Document 2qDqQpjkJEDRwL8Zg1oZgyQgg

-E- Asbestos and The Friction Material Industry Ocher requirements concerning use of callings for surfacing roads, the regulation of demolition activities, and. controlled application of spray-on materials are of little concern to friction materials processors. Our biggest concern lies with the emission standard, which will require the tightening up of dost collection, facilities and waste disposal practices wherever fugitive dust problems occur. The biggest problem with EFA regulation I have found thus far has - been non-uniform Interpretation of what constitutes a visible eniseloo. I know, the EPA people who drafted the regulation Intended this to mean Just what It 6ays. If It's visible under any condition whatso ever, and EPA approved air cleaning systems are not In use, the emission is In violation. Since nose friction materials manufacturers already are employing baghouses that meet EFA standards for cleaning their exhaust air streams. It is unlikely chat any severe lqtact will occur to the Industry as whole on account of the EFA regula tions as they now stand. Those few manufacturers who are relying on vet dust collectors that do not meet the EPA standard may have problems. The best way to be sure of meeting EPA requirements is to sharpen up on maintenance and operation of existing bagiouse filters and replace existing wet collectors with baghouse filters to eliminate visible ecdseions. In summary, the OSHA and EPA Asbestos Regulations are alot note lenient than many interested and concerned parties wish. We can expect pressure to have them tightened. Friction materials manu facturers should support Asbestos Industry efforts co have them mitigated In hopes they at least aren't made more severe. In the meantime, we should conform to the regulations to protect our employees and our customers and co avoid criticism and enforcement actions. Your Asbestos Study Committee will continue to follcx* the Interpre tation of existing regulations, the trend of proposed changes, and the development of new medical and scientific study material that nay affect future regulation of asbestos products. He welcome your questions and any lqput you may be able to make concerning our activities.