variety of forms from highly sophis-
ticated systems containing thousands
of bags
to crude devices con-
taining homemade burlap bags.
The baghouse
is
compartmentalized
to allow continuous operation by alternately cutting off sections
for cleaning while other sections
continue their dust removal func-
tion.
The bags are “cleaned” by
a mechanical shaking action,
either by
a shaking floor or, more commonly, by
a shaking support.
More elaborate cleaning systems such
as reverse cycle
air jets
or sonic systems have not been considered worth the extra complica-
tion.
The baghouse unit is frequently located outside the factory
building to conserve space.
Usually the filtered air
is exhausted
-to
the atmosphere.
In some cases
it is returned to the factory
to
conserve heat.
This air contains
some asbestos
fibers since no
control technique
is considered to be
100
efficient.
Waste products
collected in the baghouse hoppper are removed b~ihelical screw con-
veyor.
Design of the hopper emptying mechanism should provide
as
foolproof an operation
as
possible..
Severe pollution can arise
if
the
mechanism
is opene~ for repair.
Other collection devices used either in combination with fabric
filters or alone
are various types
of cyclone,separators.
Low efficiency cyclones
are used in
the asbestos industry
as first stage separators preceding fabric filters.
They are use-
ful when the waste product
is reusable
and there is
a considerable
quantity present.
Thus,
the load on the fabric filter
is relieved,
3
—
452
Further,
the removal of heavy abrasive waste material will prolong
the
life
of
the
filter
bag.
High efficiency yclones are generally employed in multiple
units.
They
are used where high efficiency
is required
and where no
use is made of backup fabric filters.
Wet
cyclones
are
employed
as
emission
control
devices
in
some
special instances where wet processes are used for production of
asbestos
products.
Although
generally
not
as
efficient
as
bag
filters,
they eliminate
the problem of filter blockage caused by
condensation.
The
fans which provide the
air movement through the
dust collec-
tion system may be mounted either upstream or downstream of the filter
system,
the
most
common
arrangement
being
downstream.
This
places
the
ventilation
system
under
a
negative
pressure
assuring
that
ambient
air will be drawn into the system in case
of leaks, rather than
dust
and fibers being exhausted to the atmosphere.
All
asbestos
product
manufacturers
are
faced
with
the
problems
of
storage
and
transportation
of
bagged
asbestos
fibers.
Emission
controls
for these operations depends
to
a great extent upon the
conscientiousness
of
the
individual
user.
Manufacturers
should provide clearly defined,
clean,
dry storage
space for the bags where they are protected from accidental damage.
A rotation system should be employed to ensure that older bags
are
used first.
Damaged bags should be placed in larger slipover bags
and resealed.
Small
tears in bags should be patched with tape.
Jute bags are permeable
and will allow fiber emission.
Kraft paper bags
are
liable
to tearing when handled roughly.
The
best compromise at this time seems
to be bags
of coated, woven
polyolefin.
Bag storage and the bag opening areas should be
as close
as
practical.
Fork-lift
trucks
are
usually
employed
to
transport
the
bags
between
these
areas.
The
route
used
by
the
trucks
should
be smooth surfaced
and
free of obstructions which might cause damage
to
the
bags.
The bags should be opened in
a hooded area using
a sharp knife
to slit the bag.
Pressure packed fibers will hold together as
a
unit
and
can
be
slipped
into
an
enclosed
conveying
system
where
they
are
transported
to
a
fiber
opener
(willow
or
fluffer)
.
All
conveyor systems transporting
asbestos fibers or mixtures of asbestos
and
other
materials
must
be
completely
enclosed.
3--453
The
emptied
bags
also present an emission source,
Care must
be
taken
to dispose
of
them.
Since
there
are
few
manufacturing
processes
which
will accept paper bags as part of the
process,
asbestos
paper being an exception,
they are usually bundled into large poly-
ethylene bags
and taken to dumps
for disposal.
Plastic shipping bags
can be similarly utilized
in some manufacturing processes
as
the floor
-tile industry,
for example.
A possible source of emission from manufacturing processes
is
the transport of fibers outside by the workers themselves.
The
control of this source
of emission to date has
not been very satis-
factory.
At best, booths
are provided where workers may clean
fibers
from
their
clothing.
The
booths
are
equipped
with
extraction
fans
in
th~ceiling and
a flexible pressure hose.
Suction hoses would be
preferable.
Separate lockers
for work and street clothing
is suggested.
See Ex.
9,
Cralley,
“Identification and Control
of Asbestos Exposures”,
American Industrial Hygiene Association Journal, February,
1971,
p.
82.
Ex.
18,
“Recommendations for Handling Asbestos”, Engineering
Equipment User Assa.,
No.
33,
Rev.
1971.
Ex.
13,
“Recommended Health
Safety Practices”,
National Insulation Manufacturers Association,
Inc.
Demolition
and waste disposal are likely to be emission sources
if
appreciable
amounts
of
asbestos
are
used
in
construction,
unless
operational
procedures
are
strictly
controlled.
Isolation,
enclosure,
and wetting down are useful.
Caution must be observed not to demolish
during high winds and
to
keep
sludge
from
drying
out
and
becoming
air-
borne later through natural forces
and from being introduced into
sources
of
drinking
water.
The subject of disposal of asbestos waste must be examined.
Re-
cycling is possible if
a plant has
a filter-ventilation system.
But
the effectiveness
of recycling varies with
the kind of processing.
If
a
product
such
as
water
pipes
is
m~de in
which
asbestos
is
mixed
with
cement,
a
chemical
reaction
occurs
making
re—use
of
much
waste
imprac-
tical or impossible.
If asbestos paper is produced, much airborne
fiber can be collected and re—used.
However, virtually all manufacturing
of asbestos products
can involve some recycling.
The dust collected in the filters,
the
“short fibers”,
can be re-
used in the manufacturing
of transite pipe.
This pipe contains mostly
long fibers used for their strength
and thus,
only
a limited amount of
the
“shorts”
can be mixed in.
Recycling
is especially
feasible
for
large companies which manufacture transite pipe
as well
as other asbes-
tos products.
In this
case, recycling
is profitable as it involves
only cleaning the filters and transporting the “shorts”
in the
area of
the plant or to the division of the company which manufactures transite,
Recycling does not appear to be relied upon
as much in plants
which do not produce transite.
In such
case,
the company
3
—
454
would
have
to
sell
its
short
fibers
•
We
do
not
know
how
great
the
demand
is
•
Nor
do
we
know
the
percentage
of
collected
fibers
which
can
be
recycled
under
optimal
economic
conditions.
Johns—Manville
in
Waukegan
claims
to
re-use
“most”
of
the
filtered
short
fibers.
But it
manufactures
transite,
brake
linings,
sheet
packing
and
gaskets,
which
facilitates
and
makes
cheaper
the
use
of
captured
fibers
in
transite
production.
Generally,
the
asbestos
collected
through
the
filters
or
swept
up
is
disposed
into
plastic
bags.
A special disposal procedure is
followed
by
some
manufacturers
of
asbestos
paper
products.
Water
is
used
in
the
production,
which
picks
up
asbestos
fibers
and
is
then
drained
off
into
settling
ponds.
The
heavy
material
settles
out
and
the
water
is
then
channeled
back
to
the
plant
for
re-use.
The
sludge
is
at
the
bottom
of
the
pond
and
is
shovelled
up
and
dumped.
The
material
is
not
buried.
We
do
not
know
if
any
factory
directly
or
eventually
discharges
this
water
into
natural
water
flows
or
sewage
systems,
which
could
pose
a
considerable
hazard.
The
Johns-Nanville
Waukegan
plant
uses
a
pond
system,
but
the water
is
recycled.
While
our
regulations
are
enacted
in
the
context
of
other
govern-
mental
controls
of
asbestos,
they
necessarily
go
beyond
these
regula-
tions to deal with significant emission sources not covered elsewhere.
The
Federal
Environmental
Protection
Agency
proposed
asbestos
standards
on
December
7,
1971,
under
its authority to regulate
hazardous
air
pollutants
(40
CFR,
Part
6).
All
emission
sources
which exist in Illinois
and
which are proposed for coverage by the
Federal
Environmental
Protection
Agency
are
covered
by today’s
regulation.
Also,
our
regulation
covers
waste
disposal
and
water
pollution;
imposes
procedural
safeguards
for
construction
and
demolition;
and
sets
a
numerical
emission
standard
in
addition
to
a
“no
visible
emission”
standard
for
manufacturing
emissions
beyond
the
plant.
The
Illinois
Department
of
Labor
adopted
the
recommended
safety
standard
of
the
American
Conference
of
Governmental—Industrial
Hygienists
for
“in-plant”
air.
The
regulation
we
adopt
today does
not
control
the
levels
of
asbestos
inside
a
plant,
largely
an occu-
pational
hazard
beyond
our
jurisdiction.
Insofar
as
this
Board’s
regulation
affects
what
transpires
inside
a
plant
or
on
a
construc-
tion
site,
the
impact
is
merely
incidental
to
the
relationship
be-
tween
certain
“in-plant”
activity
and
a
significant
hazard
of
air
pollution
beyond
the site
of
such
activity.
For
example,
Sec.
201(c)
requires
that
facilities
be
provided
at
the
work
site
to
prevent
the
removal
of
visible
amounts
of
asbes-
tos
from
the
site
on
the
clothing
of
employees.
The
evidence
shows
that
human
transport
of
asbestos
fiber
is
a
health
hazard
to
those
coming
into
contact
with
asbestos
workers
beyond
the
confines
of
the job.
3—416
The
Illinois
Department
of
Labor
also adopted procedures
for
enclosure
and
cleaning
of
construction
sites,
on
which
asbestos
is
sprayed.
These procedures were intended
to protect the health of
workers on the site,
although their effect,
if pursued, would be
to
reduce emissions to the ambient air.
The record shows that such
procedures
are cumbersome, seldom obeyed to the letter, difficult to
enforce and insufficient when obeyed to protect the public beyond
a construction site,
Hence, we have banned asbestos spraying.
Again,
the impact which
this Board’s decision exerts on the actions
of another state agency
is made necessary by
our mandate to protect
all members of
the public from air pollution.
A similar ban on spray asbestos has
already been taken by the
Cities of Chicago
(effective January
1, .1972),
and New York,
and is
being considered by several other cities.
In consideration of the foregoing factors,
the Board submits
a comprehensive regulation for asbestos controls.
To this end,
the
regulations
identify
the
significant
contributors
of
asbestos
as
the commercial use of asbestos
in construction work;
the demolition
of asbestos-containing structures;
the manufacturing and processing
of asbestos—containing pi’oducts;
the transportation of certain asbes-
tos-containing products;
and
the
disposal of asbestos—containing waste.
The use of asbestos
in brakes, while originally included
as
a sub-
ject of control, will be deferred
for the time being.
Part II of the regulations
imposes several general require-
ments upon all commercial construction, repair,
alteration, demoli-
tion, manufacturing or processing activity
from which asbestos
fiber
is
discharged
into
the
ambient
air.
The
persons
responsible
for
manufacturing activity must obtain
a permit from the Environmental
Protection Agency.
The permit system will serve
to produce the
advanced assurance of compliance with the applicable control regula-
tions
and will thus reduce the cost and burden of in-the-field en-
forcement.
In addition,
these commercial activities must provide
facilities
to prevent the removal of asbestos fibers from the site
of such activity on the clothing of employees.
Indeed,
this poses
a rather new concept of air pollution control.
Those who have died
from lung ailments induced by long,
close association to an asbestos
worker may be powerful proof of the need for novelty.
Finally,
the Regulation would provide for careful waste disposal
procedures,
as
wind—blown
refuse
heaps
and
scrap
piles
contribute
to
the
volume
of
asbestos fiber in our air.
The simple steps
for
control
eliminate
any
excuse
for
such
dangerously
sloppy
housework.
3
—
456
In
our
final
draft,
the
permit
requirement
of
Part
II
has
been
restricted
to
manufacturing
emission
sources,
This
is
in
accord with
the Agency testimony that presently it has
inadequate
staff
to handle the permit load created by
a blanket requirement.
All
manufacturers
of
asbestos
products
must.
obtain
a
permit
by
June
30,
1972.
Part
III
prohibits
the
spraying
of
asbestos-containing
insula-
tion
and
fireoroofing.
Hxperience
has
indicated
that
procedural
safeguards
are
inadequate
and
their
enforcement
is
an
overtaxing
burden.
Procedural safeguards de3igned
to
reduce
fiber
emissions
would
be
required
to
spray
non—asbestos
insulation.
The
biological
effects
of
these
fibers
is
unknown.
Prudence
would
seem
to
dictate
reasonable
efforts
to
soften
the
potential
future
blow
from
spray
fiber
aspiring
to
asbestos’
status.
Part
III
requires
that
various
asbestos—related activities
at construction sites be
done
within
an
enclosure.
It
would
also
require that asbestos construction products be so installed
as
to
preclude the emission of fiber into
the circulating air.
In the interest of efficient enforcement the numerous restric-
tions
on the
spraying
of
non-asbestos
fibrous
material
have
been
reduced to requirements
for enclosure and
for vacuuming.
Also this
section has been changed to make clear that these safeguards
are
required
only
when
spraying
of
non—asbestos
materials
occurs
in
an
area
open
to
the
atmosphere.
This
“open to the atmosphere” modifica-
tion
has
also
been
added
to
the
section
controlling
the
cutting,
trimming,
fitting
or
stripping
of
asbestos-containing
materials
at
a
construction
site.
Part
III
now
contains
a
“no
visible
emission”
standard
which
must
be
met
regardless
of
adherence
to
the
required
procedural
safeguards.
This
should
permit
easier
enforcement
and
tend
to
insure
greater
compliance
with
the
safeguards.
The
original
proposal
contained
two
regulations
controlling
the general application of asbestos-containing materials
and the
application
of
non-asbestos
materials
in
air
ducts
or
plenums.
This
has
been
altered
to
require
that
only
asbestos-containing
mater-
ials,
used in any construction work, be
so installed as to preclude
emission
of
the
fiber
to
the
circulating
air.
There
is
little
medical data available to prove
or disprove the toxic effects
of the
multitude
of non-fibrous construction material,
although one such
product,
fiberglass,
would
appear
to
be
biologically
inert.
The
Board
prefers
to
act
on
the
safe
side
of
health
in
regard
to
spray-
ing
operations,
which
can
emit
large
quantities
of fiber
if
uncon-
trolled.
In any event,
such uncontrolled emissions constitute
a
nuisance dust and could be controlled on that basis
alone.
These
reasons
do not
apply with equal force to the non—spray application
of non-asbestos materials in construction.
3—457
Part IV expresses,
ironically, what may be
a key reason
for
banning
spray
asbestos.
It
would
require
that
procedural
safe-
guards
be
pursued
in
order
to
demolish
a
structure
whose
destruction
would
otherwise
expose
members
of
the
public
to
asbestos
fiber.
Clouds
of
dust
are
often
raised
by
demolition
work,
The
fact
that
great
numbers
of
persons
may
be
exposed
to
this
dust
in
urban
areas
and
that
the
post-war
generation
of
high-rises
were
the
first
buildings
to use asbestos insulation extensively
speak in favor of such regula-
tion.
Part
IV
is
intended
to
require
an
enclosure only when neces-
sary
to
prevent
dispersion
of
dust
during
demolition
and
only
an
enclosure
which
is
reasonably
compatible
with the structure
to
he demolished.
in
some
cases,
total
enclosure
can
he feasibly achieved,
With other structures,
a ground level enclosure may he the
limit of
compatibility.
Part
V,
controlling
manufacturing
sources,
is
changed
to
re-
quire
an
emission
standard
of
two
fibers
per
cubic
centimeter
and
no visible emissions.
While some testimony
indicated
the
difficulty
in measuring compliance with
a numerical emission standard,
overall,
the evidence establishes both
the need
(protection against the great
proportion of invisible
fiber)
and the ease
of measurement
of such
a criterion.
A
“no visible emission” standard has been added to
the numerical standard to simplify enforcement against exceptionally
dirty
emission
sources.
A
grace
period,
until June
30,
1972, has been
added to permit acquisition of the necessary control equipment to
attain
the
emission
standard,
References
are made to the method to be used
in collecting and
counting
emission
samples.
The sampling method is that generally
used
in
sampling particulate emissions,
The counting method
is
that
reliably
used
by
the
U.
S.
Public
Health
Service.
A
requirement
has
been
added,
at
the
Environmental
Protection
Agency’s suggestion,
to channel
all
asbestos
emissions
inside
the
plant
through control equipment and to exhaust such emissions through
points where samples can be
taken.
This is
intended to prevent vent-
ing through windows or doors or other avenues
of escape on which
sampling
cannot
be
adequately
performed.
The
Agency
is,
also
given
the
power
to inspect manufacturing premises
at reasonable times to
determine compliance.
Also,
the manufacturer must engage in monitor-
ing and reporting.
The latter two additions are
in keeping with
the
Board’s
practice
in
most
areas
of
regulation.
The
waste
water
discharge
provision
now
requires
no
discharge
of
process
water
to
which
the
manufacturer
has
added
asbestos
unless
best
available
treatment
technology
is
first
utilized.
3
--
458
A
“no
visible
emission”
standard
has
been
added
to
the
trans-
portation
regulation.
The emission standard would measure
only
fibers longer than
five microns.
The justifica.~ion for
this seems
to
be
the
adminis
trative
convenience
of
avoiding
difficulties
in
measuring
fibers
from. 5
to
five
microns
in
length.
Some medical evidence has in-
dicated
that
the
very
small
fibers
may
be
the
most
dangerous.
The
Board
will
continue
to
examine
the
medical
implications
of
the
sub—
five
micron
fibers
and
the
means
of
measurement
and
control.
Part
V,
Sec.
501(a)
—
has been slightly changed
‘from the pro-
posed final draft to add the phrase
“into the ambient air”
in order
to make clear
that the emission standard does not apply to the in-
olant
atmosphere.
In
Part
V,
Sec.
502
—
the
word
“enclose”
has
been
changed
to
“control”
on
the
suagestion
that
as
previously
written
the
meaning
~ias
unclear
and implied total enclosure of all
facilities.
Our
original
proposal
would
have
prohibited
the
use
of
brake
lining
in
vehicles
manufactured
after
January
1,
1975
and
sold
for
use
in
Illinois.
It
was
believed
if
brake
lining
decomposition
emits
asbestos
fiber,
then
the tremendous number of vehicles using
asbestos,
and’
~he imu.racticability
of controlling these numerous
small
emission
sources
would
appear
‘to
speak
to
the
need
for
a
pro-
duct
ban.
This
ororosal
to
ban
asbestos
brake
lining
has
been
dropped
for
the
time
being.
while
the
evidence
shows
that
brake
lining
decomposi-
tion
is
a
significant
source
of
background
levels
of
asbestos,
these
ambient air levels
are
quite
small
and
have
not
been
shown
to
be
a
health hazard
(although they have not been shown not to be)
.
In
addition,
adequate alternatives
to asbestos—lined brakes
are not yet
available,
although closed braking systems,
preventing
the emission
of asbestos dust,are
possible.
The
Board
will
follow
the
medical
and engineering aspects of this problem and possibly may return to~t.
Finally,
local
governments
are
obliged
to enforce these regula-
tions,
except for
the manufacturing provisions.
Much of the problem
arises
from
numerous
construction
activities,
and
the
Agency
cannot
adequately supervise these many emission sources.
The
“no visible
emission” standard has
been
added
especially
to
facilitate
local
government
and
citizen
assistance
in
enforcement.
I, Christan Moffett, Clerk
of the Illinois Pollution Control Board,
certify that the above Opinion was adopted on
the
~~day
of
________
1972 bv~vote Of 4-0.
S
S

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