Document 06YMBd3X3qkDdX4pdprdox0Zn
DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE
PUBLIC HEALTH SERVICE CENTER FOR DISEASE CONTROL
August 8, 1975
NATIONAL INSTIHUl'f? f OR OCCUPATIONAL SAFCTY `AND HEALTH ------ - . 5600 FISHERS LANE ROCKVILLEvMARVLANO 20SS2
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Dear Colleague:
This communication is intended to alert you to recently gathered informa1tion Indicating a potential health hazard for persons exposed to asbestos during the servicing of motor vehicle brake and clutch assemblies.
On July 21, 1975, the National Institite for Occupational Safety and Health
convened a meeting of government and university scientists, industry
representatives, and labor union officials to discuss the present state of
knowledge with respect to this problem. Data was presented by Investigators
from the Mount Siani School of Medicine in New York City indicating that
workers engaged in the maintenance and repair of automobile and truck brake
linings are exposed to potentially hazardous levels of airborne asbestos
dust. Specific brake servicing operations studied included blow-out of
automobile drum brake assemblies, grinding of used truck brake linings, and
bevelling of new truck brake linings. Average peak asbestos air concentra
tions for these three activities based on personal samples taken within ten
feet of the operator were, respectively, 10.5, 3.75, and 37.3 fibers (>5
microns in length) per ml. An analysis of samples of brake drum dust
revealed that'almost all of the asbestos fibers found were shorter than
0.4 microns in length.
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Previous studies of the extent of asbestos emissions from automobile brake lining wear showed that only a very small fraction of the original asbestos content of the brake lining is found in brake drum dust (Ref. 1-3). It was presumed that this is due to thermal degradation of the fibers during braking. The present findings Indicate that enough asbestos is preserved to produce . significant exposures during certain brake servicing procedures.
The full extent of asbestos-related disease in brake servicing personnel
is not known at present because this, particular occupational group has
not been studied systematically up to now. However, a review of the
scientific literature on the association between asbestos exposure and '
mesothellal tumors of the pleura and peritoneum has revealed at least
four cases of these rare tumors in persons who were employed in jobs
involving automobile brake servicing (Ref 4-6) .
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For your information and guidance, we are enclosing pertinent references, estimates of the population at risk, a N10SH interim recommendation for brake and clutch servicing procedures, and a copy of the Department of Labor standard covering exposure to asbestos in the work place. _
The environmental studies of brake lining servicing operations outlined above together with observations of mesothelial tumors in persons so employed affirms the necessity for instituting and maintaining recommended control measures in this Industry so that the health hazards of asbestos . are minimized.
Enclosures
Office of Occupational Health
Surveillance and Biometrics
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FMSI 06260
REFERENCES
1. Lynch, J.R.: Brake Lining Decomposition Products. J Aif Pollution
Control Assoc, 18;824-26, 1968
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2. Hickish, D.E. and Knight, K.L.: Exposure to Asbestos During Brake
Maintenance. Ann Occup Hyg, 13s17--21, 1970
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3. Jacko, M.G. and DuCharme, R.T.; Brake Emissions: Emission Measure ments from Brake and Clutch Linings from Selected Sources. EPA --. Report 68-04-0020, 1973
4. Newhouse, M.L. and Thompson, H.: Mesothelioma of Pleura and Peritoneum Following Exposure to Asbestos in the London Area. Brit J Ind Med, 22:261-69, 1?65
5. McDonald, A.D. et al.: Epidemiology of Primary Malignant Mesothelial Tumors in Canada. Cancer, 26:914-19, 1970
6. Greenberg, M. and Lloyd Davies, T.A.: Mesothelioma Register 1967 1968. Brit J Ind Med, 31:91-104, 1974
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FMSI 06261
ESTIMATES OF THE WORKFORCE POTENTIALLY EXPOSED TO ASBESTOS " IN THE MANUFACTURING AND SERVICING OF BRAKE LININGS Ap CLUTCHES
Auto Mechanics
Garage Workers
Manufacture (original and rebuilding)
TOTAL
833,535 6^,679
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6,657 907,871
SOURCE: ,Adapted from 1972 Census of Manufacturers, 1972 County Business^Patterns, and Census of Population: 1970 Occupation by
Industry (all are'Department of Commerce, Census Bureau publications) .
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FMSI 06262
. RECOMMENDED (INTERIM) PROCEDURES FOR
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ASBESTOS BRAKE AND CLUTCH SERVICING f
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The National Institute for Occupational Safety and Health (NIOSH) has
research underway concerning dust exposures during brake and "clutch
servicing. Due to preliminary data demonstrating significant asbestos
exposures during presently used brake and clutch servicing techniques.
NIOSH has reviewed t alternate techniques whereby asbestos exposures are
reduced. The following are interim procedures recommended by NIOSH to,
minimize dust exposures.
1. If possible, an area shall be designated for all brake and clutch
repairs. Entrances into this area shall be posted with an asbestos
exposure warning sign as follows:
. *___
Asbestos
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' Dust Hazard
Avoid Breathing Dust Wear Assigned Protective Equipment - Do- Not Remain in Area Unless Your Work Requires It
Breathing Asbestos Dust May Cause Asbestosis and Cancer
2. During brake servicing, an air purifying respirator, either single use
( or with replaceable particulate fllter(s), as approved by the Mining
Enforcement and Safety Administration (formerly Bureau of Mines) or NIOSH, shall be worn during all procedures starting with--ther removal of the wheels and including Reassembly. During manual clutch
servicing, such a respirator shall be worn during removal and cleaning of the clutch, pressure plate and housing assembly and during instal
lation of the new clutch assembly.
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3. Dust 6hall first be cleaned from brake drums, brake backing plates, * brake assemblies and clutch assemblies using an Industrial type vacuum cleaner equipped with a high efficiency filter system (>99% efficiency for 0.3 pm diameter aerosols). After vacuum cleaning, any remaining dust shall be removed using a rag soaked in water and wrung until nearly dry. Under no circumstances shall compressed air or dry brushing be used for cleaning.
4. During arcing and riveting operations, an approved respirator, as described in (2) above, shall be worn. 'Grinding' (arcing) machines
shall be provided with lotal exhaust ventilation such that worker
exposures are maintained at least below the 1976 OSHA asbestos
standard (29 CFR 1910.1001).* At a minimum, the dustbag of the
arcing machine shall be removed and replaced with the hose of the, high
efficiency industrial vacuum described in (3) above.
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FMSI 06263
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5* Industrial vacuum cleaner bags containing asbestos dust,and cloths
used for wiping brake and clutch assemblies shall be sealed in plastic
`bags and labeled with the following warning label printed in letters
of sufficient size and contrast to be readily visible and legible;
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Caution
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: Contains Asbestos Fibers
<
' Avoid Breathing Dust
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.Breathing Asbestos Dust May Cause Asbestosls and Cancer
All asbestos waste shall be disposed of in accordance with the OSHA
asbestos regulation, 29 CFR 1910.1001(h). During removal of vacuum
bags, an approved respirator, as described in (2) above, shall be*
worn.
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6, All floor cleaning in areas where brakes and clutches are repaired shall be done with the high efficiency industrial vacuum cleaner as described in (3) above. Grinding (arcing) machines shall also be cleaned with Buch a vacuum cleaner and.any remaining dust wiped with a damp cloth'. An approved respirator, as described in (2) above, shall be used during this cleaning.
7. Although adherence to the above procedures ^should minimize any contamination of work clothing, it is required that the appropriate portions of the OSHA regulations on asbestos (29 CFR 1910.1001(d), (3
and 4)) concerning special clothing, change rooms, etc* be followed.
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NOTE: Strict adherence to the above procedures should minimize exposures
to mechanics during brake and clutch servicing. These are interim recom- ^ mendationa and are subject to revision pending results of ongoing NI0SH .
research.
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* Section 1910.1001 of the Code of Federal Regulations was formerly
Section 1910.93a. This change was noted in the Federal Register, May
28, 1975.
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J Prepared By Division of Field Studies and Clinical Investigations National Znstltute for Occupational Safety and Health , Cincinnati, Ohio
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FWISI 06264
Recommended Procedures for Sampling and Counting Asbestos Fibers
Procedures for llie Evaluation of Occupational Exposures to Airborne Asbestos
i
Joint AIHA-ACGIH Aerosol Hazards Evaluation Committee
ibrous asbestos has been
FIDENTIFIED as the causative agent of
asbestosis and has been associated with an increased cancer incidence. The American Conference of Governmental Industrial Hy gienists (ACGIH) has established (1974) a Threshold Limit Value (TLV) for asbestos of 5 fibers greater than 5 micrometers in length per milliliter of air. A TLV footnote specifics the determination shall be made by the membrane filter method at 400 X to 450 X magnification and with phase contrast illumination. These procedures define a standard of sampling and of processing the collected samples in order to evaluate occu pational exposure to asbestos fibers.
Sampling
Airborne samples of asbestos must be collected on membrane filters which retain at the surface essentially all of the particles in excess of 0.5 fim in diameter. The filter must be rendered transparent by the mount ing medium. The filter should be packed in a scaled holder which is capable of being readily opened for sampling purposes and of being rescaled after the sample has been collected. The filter must be fully exposed during sampling. (Recommended filters and filter holders arc listed under Supplies). The filter must be practically dust-free, with an average background count of less than 25
Reprints of this article are available for purchase from either the American Industrial Hygiene Association, 66 South Miller Road, Akron, Ohio 44313 or the American Conference of Governmental Industrial Hygienists, P.O. Box 1937, Cincinnati, Ohio 43201, The cost la $1.00 per copy.
fibers per square centimeter. At least 2% to 4% of the filters intended for collecting samples should be set aside to determine the background count. (Sec Counting and Cal culations sections). In addition, the filter resistance should not exceed 3 mm of mer cury when filtering air at the rate of 0.3 liters per minute (1pm) per square centimeter of filter.
When collecting the sample, care must be taken to prevent dust from falling pr from being projected onto the open filter. This may be accomplished by pointing the filter head downward. A guard or shroud should be attached to the filter holder to further protect the open filter from contamination as well as optimize uniform deposition on the filter. Its diameter should be about the same as the holder so that it can bc"attachcd tightly to it and it should project at least Wi times the filter diameter in front of it. A protective device is particularly important if the filter head is to rest on contaminated clothing. (See Figure 1.) The filter holder may be stored for a limit of six months once it is resealed.
The sample should not be too dense, since samples in which particles overlap must be rejected as uncountable. Similarly, a large enough volume of air should be sampled so that there arc sufficient numbers of fibers in each field. Experience indicates that more than 150 particles per field, including nonfibrous background, may interfere with counting the sample. It is desirable that there be no more than 10 fibers per field. Two or three samples should be collected at each sampling location. The results should
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Figure 1. Diagram of shroud for membrane fil
ler holder. The shroud may be constructed from a
plastic bottle by cutting off the neck and drilling
a hole in the bottom. To use, push the filter holder
through the hole and reach in through the top to
remove the holder cap. To remove the holder, re
place the cap and push the filter holder forward
through the hole.
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be averaged to obtain the fiber concentra tion.
Breathing zone samples should reflect the worker's entire normal work day. They must be collected as close to the worker's nose and over as long a time period as possible. Calibrated battery powered per sonal pumps (see Appendix III, Pump Cali bration) are satisfactory air movers. They can be worn by the worker and supported at the belt by means of a clip. The sam pling head, which can be pinned to the Col lar, is connected to the pump by flexible tubing. Such pumps can be operated continu ously for about eight hours and recharged overnight.
If a 37-mm filter is used to collect the sample, the pump should be adjusted to sam ple between 1 and 2 liters per minute. The volume of air sampled should be adjusted so that an optimum density of dust is col lected on the filter. Since the dust concentra tion is not known before sampling, the op timal sampling period must be determined by trial and error. It is suggested that, unicss experience indicates otherwise, the first sam ple should be collected from 20 liters of air, the second from 40 and the third from 80
February, 1975
liters. If a filter other than 37-mm is used, the volume of air sampled should be altered in direct proportion to the open filter area. Samples collected during short- periods of exposure should be collected at a high flow rate and if necessary, for the entire exposure period. In all eases the count should be adjusted with regard to time, so that the exposure is expressed as an 8-hour timeweighted average exposure. For compliance evaluations with short term exposures, 37 mm filters samples should be collected for 15 minutes at a minimum of 2 1pm.
Sample Preparation
A solution one-to-one by volume of di methyl phthalatc and diethyl oxylate in which has been dissolved 50 milligrams of membrane filter material per milliliter of solution is the preferred counting medium. The chemicals used to prepare the medium should be examined microscopically to be certain that they are dust free. The fiber material to be dissolved should not be marked and should have a maximum back ground count of 25 fibers per square centi meter of filter. The counting medium may be stored in a wide-mouthed Wheaton Bal sam bottle and should be applied with a glass rod. The counting medium has a re fractive index of 1.461 at 25C. The me dium should be made in small quantities since it has a 6 month shelf life.
Asbestos fibers are counted on wedge shaped sections cut from the filter. The wedge should be reasonably sized so that it can be mounted on a 25 x 75 mm (1x3 inch) glass microscope slide. The slide should be cleaned of dust before it is used. A drop or two of counting medium is placed on the slide and the filter wedge is placed dust side up on top of the medium. The wedge is covered by a No. \V% covcrslip. Care must be taken while lowering the coverslip to avoid trapping air under it. Air bub bles may be forced out by exerting slight pressure on the cover slip with a pencil eraser. Extreme care must be taken to avoid
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FMSI 06266
American huliislriul llynit'iif A.\.\oiiiiliiiii Jotnliiil
too much pressure, since this causes distor tion and stretching in the filter.
The wedge is usually cleared within 15 minutes; however, a residual background granularity may be noted. This will disap pear within a day. Counts must be com pleted within two days since there is a tendency for fiber migration and crystal growth. The prepared medium should be checked periodically for a background count. (See Counting and Calculations sections.)
An alternate medium may be used when the samples must be counted immediately. It is prepared in the same manner as the preferred viscous medium, except that the added membrane filter is omitted. Since this medium is much less viscous it should be stored in narrow-mouthed bottles. This me dium is applied with a glass dropper after the filter wedge has been placed dust side up on the slide. However, a drop should be placed on the slide adjacent to but not on top of each corner of the wedge. This me dium acts very rapidly and the No. 1V4 covcrglass should be lowered within a min ute. Slides made up with this "alternate medium" are ready for counting within five minutes and the count must be completed within two hours after preparation.
Filters which have been used to collect samples and which have been rescaled in a holder should be removed only in a clean environment. They should not be held with the fingers. They may be held with tweezers and cut with cither a scalpel or scissors. Bottles containing media must be tightly closed except during use. All bottles, tools used for handling and cutting filters, and containers used for storing tools must be thoroughly cleaned and dried. Tweezers, scissors, scalpels, etc. should be set aside for this purpose exclusively. Although slides and covcrslips arc purchased pre-clcancd, they should be wiped lightly with clean lens tisuc to remove traces of dust. Do not at tempt to reuse slides or covcrslips.
Microscope A microscope equipped with a phase con-
85
trasl substage condenser, it 4 mm "high dry" phase-contrast objective (40 X to 45 X) and a 10 X eyepiece is used to count the sample. It should have either a pre-focused built-in illuminator supplied with an iris diaphragm or be lighted by a separate bright illuminatorflat mirror combination. If a separate illu minator is used it should be equipped with a condensing lens, iris diaphragm, and means for adjusting both the illuminator level and the distance between the condensing lens and the bulb. Zoom microscopes may be used for counting asbestos fibers, provided that the total magnification is within the 400-450 X range.
The illuminator should be equipped with an adjustable constant voltage transformer. Both the microscope condenser and stage require close adjustment and both should be rack and pinion mounted. The stage must move along two perpendicular axes in a horizontal plane, while the condenser must move up and down in a vertical plane. Lighting must be adjusted for optimum bal ance. The Kohler method of illumination is recommended. (See Appendix I for pro cedures required to establish Kohler illu minator.)
The counting field is defined by a reticle mounted at the level of the field-limiting di aphragm in the 10 X eyepiece. The Porton reticle (Figure 2) is recommended. However, any reticle which contains markings which, in addition to outlining an area of about 0.005 square millimeters, as determined by
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Figure 2. Porton reticle.
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the combination of eyepiece and objective, and which defines linear distances that may serve as measuring aids, is satisfactory. The 'reticle must be' calibrated prior to use and ' recalibrated each time it is removed from the microscope eyepiece or when the micro scope tube length or intcrpupillary distance is changed. Zoom microscopes must be re calibrated each time the zoom position is changed. (Sec Appendix II for recommended calibration procedures.)
Counting
A fiber is defined as a particle whose length is at least three times greater than its diameter. All fibers longer than 5 /Am within the area delineated by the reticle, or which enter it from cither of two adjacent sides, arc counted. Fibers entering the area from cither of the other two sides, /.<?., those not arbitrarily chosen as "counting" sides arc not counted, nor fibers in excess of 5 /im in diameter. Touching fibers, i.e., one of whose ends touch another fiber regardless of the resulting angle, arc considered as one. Fibers that cross each other arc counted in dividually. Fibers that pass through the de lineated area arc counted provided that they cross at least one of the arbitrarily chosen "counting" sides. (Sec Figure 3.)
Fiber length should be determined by measuring against standards such as a circle or a space defined by markings on the cali brated reticle. If the fiber is curved or wavy the total length should be estimated by meas uring along the curve. Once sufficient ex perience has been gained in judging length, only fibers whose length or diameter arc in question need be measured.
A routine for choosing counting fields must be selected so that fields arc not count ed more than once and that a representative fraction of the total filter area is viewed. A convenient procedure which may be used is to select a scries of microscope viewing fields along a radial line extending from the apex of the filter to the outer edge of the sample wedge. The viewing fields must be
February, 1975
chosen without preference to a particular area and should be approximately equally spaced along the line. The first field should be located a little bit in from the point at which matter is deposited on the filter. If the required number of viewing fields can not be located on a single radial line, addi tional lines parallel to the first should be chosen.
Preferably 100 fibers should be counted but all the fibers in 20 fields should be counted even if there are more than 100 fibers. The counting may be terminated after 100 fields have been searched even if 100 fibers have not been counted.
Calculations
The concentration of asbestos fibers in air can be expressed as:
Asbestos Cone.
Fibers x R Fields x Voi
Figure 3. Illustration of fiber counting with a Porton reticle. The top and left side of the large box have been chosen as "counting sides". Circle 6 is 5 jitn in diameter. (A) Fiber A crosses the top of the box and is counted, therefore. One end of Fiber A] touches Fiber A and thus is considered
as part of it and is not counted separately. (B) Fi ber I) is a bundle containing many spikes. It passes through the box crossing bottom and top. It is
counted as one fiber. (C) Fiber C passes through the box but it crosses the right side and bollom. It is not counted. (D) Fiber D is entirely within the box and crosses over Fiber A. It is not part of Fiber A, therefore it is counted as a separate fiber. (E) Fiber E is less than 3 41m in length. It is not count ed.
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American Industrial Hygiene Association Journal
87
where:
the system except that if desired, neutral
Fibers = total number of fibers counted
density filters may be used to reduce the
Fields = total number of fields counted
light intensity. If the microscope is equipped
r_
filtration area
area of a counting field
Vol = sampling rate (1pm) x time (min)
with a built-in illuminator, proper iMumjnator positioning has already been accomplished and need not be of further concern.
x 10*
= sample volume in ml of air
Since both the filtration area on the mem
brane filter and the area of the counting
field arc normally constant, the ratio of
areas, R, is constant for the given conditions.
To illustrate: Air is sampled at 1 liter/
minute for 50 minutes on a 37-mm mem
brane filter (filtration area 855 mm2). A
total of 60 fibers each longer than 5 (im
are counted in 100 fields each 0.003 mm2 in
area:
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Fix a mounted sample on the stage and rcchcck the alignment. Raise the substage condenser until it nearly touches the bottom of the slide. Turn on the illuminator and use the tilt controls to direct the light to the center of the mirror. Tilt the mirror, direct ing the beam upward into the stage con denser. Close the microscope substage iris and the illuminator iris. Use the illuminator focus control to focus the image of the fila ment on the bottom of the substage iris. The reflection of the iris may be viewed in
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855 mm2 3 x 10-3 mm2
2.8 x 10s
and
the mirror by leaning over the microscope. After adjusting the illuminator condenser
so that there is a sharp image of the filament on the substage iris, open it about halfway.
Recheck proper position of the mirror and
Asbestos Cone. =
2.8 x IQ3 x 60 Fibers______
i1m00 cFielidis x-I---*---10:-*-1-1-1--1-x 5e0n mi.n
nun . .
then put the objective in place and focus sharply on the sample. It may be necessary to open the substage iris during focusing.
= 3-4 Fiber$/jjil
After the sample is in focus, fully close
Since the precision of this mctlibii is limited,
the iris. Readjust the condenser height so
the averaged results of the several samples
that the edge of the iris leaves are in sharp
should be reported to the nearest significant
focus and there is a bright spot within the
i figure.
iris. Readjust the mirror to obtain maximum
brightness. If the color around the iris is
Appendix I
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not uniform, rcchcck the illuminator tilt and
Recommended Procedure for Establishing
focus. If the color is uniform and maximum
Kohler Illumination
brightness has been achieved, open the field
The microscope is set on a level surface
iris until the blades just pass out of the field
at a convenient height and in such position
of view.
that sighting through the eyepieces is possible
The proper phase stop is inserted or ro
without undue strain or discomfort.
tated into place in the substage condenser.
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The illuminator is placed directly in. front
The phase objective is rotated into place.
of and aligned with the microscope. If the
The eyepiece is replaced with the phase ring
illuminator is equipped with a coil filament
centering telescope. The telescope is ad
bulb, its iris should be ten inches from the
justed for sighting. The location of the
mirror. If a ribbon filament bulb is used,
phase ring is observed through the telescope.
the front of the filter holder should be at
It may be adjusted by using the two rotating
least seven inches from the mirror. Only
shafts provided with the phase condenser.
the plane surface of the mirror should be
When the ring is centered it appears as a
used. All filters should be removed from
bright annular ring mounted on top of a
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February, 1975
grey ring. The center is black. There should
is related in terms of L units of length in
.
be no overlap of the bright ring into the
accordance with the formula:
center. When the phase stop is centered the tcleseopc is removed and the eyepiece is re placed. The microscope is now ready for use.
D = Ly/IF where n is the diameter of the circle or the width of the space and N is the number of the circle, or space.
Appendix II
The unit L is determined by measurement. A stage micrometer is the primary ruler.
Recommended Procedures for
Any one or more of the definitive linear di
Calibrating Reticle
mensions may be measured. If the length
The reticle must be slightly smaller in
of the large rectangle is measured then L
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diameter than the eyepiece in which it is to
equals I/200th of that value.
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be used. It fits into the tube and is held in
If the stage micrometer is marked in hun
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place at the eyepiece focal point by spring
dredths of millimeters the value of L is in
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pressure. The focal point is marked by an
hundredths of millimeters. If the left square
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internal collar which prevents the reticle
is used as a counting area, its area is equal
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from passing further into the tube. Some
to
manufacturers locate the focal point just
(100 x 0.01 L)2 mm2
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below the collar while others prefer a point
The filtering area of a 37-mm filter is 855
j
immediately above it. Thus it may be nec-
mm2 and thus
j cssary to insert the reticle between the lens | and the collar on one microscope and below I the collar on another. In either ease the
n - 855 K L2
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projected image of the reticle on the field
If other areas arc used as counting fields j '
c must be clear and sharp.
or other sized filters are used, the value of I./
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The reticle must project a constant count-
R must be calculated for the individual con- i -
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ing area as well as provide markings for
dition.
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sizing. Many types of reticles are satisfac-
It is wise to prepare a chart showing each
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tory. The Porton reticle illustrated in Figure
linear dimension and area for ready reference "
]
2 is recommended. It outlines a large rec-
while counting.
\ tangle that fits easily within the field of
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vision. The rectangle is divided into two
Appendix III
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\ equal squares. The left square is further
;
divided into six rectangles. Each side of
Pump Calibration
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j each square has a length equal to 100 L, Personal sampling pumps should be cali- j
then the large rectangle is 200 L units long
brated for flowrate frequently. They may be j
j
and the small ones 50 L units long and 33V6
calibrated against a primary meter such as t
]
L units high. To the left of the left square
a spirometer or againsta previously calibrat-
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is a scale which divides the side into 20
cd secondary standard such as a wet gas
;
equal increments of 5 L units each. The
-meter or dry gas meter. The train should be
right square is divided horizontally in thirds
arranged so that the pump is operating *
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corresponding to the small rectangles and
against the same resistance it would normally
vertically into a series of increasing spaces.
operate against, and that the calibrating
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The distance between each vertical line and
meter is at atmospheric pressure. Figure 4
the center of the large rectangle corresponds
illustrates the recommended arrangement.
to the diameter of a circle. Circles of sizes
Air flow through (he filter may be limited
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1 through 9 are located above and below the
by both restricting the air flow to the pump
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large rectangle. The diameter of each circle
as well as by admitting'secondary air into }
FMSl 06270
American Industrial Hygiene Association Journal
KETSR Figure 4. Diagram of set-up for calibration of pump.
the pump. Most personal pumps arc con structed with adjustment valves that permit both actions. Calibration should be repeated after each 24 to 36 hours of pump use. If the pump has not been used for a prolonged period of time it should be recalibrated. Temperature and altitude corrections should be made.
Personal sampling pumps should not be used to such an extent that the batteries arc allowed to run down below normal operating voltage. Since battery life varies, it is wise to occasionally check the life of the battery by allowing the pump to run down to the first indicated change in voltage under timed simulated conditions.
Supplies Filters ami Filter Holders
Millipore Corp." Field Monitor filter hold ers preloaded with 37-nim Type AA filters, cither white plain (catalog #MAWP037A0) or gridded (#MAWG037AO) arc recom mended. These are sold with a guaranteed average particle background and can be used without additional background checks.
It is less expensive to purchase unloaded field monitors (#MA13G037A0) to be loaded with plain or gridded filters pur chased separately in packages of 100 (#AAWP03700, and AAWG03700). The field monitor can then be reloaded after each use. However, it is necessary to care fully clean the empty monitor and to check the background count on filters in the re loaded monitor.
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Type AA fillers can be used in any di ameter in any non-leaking open-type filter holder, as long as proper adjustment is made in the calculations for the change in filtering area, and periodic background checks arc made.
Membrane filters of other types and man- ( ufacturcrs cannot be recommended at this ' time, either because they do not become optically clear in the mounting medium or because of excessive particle background.
Personal Battery Powered Sampling Pumps (1) Casclla'' MK 11 or MK 111 Personal Sampler (2) MSA' Monitairc Sampler, Model G. (3) Bendix'1 VM 22 or Micronair Per sonal Sampler or C-l 15.
Microscopes: Phase Equipped . (a) microscope body with a fine focus accuracy of 0.006 mm; (b) 10 X eyepiece; (c) mechanical stage; (d) illuminator (preferably built in and having provisions for adjusting light intensity); (c) 40 X to 45 X (0.65 N.A. at least) positive (bright field) phase-contrast objective; (f) annual ring condenser diaphragm (corresponding to the objective); and (g) phase ring centering telescope. (Note: Most manufacturers sell a basic
body unit and built-in illumination system as a unit. Phase-contrast accessories can us ually be purchased as a kit consisting of 10 X, 40 X and 90 X phase objectives, a phase condenser containing appropriate an nular ring diaphragms, a phase ring center ing telescope, and a green filter. It is to the microscopist's advantage to purchase the kit.)
A list of manufacturers of phase-contrast microscopes'' and reticles^ is given below to aid in selecting a proper instrument.
* Millipore Corp,, Bedford, Man*. 071*0. * Willson Products Div., P.O. Box 622, Reading, Penna. i%03. C. F. Casclla A Co. ltd., KegeM House, Britannia
90 February,1973
! Walk, London, N.l, England.
E. Leitz Inc., Rocklclfth, N.X. 07647.
\
<* Mine Safely Appliance Co., 201 Brnddock Avc,, Pitta-
Nikon Inc., Instrument Division, Garden City, N.Y.
| biirjih, 1`cnna. 1520H.
113.10.
j
4 Bemlix--Nlil, P.O. Box 390, Fall River, Mass. 02722.
Unitron Instrument Company, Microscope Sales Divl*
)
* Buu&ch and Lomb, Scientific Instrument Division.
sion, 66 Needham Street, Newton Highland, Mass. 02161.
| 72624 Bausch Street,Rochester, N.Y. 14602.
Carl Zeiss, 444 Fifth Avenue, New York, N.Y. 10016.
i
Olympus Microscopes, Micro Optics Company, 28163
' Edmund Scientific Co., 701 Edsorp Building, Barring
1 Greenfield, Southfield, Mich.4R075.
ton, N.J. 07007.
j!
American Optical Corporation, Reichert Products, Buf-
BGI, Incorporated, 39 Guinan St., Waltham, Main.
falo, N.Y. 14215.
02154.
| Joint AIHA-ACGIH Aerosol Hazards Evaluation Committee
AIHA
.'
ACGIH
!I Morion Lippmann, Ph.D., Chairman ! J. LcRoy Balzer, Ph.D.
Howard E. Ayer George Carson, Ph.D.
Douglas K. Craig, Ph.D.
Harry J. Eltinger
Graham W. Gibbs, Ph.D.
Murray Jacobson
William C. Janes
Geoffrey Knight
William H. Krebs, Ph.D.
Jeremiah R. Lynch
Carl A. Mangold
G. Major
Eric B. Sansone, Ph.D. .
Owen Moss
Marvin Tillery
Milton Scheinbaum
Thomas F. Tomb
Glen W. Sutton
Russell W. VanHouten
i Wesley R. VanPelt, Ph.D. Donald L. Webster
I (
i
i Industrial Hygiene Training in Israel
j Medical and engineering students at Tel Aviv University will be ob-
\ ligated in the future to undertake training in occupational safety, hygiene
j and health to inspire them with an awareness of their obligations for the
1
maintenance of the health of the worker and for the prevention of ill
j
j effects from work on man.
.
j This has been made possible by the establishment in 1974 by the
I
Faculties of Medicine and Engineering of the University, in collaboration
i
|
with the Ministry of Labor, of the National Insurance Institute and the
}
j
Workers Health Insurance (Kupat-Holim) of a Center for Occupational
t.t
; Safety, Hygiene and Health, with four major departments--Physiology of
i
Work and Rehabilitation, Occupational Toxicology, Occupational Hygiene,
l
j and Safety Engineering. It comes to fill long-standing gaps in the promo-
j lion of safety and health of the working population in Israel and the j absence of training facilities for specialists in these fields.
The new Center will immediately provide refresher courses for physicians
and nurses, but curricula for the training of Occupational Toxicologists,
Hygienists and Physiologists arc in preparation. Ultimately the Occupa-
tional Health Physician will also be trained at the Center.
Due to lack of suitable personnel in the country the Center is seeking
to recruit specialists from abroad.
%
FMSI 06272
Telephone (201) 945-0440
FRICTION
MATERIALS STANDARDS INSTITUTE,
BERGEN MALL OFFICE CENTER E. 210 ROUTE 4
PARAMUS. N J. 07652
INC.
February 23, 1977
Subject: Recommended Procedures for Reducing Asbestos Dust During Brake Servicing
Gentlemen:
As I'm sure you are aware, there have been questions raised concern ing exposure to asbestos dust during brake servicing. Actually, what applies to brake servicing might equally apply to clutch servic ing, except that ordinarily installers do not drill, cut or grind new clutch facings in the field.
As a result of the concern expressed in several quarters, two committees and our Board of Directors reviewed the problem, and have endorsed the enclosed "Recommended Procedures for Reducing Asbestos Dust During Brake Servicing."
It is felt that these are sound and workable procedures, and x*e suggest that your publication may wish to give them wider distri bution, either in a brief article on asbestos, or in a separate commentary on the subject.
You are free to use these recommendations as you see fit. There is no copyright involved, and it is not necessary to give credit to the Institute. If you wish to give credit, you may.
We believe that distribution of such information is in the best interests of all involved in the brake (and clutch) service business. If you have any questions, please let me know.
Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE
EWD/lmc
E. Ttf. Drislane Executive Director
FMSI 06273
RECOMMENDED PROCEDURES FOR REDUCING ASBESTOS DUST DURING BRAKE SERVICING
Because studies have indicated that exposure to excessive amounts of asbestos dust may be a potential health hazard, OSHA has set maximum limits of levels of airborne asbestos dust to which workers may be exposed. Since most automotive friction materials normally contain a sizable amount of asbestos, it is important that people who handle brake linings and clutch facings understand the nature of the problem and know the precautions to be taken.
1. Areas where brake work is done should be set aside if possible, and entrances should be posted with an asbestos exposure sign as follows:
Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Area Unless Your W.ork
Requires It Breathing Asbestos Dust May Be Hazardous
To Your Health
2. The amount of asbestos in the dust from brake lining wear is normally at an extremely low level because of chemical breakdown during use, and if machining of friction material does not take place, simple procedures will minimize exposure. During brake servicing, the mechanic snould wear an air purifying respirator, either a throwaway or one with replaceable particulate filter(s), as approved by the mining Enforcement and Safety Adminis tration or NIOSH. It should be worn during all procedures starting with the removal of the wheels and including reassembly.
3. During disassembly, all parts should be carefully placed on the floor to minimize the possibility of creating airborne dust. Dust should first be cleaned from the brake drums, brake backing plates and brake assemblies using an industrial type vacuum cleaner equipped with a high efficiency filter sys tem. After vacuum cleaning, any remaining dust should be removed by using a rag soaked in water and wrung until nearly dry. Under no circum stances should compressed air or dry brushing be used for cleaning.
4. Of extreme importance are the precautions which
must be taken during machining of friction ma terial. This is the operation in brake servicing when exposure to asbestos dust is at its highest. In addi
tion to the approved respirator, there must be local exhaust ventilation such that the worker exposures are maintained at least below the 1976 OSHA asbestos standards. If there is any question as to the efficiency of asbestos dust removal by the ma chine, the manufacturer should be contacted.
5. Industrial vacuum cleaner bags containing asbestos dust and cloths -used for wiping brake assemblies should be sealed in plastic bags and labeled with the following warning label printed in letters of sufficient size and contrast to be readily visible and legible:
Caution Contains Asbestos Fibers
Avoid Breathing Dust Breathing Asbestos Dust May Cause Serious
Bodily Harm
All asbestos waste should be disposed of in accord ance with the OSHA asbestos regulation. During removal of vacuum bags, an approved respirator, as described in (2) above should be worn.
6. All floor cleaning in areas where brakes are repaired . should be done with the high efficiency industrial vacuum cleaner as described in (3) above. Under no circumstances should dry sweeping take place. Grinding (arcing) machines should also be cleaned with such a vacuum cleaner and any remaining dust wiped with a damp cloth. An approved res pirator, as described previously should be used during this cleaning.
7. Although adherence to the above procedures should minimize any contamination of work clothing, it is necessary that the appropriate sections of the OSHA regulations on asbestos be followed when ceiling levels on asbestos dust exceed current stand ards. This could involve special clothing, change rooms, etc. At the very least the work clothes should not be taken home but should remain at work for industrial laundering.
8. Proper hygiene practices will help minimize ex posure to asbestos dust. Wash thoroughly before eating and do not eat in the work area. Remember, smoking is harmful to the hcnlth, and smoking coupled with breathing asbestos dust is extremely dangerous.
CAUTION: DO NOT BREATHE ASBESTOS DUST
FMSI 06274
V
V ` -The Hazards off Asbestos ffor Brake Mechanics
. > *
BARRV CASTLEMAN, LUCILLE A. CAMAROTA, ALBERT J. FRITSCH, iiUiAiN MAZZOCCHI, and ROBERT G. CRAWLEY
Asbestos is the generic name of a group of hydrated
magnesium silicate mineral fibcr$. There are two
groups of these minerals--serpentine (chrysotilc) and
amphibole (amositc, crocidolitc, anthophyllite,
trcmolitc, and actinolitc).. Ninety-five percent of the
world's asbestos production is chrysotilc.
Reports of epidemiologic and pathological studies
(1--4) reveal that occupational exposure to commercial
asbestos minerals enhances the likelihood of a number
of diseases--asbestosis and cancers of the lung, pleura,
peritoneum, larynx, and gastrointestinal tract. The
time from onset of exposure to the time of clinically ap
parent disease is usually more than 20 years. Cancer
from asbestos is not limited to workers who handle the
material. There arc also reports of pleural and
peritoneal mesothelioma (tumors rarely seen in the
general population) in persons with family, or
neighborhood, or indirect occupational exposure to
asbestos (4--7).
.
Mesothelioma was the cause of death of a man who
had regularly sanded vinyl asbestos floor tile (8). Under
simulated conditions of this man's work, a maximum
asbestos dust concentration of 1,3 fibers per ml (fibers
longer than 5 microns) was found in air samples passed
through membrane filters worn by a person sanding
vinyl asbestos (S). The type of asbestos now used in
domestic floor tile is chrysotilc--the same as that used
in brake friction materials, according to the Asbestos
Information Association. A ease of mesothelioma in a
brake mechanic has been reported (9). Clomntvitin! fritiluh niniefldU inetI In the United
States for braking passenger cars and trucks contain an
average composition of 50 percent chrysotilc by weight
(10). Asbestos has been used for brake drum linings,
disk pads, and clutch facings fob the past 50 years. Jacko and DuCharme (11) estimated that the United States annually uses 103 million pounds of asbestos for brake friction materials and 4.5 million pounds in automotive clutch friction materials.
In 1968 Lynch reported that because of the heat of friction caused by braking, almost all of the asbestos in brake linings is transformed to a nonfibrous mineral, and a small fraction of asbestos escapes as free fiber (12). Jacko and co-workers determined that vehicles in this country emit 158,000 pounds of asbestos per year, of which 11.2 percent is retailed in the brake and dis posed of during service (13).
Brake mechanics have low and intermittent exposure to asbestos. This exposure has been reported to be 0.79 fiber per ml time-weighted average (fibers longer than 5 microns), with peaks up to 7 fibers per ml when brake parts arc being cleaned (14). The standard method for removing dust from brake parts is to blow it out with a
DAir. Castleman, an environmental engineer, was with the Center Jar Science in the Public Interest when this paper was prepared; he is now with the Maryland Public Interest Research Group. Dr. Erilsch is dirtclor of the Center for Science in the Public Interest. Ms. Camarota is an occupational health nurse, District oj Columbia Department of Human Resources. Ms. Ma^uahi was a research associate, Environmental Cancer Research Project, Environmental Sciences Laboratory, Mount Sinai School of Medicine, New York City. Mr. Cratvley is a Sanitarian, Ilnltimore County Department of Health.
Tenrshe/t tet/tierii to Hurry Cattleman, Maryland Public Interest Research Group, 3110 New Alain Dining Hall, University of Ataryland, College Park, Aid. 20742.
2&4 frvt>1>C Ho*l.h ftaporU
FMSt 06275
- ^compressed ;\ir hose. In 1970 several reports ( //-/<>')
T described die levels of exposure of brake mechanics to * asbestos; alternative fiiction materials, and specific
changes in brake repair practices which would reduce the levels of exposure.
Baltimore and Washington Studies
In December 1972, the llaltimore County Department
of Health mailed a I-page mimeographed circular to
about 130 establishments which provide brake repair
service. These businesses included new car and truck
dealerships, certified motor vehicle inspection stations,
and other concerns advertising brake repair as a
specialty. Some of the establishments initially con-
tacicd hail cither gone out of business or replied that
. they do not do brake repairs. The circular warned that
inhalation of the dust from brake cleaning could cause
serious diseases, including cancer, and advised
vacuuming brakes of accumulated dust. Additional
measures suggested were improved ventilation and the use of face masks ( W). Two student volunteers went to
100 of tiie places on the'mailing list 4 months later to
ask shop managers what methods they were using in
brake repair.
A similar study was started in Washington, D.C., in
August 1973. This work was conducted by the Center
for Science in the Public Interest and the District of
Columbia Department of Human Resources. Of 186
brake service establishments initially contacted, 120
were followed up. Several new methods were tried in
ortlcr to improve the effectiveness of the warning. The
warnin'; leaflet was more eye-catching and readable
than the paragraph-form sheet used in Baltimore; the
leaflets were handed out by an occupational health
' nurse to the mechanics themselves--none were mailed;
and followup to ascertain the degree of effectiveness
was conducted by the same nurse who interviewed
the repair shop managers. The Washington study was
also featured in a local television program at the time
the leaflets were first handed out.
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To assure that students trained in brake repair by
public vocational schools would learn proper methods,
health officials met with appropriate school officials in
both locations. At the time they were contacted, school
officials in Baltimore anti Washington reported that the
schools were leaching the "blow out" method of brake
dust removal to the trainees.
.'
The standard met liorl of cleaning brakbs is "blowing
out" with a compressed air hose. In Baltimore, 63 per
cent (65 per I BO) of the brake repair establishments
contacted were using this method at the lime they
received the warning circulars. In Washington, the
figure was 91 percent (110 of 120). Most of the
managers and workers interviewed had never heard
/iboul the ha/,anions potential of brake dust. Predict
ably, the responses ranged from annoyance to apprecia
tion.
Of the 65 places in Baltimore initially blowing out
brakes, 11 were using either vacuum or wet brushing
methods at the lime of followup. Four others were still
blowing out brakes, but had improved ventilation or
provided- dust masks, or both, to reduce workers' ex
posures.
In Washington, only two establishments had
changed to wet brushing, but nope were vacuuming
brakes. Four others provided face masks. Interestingly,
two others decided to change brake shoes in all brake
repairs, thereby simplifying the problem of dust
removal and reducing the mechanics' exposures.
The degree of improvement, indexed by the percent-,
age of establishments converting from blowing out
brakes to safer techniques after a single warning, was
23 percent in Baltimore County and 7 percent in
Washington. This disparity probably arises more from
differences in the methods of the studies than from
differences in the study groups.
It may be critically important to approach manage
ment at the outset in order to enlist the cooperation
needed to implement any changes in practice. A
mechanic who is approached directly with a warning
may simply disregard it. The mechanic might reason
that if the dust were really dangerous, there would be a
law requiring the use of preferred methods in brake
repair. And the employer, if not asked to participate
from the beginning, may well conclude that he need not
be concerned with the matter. The failure to involve
management may be the main reason why the
Washington study produced less gratifying results than
the Baltimore study.
Brake warning programs consisting merely of mailed
warning notices require little manpower, compared to
other health programs. Also, the effort to implement
safe techniques in public vocational schools is lime well
spent.
Conclusion
.*
Over a 7-ycar period ending in 1976 (20,21), the U.S.
standard for time-averaged exposure to asbestos will
have been reduced from 5 million particles-per cubic
May-Juna 1075, VoL 90, No. 3 3SS
i
i i
/
t t
f
I
t 1 i
FN1SI 06276
t-fooi <>f .iir to (iIhts por ml (lilicib ImijjiT lit.in ii *, microns)? lor asbestos textile plants, this mluciiim is '"s about 15-foKI 1 22). 1`resntt anti sehecluletl stamlai ds \ claim only to protect workers ai;ainst nshrstosis, the
disease for which the dose-response relationship is most quantitatively known. The British standards for chrysotilc and amosite asbestos, which tire comparable to the asbestos standard scheduled to lake cl fee l in the United States in 1976, do not put port to provide protec tion against increased risk of cancer {23,21).
Previously studied cohorts of asbestos workers were exposed to time-averaged concentrations greater than 2 fibers per ml (fibers longer than 5 microns). Current studies of cohorts with time-averaged exposure on the order of 1 fiber per ml (greater than 5 microns in
length) may provide evidence of hazard at that level. In view of alarming preliminary findings of pulmonary
fibrosis in such a cohort, the National Institute of Oc cupational Safety and Health has suggested to the Department of Labor that consideration be* given to further lowering of the`asbestos standard (25).
The average brake mechanic is not aware of the potcr.iial hazard of ai; borne brake dust. Nor is he quick to change time-hardened habits when warned of dangers if he cannot feel their effects. Nonetheless, sub stantial reduction in asbestos exposures during brake repair can be achieved by simple changes in technique, with the use of equipment already available in most brake service establishments.
In view of the tendency of the accumulating literature to reveal cancer induction from asbestos at progressive ly lower levels of exposure, mechanics should be ad vised not to blow out brake parts and to use instead methods which create less airborne dust. The manufac turers of automotive friction materials could easily at tach a clear hazard warning to every item sold.
The limited success of both the Baltimore and Washington studies shows the limited efficacy of volun tary compliance with health warnings--the shop managers and the mechanics simply do not have the same regard for a warning that they have for a regula tion. The margin of safety, if any, provided by the current asbestos standards has been sharply criticized as insufficient (26). While it is advisable that brake mechanics at least be warned of the potential hazard of their work, it is also apparent that blowing out.brakes will be a common practice so long as health regulations permit it.
References
7. Cooper, \V. C., ct al.: Asbestos--the need for and feasibility of air
pollution controls. National Acadenty of Science*, Washington,
D.C., 1971.
.
2- Scliurr, l. J., Hammond, r. C., and Churg, J.: Mortality ex
perience* of asbestos insulation worker*, Jn Proceeding* of the
International Conference on Pneumoconiosis, Johannesburg,
1969, edited by li. A. Shapiro. Oxford University lVe*i,
Capetown, South Africa, I97u, pp. 180--186.
J. Stell, P. M., and McGill, T.: Asbestos and laryngeal carcinoma.
L.imef 2; 4 If.- 41 7, Am; !!>, I9/.V
_
/. NYwhmne, M. I... and lhnmpuMi, II ; MrmtUrlimiM ol the
pleura and pet iloncuni following exp*.sun* t. asbestos in (he I .on*
don area. Hr J 1ml Med 22; 261 -2<.9
fi. Lichen, j., and Pistawka, II : McmthiTimna ami asbestos ex
posure. Arch Environ Health 1*1: 3VJ-563 (1907).
6. Wagner, J. 0., Slrggs, G. A ami Match.md, 1*.: Diffuse pleural
mesothelioma and .`Mu-sins exposure in 111<* North Western Cape
Province, Hr.| Iml Med I?: 230-271 (1900/. ^ '
7, D.dtpien, I1., Dabbrrt, A. F., and llin/, l.: Epidemiologic der
Picurainrsothriiom.v Vorlaufiger Herirht uber IIV F.dle aus drm
Hamburger. Kauni lYax I'ncumnl 23: 347 -- S5H (1909).
5. Murphy, R. L-, cl al.: Floor tile installation as a source of
ashestu* exposure. Am Rev Respir l)is 101: 370-380, October
1971.
''
9. Sullivan, R. J., anti Aihanassiadis, Y. C.: Preliminary air pnllu-
lion survey of asbestos. Nadonal Air Pollution Control Ad
ministration, Arm 09-27. RalcighfN.G., 1909, p. 32.
JO, Harwood, C.: Asbestos air pollution from the wear of brake
linings. Illinois Institute of Technology Research Institute.
Chicago, April 1972.
11. Jaeko. M Cl., and DuCliarmc, R.T.: Brake emissions* emission
measurements from brake and clutch linings from selected mobile
*ourccs, Environmental Protection Agency Report 68-04-OO20.
Ann Arbor, 1973.
'
12. Lynch, J.: [bake lining decomposition product*. J Air Pollut
Control Assoc 18: 82-1--826 (1968).
7J. Jaeko, M. G. DuCharmc, R. T., and joiners, J. H.: Brake and
. clutch emissions during vehicle operation. Paper presented at
Society of Automotive Engineers Meeting,'Detroit, MayM973.
14. Hickish, D. E., and Knight, K. L.: Exposure to asbestos during
brake maintenance. Ann Occup Hyg 13: 17 -- 21 (1970).
15. I latch, D.: Possible alternatives to asbestos as a friction material. Ann Occup Myg 13: 23 -- 29 (1970).
16. Knight, K. L-, and Hickish, D. ir; Investigations into alternative forms of control for dust generated during the cleaning of brake assemblies and drums. Attn Occup Hyg 13: 37--39 (1970).
17. Lee, G. L.: Removing dusts from brake assemblies during vehicle
servicing--alternative cleaning methods. Ann Occup Hyg 13:
33-36 (1970).
75. Bentley, M. L.: Control of the use *>f asbestos-containing friction
materials. Ann Occup. Hyg 13: 31--32 (1970).
19. U.S. Senate, Committee on Commerce: Toxic Substances Con
trol Act of 1973. Hearings before the Environment Subcom
mittee. Statement of H. Castlrm.m 93d Cong. U.S. Government
Printing Office, Washington. D.C., 1973, pp. 117, 349--350.
20. Guenther, G. C.: Emergency standard for exposure to asbestos
dust. Federal Register, vol. 36, No. 234, Dee. 7, 1971, pp.
23207-23208.
`
21. Guenther, G. C.: Standard for exposure to asbestos dust. Federal
Register, vol. 37, No. 110, June 7, 1972, pp. 11318* 1 1322.
22. Lynch, J. R., Ayer, U. E., and Johnson. D. *L.: The in
' tcrrelntionship of selected asbestos exposure indices. Am Ind Hyg
Assoc J 12: 598-601 (1970).
2.7. Hygiene standard for chrysotilc asl>e*u>* dust. Ann Occup Hyg
. II; 47-49 (1968).
2-1. Hygiene standards for airborne atnositc asbestos dust. Ann Oc-
cup Hyg 16: 1-5 (1973).
25. Key, M. M.: Reopening of asbestos standard. Memorandum to J.
Slender, Assistant Secretary of Labor, Occupational Safety and I le.dlli Administration. Office of Technical Publications,
National Institute for Occupational Safety and 1 lealth, Rockville, Md., Marsh 28, 1974. '
2fi. Gee, U., ami Hoohuys, A.: Action ti\a*lexio. N EnglJ Med 285: 1317-1318, Dec. 2, 1971,
266 Public Health Report*
FMSI 06277