Document 064vKwvZdBddLywKnNnLDBarV

AS3ESTQS sirs? cs* fitter --- Thursday, August 17, 1972, at 9:30 A.M. at the Institute Office, E. 210 Route 4, Paraaus, N. J M?5RS PRESENT I. E. Weaver, Chairman J. C. Reusing W. Spurgeon H. Vagner E. H. Felerabend / Raybestcs-Manhattan, Inc. Firestone Tire & Rubber Co., World Bestos Division Bendix Corporation Bendix Research Laboratories Carlisle Corporation . Molded Materials Division Abex Corporation American Brakeblok Division HSSIRS NOT ?RISS!?T W. B. Reitze Johsa-Kanville Corporation OTHERS PPZSEST D. E. Stone E. W. Drislane Bendix Corporation Friction Materials Division Friction Materials Standards Institute The meeting vaa called to order by Hr. Weaver, Chairman, at 9:30 A.X. MINUTES OF PREVIOUS ~MEETING The Secretary read a summary of the Minutes of the Meeting held February 10, 1972. These minutes had been released and a motion-for their acceptance bad been obtained. . Upon motion duly nade, seconded and unanimously passed, it was RESOLVED: To aceept the minutes of the February 10, 1972 meeting as distributed. . INTERPRETATION OF THE OSHA REGULATIONS The Asbestos Information Association (AIA) met vith representatives from OSHA late in June. The purpose was to Interpret various individual requirements in the OSiiA regulations. Letters from the AIA to their member companies, dated July 5, 1972 and July 12, 1972, were distributed to the Cossnittee Members. In the first letter, they covered areas such as labeling, clothes lockers. "inures of Merging Ar.b-esros Study Committee -2- Augusc 17, 1972 respirators, monitoring and physical examinations, citations, OSHA inspections and employee notification. Is second letter. the.AlA distinguishes be-- tween non-locked.-in asbestos containing prodfits7^iKJ$o&53e$r8iiiie0liaIr.g and clutch facings). There are certain labeling requirements tied in to the non-locked-in containing asbestos products, but this letter also discussed . the problems of subsequent working of locked-in asbestos containing products. The members discussed some of ehe items in the OSHA regulations. One member indicated chat during an inspection, there were 3 OSHA people at their plant for 7 to 8 days. Interestingly, Che 3 OSHA people case on sice the first day wearing respirators. Whether this was far effect or is.a standard procedure for OSHA was not known. One of the items pointed out by an OSHA Inspector on the scene was the dry sweeping of loose asbestos-type compounds vs. the vet sweeping or vacuum cleaning that OSHA calls for. Another member advised that they had taken out all air hoses around briquette presses and ether, machinery where loose asbestos is handled before It becomes locked in. Surprisingly to some senbers, asbestos sampling indicated that the inspection and drilling locations vere problem areas. One member required chat the respirators be worn at all drilling locations. ' In an inspection at one member's plant, the OSHA people sat up 5 stations and while 4 of them sampled below the 5 fiber per ce TWA, one station read 18 fibers per/cc TWA. This member was cited (in averaging the readings). * * When the Federal Government was considering the necessiCy for asbestos regula tions, two of the companies represented by Members os ehe Committee were asked to cooperate in a survey by HICSH. This study by HIOSH was to check over medical records and other such items to attempt to put the problem in prospective. NIOSE had indicated to the cooperating manufacturers Chat the information they vere providing would be kept confidential. However, as it turns out, Che OSHA people have copies of the HIOSH studies which would indicate that Che confidentiality has been violated. - A member questioned wbat happens when the aebestoc concentration in e work erea exceeds 10 fibers per ce (the deillng concentration in the OSHA regulations). The answer is that tha employer must notify tha workar ao exposed, in writing, that he was exposed to such a concentration and tha worker must wear a respirator In that area. Tha next question concerned what the proper means for notification of tha workar would be. If an interpretation is officially asked of OSHA, they will Indicate that a registered latter to the employee la tha proper means of notification. In other areas, OSHA has indicated that mcatlag the spirit of the las is what counts and it is fait that bulletin board notification would sufficn. disposable Tha next question concerned respirators. It was indicated that there were 3 / resplrator3P?rovetiy the Bureau of Mines, and these are .manufactured by tha . A. 0. Smith Company, Welsh, and Minnesota Mining and Manufacturing (MMM). Respirators furnished employees must have a proper fie and ehe employees muse be instructed boch as eo the fit and the servicing of the respirator. Responsibility for testing and approval of respirators -for protection against asbestos dust re cently was transferred from Bureau of Mines to NIOSH. Until NIOSH approvals are Issued, It is recommended only respirators (reusable or disposable type) having Bureau of Mines approval specifically for use on asbestos dust be used in asbestos contaminated acmospheres. Ilisuces of Meeting Asbestos Study Committee _ August 17, 1972 LAEZLISG PRACTICES r There are 3 areas for concern on labeling. One is the handling of the loose asbestos fiber Jrom the point vhere it is received to the point vhere it is nixed and briquetted. The next is the handling of the products with supposedly locked-in 'asbestos during subsequent operationssuch '-as drilling ,* grinding, inspection and boxing. The last concerns the handling of the brake lining or dutch facing by the customer where he may also do some drilling or grinding before the lined assembly is a -finished product. . .- It was reported during this topic that there was a higher concentration of asbestos in the air in the Inspection Department than most members had realized One member indicated that when pallets of brake linings were shipped there , apparently is additional dust created during transportation. The question of surface dust, on the working surface of'a brake lining or a clutch facing was discussed. Vhere members have taken action to reduce the dusty type surface, they have found that they have actually altered the frictional characteristics of the material during the early miles on a vehicle. In other words, the brakes are not very responsive during the early mileage after rellne. In the AIA recommendations, it is suggested that vhere a manufacturer is shippii his brake linings or clutch facings (locked-ln-asbestos products) he should*, notify the user of his produce to the effect, "Power bench saws -without collect should not be used in cutting this product. If this is Impractical, operators should be provided with a Bureau of Hines approved respirator." It was suggested that a notification be put in boxes of brake linings or clutch facing: * being shipped to customers. A sample of the caution labels suggested is attached to these minutes. Mr.- Feierabend indicated that this recommendation would not be accepted warmly by many manufacturers. Hr. Vagner objected to the recommendation that warning notices be put in the brake linings as he felt it was another "red flag" that would bring more harm to the Industry than the alleged good that would coma from enclosing such notices. Several members have had customers call in to their Salas Departments asking if the handling of . locked-in-asbestos in brake linings and dutch facings is a hazardous condition. Another asked if this notifcation was a requirement of the OSHA regulations. % It was indicated that this was not specifically required by the OSHA regulations The concern is, do those customers doing additional grinding and drilling of. " the brake linings or clutch facings create working conditions vhere the con centration of asbestos would be a hazard. Since small manufacturers are exempti from the OSSA regulations, they, will probably not be running testa. Larger customers will, of eoursa, be covered under the OSHA regulations and it is expected that tests will be run in these manufacturers' work areas. Whether the Institute would recomend such labeling in finished products shipped to the customers was not decided. It was felt that this st&Jecc should receive furthe: consideration from the Members ofa the Cooalttee before a recoimendation is made. One member commented that there were instructions by some manufacturers advisin) that blowing out the wear debris from used brakes was not recommended. This subject of recommending chat braka lining and clutch faeing manufacturers Include a warning sheet in their shipments appears to be somewhat controversial and it is suggested that this matter receive some serious discussion by,the Members of the Coanictee with those responsible at their companies. This item --*''------- .H. M*r nMrint of che Asbestos Study Mir-uces of Masting Asbestos Study Committee -4- August 17, 1372 gAMPLIWC ?3R ASS 5705 FI3E3 COUNTING ' Ilr. Stoae questioned the possible movement of asbestos inside the filter sample when sent to th lab for examination. Hr. Weaver indicated that this possibility vas quite remote. Apparently the question arose after as OSIIA visit to the member's plant. In response'to a question, one member indicated it takes about two months from the OSHA sampling until the OSHA report is " * received. Further,' it vas indicated that the company hears if it is to be .% cited and not if the conditicns are satisfactory. The OSHA regulations call for an eight hour tiae weighted average (TWA) for Che measurement of air borne concentration of asbestos fibers. One member indicated that he runs his sample test for a continuous four hours to compute the concentration. With a continuous four hour sampling, there are soaetiaes reactions from the shop people. *. Returning to the question on sampling for fiber counting, OSHA recotmends a full straight eight hour sample. It vas indicated they used 8 filters during this continuous sample. A member suggested using 90 minute sampling for aosc areas, or a complete job cycle if it took longer than 90 minutes. He recommended four hours of sampling for specials. A member questioned as to whdt minimum time vas necessary in sampling to determine the peak concentration.' that cannot exceed 10 fibers per ce. No specific answer was given, buc Mr.<^. Weaver indicated some sampling procedures which he felt were optimum for counting fibers entrapped by the filter. The number of tests for various conditions is suggested in this tabulation. One condition is where you are aeasurlng friction materials with asbestos in the compuad, and the other is for areas where you are handling all asbestos. Optii:dzed time for fiber collection - depending on TWA fiber per cc concentratli expected In area. (Optimum for counting fibers on the filter) Friction Materials TWA Fibers per cc Optimum Number of Tests All Asbestos TWA Fibers oer cc 0- 3 5-10 10-15 15-20 - 1-8 hr. test 2-4 hr. tests 3 tests, 3,3,2 hrs. 4-2 hr. tests 8-1 hr. tests . 0- 3 3- 6 6- 9 9-13 13-20 The question arose concerning the sample, where one is trying to pick up asbestc for counting. What about the oc&I23ierlala in brake linihg that are notFons^d hazardous?.' Might Chase not be counted on the filter es well es asbestos?' One answer that is indicated for the skilled laboratory man making the examination is that ha should be able to distinguish between asbestos fibers and other materials. Furthsr, ons can go to 300X on tha microscope and get a closer look at the materials picked up on the filter. Dr. Spurgeon indicated that one can use low temperature ashing to remove resins and other organic materials (primarily friction dust). * Dr. Spurgeon indicated chat the Bendix Research Laboratories are working under contract for_E?A on particulate emissions from brake linings and clutch facings and will not be finished until March 1973. Dr. Spurgeon felt it would not be proper to discuss results and progress to date on this study under contract to fKe governsent. - . THE STATUS OF E?A RECITATIONS Mr. Weaver indicated that one of the reasons for scheduling this meeting in August was to go over the new E?A regulations. However, this agency has not finalized their regulations as yet and it is not expected to be published until sometime in Septeaber. Hr. Weaver indicated that the problem was not with the asbestos sections, but rather with some of the other materials and he expected that their regulations will not be very much different from the earlier temporary regulations on asbestos. Once again, those earlier regulations were more concerned with control practices (collectors and .disposal techniques) -than with numerical emission values. Mo further action can be taken in this area until the LPA regulations are published. CONSIDERATION OF SUBSTITUTES TOR ASBESTOS / At the Annual Meeting,in June, this Committee was directed to consider a * 4r- recoaendation that the Institute sponsor a research study to determine the possibilities of substitutes for asbestos. The purpose of this suggestion was that if an outside study were to show thae certain materials might very well be acceptable substitutes for asbestos, the information would be made available to the members. If the'outside study indicated that there were no"'N. satisfactory substitutes for asbestos in friction materials, this information ) could be used as a defense should ve have a recurrence of action similar to / Illinois' banning of asbestos based brake linings. The Cosmlctee discussed this\ and as most of them are working on asbestos substitutes and some, in particular,J have marketed materials without asbestos (primarily metallic*), they felt this / suggestion would aoe be warmly received by many members". One member indicated'" that it would be very difficult for them to sanction the Institute any such study considering the work they have done in the pest. Upon motion duly made, seconded, and unanimously passed. It wee RESOLVED: That the Asbestos Study Committee does not recommend an Institute study in the area of substitutes for asbestos. / WASTE DISPOSAL Someplace between the point where the asbestos product is finished and the waste materials are disposed of, the OSHA requirements will become EPA require ments. In other words, we are moving from the condition of standards in the work place to standards in tha atmosphere or environment. The area of waste disposal is a major problem. All asbestos, bearing wastes, according to the OSEA regulations, must be collected and disposed of in seeled impermeable bags or / ocher closed impermeable containers. Whether e closed steel truck body is considered "impermeable" is s question. Zf the OSHA people mean what they say ' yjtnutes of '.leecisg .Asbestos Study Cccmirtee -6- AugusC 17, 1972 when they suggest thee an ersployer who Is attempting to meet the spirit law will not have .difficulty, it will be assumed that renoval of the was material in enclosed steel truck bodies would be an acceptable aeans of disposal, host members indicated that they had great difficulty with po bags - they are too soft and they tear when they are stacked. The nest which is a major problem, is the actual disposal of the dust. Usually, unloaded as land fill. One member uses a screw-type conveyor to fill a with a fixed container. The material is then dumped into land fill. Th material is wet down after dumping and, after a hole is filled, it is cc Mr. Scone mentioned a procedure he had seen where they turn the dust Inc pellets and dispose of the pellets. One member indicated a solution for disposal of the paper bags that are used to package the asbestos. They the asbestos bag Inside a hood where they cut the bag. The hood has an plastic bag which the asbestos bags are picked up in. The topic of proper disposal of the friction material waste products was discussed. The most desirable method of disposing of friction nacerial products is to put it back into the friction material. Where a manufact has a one-formula product line, this is reasonable. However, most of th manufacturers would find it very difficult to segregate the various mlxe up in their collection devices and recycle it back into the friction mat without running into product problems. This is obviously the most desir thing to do with the waste material, but for turning out a quality produ becomes very difficult. The most common means of disposal are to vet th product down and dispose of it as land fill. In some areas the material bagged and sent to the dump. The problem of economical means to dispose waste from friction materials has been a problem in the industry for mar It is likely to become a much mo-re perplexing problem considering Che re by OSHA and EPA. Dr. Spurgeon brought up the question of the possibllit the Institute sponsoring paid research on waste disposal. It was indies within the Constitution and By-Laws of the Institute we could very well such research but it would be up to the Coimnittee to make recoaaendatlor this area. Generally, there are areas ocher than asbestos chat are lnvc this weste disposal problem. Among the items to be considered are: grl dust, asbestos fibers and bags, phenolles which are peked up in vet scru lead and its compounds, and the solvents that are driven off during proc The Committee will consider this possibility et s subsequent meeting. A mesber suggested a possible questionnaire to be sent out to the Membe: concerning the problems of vests disposal to see vhether the rest of thi Membership could contribute some information in this area and to determ: extent of Interest In the study of waste disposal by the Institute. Th< of the Committee should consider items to be included in such e question for discussion at tha next meeting of the Committee. MATERIALS OTHER THAN ASBESTOS Because the problem of vests disposal is not a problem of asbestos only were raised about the possibilities of extending the scope of the Coamd work beyond that c asbestos alone. The Secretary Indicated that It vo within the scope of the Committee to extend their activity to materials than asbestos. Lead and lead compounds are among the hazardous materia regulated by Federal agencies. As many manufacturers use lead and lead Sirxces of Meetlsg 'Asbestos Scudy Committee -7- Augusc 17, 1972 la their friction materials, this Eight be e material to be studied by the Committee. Oa the other hand, because of the seriousness of the asbestos regulations, by^ talcing on other oaterials, the efforts of this Cossittee might be diluted" Currently, there are regulations on solvents, silica, and ocher materials considered hazardous or noxious by the regulatory agencies. It is requested that the members consider the possibilities of expanding the activities of this Cosittee to cover other materials. METHODS FOR EXAMINATION OF FIBERS Dr. Spurgeon questioned whether there were any other reliable techniques for the ! measuresent of asbestos fibers other than the menbrane filter method. The question was also aimed at whether the regulatory agencies were considering other analytical methods. Mr. Weaver Indicated that in conversation with ALA / he had recently learned chat the Department of Labor is considering a scudy on the possibilities of the gravimetric method.for sampling asbestos fibers. He indicated that the membrane filter mecfffi5"tu3uifd be in use for some years to come and possibly up to the July 1976 date when the stlffer two fiber per cc requirement goes into effect. The Department of Labor is considering a 15 man committee to scudy this possibility for sampling the asbestos. Ihe make-up of such a committee would be as follows: 4 from industry, 4 "experts," 1 from MI OSH, 1 academic, 2 from labor, 1 medical, 1 from the Americas Industrial Health Association, and 1 consumer advocate. It is suggested that members of the^ Asbestos Study Committee consider whether their companies might wish to volunteer for service on such a Federal coiadttee. y OTHER BUSINESS . Some of the Committee Members are operations oriented and others are environment oriented. It was requested that those individuals responsible for corporate decisions in Che hygiene environment area be listed. That list is aa follows: Charles Borcherdlng Abex Corporation - Chicago, Illinois (Corporate Industrial Hygiene) Jamas Armstrong Bendix Corporation - Southfield, Michigan (Safety Director) / Ike Weaver Raybestos-Manhattaa, Inc. - Manhelm, Pa. (Director of Environmental Control) Gaorga Wilson Firestone Tire 6 Rubber Co. - Akron, Ohio ******* There being no further business brought before the Committee, upon motion duly made, seconded and unanimously passed, it was RESOLVED: To adjourn Adjourned at 4:00 F.M. . Distribution: Cosnlttee Members J. Greenes L. Stickles British Council ' A1A/HA E. V. Drislane Executive Director (SM^roc ` . Contains Asbestos.. Fibers';' . Avoid Creating Dust. , . Breathing Asbestos Dust may cause serious Bodily Harm *. -A . _> , *" _ " ' " ** : T '" * v`` ' . I . . 'r*': ~ . -JTV : - - i.: 1 `` * The "Insmiccion Shoes" should be die same size as*che caution, label, black on white and should read as follows: . * . . '_ 'V w ..V-*1-' _ m\` - . . "* . -- ' . . ' \ ' . _ ' ' -:'S. a^PORTANT '-v.-Tr:-"'- . , _ . a * * `' - . T: ' ' . - >.r ` . POWER TOOLS WITHOUT DUST COLLECTORS SHOULD , ' ' . NOT BE USED FOR MACHINING, CUTHNC OR SANDING ~ . THIS TRODUCT. ` 5.'V . :.k f *- *- .. *_ . . . IF THIS IS NOT.PRACTICAL,. OPERATOR SHOULD BE a a* * , .r*' * k * * - .** , _ .' ` * ' .. PROVIDED WITH A U.S ..'BUREAU OF MINES APPROVED . - .*. .. .. & RESPIRATOR. ./ - - 4