Document 2ReajGD905zry81kK29rbEdka

NILFISK OF AMERICA, INC. August 15, 1986 Mr. Ed Drislane Friction Materials Standards Bergen Mall Office Center East 210 Route 4 Paramus, New Jersey 07652 Institute Dear Ed: It has been almost two years since I last corresponded with you or updated you on any of the happenings here at Nilfisk. By this time, you are undoubtedly aware of the new OSHA Advisory regarding automotive brake service for shops, but I am enclosing a photocopy of 29 CFR 1910.1001, Appendix F just in case it somehow eluded you. If this new OSHA Standard starts the pot to boiling again, I will be more than happy to supply literature for dissemination to your membership. Best regards, NILFISK OF AMERICA, INC. RSM:jds Enclosure FMSI-0458 FMSI 02266 Federal Register / Vol. 51, No. 119 f Friday, June 20, 3986 / Rules and Regulations . 22753 Appendix E to 1810.1001--Interpretation and Classification or Cbest Roentgenograms--Mandetorjr (a) Cheat roentgenograms shall be interpreted and classified In accordance with a professionally accepted classification system and recorded on a Roentgenographlc Interpretation Form. 'Form CSD/NIOSH (M) 2.8. (b) Roentgenograms shall be interpreted and classified only by a D reader, a board eligible/certified radiologist, or an experienced physician with known expertise in pneumoconioses. (c) All interpreters, whenever interpreting chest roentgenograms made under this section, shall have Immediately available for reference a complete set of the 1LO-U/C International Classification of Radiographs ;. for Pneumoconioses, 1800. Appendix F to ( 1910.1001--Work Practices and Engineering Controls for Automotive Brake Repair Oporationa--Non-Mandatory This appendixes intended as guidance for - - employers in the automotive brake and clutch repair industry who wish to reduce their employees' asbestos exposures during repair operations to levels below the new standard's action level (0.1 f/cc). OSI1A believes that employers in (his industry sector are likely to be able to reduce their employees' exposures to asbestos by employing the engineering and work practice controls described in Sections A and B of this appendix. Those employers who choose to use these controls end who achieve exposures below the action level will thus be able to avoid any burden that might be imposed by complying with such requirements as medical surveillance, recordkeeping, training, respiratory protection, and regulated areas, which are triggered when employee exposures exceed (he action level or PELAsbestos exposure in the automotive brake and clutch repair Industry occurs primarily during the replacement of clutch plates and brake pads, shoes, and linings. Asbestos fibers may become airborne when an automotive mechanic removes the asbestoscontaining residue that has been deposited as brakes and clutches wear. Employee exposures to asbestos occur during the cleaning of the brake drum or clutch housing. Based on evidence in the rulemaking record (Ext. 84-74. 84-263. 90-148). OSHA believes that employers engaged In brake repair operations who implement any of the work practices and engineering controls described in Sections A and B of this appendix may be able to reduce their employees' exposures to levels below the action level (0.1 fiber/cc). These control methods and the relevant record evidence on these and other methods are described in the following sections. A. Enclosed Cylinder/HEPA Vacuum System Method The enclosed cylinder-vacuum system used in one of the facilities visited by representatives of the National Institute for Occupational Safety end Health (N10SH) during a health hazard evaluation of brake repair facilities (Ex. 84-203) consists of three components: (1) A wheel-shaped cylinder designed to cover and enclose the wheel assembly; (2) A compressed-air hose and nozzle that fits into a port in the cylinder; and ___ (3) A HEPA-filtered vacuum used to evacuate airborne dust generated within the cylinder by the compressed air. To operate the system, the brake assembly Is enclosed in a cylinder thal.has viewing ports to provide visibility and cotton sleeves through which the mechanic can handle the brake assembly parts. The cylinder effectively isolates asbestos dust in the drum from the mechanic's breathing zone. The brake assembly isolation cylinder is available from the Nilfisk Company1 and comes in two sizes to fit brake drums in the 7- lo-12-inch size range common to automobiles Bnd light trucks and the 12-to-lB-inch size range common to large commercial vehicles. The cylinder is equipped with built-in compressed-air guns and a connection for a vacuum cleaner equipped with a High Efficiency Particulate Air (HEPA) filter. This type ol filter is capable of removing all particles greater than 0.3 microns from the air. When the vacuum cleaner's filter la Tull, it must be replaced according to the manufacturer's instruction, and appropriate HF.PA-fillered dual cartridge respirators should be worn during the process. The filter of the vacuum clenner is assumed to be contaminated with asbestos fibers and should be handled carefully, wetted with a Tine mist of water, placed immediately in a labelled plastic bag. and disposed of properly. When the cylinder is in place around the brake assembly and (be HEl'A vacuum Is connected, compressed air is blown into the cylinder to loosen the residue from the brake assembly parts. The vacuum (hen evacuates the loosened material from within the cylinder, capturing the airborne materia) on the HEPA tiller. The HEPA vacuum system can be disconnected from the brake assembly Isolation cylinder when the cylinder is nol being used. The HEPA vacuum can then be used for clutch facing work, grinding, or other routine cleaning. B. Compressed Air/So/cent System Method A compressed-air hose fitted at (he end with a bottle of solvent can be used lo loosen the asbestos-containing residue and to capture the resulting airborne particles in (he solvent mist. The mechanic should begin .... spraying the asbestos-contaminated parts with the solvent at a sufficient distance to ensure that the asbestos particles arc not dislodged by the velocity of the solvent spray. After the asbestos particles are thoroughly wetted, the spray may be brought closer to the parts and the parts may be sprayed as necessary to remove grease and other material. The automotive parts sprayed with the mist are then wiped with a rag. which must then be disposed of appropriately. Rags should be placed in a labelled plastic bag or other container while they are stilt wet. This ensures that the asbestos fibers will not become airborne . 1 Mention of Irodcnomc* or commercial product* docs not constitute endorsement of recommendation for use. after the brake and clutch parts have been .. cleaned. (If cleanup rags are laundered rather . than dispoaed of. they must ba washed using . methods appropriate for the laundering of asbestos-contaminated materials.) ; ' OSHA believes that a variant of this - - ............ compressed-alr/solvent mist process offers ' advantages over the compreased-air/solvent mist technique discussed above, both in terms of costs and employee protection. The variant involves the use of spray cans filled with any of several solvent cleaner* commercially available from auto supply stores. Spray can* of solvent are inexpensive, readily available, and easy to use. These cans will also save time, because no solvent delivery system has to be asembled. i.e., no compressed-air hose/mister ensemble. OSHA believes that a spray can will deliver solvent to the parts lo be cleaned with considerably less force than the alternative compressed-air. ___ delivery system described above, and will thus generate fewer airborne asbestos fibers than the compressed-air method. The Agency therefore believes (hat the exposure levels of automotive repair mechanics using the spray can/solvent mist process will be evenlower ) than the exposures reported by NIOSH (Ex. ' 84-203) for the compressed-alr/solvent mist syslem (0.08 f/cc). C. Information on the Effectiveness of Various Control Measures The amount or airborne asbestos generated during brake and clutch repair operatlona depends on the work practices and engineering controls used during the repair or . removal activity. Data in the rulemaking record document the 8-hour time-weighted average (TWA,) asbestos exposure levels associated with various methods of brake and clutch repair and removal. NIOSH submitted a report to the record ' entitled "Health Hazard Evaluation for Automotive Brake Repair" (Ex. 84-263). In addition. Exhibits 84-74 and BO-148 provided exposure data for comparing the airborne concentrations of asbestos generated by the use of various work practices during brake repair operations. These reports present . exposure data for brake repair operations involving a variety of controls and work practices, including; Use of compressed air to blow- out the brake drums: .. Use of a brush, without a wetting agent.________ to remove the asbestos-containing residue; Use of a brush dipped in water or a solvent to remove the asbestos-containing residue; Use of an enclosed vacuum cleaning system to capture the asbestos-containing residue; and Use of e solvent mixture applied wilh compressed air lo remove the residue. Prohibited Methods The use of compressed sir to biow the asbestos-containing residue off the surface of the brake drum removes the residue effectively but simultaneously produces an airborne cloud of asbestos fibers. According to NIOSH (Ex. 64-263), the peak exposures of mechanics using this technique were as high as 15 fibers/cc, and 8-hour TWA exposures ranged from 0.03 to 0.18 f/cc. FMSI 02267 22754 . Federal Register / Vol. 51, No. 119 / Friday, June 20, 1986 / Rules and Regulations '* ,!i ih: Dr. William Nicholson of the Mount Sinai School of Medicine (Bx. 84-74) cited data from Knjght end Hlckish (1970) that indicated that the concentration of asbestos ranged from 0.84 to 5.35 f/cc over a 60-minute sampling period when compressed air was being used to blow out the asbestoscontaining residue from the brake drum, in the same study, a peak concentration of 87 f/ cc was measured for a few seconds during brake cleaning performed with compressed air. Rohl et si. (1976) (Ex. 00-148) measured area concentrations (of unspecified duration) within 3-5 feet of operations involving the cleaning of brakes with compressed air and obtained readings ranging from 6.0 to 29.8 if cc. Because of the high exposure levels that result from cleaning brake and clutch parts using compressed air. OSHA has prohibited this practice in the revised standard Ineffective Methods When dry brushing was used to remove the asbestos-containing residue from the brake drums and wheel assemblies, peak exposures measured by NIOSH ranged from n ot to 0.81 f/cc, while 8-hour TWA levels were at the new standard's permissible exposure limit (PEL) of 0.2 f/cc (Bx. 84-203) Rohl and his colleagues (Ex. 90-146) collected area samples 1-3 feet from a brake (.leaning operation being performed with a dry brush, and measured concentrations ranging from 1.3 to 3.6 f/cc; however, sampling limes and TWA concentrations were not presented in the Rohl et al. study. When a brush wetted with water, gasoline, or Stoddart solvent was used to clean the asbestos-containing residue from the affected parts, exposure levels (8*hour TWAs) measured by NIOSH also exceeded the new 0.2 i/cc PEL and peak exposures ranged as high as 2.62 f/cc (Ex. 84-283). Preferred Methods Use of an engineering conliol svstem involving a cylinder that completely encloses the brake shoe assembly end n H:yb Efficiency Particulate Air (HEPA) fillerequipped vacuum produced 8-hour TWA employee exposures of 0.01 f/cc and peak exposures ranging from nondelectabii: to 0 07 f/cc (Ex. 84-263). (Because this system achieved exposure levels below the standard's action level, it is described in detail below.) Data collected by the Mount Sinai Medical Center (Ex. 90-148) for NilTisk of America, Inc., the manufacturer of the brake assembly enclosure system, showed that Tor two of three operations sampled, the exposure of mechanics to airborne asbestos fibers was nondetectable. For the thud operator sampled by Mt. Sinai researchers, the exposure was 0.5 f/cc, which the authors attributed to asbestos that hBd contaminated the operator's clothing in the course of previous brake repair operations performed without the enclosed cylindcr/vacuum system. Some automotive repair facilities use a compressed-air hose lo.apply a solvent mist to remove the asbestos-containing residue from the brake drums before repair. The NIOSH data (Ex. 84-263) indicated that mechanics employing this method experienced exposures (8-hour TWAs) of 0.8 f/cc, with peaks of 0.25 to 0.88 f/cc. This technique, and a variant of it that OSHA believes is both less costly end more effective in reducing employee exposures, is described in greeter detail above in Sections A and B. D. Summary in conclusion, OSHA believes that it is likely that employers in the brake and clutch repair industry will be able to avail themselves of the action level trigger built into the revised slundard if they conscientiously employ one of the three control methods described above: the enclosed cyfinder/HEPA vacuum system, the compressed nir/solvcnt method, or the spray cen/solvent mis! system. Appendix G to 19101001--Substance Technical Information for Asbestos--Non Mandatory I. Substance Identification A. Substance: "Asbestos" is the name of a class of niagnesium-siliciiU' minerals (hot occur in fibrous form. Minerals that are included In this group arc chrysolite, crockiolitc!, arrwsfte, tremolite asbestos, enthophyllile asbestos, end actinolite asbestos. B. Asbestos, tremolile. anthophyllite. and actinolite arc used in the manufacture of heat-reristnnt clothing, automative broke and clutch linings, nnd a variety af building materials including floor tiles, roofing felts, ceiling tiles, asbestos-cement pipe am! sheet, nnd fire-resistant dryvvall. Asbestos is also present in pipe and boiler insulation materials, and in sprayed-on materials located on beams, in crawlspanes. and between walls. C. The potential for a product containing asbestos, trcmolitc. anthophyllite. and uctinolite to release brealhcable fibers depends on its degree of friability. Friable moans that the material esn be crumbled with hand pressure and is therefore likely to emit fibers. The fibrous or fluffy sprayed-on materials used For fireproofing, insulation, or sound proofing are considered to be friable, and they readily release airborne fibers if disturbed. Materials such as vinyl-asbestos floor tile or rooting felts arc considered nonfriable and generally do not emit airborne fibers unless siwjccted to sanding or sawing operations. Asbculos-ccmenl pipe or sheet can emit airborne fibers if the materials are cut or sawed, or if they are broken during demolition operations. D. Permissible exposure: Exposure to airborne asbestos, treniolite, anthophyllite, and actinolite fibers may not exceed 0.2 fibers per cubic centimeter of air (0.2 f/cc] averaged over the 8-hour workday. II. Health Hazard Data A. Asbestos, treniolite. anthophyllite, and actinolite can cause disabling respiratory disease end various types of enneers if the fibers are inhaled. Inhaling or ingesting fibers from contaminated clothing or skin can also result in these diseases. The symptoms of these diseases generally do not appear for 20 or more years after initial exposure. B. Exposure lo asbestos, treniolite, anthophyllite, and actinolite has been shown to cause lung cancer, mesothelioma, and cancer of the stomach and colon. Mesothelioma is a rare cancer of the thin membrane lining of the chest and abdomen. Symptoms of mesothelioma include shortness of breath, pain in the walls of the chest, and/ or abdominal pain. v : 1 * ... III. Respirators end Protective Clothing A. Respirators: You are required to wear a respirator when performing tasks that result in asbestos, tremolile. anthophyllite. and actinolite exposure that exceeds the permissible exposure limit (PEL) of 0.2 f/cc. These conditions can occur while your employer is in the process of installing engineering controls to reduce asbestos, trcmolitc, antbophyllile, and actinolite exposure, or where engineering controls are nol feasible to reduce asbestos, Iremolite, anthophyllite, and actinolite exposure. Airpurifying respirators equipped with 8 highefficiency particulate Bir (HEPA) filter can be used where airborne asbestos, tremolile, enthophyllilc, and aclinolite fiber concentrations do not exceed 2 f/cc otherwise, air-supplied, positive-pressure, full faccpiccn respirators must be used. Disposable respirators or duBt masks are nol permitted to be used for asbestos, tremolhe. antbophyllile, and actinoiile work. For effective protection, respirators must Hi yovr face and heed snugly. Your employer is required to conduct fit tests when you are first assigned a respirator and every 8 months thereafter. Respirators should nol be loosened or removed In work situations where their use is required. B. Protective Clothing: You are required to wear protective clothing in work areas where usbeslos. tremolile, anthophyllite, and actinolite fiber concentrations exceed the permissible exposure limit (PEL) of 0.2 f/cc to prevent contamination of (be skin. Where protective clothing Is required,your employer must provide you with clean garments. Unless you are working on a large asbestos, tremolile. anthophyllite, and actinolite removal or demolition project, your employer must also provide a change room and separate lockers for your street clothes and contaminated work clothes. If you are working on a large asbestos, trcmolitc, anthophyllite, and actinolite removal or demolition project, and where it is feasible to do so, your employer must provide a clean room, shower, and decontamination room contiguous to the work area. When leaving the work area, you must remove contaminated clothing before proceeding to the shower. If the shower is not adjacent to (he work area, you must vacuum your clothing before proceeding to the change room and shower. To prevent inhaling fibers in contaminated change rooms and showers, leave your respirator on until you leave the shower and enter the clean change room. IV. Disposal Procedures and Cleanup A. Wastes that are generated by processes , whereasbestos, tremolile, anthophyllite, and ` actinolite is present include: 1. Empty asbestos, tremolile. anthophyllite, and actinolite shipping containers. - 2. Process wastes such as cuttings. ` trimmings, or reject material. FMSI 02268