\ 33Ui £ I tW? I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON B.C. 20460 April 21, 1992 OFFICE or THE ADMINISTRATOR SCIENCE advisory BOARD EPA-SAB-IAQC-COM-92-005 Honorable William K. Reilly Administrator U.S. Environmental Protection Agency 401 M Street, SW Washington, DC 20460 Re: Science Advisory Board Commentary on the Agency's Asbestos Program Dear Mr. Reilly; As we expressed in our letter to you of April 20, 1990, the SAB is concerned that the scientific basis for EPA's regulatory actions and guidance documents on asbestos have not had the benefit of review by the Science Advisory Board (SAB), You yourself indicated some concerns about past Agency decisions on asbestos in your address of June 12, 1990 to the American Enterprise Institute (AEI) entitled "Asbestos, Sound Science, and Public Perceptions." The report you received in September of 1991 from the Health Effects Institute (HE!) - Asbestos Research on "Asbestos in Public and Commercial Buildings: A Literature Review and Synthesis of Current Knowledge" is a comprehensive, up-to-date, and objective summary of the available data on human exposure, effectiveness of remediation procedures, and critical issues in toxicity assessment and exposure-response relationships. In view of these concerns and developments, the Indoor Air Quality and Total Human Exposure Committee (IAQTHEC) of the SAB invited representatives of the Office of Research and Development (ORD) and the Program Offices having significant asbestos interests and responsibilities to provide a briefing on their current asbestos-related activities. The briefing was held during the Committee's public meeting in Arlington, Virginia on February 24-25, 1992, Presentations were made by Mr. Michael Beard (Atmospheric Research and Exposure Assessment Laboratory, Research Triangle Park - ORD) on asbestos and substitute libers monitoring methods research, by Mr. Roger Wilmoth (Environmental Monitoring Systems Laboratory, Cincinnati - ORD) on asbestos control technology, and by Dr. Joe Schecter (Environmental Assistance Division - OPP&T) on regulatory concerns and actions currently ------- being considered, including coordination with OSHA, and possible responses to recent court decisions. Although representatives of OAR and GSWER were not present, some of their current and recent activities were discussed briefly by the ORD and OFP&T representatives in yrms of their knowledge of past liaisons and cooperation. We wish to commend Mr. Beard, Mr. Wilmoth, and Dr. Schecter for the time and effort that they made in preparing their presentations, and for their candor and responsiveness in the discussions with the members of the Committee that followed. Based on these discussions, the Committee was able to come to consensus on some preliminary concerns about the Agency's asbestos program and its capacity to meet its regulatory responsibilities and commitments to reducing future risk in cost-effective ways. Our preliminary consensus concerns are as follows: 1) We heard no evidence that there is any strategic planning for addressing either important research needs or the implications of past research concerning the importance of fiber dimensions on inhalation hazard. The ORD programs for measurements and controls appear to be based on outmoded notions of which fibers need to be measured and controlled, and the scientists and engineers in ORD have not redirected, nor have been requested to redirect, resources to what they acknowledge is a critical need. In fact, there is an absence of guidance, in general, from the Agency's health scientists on the specification of the factors that govern toxicity. 2) There appears to be little, if any ongoing research on the critical issue of fiber properties affecting toxicity since the retirement of Dr. David Coffin from the Health Effects Research Laboratory (HEEL). It is possible that replacement fibers for asbestos in products and buildings may be as hazardous or more hazardous than the asbestos products they replace. Such research is needed if the Agency is to make scientifically sound policy regarding asbestos and substitute products. 3) There does not seem to be any formal mechanism for coordination on hazard ranking, monitoring methodology, or control technology on an Agency-wide basis. It is necessary to bring together the expertise and insights of OED, OAR, OSWER, OPP&T, and other Agency units having related interests in 2 ------- asbestos. Further, there is no evidence of such coordination between involved Federal agencies. Given the preliminary nature and incomplete coverage of our initial review of Agency programs in asbestos, we propose that the above concerns receive a more thorough İsam-ination at the next meeting of the IAQTHE Committee, which is tentatively scheduled for June-July 1992. We urge you to attend if your schedule permits, and to advise us if you have any particular concerns regarding asbestos which you would like us to examine. We hope that a further dialogue will prove valuable to you as you come to grips with the difficult issues in asbestos risk assessment and risk management that will confront the Agency in the near future, and for many years to come. Sincerely, Dr. Eaymond Loehr, Chair Executive Committee Science Advisory Board Dr, Morton Lippmann, Chair Indoor Air Quality and Total Human Exposure Committee Science Advisory Board 3 ------- NOTICE This report has been written as a part of the activities of the Science Advisory Board, a public advisory group providing extramural scientific information and advice to the Administrator and othe> officials of the Environmental Protection Agency. The Board is structured to provide balanced, expert assessment of scientific matters related to problems facing the Agency, This report has not been reviewed for approval by the Agency and, hence, the contents of this report do not necessarily represent the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive Branch of the Federal government, nor does mention of trade names or commercial products constitute a recommendation for use, ------- U.S. Environmental Protection Agency Science Advisory Board Indoor Air Quality and Total Human Exposure Committee fhalrman Dr. Morton T.ippmann, Institute of Environmental Medicine, New York University Medical Center, Tuxedo, NY Vim Chairman Br. Jail AJ. Stolwijk, School of Medicine, Department of Epidemiology and Public Health, Yale University, New Haven, CT Members/Consultants Br, Joan Baisey, Indoor Environment Program, Lawrence Berkeley Laboratory, Berkeley, CA Br. Timothy Larson, Environmental Engineering and Science Program, Department of Civil Engineering, University of Washington, Seattle, WA Br. Victor G. Laties, Environmental Health Science Center, University of Rochester Medical Center, Rochester, NY Dr. Paul Lioy, Department of Environmental and Community Medicine, Robert Wood Johnson School of Medicine, Piscataway, NJ Mr. Roger G. Morse, ENTEK, _*ivironmental and Technical Services, Inc., Troy, NY Dr. Jonathan M. Samet, The University of New Mexico School of Medicine, New Mexico Tumor Registry, Albuquerque, NM Dr. Jerome J. Wesolowski, Air and Industrial Hygiene Lab., California Department of Health, Berkeley, CA Br. James E. Woods, Jr., College of Architecture and Urban Studies, Virginia Polytechnic Institute and State University, Blacksburg, VA Science Advisory Board Staff Mr. A. Robert Flaak, Assistant Director, Science Advisory Board (A-10IF), U.S. EPA, Washington, DC 20460 Ms. Carolyn Osborne, Program Assistant, Science Advisory Board ------- Distribution List Administrator Deputy Administrator Assistant Administrators EPA Regional Administrators EPA Laboratory Directors Deputy Assistant Administrator for Solid Waste and Emergency Response Deputy Assistant Administrator for Air and Radiation EPA Headquarters Library EPA Regional Libraries EPA Laboratory Libraries ------- |