Re: Ban Asbestos Bill Falls Short. Letter in Opposition to AB 74 - Again

[Guest guest]

Dana (from a couple posts):

1. " Good lord! "

RESPONSE:

Capital L

2. " Big fat negative. NOTHING and I mean NOTHING turns things around in

the short long and long run is ENFORCEMENT. We have had almost 25 years of

" asbestos " training in the United States and the " Training " is already

required.

Tony, you want to take 50% of the ENFORCEMENT Budget and use it for

training??? " Can you hear me Major Tom " ? Get it Get It! "

RESPONSE:

I disagree in two parts.

a. We have had little training in the last 10 years.

b. A read through literature (and my experience) is that it takes both

means: Education and Enforcement.

You'll note I said 50% for training; you can't eliminate enforcement

and shouldn't.

Lit examples:

Improving Compliance with State Environmental Regulations

J. Burby, G. Paterson

Journal of Policy Analysis and Management, Vol. 12, No. 4 (Autumn, 1993),

pp. 753-772

Regulatory Enforcement and Compliance: Examining Danish Agro-Environmental

Policy

J. May, Soren Winter

Journal of Policy Analysis and Management, Vol. 18, No. 4 (Autumn, 1999),

pp. 625-651

Motivation for Compliance with Environmental Regulations

Soren C. Winter, J. May

Journal of Policy Analysis and Management, Vol. 20, No. 4 (Autumn, 2001),

pp. 675-698

Improving Compliance with Regulations: Choices and Outcomes for Local

Government,

J. Burby, J. May, C. Paterson;

Journal of the American Planning Association, Vol. 64, 1998

3. " Collectively, there was nothing but spin, although Tony does back

up his posts, these " references " are carefully chosen, and do not represent

the

body of information, research, and state of the Industry. "

RESPONSE:

a. Please read:

Berman, D.W. and K.S. Crump: " Final Draft, Technical Support Document for a

Protocol to Assess Asbestos-Related Risk, " prepared for EPA Office of Solid

Waste and Emergency Response, (Oct 2003) EPA # 9345.4-06.

EPA, Report on the Peer Consultation Workshop to Discuss a Proposed Protocol

to Assess Asbestos-Related Risk, ERG, May 30, 2003.

b. " ...peritoneal mesotheliomas have not been convincingly related to

chrysotile exposure (National Academy of Sciences, 1984; Doll and Peto,

1985; and , 1996; Roggli et al., 1997; Sporn and Roggli, 2004;

Markaki et al., 2005). "

Do EPA, EPA Peer Consultation, NAS, Doll & Peto, carry any weight?

4. I repeat.

Banning a substance completely is Poor Risk Management.

5. Regular Coffee - Care to ban it?

- average 500 ug per cup of carcinogens

hydrogen peroxide, methylglyoxal

- average 250 mg mutagens

- 100 mg caffeine

- hydroquinone 100 ug

- catechol 400 ug

- MeIQ 0.064 ng

- caffeic acid 7.2 mg

- furfural 630 ug

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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