Document 1g4aGjOMGn9pjeEk3z2rQdZgm

ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE - TASK FORCE REPORT Engineering Staff Manufacturing Staff May 27, 1980 8006 1306 SCF-ALLF-08132 ' PRODUCED BY FORD CARCINOGENS IN THE WORKPLACE INTRODUCTION At the October 1-979 joint meeting of the Engineering and Research and Manufacturing and Supply Subcommittees, a report on the Occupational Safety and Health Administration (OSHA) Policy for Regulating Workplace Carcinogens was presented by Personnel and Organization Staff. This report noted that final regulations for carcinogens in the workplace were anticipated by the end of 1979. It was agreed that efforts to eliminate the use of potential carcinogens where possible should be preceded by analysis of the affected materials and processes. In this- regard, a Task Force was established by the Subcommittees to identify carcinogens and quantities in use, set targets for elimination ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify and control potentially carcinogenic substances. Since October, OSHA has released Its Policy which establishes criteria and procedures for the identification, classification and regulation of potential carcinogens in the workplace. The Policy further defines Category I potential carcinogens as substances known to be carcinogenic in humans or which have- been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are those where data are suggestive of carcinogenicity in humans and test animals. The Policy also outlines criteria for classifying a substance into Categories I or II and establishes the mechanism for issuance of standards governing use of a particular substance. No specific substances were categorized, or standards promulgated, with the issuance of the Policy. Normally, once the need for a standard is determined by OSHA, it could take one to two years before the standard is issued. If an "Emergency Standard" is set, the ruling is issued and immediate compliance is required. A number of court challenges of the new Policy are expected to center primarily on stringent rules virtually precluding use of negative evidence studies when defining the carcinogenicity of a substance and cost/benefit criteria. A draft list of candidate substances governed by the Policy, was issued by OSHA two years ago. A revised list is expected to be released in July, 1980 followed by a prioritized extract in September. The Task Force has concentrated on developing the capability for managing the eliminaation or control of Category I potential carcinogens in the workplace. A start has been made in identifying specific applications for subsequent elimination or control of asbestos, hexavalent chromium compounds and benzene. 8006 1307 -1 - May 27, 1980 ' PRODUCED BY FORD FEDERAL ACTS REGULATING TOXIC/IIA7.ARDOUS MATERIALS JJAVJNC JMPACT ON THE COMPANY FIGUHF. I Workplace Related Occupational Safety and Health Act - 1970 D.O.L. (OSHA) Hazardous Materials Transportation Act - 1975 D.O.T. (HTMA) Toxic Substances Control Act * 1976 E.P.A. (TSCA) Resource Conservation and Recovery Act * 1976 E.P.A. (RCRA) Clean Air Act and Clean Water Act Amendments - (CAA) 1977/78 E.P.A. Packaging tc Slacking Federal Hazardous Substances Act -1970 Poison Prevention Packaging Act - 1970 Consumer Product Safety Act - 1972 Waste Management Resource Conservation and Recovery Act -- 1976 E.P.A. (RCRA) FIGURE 2 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) Staff ESES Responsible Activity - SSECO P&O - Employe Health Services MFG. STAFF - Safety Engrg. - Plant Engrg. Office . - Mfg. Engrg. & Systems - Plants EARS - Prog. Anal. & Metis. Engrg. - Research Staff SUPPLY - Trans, it Traffic OSHA Compliance Reporting Identification of Controls Monitoring Enforce Controls Facility Controls Development Process Controls Development . Process Controls Implementation Facility Control Implementation Develop new metis., mfg. processes, it measurement devices. REGULATORY ACT TSCA Compliance Reporting Material Inclusion in EPA Inventory . Interpretations . Eval. working conditions . Audit HMTA DOT lobel in Data Base Non-Prod. & Prod. Metis. Review Non-Prod. Mails. Review Packaging Storage Non-Prod. Metis, review ' Material Charocterization Production Metis. Review Compliance Reporting - 2f - May 27, 1980 ' PRODUCED BY FORD BACKGROUND Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated by the U.S. Department of Health, Education and Welfare that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.SL might be associated with occupational factors.-' Accordingly, Personnel and Organization Staff, Employe Health Services, has been involved in a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. - Public concerns relating to the control of toxic/hazardous materials, are shared by the Company and the UAW. The right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques and by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines of $25,000 per day; a citation normally consists of multiple related violations. Litigation is also a growing concern. For example at present the Office of the General Counsel has three suits pending, involving deaths allegedly due to the inhalation of asbestos. Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been .issued, additional standards are anticipated, and the level of economic risk has increased. 1/ Federal Register 45(15): 5031, January 22, 1980. 8006 1309 -2 - May 27, 1980 ' PRODUCED BY FORD FIGURE 3 REPRESENTATIVE PAST COMPANY ACTIONS Production . Removal of lead and chromium from topcoat paints for passenger vehicles. . Removal of "Tris" flame retardant ` . Controls instituted for asbestos in new designs. - Nonproduction . . Removal of asbestos from, . - Structural fireproofing - Thermal insulation - Molding compounds ' . . Substitution of vacuum for air blowing in broke and clutch maintenance . Protection of personnel potentially exposed to benzene in light oil tanker loading operations . . Substitution for lead-containing maintenance oils . Substitution for benzene-containing adhesives . Reduction of lead-chromates in vinyl operations - 3f - May 2?, 1980 8006 1310 PRODUCED BY FORD REPRESENTATIVE PAST COMPANY ACTIONS (Fig. 3) The Company has issued Directive B-101 which assigns responsibilities for Toxic/Huzardous . material control. Product Engineering Procedure PEP 3-189 and Manufacturing Procedure Il.d.l. provide for systematic review and clearance of new production and nonproduction materials. Production Materials . In response to OSHA regulations issued in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. In 1979, Car Engineering released a practice banning new designs containing asbestos unless a documented rationale for its use is provided and it is encapsulated. Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction stand ards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. Since 1973 new suppliers have been required to furnish complete compositional data to obtain clearances prior to use in the plants. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with lead naphthenate free M-2C142 materials, and deleted the use of asbestos containing molding com pound for heater housings at Sheldon Road. In 1978, an adhesive used at San Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories were revised to eliminate benzene, where possible. The volume of lead-chromate employed in vinyl plant operations was reduced and ventilation/protective measures were identified at the Romeo Tractor Plant to minimize potential hazards from chromium compounds used in painting. -3 . May 27, 1980 8006 1311 ' PRODUCED BY FORD FIGURE 4 TASK FOnCECIIARTl-lt Tho Task Force was chartered by Fill and M&S Subcommittees (Meeting of 10/24/791 for coordinating plans and efforts to: . 1. Identify substances in use (OSI1A Categories I and II). i. 2. Determine quantities used (for materials regulated by Michigan Department of Noturat Resources). ' 3. Set targets for elimination of as many Category I substances os possible. 4. Take aggressive steps to find substitutes for as many Category I substances os possible in anticipation of government regulations. . ' 5. Develop o policy and action plan for eliminating potential carcinogens where possible. 6. Organize to identify substances systematically. ' FIGURE 5 1979 USAGE OF MICHIGAN CRITICAL MATERIAL AS REPORTED TO MATS* (ADJUSTED BY Till" PLANTS IN TIIEIU MDNR REPORTS! Moteriel Acrylic Acid Acrylonitrile Aniline Antimony Arsenic Benzene Cadmium Chromium Cloroprene ' Cobalt ' Copper Cyanides Dichlorobenzenes Formaldehyde Hydrazcne Hydroquinone Hypochlorite Lead Lithium Nickel Phenol Selenium Silver Silieon-Dioxide Coated Lead Chromate Styrene Tetracloroethylenc Thiourea Triaryl Phosphate Esters Trichloroethylene . Vinyl Chloride Zinc Lbs. of Usage 251.707 641,133 90 830,571 11,157 ` 385,028 ' 3,311 81,377 24,676 210 321,704 923,069. 2,542 488,965 130 1 15,841,758 626,027 123 126,624 5,839 127 25 2,317 1,413,986 1,095 18 160,022 91,849 118 1,085,724 __Principo) Users PPV - Paint ' PPV - Paint MCC, Dbn. Glass, T&C Sterling PPV - Vinyl T&C Vandyke. PPV - Vinyl AAD - Dearborn Assy., Gen. Service PPV - Vinyl PPV - Paint. EED - Ypsi. AAD > Utica PPV - Saline AAD - Dearborn, PPV - Saline, MSD Monroe MSD * Monroe FTO - Highland Park MCC. PPV - Paint PPV PPV * Vinyl MSD - Monroe AAD * Wayne/Dearborn, PPV - Paint ED - Northville, T&C Sterling MSD - Monroe, T&C Sterling Mich. Cast. Cntr. T&C Sterling T&C Sterling PPV PPV-Milan, PPV-Vinyl AADGO, Mich. Prov. Grnd. PPV - Vinyl Steel, T&C Sterling EED - Rawsonville PPV - Vinyl PPV - Paint, AAD. FPSD, FTO Michigan locations reported to the State of Michigan but not to MATS: Detroit Industrial Engine Research & Engineering Center Research - Glendale Troy - Tractor Category I Potential Carcinogens . Vulcon Forge Dearborn Gloss Dearborn Specialty Foundry Wixom Assembly - 4f - Moy 27, 1980 8006 1312 PRODUCED BY FORD TASK FORCE CHARTER The complete Task Force Charter assigned by the Engineering and Research and Manufacturing and Supply Subcommittees is shown in Figure 4. To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategics to eliminate, where possible, the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. - A listing of 36 Category I substances or groups of substances in use in the automotive industry has been prepared. (Exhibit I), based on a 1978 MVMA Information Bulletin on substances associated with automotive production. - For materials regulated by Michigan Department of Natural ` Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used 81,377 pounds of chromium compounds, and 385,028 pounds of benzene (primarily in gasoline). Asbestos is not one of the currently designated critical materials. The largest use, 641,000 pounds of acrylonitrile principally at the PPV paint plant, is planned to be removed from topcoats by Job #1, 1981 and from DSO and fleet ' colors by year end, 1980. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances were examined in detail. -4- May 27, 1980 8006 1313 PRODUCED BY FORD FIGURE 6 POTENTIALLY CARCINOGENIC SUBSTANCES Prioritized ' Substance 1. Asbestos 2. Hexavalent Chromium Compounds 3. Benzene 4. Cadmium Oxides and inorganic salts 5. Coke Oven Emissions/ Coal Tar Pitch Volatiles 6. Vinyl Chloride 7. Beryllium Oxide and inorganic salts 8. Trichloroethylene Occurrence within Company Friction materials, gaskets, sealers Paint pigments . Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Vinyl Manufacturing Aluminum foundry operations Degreaser Current Exposure Limits 2 fibers/cc 52 yg/m3 (as Cr)* 10 ppm * 0.1 mg/m3, (fumes)*' 0.2 mg/ntr (dust)* 3 0.2 mg/m 1 ppm 2 yg/m3* 100 ppm* Exposure limit not based on carcinogenicity. 8006 1314 - 5f- May 27, 1080 PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES The highest priority of Category I substances contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6, along with exposure limits and typical usage. The complete listing is provided in Exhibit I. The substances are presented in order of priority as established by Task Force consensus. The development of a capability for managing the elimination/control of Category I potential carcinogens was determined by evaluating the scope of usage of asbestos, hexavalent chromium compounds and benzene (priority ranks 1, 2 and 3, respectively) as test cases. - May 27, 1980 8006 1315 ' PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES Asbestos FIGURE 7 Potential Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer FIGURE 8 Exposure Limits Time Weighted Average Time Weighted Average Ceiling OSHA ____________________NIOSH Proposed Regulation for Regulation Recommended (Fibers/cc) (Fibers/cc) (Fibers/cc) 2.0 10 . 0.5 5 0.1 FIGURE 9 Summary of Asbestos Usage Production Nonproduction Clutch Plates Drake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Brake Linings . Millboard Asbestos Reinforced Paper Core A Mold Making Sealers ' Safety Apparel Clutch Platps ' 00 o o o IM O- - 6f - May 27, 1980 PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES Asbestos During the past several years, OSHA has reported evidence of a link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer (Fig. 7). These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. ' _ The permissible exposure limit by OSHA is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group in The Department of Health and Human Ser vices (formerly HEW) has recommended to OSHA that limits be tightened to as low as 0.1 f/cc in 1980, (Fig. 8). Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban, under the Toxic Substances Control Act, on all non-critical uses may occur as early as 1985. . Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of vehicles, manufacturing equipment and plants. -6 May 27, 1980 8006 1317 PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES Chromium Compounds it ' i' Potential Health Effects on Humans Hexavalent Chromium Compounds FIGURE 10 Other Chromium Compounds Respiratory Tract Irritation/Perforation of Mucous Membranes, Bronchitis X X ERROR: timeout OFFENDING COMMAND: timeout STACK: -savelevel- PLAINTIFF'S exhibit FD-481 ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT Engineering Staff Manufacturing Staff May 27,1980 Rfidl lf7f> pponi ircri t>v 1 1 r CARCINOGENS IN THE WORKPLACE INTRODUCTION At the October 1979 joint meeting of the Engineering end Research and Manufacturing and Supply Subcommittees, a report on the Occupational Safety and Health Administration (OSHA) Policy for Regulating Workplace Carcinogens was presented by Personnel and . Organization Staff. This report noted that final regulations for carcinogens in the workplace were anticipated by the end of 1979. It was agreed that efforts to eliminate the use of potential carcinogens where possible should be preceded by analysis of the effected materials and processes. In this regard, a Task Force was established by the Subcommittees to identify carcinogens and quantities in use, set targets for elimination ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify and control potentially carcinogenic substances. - Since October, OSHA has released its Policy which establishes criteria and procedures for the identification, classification and regulation of potential carcinogens in the workplace. The Policy further defines Category I potential carcinogens as substances known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category D substances are those where data are suggestive of carcinogenicity in humans and test animals. The Policy also outlines criteria for classifying a substance into Categories I or n and establishes the mechanism for issuance of standards governing use of a particular substance. No specific substances were categorized, or standards promulgated, with the issuance of the Policy. Normally, once the . need for a standard is determined by OSHA, it could take one to two years before the standard is issued. If an "Emergency Standard" is set, the ruling is issued and immediate compliance is required. A number of court challenges of the new Policy are expected to center primarily on stringent rules virtually precluding use of negative evidence studies when defining the carcinogenicity of a substance and cost/benefit criteria. A draft list of candidate substances governed by the Policy was issued by OSHA two years ago. A revised list is expected to be released in July, 1980 followed by a prioritized extract in September. The Task Force has concentrated on developing the capability for managing the eliminaation or control of Category 1 potential carcinogens in the workplace. A start has been made in identifying specific applications for subsequent elimination or control of asbestos, hexevalcnt chromium compounds and benzene. i U '> \ 10QU -1 May 27, 1980 BACKGROUND -Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated by the U.S. Department of Health, Education and Welfare that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.S. might be associated with occupational factors.-' Accordingly, Personnel and Organization Staff, Employe Health Services, has been involved in a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. Public concerns relating to the control of toxic/hazardous materials, are shared by the Company and the UAW. The right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques and by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. l). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines of $25,000 per day; a citation normally consists of multiple related violations. Litigation is also a growing concern. For example at present the Office of the General Counsel has three suits pending, involving deaths allegedly due to the inhalation of asbestos. Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards ore anticipated, and the level of economic risk has increased. 1/ Federal Register 45(15): 5031, January 22,19B0. Hi.41 i nuu -2- May 27, 1980 PPOnTtppn pv poor* i ( REPRESENTATIVE PAST COMPANY ACTIONS {Fig. 3) The Company has issued Directive B-101 which assigns responsibilities for Toxic/Hazardous . material control. Product Engineering Procedure PEP 3-189 and Manufacturing Procedure D.d.1. provide for systematic review and clearance of new production and nonproduction materials. Production Materials In response to OSHA regulations issued in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job $1, 198D. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardunt treatment for fabrics, was removed during 1977. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. In 1979, Car Engineering released a practice banning new designs containing asbestos unless a documented rationale for its use is provided and it is encapsulated. Honproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction stand ards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. Since 1973 new suppliers hove been required to furnish complete compositional data to obtain clearances prior to use in the plants. In 1974, Steel Division light oil by-product tBnker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with lead naph- thenate free M-2C142 materials, and deleted the use of asbestos containing molding com pound for heater housings at Sheldon Road. In 1978, an adhesive used at San Jose wbs reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories were revised to eliminate benzene, where possible. The volume of lead-chromate employed in vinyl plant operations was reduced and ventilation/protcetive measures were identified at the Romeo Tractor Plant to minimize potential hazards from chromium compounds used in painting. - too* May 27, 1980 PPOTYnrpn pv prpr> TASK FORCE CHARTER The complete Task Force Charter assigned.by the Engineering and Research and Manufacturing end Supply Subcommittees is shown in Figure 4. To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate, where possible', the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. ^ - A listing of 36 Category I substances or groups of substances in use in the automotive industry has been prepared. (Exhibit I), based on a 1676 MVMA Information Bulletin on substances associated with automotive production. - For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure S. As reported to the State of Michigan, in 1676, the Company used 61,377 pounds of chromium compounds, and 365,028 pounds of benzene (primarily in gasoline). Asbestos is not one of the currently designated critical materials. The largest use, 641,000 pounds of acrylonitrile principally at the PPV paint plant, is planned to be removed from topcoats by Job #1, 1981 and from DSO and fleet colors by year end, 1880. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category 1 substances were examined in detail. -4- Moy27, 1980 0001 1680 PPrvrvnr'Trr, r>v T7/"YDr'> POTENTIALLY CARCINOGENIC SUBSTANCES The highest priority of Category I substances contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6, along with exposure limits and typical usage. The complete listing is provided in Exhibit L The substances are presented in order of priority as established by Task Force consensus. The development of a capability for managing the elimination/control of Category I potential carcinogens was determined by evaluating the scope of usage of asbestos, hexavalent chromium compounds and benzene (priority ranks 1, 2 and 3, respectively) as test cases. - 5- May 27,1DB0 noul 1681 pprvrvnr'-pT'! stm POTENTIALLY CARCINOGENIC SUBSTANCES Asbestos During the past several years, OSHA has reported evidence of a link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer (Fig. 7). These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. . The permissible exposure limit by OSHA is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group in The Department of Health and Human Ser vices (formerly HEW) has recommended to OSHA that limits be tightened to as low as 0.1 f/cc in 1980, (Fig. 8). Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban, under the Toxic Substances Control Act, on all non-critical uses may occur as early as 1985. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of vehicles, manufacturing equipment and plants. \ -6- May 27, 1980 H001 166? pponnrpn pv pno-n POTENTIALLY CARCINOGENIC SUBSTANCES Chromium Compounds Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (Figure 10). Chromium in hexavalent combination with hydrogen, the alkali metals (e.g., sodium), ammonia and oxygen are considered noncarcinogenie. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered potentially carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of handling them primarily in paint making and application. Pro tective measures are employed so that regulated limits are not exceeded. The current statutory limits for all chromium compounds is 52 yg/nr although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. -7- May 27,1980 8901 16B3 pprvnT Tppn pv men POTENTIALLY CARCINOGENIC SUBSTANCES Benzene ' Benzene is e potential leukemia producing agent. Excessive exposure may result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. ** At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, but employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The proposed standard was not upheld by the Court of Appeals because OSHA did not determine whether the benefits expected from the standard bear a reasonable relationship to the cost imposed. The case is now before the Supreme Court, which is expected to rule on it shortly. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no known way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services .has reported that no indication of excessive exposure exists for Ford employes os a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. May 27, I960 SO 01 16F>< DprvrYT Trcn r>v crvr>T> I I r ronSEARCH potential carcinogens Three Category I substances were examined to identify material specifica tions, parts and nonproduction uses. Existing data bases containing Product, Manufacturing and Purchasing information were found to be inodequnte for complete identification of all uses of these substances. In the absence of one reliable system, the detailed steps in Figure 16 were undertaken. For production materials, each design responsible PEO reviewed the' material/usage list for completeness and established a list of ports and bulk materials thought to contain the subject substances. These lists were, returned to Engineering Staff. E&RS is consolidating the lists to provide them, along with the approved source and material identifications, to Purchasing and Supply Staff for supplier contact to determine usage and substitutability. Nonproduction materials were identified by similar methods. The production asbestos list is with buyers; benzene and hexavalent chromium compounds are under PEO review. . MATERIALS AND TOXICOLOGY SYSTEM (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (PflcO Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); end the Environ mental in Process Engineering Review System (Mfg. Staff). These Systems can be linked with some manual effort to search for uses of potential carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing Category 1 chemical compounds can be identi fied in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specifica tion. A. With the parts list, Purchasing can determine quantity used and Manufacturing Engineering can determine processing methods. Other functions of MATS include Approved Source Lists for production and nonproduetion materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hnzordous MateriuLs for plant physicians and Hazardous Material Information Center, verification that a substance is on the Toxic Substances Control Act (TSCA) inventory, and listing of hazardous material usage und precautions for each plant. . 4 9 May 27, 1980 B001 lf>*5 PRODUCED RY FORT) POTENTIAL CARCINOGEN SEARCH RESULTS Partial listings of 111 asbestos, 126 chromium compounds and 7 benzene production and nonproduction applications (Appendices 1, II and in, respec tively) were examined. * These applications were classified as: . A - Known substitute material available for application without ' major redesign; ' * # B - Known substitute material available for application with major redesign; C - No known substitute. Advanced Engineering Project required; The number of applications in eBch group are shown in Figure 18. Even in Group A, (known substitute without major redesign) extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required and experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then establish sources for production as well as nonproduction requirements. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. -10- Mny 27. 1980 8t>01 1686 PRont Trpn pv popp h & ALTERNATIVE STRATEGIES FOR ELIMINATiON/CONTROL OF POTENTIAL CARCINOGENS Strategy alternatives were considered for the elimination and control of asbestos, hexavalent chromium compounds and benzene. The Task Force agreed that the Company shpuld proceed now to eliminate Group A (known substitute without major redesign) by Job #1, 19B5 where appropriate. Where-elimination is not appropriate control exposure by design or process for specific applications. (Fig. 19) For those applications requiring major redesign (Group B), the elimination timetable must reflect Company cycle plans on new plant construction or renovation plans. Finally, where no known feasible substitutes exist (Group C), advanced engineering will have to be completed before elimination strategies or timetables can be established. Individual timetables remain to be established for the balance of the eight prioritized substances. 100b -11 Moy 27,1980 ppnrTT^rr */> I / Vy GENERALIZED WORKPLAN The foregoing stra r, even though having been tested only for asbestos, chromium compounds and benzene, ere judged to be appropriate in concept for other carcinogens with timing adjusted to adapt to the realities associated with elimination. ' * A generalized workplan has been prepared on the basis of the evaluation of the substances referred to above. The workplan requires central program management, with action implementation by NAAO/DPO Product Engineering Offices,*Purchasing activities. Vehicle activities. Manufacturing activities, and the Manufacturing and Supply Staffs. The workplan timing requires one year to define the uses of a potentially carcinogenic substance with elimination requiring two additional years for a substance having a known substitute with no major redesign required. For material substitutions requiring major redesign, the timing is consistent with new product phase V timing of 33 months for vehicle and 45 months for powertrain programs. Four of the first five actions of the workplan (items 2-5) have been completed for asbestos, hexavalent chromium compounds, and benzene. The sixth and seventh actions have been initiated for production materials and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. (Fig. 2D) Completing the actions by these dates requires Corporate direction that the elimination/control of these substances in vehicle, component, plant renovation and new construction programs is a mandatory priority effort. Overall program management is essential to this effort. t'8 * l 100b -12- May 27, 1980 DPAnTirrn t>v crinr\ PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the fequirements for chemical substances control. ' It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issues. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an E&SES location was recommended. (Pig. 21) Jn view of budget Constraints, it has been agreed that the existing Com pliance and Liaison Department would perform the program management function. The Department Manager should be responsible for implementing control strategies and coordinating Company response to potential and promulgated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities and expand operations' role, assuring that Operating Components and Staffs issue facing documents to B101, establishing a financial measurement of the compliance effort, assuming development direction and control for the computer information system and implementing the workplan as directed. Although additional budget is not now requested, the transfer of a currently budgeted MR employe from Engineering Staff to E5ES with the MATS computer development budget component has been mutually arranged. The ongoing responsibilities of the Compliance and Liaison Department Manager will be to coordinate the product/facility/manufaeturing/health/ environment response of the Company to changing regulations. This will include comments to government agencies regarding proposed regulation, forecasting/ regulatory impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing 8nd Supply Subcommittees nBme as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page (Fig. 22). It is further recommended that the Committee be chaired by the E&SES representative. . " 8001 1889 -13 - May 27, 1980 ppnrT Tppn pv pr*pr 1( PROPOSED PHIDUtTY ACTIONS Although a strategy and workplan are froposed in this paper and efforts have been started in those areas, there are considerable timing and feasibility issues in each of tlie identified applications. Without funding or directed prioritisation over other engineering effort the work on the identified asbestos, hexavalcnl chromium compounds or benzene applications cannot proceed under present economic conditions. Nevertheless, a. measured Company reaction is necessary to initiate orderly substitution programs with sufficient flexibility to adapt to engineering and economic limitations. - _ Achievement of the elimination or control of potential enreinogens requires'a corporate commitment to foster an Integrated and sustained effort throughout the Company over a number of years. To accomplish this, the following actions and responsibilities are recommended: (Fig. 23): `. 1. Assign hazardous substance control program management responsibility to Environmental and Safety Engineering Staff. (Responsibility: Environmental it Safety Engineering Staff * ESES) 2. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. (Responsibility: ESES) ' 3. Revise Directive B-101 (Occupational Safety and Health and Control of Hazardous Materials) to reflect adjusted responsibilities for line and staff. No new Policy is required, the matter is covered under Policy C-3, Standards of Corporate Conduct. (Responsibility: ESES Program Manager) 4. Adopt ns the Company potential carcinogen listing, the 36 current OSIIA-rcgulated and proposed Category 1 substances used in automotive production. Estoblish the top eight priorities proposed by the Task Force os Company priorities. Direct that the listing be updated semiannually. (Responsibility: P&O Staff) 6. Complete strategies and timetables for the eight prioritized potential enreinogens for review ond approval by the subcommittees. (Responsibility: ESES Program Menoger) 6. Continue the development of MATS by Environmental it Safety Engineering Staff. A budget ond headcount transfer from Engineering Staff has been agreed to. (Responsibility: ESES Program Manager) The Company has demonstrated a commitment to protect workers while seeking to eliminate specific substances. Directions on the use of and protection for numerous substances hove been issued. Workers ore protected by restricting exposure ond by special clothing and engineered safcguurds designed to keep exposure within known permissible limits. Specific recommendations for eliminating asbestos, hcxavalent chromium compounds and benzene' follow:" 7. Proceed with the elimination of Group A (known substitutes without major redesign) no later than Job II, 1985 where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: PECs, BMD's, Purchasing) 8. Include Group B (known substitutes with major redesign) elimination actions in Phase V of vehicle and powertrain programs and in new plant and renovation projects where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: ESES Program Manager, Product Planning, Vehicle Engineering, Manufacturing Staff) - 9. Recommend Advanced program funding to develop designs and/or substitutes for new production and nonproduction parts nnd materials to identify feasibility, reliability, cost and weight implications of alternative matcrinls/dcsigns for Croup C applications (no known substitute, edvonecd engineering required). (Responsibility: ' PEG'S, BMD's, Technical Planning, Scientific Research Staff) The implementation of the above actions ond responsibilities should be reviewed periodically by the Engineering nnd Research end Manufacturing end Supply Subcommittees to provide a forum for discussion. Corporate overview and endorsement of appropriate funding and prioritization of efforts. .' | Vertical tine indicates revision ot subcommittee direction. . ' -14 - ' May 27,1980 O f^ I toofa ~ . pp nrvr tpph p v pop r EXHIBIT 1 . OSHA CATEGORY 1 SUBSTANCES WITH AUTOMOTIVE IMPACT Regulated as Carcinogens Potential for Regulations as Carcinogens . Acrylonitrile Acetamide Arsenic (inorganic) Benzidine Sulfate 0) Asbestos, including: (7) Beryllium oxides & inorganic salts Amoslte (4) Cadmium oxides & inorganic salts Anthophylite Carbon tetrachloride Chrysotile Chloroform . Croeidolite (2) Chromium, hexavalent Serpentine Diethylamine, N-Nitroso (S) Benzene . ' p-Dixoane Benzidine ** Ethane, 1,2-Dibromo- (5) Coke Oven emissions, including: Ethane, 1,1, l-Trichloro-2, 2-bis (p-chorophenyl) Benz (e) acephenanthrylene (8) Ethylene, Trichloro- Benz (a) anthracene Hematite . Benz (a) anthracene, 7,12-Dimethyl- Hydrazine Benz (a) anthracene, 7-Methyl- Hydrazine Sulfate Benz (a) anthracene, Lead Acetate 7, 8,12-Trimethyl- ` Lead Naphthanate Benzo (rst) pcntaphene Nickel oxides Jc salts Benzo (c) phenanthrene, 8-Methyl . Polychlorinated biphenyls Benzo (a) pyrene Polyethylene glycol monostearate Dibenz (a, h) acridine Sulfuric acid, Dimethyl ester Dibenz (a, j) acridine Tannic acid Dibenz (a, h) anthracene Tannin Dibenzo (b, def) chrysene o-Toluidine Dichlorobcnzidine Urea, Thio- Dimethylamine, N-Nitroso- 1-Naphthylamine 2-Naphtylamine (6) Vinyl Chloride 1/ MVMA InformationBulletin, September 28, 1978 2/ Parenthetical numbers refer to Task Force priorities. Note: Candidate substance list is expected to issue from OSHA July, 1980. * _ Prioritized candidate substance list is expected to issue from OSHA Sept., 1980 May 27, 1980 8001 lf>9) T>'DrYrvMr,'nT'> w nr\-tt> t iJ V/'VfV'A i. it/ EXHIBIT U CARCINOGEN SEARCH Materials and Toxicology System <MATS) . To overcome the deficiencies of monual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common duta base. The four systems are: the CATALOG of Haznrdous Materials (P&O Staff) containing Company materials, their toxicological evaluation for worker/ consumer protection and the chemical composition, the Engineering Material Approved Source' List (E&RS) containing the material specification title nnd the materials approved to that specification; the Nonproduction Material Approved Source List (Manufacturing Staff) contain ing tliernonproduction material standard and the approved materials; and the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, Treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. * Carcinogen Search Strategy . Developing the links between the above systems will, in the future, provide a method for loca ting Category 1 potential carcinogens in nonproduclion materials and production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the following search steps: ' 1. The Chemical Abstracts Service numbers of the Category 1 substance and their com pounds are identified bylH&T. The system will then generate a list of materials which ' contain those chemicals. 2. Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other Category 1 containing materials end specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEP1S) which contains the engineering notices from all of the product engineering offices. The NAEPiS system will then produce a cross reference list of all parts which use that materials. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or materia) is handled in AAD. . Functions A function of MATS is to maintain and produce the Approve Source List for nonproduction and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by Hazardous Material Information Center and plant physicians for verification that the substances are on the TSCA inventory and is required to be furnished to the UAW under the current contract. The system is also available to the plants Hazardous Material Information Center to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a materia). The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" c.g., chromium. Affected Activities : All Corporate Staffs concerned with mnterials/toxicologieal/environment controls are currently involved in using/dcvcloping the system. All NAAO/DPO plants are planned to hove access to the system by third quarter 1980. ' May 27, 1980 26*1 ioo- PRODT TPPn RY POT?r> MATERIALS CONTAINING ASBESTOS * * -1- * Group A -- Known Substitute Material Available Without Major Redesign Production Materials Specification Lirrht Truck ESF-M8G55-A ESW-M8GJ09-B -- . -- ~' Body ESB-M2G58-C ESB-M2G171-AB ' ESB-M2G188-A ESB-M3G95 ESB-M4G1-B ESB-M4G31-A ESB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A ESB-M4G177-A/B Material Gasket Gasket Deadener Sealers -- Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Basic Port No. ' Part * 7086 ' 4035 350038 350038 0900000 Trans. Ext. Gasket Carrier Gasket Econ. PDV Box Assy. Eeon. PDV Box Assy. Courier Box Assy. . mm --. Primer for Adhesive -- ---- -- -- -- -- ---- ---- ---- -- .-- --mm ---- ---- ---- --- ---- ---- ---- ---- -- -- ---- ---- -- -- -- .-- . .' -- APPENDIX I "5/27/80 031 1693 PRorvnrFn rv forri i I MATERIALS CONTAINING ASDESTOS Afl'bNQtA I B727/8TJ-- Group A -- Known Substitute Material Available Without Major Redesign (contVJ.) Nonproduction Materials . Specification M-10G11 M-10G12 . M-10G15 ; M-10G16 M-99G59A M-99G82A M-99G84A M-4R29A Material Asphalt Saturated Asbestos Roofing Felts - IS lb. Asphalt Saturated Asbestos Roofing Felts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. * Asphalt Saturated and Coated Asbestos Roofing Felts - SO lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper Mold Sealer . %0 01 1A9<* PDnmTPm t>v enpn I APPENDIX 1 .MATERIALS CONTAINING ASBESTOS . ............................ --5- 5/27/60 * ' Group C -- No Known Substitute. Advanced Engineering Project Required. Production Materials . Specification Light Truck ES-C8A4.-2B282-A ES-D20A-2B072-BB Material . Basic Part No. 2021 Part * Lining Front Wheel Brake Outer ES-C8AA-2B282-A -- ES-D20A-2BD72-BB if \\ Vendor Print -- 2022 2019 Lining Front Wheel Brake Inner Shoe and Lining Inner Vendor Print -- 2018 Shoe and Lining Outer ES-EOTA-2B120-AA 2018 Shoe and Lining Outer ES-D6TA-2B118-AA ES-C8TA-2B282-A Mb 4* 2022 . Lining Front Wheel Brake Inner ES-C8TA-2210-D -- 2209 RR Brake Shoe Lining ES-CBTA-201D-C -- 2284/5 RR Brake Shoe Lining ES-D8TA-7550-A -- 7550 Driven Member Clutch -r -- 4797 Clutch Plate -- -- 4A325 Clutch Plate -- -- 2598 Parking Brake Lining Heavy Truck -- -- -- -- -- -- --` '-- _ -- --* --. _ -- -- -- -- -- -- -- -- -- -- -- M. 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A596 7550 7E434 Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Brake Compressor Fan Clutch Assy.' Clutch and Bracket Assy. Muffler Assy. * Clutch Disc Assy. Torque Limiting Brake Assy. Chassis ESE-M8G149-A Gasket M- SF263 2284 2285 Exhaust Manifold Casket Rear Broke Shoes ' B601 1*95 Dorvrvr ir,t?T' r>v rr/^n^ APPENDIX n MATERIALS CONTAINING HEXAVALENT CHROMIUM COMPOUNDS^ ' 6/27/80 1- ' Group A -- Known Substitute Material Available Without Major Redesign Nonproduction Materials Specification No. Title M5B40 M-5B165X M-5B220A(F) M-5J30 M5J68A M5J75 M-5J79A M-5J84 M5J99N M-5J105A M-314 M-325 M-332 M-400A Metal Cleaner for M-99J2G Fingerprint Remover Paint Stripping - Organic Additive Yellow Marking Paint for Crfcosoted Floors Enamel, Semigloss, Yellow Corridor Accent Maintenance Paint - Zinc Chromate Primer .Medium Green (Maintenance Paint) ' Yellow Road Marking Paint Coatings, Administration Offices and Employe Facilities Diamond Phosphorescent Pink Enamel Alert Orange (Maintenance Paint) Target Yellow (Maintenance Paint) Seal Brown (Maintenance Paint) Primer, Red Oxide . Air Paint NR-73 Also Kote ZSD-NA Alert Orange Enamel Alkyd M332 85-Y-95 Alkyd M472 85-R-122 APS93 Paint and Resin Remover Brown Air Dry Primer C168 Corrosion Inhibitor C2041 Celite S35 Chrome Yellow Medium Cooling Water TRT Chem. CR 401 Copper NAD Acrylic Enamel CWT 204 CWT 404 D-Smut 1 Dearborn 517 - 1/ Hcxavalent chromium combinations with hydrogen, alkali metals, ammonia and oxygen excluded. * pool 1696 pponr Tppn nv enpri - ,,, APPENDIX 11 MATERIAL CONTAINING HEXAVALENT CHROMIUM COMPOUNDS^' " i/27/80 .. Group A -- Known Substitute Material Available Without Major Redesign (cont'd.) Nonproduclion Materials Specification No. Title ,, . PI. Color Conc/Pinc Green - MMCA PL Color Conc/Lt. Sand Quick Dry Yellow Traf. Marking Paint Red Enamel Safety Orange Aquapon 902176H Safetylite 75 Traffic Yellow Seal Brown Enamel ' Strontium Chromate - Pig Yell 32 Tangerine NAD Enamel 44-3108 Target Yellow Enamel ITactor Enamel 83132AM , Traffic Paint for Creosoted Floor Valencia Orange Valencia Orange Red 104 Vulcan Cooling Water Treatment W and B Grinding Coolant E-55 X-2777 Regal Yellow Light X2552 Rex Orange . X2B65 Strontium Yellow Yellow K831-742 Yellow Iron Oxide Ylo 1789 Yellow NAD Acrylic Enamel Yellow Road Marking Paint TP702 Yellow Safety Enamel STP Yellow Truck Enamel * a 1/ Hexavalent chromium combinations with hydrogen, alkali metals, ammonia and oxygen excluded. ftOOl 16V7 PPOTYt iPPn tv rrnt>r> . APPENDIX II MATERIAL CONTAINING HEXAVALENT CffflOMIPM COMPOUNDS^7 5/27/60-- -S- Group C -- No Known Substitute. Advanced Engineering Project Required Production Materials Specification No. Title ESF-M1F10-A Leather, Chrome Tan - Vegetable Reton ESB-M99Q109-A Ceramic Coating, Glass Decorative ESA-M2J52-A ESN-M2J114-A ESB-M2J214-A Enamel, Air Dry Asphaltum, Chassis Black Enamel, Standard and Low Bake, Tractor Quality Enamel, Baking, Clear, Unanodized Aluminum - Interior ESN-M6J96-A ESN-MGJ96-B ESB-M6J119-B ESB-M6J120-C ESB-M32J104-A-/ ESB-M32J104-B ESB-M32J105-Cl-^ ESB-M5DJ100-A--^ ESB-M50J1DD-B ESB-M50J1D5-aI( ESB-M50J106-A- ESW-J^J^-A-^ ESA-M62J16-A Primer, Air Dry or Baking, For Export Primer, Air Dry or Baking, For Export Primer Surfacer, Taupe, Epoxy, Low Bake Primer Surfacer, Low Bake Epoxy, Exempt Solvent Taupe (ft>% Reactive Solvents) Baking Enamel, .Reflow Acrylic - Exterior Quality Enamel, Baking Exempt Solvent (10% Reactive Solvents) Reflow Acrylic Exterior Quality Paint, Enamel, Acrylic Basecoat for Basecoat/Clearcoat Wet-on-Wet (10% Reactive Solvents) Paint, Enamel, Acrylic Baking (NAD), Exterior Passenger Car Quality Enamel, Acrylic Baking - Non-Aqueous Dispersion (NAD), Exterior Body Quality Paint, Enamel, Acrylic Baking, Non-Aqueous Dispersion (NAD) Paint, Enamel, Acrylic Baking, Non-Aqueous Dispersion (NAD), Exterior Paint, Water Dispersible, Black Water Dispersible Black Paint ESB-MS4 J12-B ESB-M64J13-B ESB-M64J13-C Primer, Woterborne Electrocoat - Black - Low Solids Type Primer, Waterborne Electroeoat - Black - Medium Solids Type Primer, Waterborne Electrocoat - Black - High Solids Type ESB-M99J248-A Paint, Color Coat for Acrylonitrile - Butadiene - Styrene - First Surface Exterior Nonproduction Materials ` Chromium Aeetylaeetonale . SSK1D2 WS164 - WS 64 1/ Hexnvolcnt chromium combinations with hydrogen, alkali metals, ammonia and oxygen ~ excluded. . 8001 1698 opnnr tren dv prior, . MATERIALS CONTAINING BENZBN^ APPENDIX m "5727755 I vjV,$' h V Nonproduetion Materials t Specification No. ' Title * Group A -- Known Substitute Materials Available Without Major Redesign . Sno-Sol 184C Group B -- Known Substitute Materials Available With Major Redesign Iso) 2429, 2429 Naphtha Production Materials Group C -- No Knowp Substitute.``Advanced Engineering Project Required Z00003290 ESF-M10C1-A ESE-M99C21-A X3512 ESR-M99P4-B 10SOL2429 2429 Naphtha GP1140 Carburetor Fluid Hydraulic Tappets Oil Sunfleet Super C 10W Oil Underbody Coating/Daubert AC690B MEMO: The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. The following fuels are so identified: M-4C20A ESE-M4C50-B ESE-M4C51-A ESE-M4C56-B XMS08 Z00002232 ESE-M4C45-A ESE-M4C89-A ESE-M4C91-A #2 Fuel Oil, Arco Heating Oil Indolene High Octane DI Gasoline Indolene Motor Fuel No. 5 Indolene High Octane Motor Fuel 30 Certified MS-08 Amoco Premium Pb-Free Gasoline Regular Gasoline Lead Free Gasoline Cetron Gasoline 1/ Materials known to contain benzene at levels 0.1% *no) 1659 PROFITTOFFi RV POPP