Document 2qg5278V3jyrr30Rr7gd720Bg

REPORT OK *r!5~ ASBESTOS STJDY CQE-~T7ZZ ATTr.ITTE?. -?~s Asbestos Study Committee was formed July 1971 with t*ne assignee purpose to review sr.z roswent on rules anc regulations promulgated by state and federal governments concern ir.r asoestos and its applications. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. ?. Stefl of Raybestos-Manhattan, with members from Morldbestos, Abex, Bendix, amd Carlisle Corporation and J-M present. The following items were reviewed and/or discussed: (1) Relationship with Asbestos Information Association/North America. (2) Proposed Illinoi Regulations. (3) Vehicle friction material emission test program to be conducted by Bendix under E?A contract. (4) Monitoring for airborne asbestos fibre. (5) Districutior. and circulation of literature on Asbestos/Healtb subjects. The purpose of the Asbestos Study Conmittee was restated as follows: "to gather and dessimate to its members information about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environment(particulate emission and to draft comments relative to proposed regulations in defense of reasonableness." The following is a list of the actions taken by the FM51 Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: September 30 - Issued minutes of first Committee meeting with letter commenting on proposed Federal EFA and Illinois emission standards. October 26 - Issued bulletin and further information on Illinois hearings. Novender 10 - Issued information on membrane filter monitoring method. November 14 - Issued bulletin on revisions to Illinois and Federal EPA proposals. December S - Issued information concerning final draft of proposed Illinois regulation, proposed EPA emission standards, and Federal Department of Labor Regulations on Occupational Exposure. Or. January 26, 1972 arrangements were announced for Bill Reitze of J-M to conduct an instruction session on asbestos fibre monitoring at FH5I headquarters February 10. On February 10 this session.was presented to nine attendees representing six member companies. .. ?he second Asbestos Study Committee meeting also was held on February 10 with 1. K. "Weaver Raybestos-Manhattan, acting as chairman and members representing Worldbestos, J-K, Bendix, anc Carlisle attending. The following items were covered: 1. Review oAIA/NA comments regarding OSHA meeting in Washington on January 26. 2. Review of proposed OSHA asbestos standard and comparison with British standards and regulations. 3. Review of British Friction Material Council comments on Illinois standards. It was resolved to forward to BFMC copies of minutes of future FI-21 Asbestos Study Committee meetings. 4. Recommendation made that the FM5I Asbestos Study Committee maintain close liaison with A1A/NA. 5. Reviewed background and expected thrust of QSHA .nd EPA regulations. FMSI--0084 t. Reviewed monitoring equipment and astnocs. 7. Recomendec future course for Asbestos Study Committee. The following is a. summary of actions taken by the Executive Secretary during the firs*, hair of 1972 in regard to Asbestos Study Committee matters: February IS - Circulated Bulletin U27 regarding various standards for asbestos dust exposure and control. This included copies of the January 12 Federal Register announcement of proposed permanent OSSA standard for asbestos control in the work place. February 18 - Issued Bulletin A28 reporting on February 10 demonstration by Mr. Reitz cf membrane filter monitoring method. June 1 - Circulated announcement of Microscopy Seminar scheduled by MeCrone Research Institute in Chicago week of June 26. June 6 - Circulated supplementary information received from Illinois Institute of Technology Research Institute regarding friction material emissions and issued tentative schedule for third Committee meeting to be held late July or August. June 12 - Issued announcement of CSHA permanent standards on asbestos dust exposure as published in June 7 Federal Register. The latter item has been rather intensively studied by your Chairman, by AIA^iA, and no doubt also by concerned individuals in practically all companies represented in ?K5i. Tne consensus appears to be that the new regulation is stricter than need be in respect to the future TLV of 2 fibres per cc, but is more lenient than was expected in regard to many other important matters. Major changes between the new regulation and the earlier emergency standard and earlier proposed permanent regulations are as follows: 1. Automatic reduction of TLV to 2 fibres in four years. Z. Use of protective clothing required above 10 fpcc ceiling limit. Change rooms, dual locker facilities, and special laundering and clothing handling procedures required. - 3. Monitoring required at least every six months at operations exceeding allowable TWA concentration. . L. Physical exam and doctor's approval required before assigning employees to Jobs requiring use of respirators. 5. Elimination of references to ,seanc'er,: and ''danger" on signs and labels. Labeling eliminated for products containing locked-in fibre. 6. Specific restrictions on "dry sweeping1' and use of compressed air for cleaning eliminated. . 7. Medical examinations, including pulmonary function tests,required annually for all employees exposed to dust. E. Employee access to medical and monitoring records required. Employees exposed to levels above TLV must be notified in writing. . 9. Waste containing only locked-in fibre need not be sealed nor labeled. T TT j,- many serious difficulties are expected ir. achieving compliance with the new by ciners*, ns that textile manufacturers, >st friction material and insulation fabricators and installers, it zz manufacturing operations not relying on textile vie have relatively little trouble, although some dry mold type friction operat _S: pose problems. Perhaps of a more serious nature is the potential threat of banning of asbestos in friction materials, particularly in automotive vehicles, to eliminate emissions from wear debris. It is doubtful that any further action in this direction will be taken until results of me comprehensive study by Bendix Corporation for EPA have been announced. I have beer, advised* that this study, originally to have been completed this month, now is not expected to be finished until late this year. Most of the difficulties that arose in this study to date have occurred in connection with the gas collection phase of the program. Since the study involves collection and analysis of g aseous emissions as well as particulates, precision rotary seals and gas collection systems had to be developed and evaluated, and this has necessitated extensive and time consuming engineering design efforts. Another vital EPA program also is running behind schedule. That is promulgation of the permanent regulations and standards for asbestos emissions to the ambient atmosphere. I have been advised by the EPA Hazardous Pollutants Branch that the earliest date these standards are expected to be issued is the beginning of August, and they could be delayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatins. Significant changes are expected in the sections applying to mining and spraying operations. Probably the only significant change between the proposed regulation and the expected final regulation as far as manufacturing operations are concerned is the broadening of specifications on fabrie filters and wet" dust collectors. This should be helpful to industry in permitting somewhat core flexibility in dust collector selection and application. Before closing, 1 should like to recomnend a few of my thoughts and suggestions that 1 have received from others concerning items that should be considered ana reviewed by the Asbestos Study Committee during the following year. 1. Uniform interpretation of OSHA standards. Liaison with AlA/^iA will be helpful in this. 2.. Determination o`f technological feasibility of achieving both 2 and 5 fibres tnroughout the industry. 5. Determination of the overall effect on the friction material Industry of the OSHA standards. 5. Development of guidelines, aids, and educational programs to help customers comply with the regulations. 6. Investigate a suitable standard method for analysis for asbestos in brake lining wear debris. 7. Develop methods and recommendations for safe disposal or recycling of friction material grinding waste. 8. Follow as closely as possible medical and occupational health research concerning asbestos and asbestos-related diseases and determine whether FMSI or its member companies should help sponsor or otherwise suppofcT work of this nature. T T AH of these subjects probably will be reviewed at the third Asbestos Study Committee meeting to be scheduled within the next month or so. Please advise us of any additional itens you or others in your organization may wish to add to our agenda for this up coming meeting* Respectfully submitted. I. H. Weaver, Chairman T T