Document 2jRkJ7BDD676ez75m931gMM1r

- \7RICTI0N MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, RAj^A* ** MINUTES Of THE MEETING ' of Che *1^ v /O J, PLAINTIFF'S . EXHIBIT AB-177 -- ASBESTOS STUDY C0>C4ITTEE Thursday* August 17, 1972, at 9:30 A.M. |33 at the Institute Office, E. 210 Route 4, Paramus, N. J. r:g3ERS PRESENT I. H. Weaver, Chalrsan J. C. Henning W. Spurgeon H. Wagner E. B. Felerabend HggERS NOT PRE5EKT Raybestoa-Manhettan, Inc. Firestone, Tire & Rubber Co., World Bescos Division Bendix Corporation Bendix Research Laboratories Carlisle Corporation . Molded Materials Division Abex Corporation American Brakeblok Division % df- W. B. Reitz* Johns-Manville Corporation OTHERS PPESEST . D. E. Stone E. W. Drislane Bendix Corporation Friction Materials Division Friction Materials Standards Institute The nesting was called to order by Mr. Weaver, Chalman, at 9:30 A.K. MINUTES OF PREVIOUS'MEETING The Secretary read a sunnary of the Minutes of the Meeting held February 10, 1972. These ninutes had bean released and a notion.for thalr acceptance had been obtained. . Upon notion duly nade, seconded and unaninoualy passed, it was RESOLVED: To accept Che ninutes of the February 10, 1972 nesting as distributed. . INTERPRETATION OF THE OSHA REGULATIONS The Asbestos Information Association (AZA) nee with representatives fron OSHA lata is June. The purpose vas to interpret various individual requirements in the OSilA regulations. Lattera fron the ALA to their nenber companies, dated July 5, 1972 and July 12, 1972, were distributed to the Coanittee Members. In the first letter, they covered areas such as labaling, elothss lockers. . , Minutes of Meeting _ Asbestos Study Const!ttee 2 August 17, 1972 respirators, monitoring and physical examination*, citations, QSKA inspections and employee notification. In the second letter. the.AjA distinguishes be tween non-lodied-in asbestos containing prdits;^ife1&o!i!5Hfc5Sznfce5'ii&ifig and clutch facings). There are certain labeling requirements tied in to the non-loeked-in containing asbestos products, but this letter also discussed < . the problems of subsequent working of loeked-in asbestos containing products. The members discussed some of the items in the OSSA regulations. One member indicated chat during an Inspection, there were 3 OSHA people at their plant for 7 to 8 days. Interestingly, the 3 OSHA people came on, sice the first day veering respirators. Whether this was for effect or Is.a standard procedure for OSHA was not known. One of the items pointed out by -an OSHA inspector on the scene was the dry sweeping of loose asbestos-type compounds v*. the vet sweeping or vacuum cleaning that OSHA calls for. Another member advised that they had taken out. all air hoses around briquette presses and ocher machinery where loose asbestos is handled before It becomes locked in. Surprisingly to some members, asbestos sampling indicated that the inspection and drilling locations were problem erees. One member required that the respirators be worn et ell drilling locations. ' In an Inspection et one member's plant, the OSHA people set up 5 stations and while 4 of them stapled below the 3 fiber per ee TWA, one station read 18 fibers persce TWA. This member wee cited (la averaging the readings). < When the Federal Government was considering the necessity for asbestos regula tions, two of the companies represented by Meobcrs on the Committee were asked to cooperate in e survey by NIOSH. This study by HIOSH was to check over medical records and other such items to attempt to put the problem in prospective, N10SE had indicated to the cooperating manufacturers that the information they ware providing would be kept confidential. However, as it turns out, the OSHA people have copies of tht NIOSH studies which would indicate that the confidentiality has been violated. A member questioned what happens whan the asbestos concentration in a work area exceeds 10 fibers par ee (the delUng concentration in the OSHA regulations). The answer Is thee the employer muet notify the worker so exposed, in writing, that he was exposed to such e concentration and the worker must wear a respirator in that area. Tbs next question concerned what the proper means for notification of the worker would be* Zf ea interpretation is officially asked of OSHA, they will indicate that e registered letter to the employee Is the proper means of notification. In ocher areas, OSHA has indicated that meeting the splrle of the lav la what counts and it is fait that bulletin board notification would suffice. disposable The next question concerned respirators. It was Indicated that there were 3 / respiratorjpprovefy the Bureau of Hines, and these ere-manufactured by the . A* 0. Smith Company, Welsh, and Minnesota Mining end Manufacturing (MMM). Besplrators furnished employees must have e proper fit end the employees must be instructed both ee to the fit and the servicing of the respirator. Responsibility for testing end approval of respirators -for protection against asbestos dust re cently was transferred from Bureau of Mines to NIOSH. Until NIOSH approvals are Issued, It is recommended only respirators (reusable or disposable type) having Bureau of Mines approval specifically for use on asbestos dust be used in asbestos eontaainsted atmospheres. . .Ilinuee# of Meeting Asbestos Study Committee -3- August 17, 1972 Uffi2LIG PRACTICES There are 3 areas for concern on labeling. One Is the handling of the loose asbestos fiber Iron the point vhere it Is received to the point where it is mixed and briquetted. The next is the handling of the products with supposedly locked-in-asbestos during subsequent'operations,'such'as drilling,-grinding, inspection and boxing. The last concerns the handling of the brake lining or clutch facing by the customer where he may also do some drilling or grinding before the lined assembly is a -finished product. . .- It was reported during this topic that there was a higher concentration of asbestos in the air in the Inspection Department than most members had realized. One member indicated that when pallets of brake linings were shipped there apparently is additional dust created during transportation. The question of surface dust, on the working surface of'a braka lining or a clutch facing was discussed. Where mecbers have taken action to reduce the dusty type surface, they have found that they heve actually altered the frictional characteristics of the material during the early miles on a vehicle, la other words, the brakes are not very responsive during the early mileage after reline. In the AIA recosoendatlons, it is suggested that vhere e manufacturer la shipping his brake linings or clutch facings (lockad-in-asbestos products) he should*, notify the user of his product to the effect, "Power bench saws-without collectors should not be used in cutting this product. If this is impractical, operators should be provided with a Bureau'of Hines approved respirator." It was suggested that a notification be put in boxes of brake linings or dutch facings being shipped to customers, A sample of the caution labels suggested is attached to these minutes. Mr; Felerabcnd indicated that this recommendation would not be accepted warmly by many manufacturers. Mr. Wagner objected to the recommendation that warning notices be put in the brake linings as he felt it was another "red flag" that would bring more harm to the industry Chan the alleged good that would coma from enclosing such notices. Several members have had customers call In to their Seles Departments asking If the handling of loeked-in-asbestot in brake linings and clutch facings la a hazardous condition. Another asked if this notifcation was a requirement of the OSBA regulations. It was indicated that this was not specifically required by the OSBA regulations. The concern Is, do those customers doing additional grinding and drilling of. the brake linings or clutch faeings create working conditions where the con centration of asbestos would be e hazard. Since smell manufacturers ere exempted from the OSBA regulations, they will probably not be running tests, larger customers will, of course, be covered under the OSBA regulations end it is expected that tests will be run in these manufacturers* work areas. Whether the Institute would recoosend such labeling in finished products shipped to the customers was not decided. It was felt that this stbjeet should receive further consideration from the Mecbers of,the Cocmittee before a recommendation is made. One member commented that there were instructions by some manufacturers advising that blowing out the wear debris from used brakes was not reeonsended. This subject of recommending that brake lining and clutch facing manufacturer* include a warning sheet in their shipments appears to be somewhat controversial and it is suggested that this matter receive some serious discussion by.the Members of the Committee with those responsible at their companies. This item will most definitely be on an agenda for the next meeting of the Asbestos Study Committee. ' .Minutes of Meeting . Asbestos Study Committee -4- August 17, 1972 SAMPLING FOR ASBESTOS FIBER COUNTING ' iir. Stone questioned the possible movement of asbestos Inside the filter sample when sene to th& lab for examination. tlr. Weaver Indicated that this possibility was quite remote. Apparently the question arose after as OSHA visit to the meter's plant. In response to a question, one aether Indicated it takes about two months from the OSEA sampling until the OSHA report is received. Further, it was indicated that the company hears if it is to be cited and not if the conditions are satisfactory. The OSHA regulations call for an eight hour time weighted average (TWA) for the measurement of air. borne concentration of aabestos fibers. One member indicated that he runs his sample test for a continuous four hours to compute the concentration. With a continuous four hour sampling, there are sometimes reactions from the shop people. *. Returning to the question on sampling for fiber counting, OSEA recomaends a full straight eight hour sample. Xt was Indicated they used 8 filters during this continuous sample. A member suggested using 90 minute sampling for most araas, or a complete job cycle if it took longer then 90 minutes. He recommended four hours of sampling for specials. A member questioned as to whit minimus time was necessary in sampling to determine the peak concentrations that cannot exceed ID fibers per cc. Ho epeeifle answer was given, but Weaver indicated some sampling procedures which he felt were optimum for counting fibers entrapped by the filter. The number of tests for various conditions is suggested in this tabulation. One condition is where you are measuring friction materials with asbestos In the compund, and the other is for arses where you are handling all asbestos. Optlirdaed time for fiber collection - depending on TWA fiber per cc concentration expected la area. (Optimum for counting fibers on the filter) Frleelon listcrisis TWA Fibers oer cc Optimum Humber of Tests All Asbestos TWA Fibers per cc 0- 3 5-10 10-13 1J-20 am 1-8 hr. tsst 2-4 hr. tests 3 tests, 3,3,2 hrs. 4-2 hr. tests 8-1 hr. tests . 0- 3 3- 6 6- 9 9-13 13-20 The question arose concerning the sample, where one is trying to pick up asbestos for counting, What about the ocnft'iSSflBtrials in brake linihg that ere not?Bns)der< hazardous? Might Chase not be counted on the filter as well as asbestos? One answer that is indicated for the skilled laboratory nan making the examination is that he should be able to distinguish between asbestos fibers and other materials. Furtbar, one can go to 300X on the microscope and get a closer look at the materials picked up on the filter. Or* Spurgeon indicated that one can usa low temperature esfaing to remove resins and other organic materials (primarily friction dust). * :j.nute oi Meeting - Asbestos Study Committee 5- August 17, 1972 E?A AUTOMOTIVE MISSIONS Dr. Spurgeon Indicated that the Bendix Research Laboratories are working under contract for EPA on particulate emissions from brake linings and clutch facings and will not be finished until March 1973. Dr. Spurgeon felt it would not be proper to discuss results and progress to date on this study under contract to the government. - - THE STATUS OF EPA REGULATIONS Mr. Weaver indicated that one of the reasons for scheduling this meeting in August was to go over the nev EPA regulations. However, this agency has not finalized their regulations as yet and it is not expected to be published until sometime in September. Ilr. Weaver indicated that the problem was not with the asbestos sections, but richer with some of the other materlsls and he expected that their regulations will not be very much different from the esrller temporary regulations on asbestos. Once again, those esrller regulations were more concerned with control practices (collectors and .disposal techniques) -than with numerical emission values. No further action can be taken in this area until the EPA regulations are published. CONSIDERATION OF SUBSTITUTES TOR ASBESTOS / At the Annual Meeting,in June, this Committee was directed to consider a 4r recomendation .that the Institute sponsor a research study to determine the possibilities of substitutes for asbestos. The purpose of this suggestion was that if an outside study were to show that certain materials might very veil be acceptable substitutes for asbestos, the information would be made available to the members. If the* outside study indicated that there were no satisfactory substitutes for asbestos in friction materials, this information could be used as a defense should we hsve a recurrence of action similar to Illinois* banning of asbestos based brake linings. The Committee discussed this and as most of them arc working on asbestos substitutes and soma, in particular, have marketed materials without asbestos (primarily aataUd.cs), they felt this suggestion would not be warmly received by many members''. One member indicated that it would be very difficult for than to sanction the Institute making any such study considering the work they have done in the past. Upon motion duly made, seconded, and unanimously passed, it wss RESOLVES: That the Asbestos Study Committee does not recommend an Institute study in the area of siAstltutes forasbestos, WASTE DISPOSAL Someplace between the point where the asbestos product is finished and the waste materials are disposed of, the OSSA requirements will become EPA requireaents. In other words, we are moving from the condition of standards in the work place to standards in the atmosphere or environment. The area of waste disposal is a major problem. All asbestos, bearing wastes, according to the OSHA regulations, must be collected and disposed of In sealed impermeable bags or other closed impermeable containers. Whether a closed steel truck body is considered "impermeable" is a question. If the OSSA people mean what they say ' Minutes of Meeting .'Asbestos Study Coccittee "6-- August 17, 1972 when they suggest that an employer who Is attempting to meet the spirit of the lav will not have .difficulty, it will be assumed that removal of the waste material in enclosed steel truck bodies would be an acceptable means of disposal, (tost members indicated that they had great difficulty with polyethelene bags - they are too soft and they tear when they are stacked. The next area, which la a major problem, la the actual disposal of the dust. Usually, it is unloaded as land fill. One member uses a screw-type conveyor to fill a truck with a fixed container. The material Is then dumped Into land fill. The material is vet down after dumping and, after a hole is filled. It is covered up. !-lr. Stone mentioned a procedure he had seen where they turn the dust into pellets and dispose of the pellets. One member Indicated a solution for the disposal of the paper bags that are used to package the asbestos. They unload the asbestos bag inside a hood where they cut the bag. The hood has an empty plastic bag which the asbestos bags are picked up la. The topie of proper disposal of the friction material waste products was discussed. The most desirable method of disposing of friction material waste products is to put it back into the friction material. Where a manufacturer has a one-formula product line, this is reasonable. However, most of the larger manufacturers would find it very difficult to segregate the various mixes picked up in their collection devices and recycle it hack into the friction material without running into produce problems. This Is obviously the most desirable thing to do with the vesee material, but for turning out a quality product ifr becomes very difficult. The most common means of disposal are to wet the ^ product down and dispose of it as land fill. In some areas the material is bagged and sent to the dump. The problem of economical means to dispose of the waste from friction materials has been a problem in the industry for many years. It is likely to become a much more perplexing problem considering the regulations by OSHA and EPA. Dr. Spurgeon brought up the question of the possibilities of the Institute sponsoring paid research on vasta disposal. It was indicated Chat within the Constitution and By-Laws of the Institute we could very well sponsor such research but it would be up to the Coimnletee to make recommendations in this area. Generally, there ere areas other than asbestos that are involved in this waste disposal problem. Among the items to be considered ere: grinding dust, asbestos fibers and begs, phenolles which ere poked up in vet scrubbers, lead end its compounds, and the solvents that arm driven off during processing. The Committee will consider this possibility at e subsequent meeting. A member suggested a possible questionnaire to be sent out to the Membership concerning the problems of waste disposal to see whether the rest of the Membership could contribute some information in this area and to determine the extent of interest in the study of vesta disposal by the Institute. The Members of the Committee should consider items to be included in such s questionnaire for discussion at the next meeting of the Committee. MATERIALS OTHER THAW ASBESTOS . Because the problem of waste disposal is not a problem of asbestos only, questions were raised about the possibilities of extending the scope of the Conalttee's 4 work beyond that of asbestos alone. The Secretary indicated that it would be within the scope of the Committee to extend their activity to materials, other then asbestos. Lead and lead compounds ere among the hazardous materials being regulated by federal agencies. As many manufacturers use lead and lead compounds "Minutes of MetCisg * Asbestos Study Committee 7- Augusc 17, 1972 in their friction materials, this might bs material to b studied by the Committee. On the other bend, because of the seriousness of the asbestos regulations, by,taking os other materials, the efforts of this Cooittee sight be diluted' Currently, there are regulations on solvents, silica, and other aattrftls considered hazardous or noxious by the regulatory agencies. It is requested that tha members consider the possibilities of expanding the activities of this Comlttce to* cover other materials. METHODS FOR EXAMINATION OF FIBERS Dr. Spurgeon questioned whether there vert any ocher reliable techniques for the measurement of asbestos fibers other than tha membrane filter method. The question was also aimed et whether the regulatory agencies were considering other analytical methods. Mr. Weaver indicated that in conversation with AIA he had recently learned.that the Department of Labor is considering s study os the possibilities of tha gravimetric method, for sampling asbestos fibers. He indicated that the membrane filter method.5would be in use for some years to come and possibly up to tha July 1976 data when the stlffer two fiber per cc requirement goes into effect. The Department of Labor is considering a 13 man committee to study this possibility for sampling the asbestos. Tha make-up of such a committee would be as follows: 4 from industry, 4 "experts," 1 from MIOSH, 1 academic, 2 from labor, 1 medical, 1 from the American Industrial Health Association, and 1 consumer advocate. It is suggested that members of the* Asbestos Study Comic tee consider whether their companies might wish to volunteer for service on such e Federal eosnlttea. OTHER BUSINESS Soma of tha Committee Members are operations oriented and others are environment oriented. It was requested that those individuals responsible for corporate decisions la the hygiene environment area be listed. That list is as follows: Charles Boreherding ' Jamas Armstrong Abex Corporation - Chicago, Illinois (Corporate Industrial Hygiene) Beadlx Corporation - Southfield, Michigan (Safety Director) Ike Weaver Raybestos-Manhattan, lac. - Haaheim, Fa. (Director of Environmental Control) George Wilson Firestone Tire 4 Rubber Co. - Akron, Ohio There being no further business brought before the Committee, upon motion duly made, seconded and unanimously passed, it was RESOLVED: To adjourn Adjourned et 4:00 ?.M. Distribution: Cnemlttee Members J. Creeaca L. Stickles British Council ' AlA/HA E. W. Drlslane Executive Director J * [uM\3l . m T * ' -- * >' c. * * r*" *-^*' * ^ i *! * ?. "* " ,," r * . / ' Contains Asbestos Fibers : : -" . '* - -., * s# , m- r^"" . **..*.*..*.......` . t *.*-+mVam*m.*vv~ .-.**V#* V.\~* .'.v1v--` ' J . Avoid .Creating Dust ~. ' . 's*. "V., . '';V. =:. Breathing Asbestos Dust . ** '` . . * , 4' :' _ * * -*. . : may cause serious Bodily Harm . ` *%.-* * - ***; . 4 ^ ` ' '*/* ** .1 **. ^ * v, ... ** 4 1 *' 4.4 ' 4; % * *fc-**-*,4*`4 * . / *. * . , **. - * : * * .* ' it ' .* ** - ' _ , ** * ^ ' *'. * . ** * . *x*.* `.i'. . 4 * '**.".- - %,*" . . .: * " i , " ^ 1 .' ** \ .** ***. * ** u' * / * * r . /, * *.... . * . *. * ^ s*' * r * f 1 * - * f .** * `. ' i ' ."*?; % The "Insthictioa Sheet" should be the same size as-the caution label, black on wh and should read as follows: >,V> *V - v ^ , * * . * . . * ' 4 4 * * . 4 . * 4 m ^ ** ^ ' ^ ** ' *; . IMPORTANT - . . . .* *k " r* *. *' * 4 ^ 4 * ` v 4* VV. t"; ' : * | * , ( * * . . * * . ** ` , ' ` ' ,* . * ** ^4 s^^ ^ ^ ^4 - POWER TOOLS WITHOUT DUST COLLECTORS SHOULD . . %" * ,, . - ..r .r > . . . . NOT BE USED FOR MACHINING, CUTTING OR SANDING * [* * . THIS PRODUCT. )4 ^ 1 * 4 i** *" * * ' * e"4 ' i *-v 4 * \ IF THIS IS NOT. PRACTICAL,. OPERATOR SHOULD BE ; . ;* ;' * ***. ,*- . ' 4* '.# .,4 . . *4 PROVIDED WITH A U.S..'BUREAU OF MINES APPROVED . - ,4 *4 w. . >.. . ' ; RESPIRATOR. ** :: ' * "`, 4 -'j*'-- '. * f".*'; 1 * * * ' '* ' r v.*.i ; t1*' * V