Document 3eVMyBzLOb7gGdaBdbbZpYKLn

TO. j *1 ' ' , l'o-ordinaU>ro \sfivi.a /'ml or son r ,lob'i J: ') e ] ' 31 C'lij boll PLAINTIFF'S EXHIBIT Ken Kirchoff FD-9J6 PLfUi2 n Dm. Asm,.) n * 1 (_`J <r* ID ^~>h trr. i. DT;;. D BY IDAIT) , , f}. J C|M. U: - Cl?v.. Lia-w The attached Asbestos Plan has Veen developed for a presentation before the Auanccd Review C^'ujiteo in l^tf!. Please review the rceomraeri''.t'onc and 1 ud^et allocations ana od.'Isc ur of any necessary changes. Your coitfiients will be welcome. ML PL Carolyn B. Zclck /{f*'*>7/t'tV Vchiclo Ihlcriala VnjincorinR . 31 Dili 9/8/73 TSAtitUITTAI i SCF-FORD-1601 8003 1859 PRODUCED BY FORD ENGINEERING ASBESTOS PLAN UPDATE rPurpose~l To provide a current evaluation on the asbestos regulation, usage and future trends to supplement the Vehicle Materials Engineering Asbestos Plan established August 26, 1977. 1 Regulation 1 Although a .5 fiber/cc standard was proposed by OSRA on October 9, 1975, no measures have been taken to lower the present 2 fiber/cc permissible exposure limit. The following pressures are contributing to further regulation by early 1979s . Hearings have concluded after 44 days of testimony on OSHA's Generic Policy to regulate all carcinogens. By law, OSHA must act within 60 days of the close of the record, but that deadline seldom has been met with past standards. Final rules to set guidelines for all carcinogens, e.g., asbestos, could easily be issued before the end of the year. . Concurrently, extensive media coverage will expedite the asbestos standard below the current 2 fiber/cc level. Medical authorities have taken the position that a safe level cannot be identified. . The completion of the Cotton Bust Standard set a precedent for protection of employes exposed to airborne carcinogens. . The British have adopted an approach aimed at reducing asbestos exposure to the lowest attainable level with a 2 fiber/cc maximum ceiling, for excursions. Further action is pending on the standard until reports are published by the Advisory Committee. Compliance is enforced under the Health and Safety at Work Act. I Program Development I The Asbestos Plan, as delivered to the Advanced Review Committee, February 9* 1978, emphasized programs to prepare the Company for a staged tightening of the standard. Progress of these programs and recommendations are detailed below: Programs . VMD&P and NAAO Purchasing monitoring supplier com pliance and engineering programs. Status Recommendations As of August 26, 1977 . Suppliers reaching compli ance to 2 fiber/cc level with active programs to meet lower levels. . Engineering programs in initial stage of develop ment of alternative materials. Raybestos-Manhattan R&D Review, 9/27-28/78. 8003 VMD&P and NAAO Purchas ing to monitor suppliers progress of achieving efficient environmental controls. VMD&P and Engineering to track R&D efforts and manufacturing feasibility of substi tutos 1860 PRODUCED BY FORD -2- PragrAffip Status Recommendations NAAO Purchasing monitor ing costs of asbestos containing components and engineering conduc ting comparisons with alternative materials. Analysis limited to raw asbestos fiber. NAAO Purchasing to evalu ate the cost of the final product on a directional basis on engineering determined substitutes. Advanced Engineering Programs funded for 1978 in Chassis and Transmission and Axle to assess substitutes. Transmission $83,000 As of 8/78, $28,000 spent on feasibility programs for non asbestos clutch facings. Project is continuing with a planned release date of Job 1, 1978, on two models. Current support from two suppliers. Transmission to continue an active program on non asbestos replacements. Funding for 1979 will be in excess of $100,000 and incorporated into total budget allocations, for production implementation. Chassis $114,000 Funding oanoelled for calen dar year 1978. Lack of supplier submissions. Budget for 1979 recommended _at $580,000 for advanced projects on non-asbestos. iBendix semi-metallic disc with asbestos backing intro duced on 2.3 liter turbo engine, 1979 Mustang, as pilot program.) Chassis to support tran sition to non-asbestos friction materials by evaluating supplier R&D submissions. Research support of Engineering in parallel projects. Yearly allowance for the Machining and Wear Depart ment, $312,000. The non asbestos project, not separately funded, does not incorporate the full time effort of one employe. E&R Staff to reassess the flat budget planned for 1979 to sustain future supplier submissions, lawsuit inquiries and ICBA requests from Engineering. I Usage.) The transition to non-asbestos substitutes has been associated with the increased cost of asbestos and the pressure to limit employe exposure by utilization of environ mental controls with an approaching stricter standard. However, the unique properties of asbestos fiber have slowed efforts towards substitution, particularly in applica tions receiving heavy duty service, e.g., friction brake components. Supplier sub missions in those areas have been limited to evaluation by Scientific Research, with no level of success reported. 8003 1861 PRODUCED BY FORD Future Trends . Selective removal of asbestos as a product constitutent appears to be the future trend where asbestos is not critical to product acceptance and performance. This assessment is supported by the reduced demand for asbestos fiber imports, since 1973. . Products such as friction materials, where there is difficulty in duplicating the attributes of asbestos and where there are no economically feasible alternatives, will continue to be produced. . High costs of worker protection and environmental control in regulated, indus trialized nations like the United States will encourage hazardous and polluting industries to export their factories to non-regulating Third World Nations, e.g., Mexico, Taiwan, Brazil and South Xorea. The U. S. Government will initiate moni toring of exporting hazards to other countries and will pressure world financial institutions to restrict funding to such concerns. Vehicle Materials Engineering September, 1978 8003 1862 PRODUCED BY FORD