Document 0qd61vO38RNLL6GM0KGMwX68V

- FRICTIO~ HATERIALS STANDARDS INSTITUTE, INC., E-210 ROU'fE /14, PAIW-1US, N.J. 07652 l1:!:NUTES OF THE Hl~ETING of the ASBESTOS STUDY COI-&UTTEE Friday, October 24, 1975, at 9:30AM Institute Office, E-210 Route 4, Paramus, N.J. lffi:tffiERS PRESENT H. Hagner, Chairman E. H. Feierabend D. E. Stone I. H. \Jeaver J. Dunderdale Carlisle Corporation Ahex Corporation Bendix Corporation Raybestos-l~nhattan, Inc. Royal Industries OTHERS PRESENT H. R. Cole E. H. Drislane Clapp & Eisenberg Friction Uaterials Standards TnsLl.l:ute NEHBERS NOT PRESENT H. Jacko E. P. Stefl Bendix Corporation H. K. Porter Co. The meeting was called to order by Hr. \<Tagner, Chairman, at 9:30 A.M. HINUTES OF PREVIOUS HEETlilG The Hinutes of the Heeting held April 28, 1975 had been distributed. These minutes '-1ere reviewed and a motion for their acceptance uas made. Upon motion duly made, seconded and unanimously passed, it -o;.;ras RESOLVED: To accept the minutes of the April 28, 1975 meeting as '"ritten. ASBESTOS Il!FO'&'fATION ASSOCIATIOH CONFEREl~CE FMSI 06378 The Asbestos Information Association (AlA) held their annual GovernmentIndus try Conference in Hashington on September 10-11, 19 75. Non-members of AlA uere invited to attend this conference. Several individuals representing friction materials attended. 8ne of the iteT'ls of interest ~vas the proposed OSHA regulation uhich uas due near the end of September. It had been indicated that the OSHA standards would be oriented more tmvards work practices than to a numerical standard. t1r. Heaver indicated that the OSHA individual who indicated this did so believing that the ne\-t standard \oTould not have a nen numerical limit. Apparently there was alot of movement ,.;rithin OSHA by other groups--possibly labor unions and NIOSH--and that the proposed lm-1er numerical standard came in at the very end of the write-up as it was .( Minutes of the Meeting Asbestos Study Committee -2- October 24, 1975 prepared for publication. The standard, 111hich 't-lill be discussed later, proposed a numerical standard of 0.5 fibers/cc (Tl.JA). Several attendees stated that this conference was most \11orthl-:hile. It gave a good overvie1 on asbestos. The only criticism made was that the speakers did not have sufficient time to be questioned after their presentations. The Institute ~..rill continue to monitor this conference and expresses its support of the \..rork of the AIA. PLANS FOR INSTITUTE SEMINAR ON ASBESTOS T1r. Hagner and Hr. Drislane had taken the initial steps to organize this seminar. At the April 28, 1975 meeting of the Asbestos Study Committee a resolution uas passed recommending that the Institute sponsor a workshop on the asbestos problem in the fall of 1975. This resolution t11as revia-1ed N'ith the President of the Institute, Hr. Simon, and it t~Tas decided to proceed t-dth such a seminar. :Hr. Wagner contacted 1~. Noel Hendry of Johns-~~nville relative to his putting on a session similar to that 't~Yhich J-H presented t\-70 years ago. (For reference: ~1r. Noel Hendry, Denver, Colorado, telephone 303-770-1000, Extension 2142). It \laS suggested that the Johns-Hanville presentation t-:ould have to be the corner-stone of any seminar and that this would have to be arranged first before arranging other presentations. Hr. B. K. K,ron of OSHA had been invited by Hr. Wagner to address this seminar. l:lr. K\wn had indicated that he should be able to attend. It tYas suggested that the seminar t.rould be a good time for a synopsis of the major points of the ne,.,. OSHA standard. Also it t-:ould be t7ell for Ur. Kuon to talk with people from our industry. A comment was made to the effect that OSHA had misled those attending the conference in Uashington indicating that the proposed standard ~muld be '.York practices oriented. (The standard came out "lith a lot11er numerical limit.) It was stated that Iir. Kwon tl1as knm-1ledgeable in the indust-.:i.a.l hygiene area but he uas not a policy maker. He 'tYas not responsible for the addition of numerical standard in the proposed amendments to the OSHA regulations. Mr. Drislane indicated that he had talked tl1ith Hr. Bob Uereness of the Asbestos Information Association, and Hr. Hereness indicated that he \-Tould be pleased to attend. Also Ur. Drislane contacted Hr. R. Magdelain of Hilfisk of America Inc. }~r. Magdelain l-TOuld be most pleased to put on a presentation relative to that type of vacuum cleaner for the work place. E:r. Hagner also talked ~.;rith Ur. 1'1. Engeleightener of Ferro-Tech relative to their pelletizing equipment. }1r. Engeleightener will also make a presentation. At the meeting Hr. Hagner called ~Ir. Noel ~dry to firm up the J-M participation. In summary, it v1as indicatea that lir. Bill Rei tze tmuld discuss the medical aspects of the regulations. Ur. Ed Fenner vYould revieH OSHA and EPA regulations. Ur. Noel Hendry t.rould discuss fiber handling. The J-E lJresentation 11ill rcquir:ea 35 nun projector, a 60 x 60 screen, along with a podium and a PA system. l'1r. Drislane indicated that arrangements for these ~-1ould be made. FMSI 06379 Minutes of the ~!ecting Asbestos Study Committee -3- October 24, 1975 The seminar uill be scheduled for Uedncsday, December 3, and Thursday, December 4. The opening session will be a presentation by Johns-11a.nville for the full afternoon on December 3. Other topics will be scheduled on Thursday morning, ~~ith !lr. Mereness (or someone else from AlA) talking at the luncheon on Thursday. There would be a registration fee of $10 for the seminar. Hr. Drislane l.rill try to make arrangements at either the llarriott at Saddle Brook, the Ramada Inn in Rochelle Park, or the Sheraton Heights in l~asbrouck Heights. !!r. Drislane will write !fr. Magdelain and Mr. Mereness to officially.invite them. :Hr. Wagner will write toUr. KtTOn, Ur. Engeleightener, and ~tr. i:!endry to firm up the arrangements. The committee recommends that Messrs. Wagner and Drislane plan and schedule the seminar. It was suggested that the type of person to be invited should be someone involved with plant problems, but it should also be the foreman or other individual ~.mo could get across the message to not use an air hose or a broom. The possibility of a movie being shoun ~7as discussed. It was suggested that the controversial interview of Dr. Selikoff and Dr. L~.rinsohn of Turner Brothers ..;.rould not be the right presentation. Perhaps a movie that emphasized controls in the ..rork place might be l.rorthwhile. 1-ro decision t~as made as regards a movie. Another suggestion was to have a presentation by those who have used foam to envelope the 't.rork station so that no dust is raised during mixing. Hr. Heaver felt that this toms an interesting technique. Ur. Stone had discussed this at an earlier meeting but had made no further progress on this since that time. It was decided that this would not be added to the agenda. As regards the IUlfisk equipment, it t~as noted that this is good equipment for local pick-up of dust and debris in the work place. Hot-7ever, this subject should be expanded to include a central system such as a Hoffman unit. It ~~as felt that this session should be called "housekeeping in the work placed rather than "Nilfisk". Hrn.rever, the Nilfisk representative would discuss his unique equipment. The idea was to sell the concept of cleaning the T:10rk area (not to sell the vacuum cleaner). Hr. Drislane will indicate this particular point to l!r. :ragdelain in his invitation. AIA BOCKLET "ASBESTOS AND BRAKE LININGS" 11r. Hereness requested Hr. Drislane to have this booklet reviewed for update and corrections. The first question raised was "mto is this booklet aimed at? 11 Also, "~.Jhat is the purpose of this booklet?" It 1r1as stated that this write-up was not a complete presentation of any particular aspect of the asbestos problem, and while interesting insofar as it went, was not particularly convincing. It is not the type of message that would ordinarily be given to customers of friction material manufacturers. The nessage for re-builders and the garage people is to not create dust in the work place. There should be more emphasis, if this T.ras the direction of the booklet, on such things as labellin~, possible use of instruction sheets, the handling of lining, and the proper use of exhaust systems. One of the problems in the field is that these customers T.Yill often groove, chamfer or provide extra drilling. It is during these subsequent operations that asbestos concentrations may be raised to levels above that allowable. It was pointed out the Asbestos Study Committee could not re-write a draft unless it knew ~~hat the booklet was aiming at. It '~as stated that the title is wrong. Perhaps there should FMSI 06380 t 'I Hinutes of the Heeting Asbestos Study Committee -4- October 24, 1975 be t'.Jo separate pamphlets, one for the garage and the re-builder type operation (for those v7ho are doing brake service), and another for the general public. It ~.,as stated that the audience for this booklet, as written, must have been the environmentally concerned customer. llr. Weaver suggested alternatives as regards this write-up: (1) Drop it-do not use it. (2) Re~.-1rite it for those servicing and installing friction materials. (3) Hrite a complete new article. The '"rite-up made has lit~le impact. One advantage may be the listing of reference material at the end of the booklet. If the AlA believes that the booklet should get to the user (the cuctomer of the friction materials manufacturer) it is suggested that information be given to the user as indicated in the proposed regulations under nDA:~GER" labels. This concerns the requirement during "any reasonably forseeable use, handling, storage, disposal, processing, or transportation" that no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed be released. The items that foll~v this section on housekeeping and waste disposal are particularly pertinent to the users of friction materials prior to installation on a vehicle. Hr. Drislane 'vas advised that the Asbestos Study Committee will not re-write the article. The Committee recommends emphasis on recommendations for garages and the re-builders. The Cow~ttee would be happy to review a neH write-up prepared by AlA l>Jhich tvas aimed for this user, with emphasis on the those uho actually do subsequent work on friction materials such as grooving, cutting, grinding, chamfering, etc. RECIT~llifiDED PROCEDURE FOR BRAKE &iD CLUTCH SERVICING This '"'rite-up had been prepared by the Raybestos-Hanhattan, Inc. Y.oc. Heaver distributed copies to Committee members. Raybestos would welcome comments on this ~>Trite-up along "lith any recommendations for changes. Committee members T:lishing to comment should send their recommendations to the Institute office. THE PROPOSED OSHA STAilDARD AND THE 0. 5 FIBER/CC LIMIT Prior to discussing details on the proposed OSl~ standards, several members stated that they had been inspected by OSHA. Tlhile in a few cases citations were made for higher concentrations of asbestos than permitted, there had been many instances where counts were made ~7ithout a citation. Vlhile the values on the concentration are revealed uhen a citation is made, OSHA does not provide information on the counts '"hen a citation is not issued. Several meribers indicated that they believed that OSHA will not provide written results on their test in the vJOrk place unless it is necessary to support a citation. In other uords, l>There a citation is not involved they \.;rill not reveal the data. Legal Counsel lV'ill check on the availability of this information and >vhether OSHA can be requested to provide this data when a citation is not involved, and ~V'ill report in writing to the Institute on th:!.s. T:1e proposed OSHA standard is far reaching. The main problem is the neu more difficult numerical standard (0.5 fiber/cc). OSHA has put out a list of rather specific items for public participation with the main item being that the comments must be postmarked on or before December 8, 1975. FMSI 06381 J Minutes of the Heeting Asbestos Study Committee -5- October 24, 1975 Written comments concerning the proposal must be submitted in quadruplicate: DoCket Officer, Docket H-033 US Department of Labor, Room N3620 200 Constitution Avenue N.W. Washington, D.C. 20210 The question t.ras asked as to what would be the most effective means of communicating t.rith Washington to indicate the problems trlth this new numerical standard. Should the Institute comment? Should the individual members comment? It is not enough for the manufacturer to feel his views will be represented to the regulators by the Asbestos Information Association or FHSI. It tvas suggested that it would be best if both the Institute and individual members respond uith points that are particular to their factories. It is felt that participation by the small manufacturer will be most meaningful. The Asbestos Study Committee t.rill revietlf the proposed standard and note some of the points that members may wish to comment on. It should be pointed out that even if members comment to the effect that they support the AlA comments or they support the FUSI comments, at least they will be on record espousing their viewpoints. A comment was made to the effect that everyone has been gearing to get their concentrations dotm to the 2 fiber/cc limit by July 1, 1976. The technology necessary to take the count down to 0.5 fiber/cc is not knmm. How can comments be made on the cost impact, effects on competition, effects on employment, effects on energy supply, t7hen the technology for getting to the 0.5 fiber/cc is not even knrnm at this time? The least that can be done is to request an extension of time for comments past December 8, 1975. Upon motion duly made, seconded, unanimously passed it t~as RESOLVED: That the Institute tvill request the Department of Labor to delay the cut-off date for comment on these proposed amendments to April 1, 1976. The friction materials industry does not knrn.r whether the 0.5 fiber/cc limit can be reached. Perhaps it uill be necessary to go to materials with a material cost ten times that of asbestos in order to get the wprk place dmm to the proposed level. Industry is confronted with requirements for Standard 121 and Standard 105-75 from the National Highway Traffic Safety Administration tvith stringent friction materials requirements at the same time that they must evaluate whether they can s.t.i11 use asbestos in their products. There are several points in the OSHA standard besides the 0.5 fiber/cc limit. However, the main problem is the 0.5 fiber/cc limit. Some of the comments to follmv concerned ne\17 problems that may arise as a result of this proposed standard. These problems vill be pointed out to the members so that they can look at these from their vi6-Tpoints \vith the aim of advisinp, Hashington on their individual problems ~-tith this standard. The reduction of the limit to the 0.5 level is going to effect processors such as the re-builder and the garages who were not really included in this standard before. Any outfit that handles friction materials may very ~~ell find airborne concentrations of asbestos fibers that exceed the 0.5 fiber/cc level. For example, a junk yard lvhich might have a side line in brakes might have no problem at the present time. However FMSI 06382 ' Hinutes of the Ueeting Asbestos Study Committee -6- October 24, 1975 any work that they migl1t do :rhich could bring their concentration above 0.5 fiberlcc to7ould nm-1 be a problem. These people t-lould now be covered by the requirements of the OSHA standard. Many smaller operators have to drill materials to adapt them to unique shoes in the field. Additional drilling l-Jould probably move concentration levels lo7ell above the maximum ceiling concentration of 5 fiberlcc. A point to be mentioned is not to adopt the tactic of "You can't do it ... The point is that at the present time technology is not available in the factory to get down to these levels. The industry does not knm-1 what the costs are. H~-1 can comments be made on cost impact, competition, employment, energy, etc. lo7hen the technology to get there is not known? Still further, is such a limit necessary? It is suggested that unless a member has specific medical information suitable to refute the proposals in the standard that he not attempt to resist the 0.5 fiberlcc limit based on non professional observations of v10rkers made in the past. In other words, if it \7as not good medical information don't use it. The Asbestos Information Association lo7ill try to assemble some realistic medical information for consideration by the Department of Labor. As regards the problen uith cost impact on the consumers, it may be that clean rooms for the elimination of asbestos may be required. Hithout knm-ling figures perhaps costs "1111 more than double with poorer performance at a time lo7hen the National Highway Traffic Safety Administration is calling for even higher performance. llembers have made extensive plans for equipment, exhaust systems and procedures to set to the 2 fiberslcc limit on July 1, 1976. Since this equipment will not get them to the 0.5 fiberlcc level, this huge capital investment should perhaps be stopped until such time as a new standard is decided. Should a manufacturer discontinue his heavy commitment to equipment for the 2 fibers Icc limit Hhen this equipment will not meet the 0.5 fiberslcc limit? Could there be more emphasis on protective clothing with cover-alls, smocks, boots and gloves as \Tell as a respirators. Hi th reduction to the tl.ro fibers Icc level on July 1, 19 76 and better \10rk practices, the clothing might do the job as vJell as the nevJ difficult-to-measure 0.5 fiberlcc limit. The members don't knm-1 hmT lm.r they can get in fiber counts until this new collection equipment is actually installed and in operation. Suggestions made for cleaning the -vrorl~ area are all well and good but the only proof that one has reached an arbitrary fiber limit is when the installation is completed. As regards energy "1ho can say that if double the horsepm~er was added to collection systems that they tmuld get do-vm to the new limit? How can the energy cost be estimated until this same equipment has actually reduced the concentrations dm-in to the new levels? llliere regulated areas are established where allowable concentrations may be exceeded, it is difficult to get employees to wear the proper clothing. If one to1ere trying to operate a clean room along uith proper protective clothing, employees t.muld t-Tant air-conditioning in the FMSI 06383 Ninutes of the Heeting Asbestos Study Committee -7- October 24, 1975 work place for the uncomfortable clothing. To require air-conditioning in the work place while also ~~intaining the extensive exhaust systems would be prohibitively expensive--if it can be done at all--because one is at cross purposes lvith the other. Costs also will be increased because of the new monitoring requirements. As regards the effect on competition it uas pointed out that this may very well be the trigger which l7ould close do<.m some marginal operations with a resulting transfer of jobs outside of the U.S. Even in Great Britain Hhere much medical information has been gathered they have not gone to the 0.5 fibers/cc limit. It does not appear that Great Britain has sufficient medical evidence to support such a limit. Countries on the continent do not have this 0.5 fiber/cc limit. The Latin American countries have no limits. As regards the effect on employment and competition, the huFe capital expenditures required for the U.S. plants may very well export additional jobs. llliile some of the procedures recommended for handling asbestos and removing the \-lorker from contact Hith the product may shoH labor saving results, the actual level of exposure to the remaining workmen from these chan~es still will be quite high. There t.;rould be considerable costs for members in the friction materials industry to requalify brake blocks and heavy duty segments for the requirements of the NHTSA Standard 121 which \Tent into effect during 1975. There has been a considerable expenditure of funds for Standard 105-75 (hydraulic brake systems standard} by nany members. Any changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard ~vould add additional costs for manufacturers in requalifying their materials. The friction materials industry in particular is caught beo1een the forces of improved performance of braking materials along with restrictions on hem to manufacture and distribute their materials. There may be considerable testing to requalify materials if there should be a change in processing or compounding. As regards the costs to consumers and society in general the industry does not know t11hat can be done if it is necessary to remove asbestos from brake lining. The industry could be subject to 5 - 10 years of serious dislocation. In addition to the problems with the OSHA standard that appear evident, costs can not be quantified at this tifle. Industry needs more time to respond to these far reaching regulations. One of the requirements for record keeping stated that the records must be maintained for forty years, or for an employment interval plus 20 years, ~-1hich ever is longer. This is a considerable record keeping requirement. Hmvever it uas stated that perhaps this is necessary in order for subsequent study of the epidemilogy of asbestos. It was suggested that perhaps this is one of the ne'" proposals that can be lived Hith. In prior meetings and at prior workshops the problem of correlation of fiber count has been discussed. In eeneral there seems to be some agreement that different experienced counters may total up results showing as much as a 30% variation in counts from the same sample. This is already a problem. However these counts where the 30% variation is evidenced are in the 2 fibers per cc to 5 fibers/cc area. A 30% difference with a 5 fiber/cc count is 1.5 fiber/cc. Here, OSHA is asking for a concentration limit of 0.5 fibers/cc when tdth current observations there can be variations of as muCh as 1.5 fibers/cc. As concentrations move towards 0.5 fibers/cc not only does technology get -----'"--- '-~-~~= ...,,.,,...., nf n nroblem. ! .l ~ Hinute~ of the Heating Asbestos Study Committee -8- October 24, 1975 Industry conditions in 1975 (under the current 5 fibers/cc limit) are much improved over industry conditions l~hich were in effect through most of the 1960's. Each additional step approaching zero fibers/cc is a lot more difficult than the steps that were taken to get industry down to the 5 fibers/cc limit. While it will be burdensome to move the concentrations to the 2 fibers/cc limit, the steps necessary to get down to 0.5 fibers/cc are not known. There are requirements in the proposed standard for '~orker re-assignment. If many employees are moved to lesser and lesser duties maintaining the same premium pay that they had received for working with the asbestos products, there lIill be a negative productivity result. It has been industry practice in the past for night shifts and more difficult tasks to command higher pay preiums. This rotation to another job with no loss in pay will be another penalty to productivity. The recommendations that will be made by the Fl'1SI or the AIA are not knmm at this time. It is believed that the AlA stand will include background on medical information. H~ever, it is most important that the individual companies make a response. They should not expect that someone else will urite it for them. The Secretary '-Till prepare a bulletin to be sent to the membership suggesting that they comment to OSHA on these requirements. It r-Jill be pointed out that the comr.tents must be those of the individual member and they should not echo the suggested outline of problems which the Institute Hill prepare. It Has also pointed out that there are a lot of new items in the proposed regulations including items on loading, unloading and storing of asbestos cargo. The carrier--be it a railcar, ship or other--must make a visual inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed. Hho does this? Does the carrier do this? Are the carriers aware of this problem? A close reading of the proposed OSHA standards revealed many problems of this nature ll1hich ldll have to be pointed out to others who may not feel that they are affected by the asbestos regulations. TilE EPA NATIONAL EMISSIONS STANDARDS FOR ASBESTOS FMSI 06385 The Environmental Protection Agency published the amended standards for the .~ational Emissions Standards for Asbestos. This appeared in the Federal Register October 14, 1975. Ordinarily the EPA amendments ,.,.ould be an item of prime concern to the manufacturers. However the proposed OSHA standards are so extensive and so far reaching they must take priority over these nel.r EPA Standards. It ~ras pointed out that the EPA notice is the adoption of the amendments to the standards. These are not proposed amendments. In particular the waste disposal requirements are of interest to friction materials manufacturers. The friction materials manufacturer is responsible to see that land-fill operators and trucks carrying waste comply with the requirements of EPA on disposal of asbestos bearing materials. The manufacturer is responsible for supervision to see that these requirements are carried out. Uembers revicned the section 61.25 on l.raste disposal. There lMS some difficulty \vith interpretation. lir. Heaver pointed out that the requirements for covering the asbestos containing material were applicable only if there ,..ere visible emissions to the outside air from the ll1aste disposal site. In other t11ords, if there t.:rere"no visible emissions" requirements (e) (1) and (e) (2) Hinutes of the Heeting Asbestos Study Committee -9- October 24, 1975 of 61.25 do not come into play. Ho11ever these requirements for cover do take effect if there are any visible emissions. The most difficult areas of the new EPA standard are in the waste disposal area. There was no other business called to the attention of the committee. Upon motion duly made, seconded and unanimously passed it was RESOLVED: To adjourn. Adjourned: 2:15 PM E. W. Drislane Secretary ' FMSI 06386