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Re: moving asbestos ceiling tiles - need quick please

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athan:

I completely understand your concern that if you give an inch they'll take a

foot.

But let me play devil's advocate:

Let's say you were trying to introduce a new regulation, then

Question 1: What evidence is there that removal of <3 SF or <16 SF of

amosite ceiling tile on an irregular basis will

a) result in an exceedance of the 1 f/cc Excursion Limit?

[Note: statistically this will occur on an irregular basis even in a

controlled removal scenario]

B) result in an exceedance of the 0.1 f/cc 8-Hour TWA Limit? (given the

actual time involved)

[Note: statistically this will occur on an irregular basis even in a

controlled removal scenario]

c) result in a chronic fiber burden >4.5 f/cc-years?

d) create a significant risk based on the revised EPA data [berman, Update

of Potency Factors for Asbestos-Related Lung Cancer and Mesothelioma, Crit

Rev Tox, 38, S1, 1-47, 2008]?

Question 2: What is the cost-benefit value in terms of $ spent per life

saved? And would that money be better served elsewhere in the economy - say

neonatal care or weight reduction?

Something to think about.

Tony

.......................................................................

" Tony " Havics, CHMM, CIH, PE

pH2, LLC

5250 E US 36, Suite 830 Avon

IN 46123

www.ph2llc.com

off

fax

cell

90% of Risk Management is knowing where to place the decimal point...any

consultant can give you the other 10%(SM)

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Hello,Who gets to pick the value of a human life or the morbidity costs?Big policy issues when doing a CBA.Is ~ $1,000,000 still being used for the value of a life in environmental health CBAs? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Bradley Harr MS, CHMM, CMC, HHS, RPIH Sr. Environmental ScientistBoise, Idahohttp://summitenviroinc.com From: iequality [mailto:iequality ] On Behalf Of KlaneSent: Monday, March 21, 2011 11:38 AMTo: iequality Cc: HavicsSubject: Re: Re: moving asbestos ceiling tiles - need quick please Thanks Tony! As always you ask some very good questions. - Klane, M.S.Ed., CIH, CHMM, CETKlane's Education Information Training Hub, LLC (KEITH)491 Norridgewock Rd.Fairfield, ME 04937-3116P: 207-453-KEITH (5348)jonathan@...www.trainerman.com " Take a step in the right direction " athan:I completely understand your concern that if you give an inch they'll take afoot.But let me play devil's advocate:Let's say you were trying to introduce a new regulation, thenQuestion 1: What evidence is there that removal of <3 SF or <16 SF ofamosite ceiling tile on an irregular basis willa) result in an exceedance of the 1 f/cc Excursion Limit? [Note: statistically this will occur on an irregular basis even in acontrolled removal scenario]B) result in an exceedance of the 0.1 f/cc 8-Hour TWA Limit? (given theactual time involved)[Note: statistically this will occur on an irregular basis even in acontrolled removal scenario]c) result in a chronic fiber burden >4.5 f/cc-years?d) create a significant risk based on the revised EPA data [berman, Updateof Potency Factors for Asbestos-Related Lung Cancer and Mesothelioma, CritRev Tox, 38, S1, 1-47, 2008]?Question 2: What is the cost-benefit value in terms of $ spent per lifesaved? And would that money be better served elsewhere in the economy - sayneonatal care or weight reduction?Something to think about.Tony...................................................................... " Tony " Havics, CHMM, CIH, PE pH2, LLC 5250 E US 36, Suite 830 AvonIN 46123 www.ph2llc.com(317) 718-7020 off fax cell90% of Risk Management is knowing where to place the decimal point...anyconsultant can give you the other 10%(SM)This message is from pH2. This message and any attachments may containlegally privileged or confidential information, and are intended only forthe individual or entity identified above as the addressee. If you are notthe addressee, or if this message has been addressed to you in error, youare not authorized to read, copy, or distribute this message and anyattachments, and we ask that you please delete this message and attachments(including all copies) and notify the sender by return e-mail or by phone at. Delivery of this message and any attachments to any personother than the intended recipient(s) is not intended in any way to waiveconfidentiality or a privilege. All personal messages express views only ofthe sender, which are not to be attributed to pH2 and may not be copied ordistributed without this statement.

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Hello,Who gets to pick the value of a human life or the morbidity costs?Big policy issues when doing a CBA.Is ~ $1,000,000 still being used for the value of a life in environmental health CBAs? ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~Bradley Harr MS, CHMM, CMC, HHS, RPIH Sr. Environmental ScientistBoise, Idahohttp://summitenviroinc.com From: iequality [mailto:iequality ] On Behalf Of KlaneSent: Monday, March 21, 2011 11:38 AMTo: iequality Cc: HavicsSubject: Re: Re: moving asbestos ceiling tiles - need quick please Thanks Tony! As always you ask some very good questions. - Klane, M.S.Ed., CIH, CHMM, CETKlane's Education Information Training Hub, LLC (KEITH)491 Norridgewock Rd.Fairfield, ME 04937-3116P: 207-453-KEITH (5348)jonathan@...www.trainerman.com " Take a step in the right direction " athan:I completely understand your concern that if you give an inch they'll take afoot.But let me play devil's advocate:Let's say you were trying to introduce a new regulation, thenQuestion 1: What evidence is there that removal of <3 SF or <16 SF ofamosite ceiling tile on an irregular basis willa) result in an exceedance of the 1 f/cc Excursion Limit? [Note: statistically this will occur on an irregular basis even in acontrolled removal scenario]B) result in an exceedance of the 0.1 f/cc 8-Hour TWA Limit? (given theactual time involved)[Note: statistically this will occur on an irregular basis even in acontrolled removal scenario]c) result in a chronic fiber burden >4.5 f/cc-years?d) create a significant risk based on the revised EPA data [berman, Updateof Potency Factors for Asbestos-Related Lung Cancer and Mesothelioma, CritRev Tox, 38, S1, 1-47, 2008]?Question 2: What is the cost-benefit value in terms of $ spent per lifesaved? And would that money be better served elsewhere in the economy - sayneonatal care or weight reduction?Something to think about.Tony...................................................................... " Tony " Havics, CHMM, CIH, PE pH2, LLC 5250 E US 36, Suite 830 AvonIN 46123 www.ph2llc.com(317) 718-7020 off fax cell90% of Risk Management is knowing where to place the decimal point...anyconsultant can give you the other 10%(SM)This message is from pH2. This message and any attachments may containlegally privileged or confidential information, and are intended only forthe individual or entity identified above as the addressee. If you are notthe addressee, or if this message has been addressed to you in error, youare not authorized to read, copy, or distribute this message and anyattachments, and we ask that you please delete this message and attachments(including all copies) and notify the sender by return e-mail or by phone at. Delivery of this message and any attachments to any personother than the intended recipient(s) is not intended in any way to waiveconfidentiality or a privilege. All personal messages express views only ofthe sender, which are not to be attributed to pH2 and may not be copied ordistributed without this statement.

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