Risk Assessment in the Federal Government Managing the Process Working Papers (1983) / Chapter Skim
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Asbestos: Part I
Asbestos: Part I
Pages 55-68
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From page 55... ...
Me case has been reviewed by individuals outside the study pro Sect who are directly familiar with the federal analyses and decisions described; however, responsibility for the paper rests with the au£J,or, and it does not necessarily reflect the judgment of the Committee on the Institutional Means for Assessment of Risks to Public }search or the National Researcl' Council. It has not been subjected to internal review procedures that apply to reports prepared by NRC commit tees .
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From page 56... ...
. Advance not ice 0 f proposed rulemaking First draft support document assessing risk of asbestos in s choot s Final Rule September 1980 Oct.
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From page 57... ...
) Human Data The epidemiological data selec ted to be the basis for making quantitative estimates of premature death from exposure to asbestos in schools -~as a large study of asbestos insulation workers (12,0S1 men)
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From page 58... ...
similarities between the material to which the insulation workers were exposed and the ashes tots present in schools. Data on Exposed School Population EPA gathered information on the presence o f friable asbes toscontaining materials in public schools and the number of people exposed by conducting a survey of the nation's school districts.
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From page 59... ...
What factors influenced the degree of quantif ication^ lathe results were presented in a precisely quantitative fashion -- as lifetime risk and number of premature deaths for students and adul t empl oyees . The EPA staff felt there was sufficient data, with reasonable assumptions, to proceed with a highly quantified assessment.
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From page 60... ...
6. How were Qualitative factors dealt with Mechanism of action, associated thresholds E ffec ts on population subgroups - Other confounding factors EPA was unaware of information about the pharmacokineeics of asbestos that would provide definitive evidence about the shape of the dose-response curve ~ or the existence of thresholds O EPA did consider biological susceptibility to asbestos as a function of age O After reviewing the literatures EPA determined that there was little confirmatory evidence to assume that children were more susceptible to asbestos exposure than adults.
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From page 61... ...
were: the fact that the authors of two major studies of asbestos workers believe their data for increased respiratory cancer risk are best described by the linear nonthreshold relationship, the fact that reviewers of the asbestos literature have recommended the use of this dose-response curve for lo~dose extrapolations, and that for quantitative risk assessments of carcinogens in general, the EPA Interim Guidelines (EPA 1976, Albert _ al . 1977 ~ Cal is for the use of the 1 inear nonthreshold dose-re s pans e curve .
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From page 62... ...
They also urged the authors to incorporate more evidence from qualitative epidemiologic data showing the incidence of mesoehelioma occurring at extremely low levels of asbestos exposure. This data they suggested was the best evidence that a threshold did not exist.
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From page 63... ...
'the quantitative risk assessment played no identifiable role in the final rule. In fact the calculations and estimation of numbers at risk were removed from the f inal rifle assessment document.
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From page 64... ...
Me calculated numbers for school occupants at risk, present in the July 1981 draft, were deleted in the final version of the risk assessment (January 1982~. Apparently, the decision to remove the numbers was made by the Deputy Ass istant Administrator for Toxic Substances without consultation with the Toxic Sub~ Lances Subcommittee o ~ the EPA' s Science Advisory Board ~ SAB)
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From page 65... ...
Early in the review process, representatives from the Asbestos Information Association (AIA) , an industry trade association, expressed strong opposition to various aspects of EPA's quantitative risk assessment (see Q
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From page 66... ...
Initially EPA was planning to require school districts to take corrective actions to protect occupants of schools from asbestos exposure. Such a rule would have been very expens ire to inact .
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From page 67... ...
The Deputy Assistant Administrator (DAA) for Toxic Substances, who called for the deletion of the quantitative risk assessment from the July 1981 draft, cited two reasons for doing so.
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From page 68... ...
Tori. 19780 Metrological survey of atmospheric pollution inside buildings insulated by asbestos projection.
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