Document 4v0RoOY2DyBZbyjbxqkdJKyRe

FRICTION MATERIALS STANDARDS IMSTITUTE, INC., E-210 ROUTE &4, PARAMUS, N.J. 07652 iinnss of the mxetiing of Che ASBESTOS STUDY COMMITTEE Friday, October 24, 1975, at 9:30 Arl Institute Office, E-210 Route 4, Paxamus, H.J. wr.MRF.RS PTU-SEKT H. Wagner, Chairman E. H. Feierabend D. Z. Stone I. >1. Weaver J. Dunderdale OTHERS PRESENT Carlisle Corporation Abex Corporation Bendix Corporation P.aybestos-V.arhattatv, Inc. Royal Industries '- M. R. Cole E. W. Drislane Clapp A Eisenberg Friction Materials Standards Tn*i.itute HOT PRESE'.JT It. Jacko E. P. Stef1 Bendix Corporation H. K. Porter Co. The meeting was called to order by Mr. Wagner, Chairman, at 9:30 A.K. MXaUTES OF PREVIOUS 1SETIMS The Minutes of the Meeting held April 28, 1975 had been distributed. These minutes were reviewed and a motion for their acceptance was made. bpvriTsgtiim -duly seconded -amd <aaanisously pasJfc&d, J.t was RESOLVED: To accept the minutes of the April 28, 1975 meeting as written. ASBESTOS IirrOSHATlOH ASSOCIATION COSPERSIJCS The Asbestos Information Association <AIA) Held their annual GovemoentXndustry Conference in Washington on September 10-11, 1975. Hon-merabers of AIA were invited to attend this conference. Several individuals representing friction materials attended. One of Che iteas of incarest was the proposed OSJiA regulation which was due near the end of September. It had been indicated that the OSRA standards would be oriented more towards work practices than to a numerical standard. Hr. Heaver indicated that the OSHA individual who indicated this did so believing that the new standard would not have a new numerical Unit. Apparently there vas aloe of aroawas 3SHA by other groups--possibly labor unions and HIOSH--and that the proposed lower cuaerioAl stasuiartf caw is at the v*ry eod of the write-up as it was WV-06042 Minutes of the Meeting Asbestos Study Committee -2 October 24, 19 75 prepared for publication. The standard, which vill be discussed later, proposed a numerical standard of 0.5 fibers/cc (TWA). Several attendees stated that this conference was most worthwhile. It gave a good overview on asbestos. The only criticism made was that the speakers did not have sufficient tine to be questioned after their presenta tions. The Institute will continue to monitor this conference and expresses its support of the work of the AIA. hLAHS FOR INSTITUTE SEMINAH OH ASBESTOS Mr. tfagnar and Mr. Drislane had taken the initial steps to organise this seminar. At the April 28, 1975 meeting of the Asbestos Study Committee a resolution was passed recommending that the Institute sponsor a workshop on the asbestos problem in the fall of 1975, This resolution was reviewed with the President of the Institute, Mr. Siracm, and it was decided to proceed with such a seminar. Mr, Wagner contacted Mr. Noel Hendry of Jehns-*lanville relative to his putting on a session similar to that which J-lt presented two years ago. (For reference." Mr. Uoel Hendry, Denver, Colorado, telephone 303-770-1000, Extension 2142), It was suggested that the Johns-rtanvilie presentation would have to be the corner-stone of any seminar and that this would have to be arranged first before arranging other presentations. Mr. B. K. Kwon of OSHA had been invited by ?Sr. Wagner to address this seminar. Mr. &roa had indicated chat he should be able to attend. It was suggested that the seminar would be a good time for a synopsis of the major points of the new OSHA standard. Also it would be well for Mr. SCwon to talk with people from our industry. A comment was made to the effect that OSHA had misled those attending the conference in Washington indicating that the proposed standard would be work practices oriented. (The standard came out' with a lover numerical limit.) It was stated that Mr. Kwon was knowledgeable in the ind.**cxi.J hygiene area but he was not a policy maker, He was not responsible for the addition of numerical standard in the proposed amendments to the OSliA regulations. Mr. Dris lane indicated that he had talked with Mr. Bob Mereness of the Asbestos Information Association, and Mr. Mereness indicated that he would be pleased to attend. Also Hr. Drislane contacted Mr. R. Magdelaia of Hilfish of America Inc. Mr. Magdelairt would be most pleased to put on a presentation relative to that type of vacuum cleaner for the work place. Mr. Hagner also talked with Mr. . Engeleightener of Ferro-Tech relative to their pelletising equipment. Hr. Engeleightener will also make a presentation. At the meeting Mr. Magner called ilr. Hoel H^pdry to firm up the J-M participation. In summary, it was indicated chat 7ir, 5/21 Reitso would discuss the medical aspects of the regulations. Mr. Ed Fenner would revie? OSHA and EPA regulations. Mr. Moel Hendry would discuss fiber handling. The J-f: presentation will require-a 35 can projector, a 60 x 60 screen, along with a podium and a PA system. Mr. Drislane indicated that frr erase would ha aade. Minutes of the Keating Asbestos Study Committee -3- Gctober 24, 1975 The seminar will be rd for Heetccity, Becc-feer X* Thursday. Becenber <. The openIns session will be * tias >* T,,t. MaEViile for the. full afternoon on Bocenber 3. Other topics will he scheduled on Thursday morning, with Mr. --Jcraness <ar someone else from AlA> calkin? at the luncheon on Thursday. There would he a registration es> of $10 for the seminar. Hr. Orislane will try to make arrangements at either the Harriott at Saddle 3rook, the ilamada Inn in Rochelle Park, or the Sheraton Heights in lasbrouck Heights. Mr. Bris lane will write Ur. Magdelain and Mr. tiereness to officially invite them. Mr. Wagner will write to*Mr. Kwon,' Mr. Inseleightener, and Hr. Hendry to firm up the* arrangements. The comictee recommends that Messrs. Wagner and Brislane plan and schedule the seminar. It was suggested that the type of person to be invited should be someone involved with plant problems, but it should also be the foreman or other individual who could get across the message to not use an air hose or a brooa. The possibility of a movie being shown was discussed. It was suggested thar the controversial interview of Dsr. Seltkoff and 2>r. Xevlnsoha of Turner Brothers would not be the right presentation. Perhaps a novie that emphasized controls in the work place might be worthwhile. Mo decision was made as regards a movie. Another suggestion was to have a presentation by those who have used foam ro envelope the work station so that no dust is raised during mixing. :ir. 'leaver felt that this was an interesting technique. Mr, Stone had discussed this at an earlier meeting but had made no further progress on this since that time. It was decided that this would not be added to the agenda. As regards the Hilfisk equipment, it was noted that this is good equipment for local pick-up of dust and debris in the work place. Hovever, this subject should be expanded to include a central system such as a Hoffman unit. It was felt that this session should be called '*housekeeping in the work placerather Chau "Xtlfisk'', However, the Wilfisk representative would discuss his unique equipment. The idea was to sell the concept of cleaning the work area (not to sell the vacuum cleaner). Mr;* Brislane will indicate this particular point to Mr. M2gdelain in his invitation. AIA SOTm-TS -ftSSgSTOS 'AMP STcAfg: -HiCZvSS^ Uc. Hereness requested Mr. Brislane to have this booklet reviewed for update and corrections. The first question raised was "Who is this booklet aitied at?". Also, "tihat is the purpose of this booklet?" It was stated that this write-up was not a complete presentation of any particular aspect of the asbestos problem, and while interesting insofar as it vent, was not particularly convincing. It is not the type of message that would ordinarily be given to customers of friction material manufacturers. The message for re-builders and the garage people is to not create dust in the work place. There should be more emphasis, if this vas the direction of the booklet, on such things as labelling, possible use of instruction sheets, the handling of lining, and the proper use of exhaust systems. One of the problems in the field is that these customers will often groove, chamfer or provide extra drilling. It is during these subsequent operations that asbestos concentrations may be raised to levels above that allowable. It was pointed out the Asbestos Study Committee could not re-write a draft unless it knew what the booklet wps tiding at. It. *-* s.tatad that the title is wranft. Perhaps there should Minutes of the Seeing Asbestos Study Committee 4 October 24, 1975 be two separata oaisphlcts, one for the garage and the re-builder type operation (for those who art doing brake service), and another for the general public. It was stated that the audience for this booklet, as written, rust have been the er.vironmentally concerned customer. Hr. leaver suggested alternatives as regards this write-up: (1) Drop it-- do sor use it. (2\ Rewrite it for those servicing and installing friction materials. (3) Hrite a complete new article. The write-up made has little imp3ct. One advantage may be the listing of reference material at the end of the booklet. If the ALA believes that the booklet should get to the user (the cur toner of the friction materials manufacturer) it is suggested that information bo given to the user as indicated in the proposed regulations under "DAGGER" labels. This concerns the requirement during "any reasonably forsoeable use; handling, storage, disposal, processing, or transportation1' that no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed be released. The items that follow this section on housekeeping and waste disposal are particularly pertinent to the users of friction materials prior to installa tion on a vehicle. Mr. Drislane was advised that the Asbestos Study Committee will not re-write the article. The Committee recommends emphasis on recommendstions for garages and the re-builders. The Committee would be happy to review a new write-up prepared by AlA which was aimed for this user, with emphasis on the those who actually do subsequent work on friction materials such as grooving, cutting, grinding, chamffiring, etc. REC<T TENDED PROCEDURE FOX BRAKE AI*D CLvTCH S.E..RVICING This write-up had been prepared by the Kaybestos-Manhattan, Inc. Hr. Heaver distributed copies to Committee members. Roybestos would welcome comments on this write-up along with aay recommendations for changes. Cecinittee members wishing to comment should send their recommendations to the Institute office. TiTE'??{??Jbtl) Ci'SnA TTTiMDARP AITP T2g 3.`5 glf>ER-/C -LBttg Prior to discussing details on the proposed OSHA standards, several laeobsts stated that they had been inspected by OSHA. -lhile in a few cases citations were made for higher concentrations of asbestos than permitted, there had beets many instances where counts were made without a citation. While the values on the concentration are revealed when a citation is made, OSHA does not provide information on the counts when a citation is not issued. Several members indicated that they believed that OSHA will not provide written results on their test in the work place unless it is necessary to support a citation. In other *ords, where a citation is not involved they will not reveal the data. Legal Counsel will check on the availability of this information and whether 3SHA can be requested to provide this data when a citation is uot involved, and will report in writing to the Institute on this. The proposed OSSA standard is far reaching. The main problem is the new issss LLzzlz oaaaericxl standard (0.5 fiber/cc5. GSEA has put out a rt richer specific itra r= ?toiic paarictpaT^nr sitfe tae mas * *tt* being that che comments must be postmarked on or before December 8, i?/o. Minutes of the Meeting Asbestos Study Committee 5- October 24, 1975 Written comments concerning the proposal must be submitted in quadruplicate: Docket Officer, Docket il-033 US Department of Labor, Rooa U362Q 200 Constitution Avenue N.W. Washington, D.C. 20210 The question was asked as to what would be the roost effective means of communicating with Washington to Indicate the problems with this new numerical standard. Should the Institute comment? Should the individual members comment? It is not enough for the manufacturer to feel his views will be represented to the regulators-by the Asbestos Information Association or FHSI. It was suggested that it would be best if both the Institute and individual members respond with points that are particular to their factories. It is felt that participation by the small manufacturer will be most meaningful. The Asbestos Study Committee will review the proposed standard and note some of the points that timbers may wish to comment on. It should be pointed out that even if numbers comment to the effect that they support the AlA comments or they support the FMS1 cements, at least they will be on record espousing their viewpoints. A comment was made to the effect that everyone has been gearing to get their concentrations down to the 2 fiber/cc limit by July 1, 1976. The technology necessary to tike the count down to 0.5 fiber/cc is not known, now can comments be made on the cost impact, effects on competition, effects on employment, effects on energy supply, when the technology for getting to the 0.5 fiber/cc is not even known at this time? The least chat can be done is to request an extension of time for comments past December 8, 1975. Upon motion duly made, seconded, unanimously passed it was RESOLVED: That the Institute will request the Department of Labor to delay the cut-off date for comment on these proposed amendments to April I, 1976. lhe friction materials industry does not know whether the 0.5 fiber/cc limit can he reached. Perhaps it will be necessary to go to materials with a material cost ten tines that of asbestos in order to get the work place down to the proposed level. Industry is confronted with requirements for Standard 121 and Standard 105-75 from the Uatiosial Highway Traffic Safety Administration with stringent friction materials requirements at the same time that they must evaluate whether they can still use asbestos in their products. There are several points in the OSKA standard besides the 0.5 fiber/cc limit. However, the main problem is the 0.5 fiber/cc limit. Some of the comments to follow concerned new problems that may arise as a result of this proposed standard. These problems will be pointed out to the members so that they can look at these from their viewpoints with the aim of advising T-Tashington on their individual problems with this standard. The reduction of the limit to the 0.5 level is going to effect processors such as the re-builder and the garages who were not really included in tfris 5 tandard before, fatj octfii frirrdac rnst,trials asap very well find airborne concentrations of evbesros fibers that uu,tii Che 0.5 fiber/cc level. For example, a junk yard which night have a side line is brakes sis&r bar no problem sr tss present Minutes of tha Meeting Asbestos Study Committee ->- October 24, 1975 any work that they might do which could bring their concentration above 0,5 fiber/cc would now be a problem. These people would now be covered by the requirements of the OSRA standard. Many smaller operators have to drill materials to adapt them to unique shoes in the field. Additional drilling would probably move concentration levels well above the maximum ceiling concentration of 5 fiber/cc. A point to be mentioned is not to adopt the tactic of "You can't do it." The point is that at the present time technology is not available in the factory to get down to these levels. The industry does not know what the costs are. Hot/ can comments be made on cost impact, competition, employment, energy, etc. when the technology to get there is not known? Still further, is such a limit necessary? It is suggested that unless a member has specific medical information suitable to refute the proposals in the standard that he not attempt to resist ehe 0.5 fiber/cc limit based on non professional observations of workers made in the past. In other words, if it was not good medical information don't use it. The Asbestos Information Association will cry to assemble some realistic medical information for consideration by the Department of Labor. As regards the problem with cost impact on the consumers, it nay be that clean rooms for tha elimination of asbestos may be required. Without knowing figures perhaps costs will more then double with poorer performance at a time when the National Highway Traffic Safety Administration is calling for even higher performance. Members have made extensive plans for equipment, exhaust systerns and procedures to set to the 2 fibors/cc limit on July 1, 1976. Since this equipment will not get them to the 0.5 fiber/cc level, this huge capital investment should perhaps be stopped until such time as a new standard is decided. Should a manufacturer discontinue his heavy cotemitment to equip ment for the 2 fibers/cc limit when this equipment will not meet the 0.5 fibers/cc limit? Could there be more emphasis on protective clothing with cover-alls, smocks, boots and gloves as veil as a respirators. With reduction to the two fibers/cc level on July 1, 1976 and better work practices, the clothing might do the job as well as the new difficult-to-raeasure 0.5 fiber/cc limit. 'flie members don't know hoi/ lor/ they can get in fiber counts until this new collection equipment is actually installed and in operation. Suggestions made for cleaning the work area are all well and good but the only proof that one has reached an arbitrary fiber limit is when the installation is completed. As regards energy who can say that if double the horsepower was added to collection systems that they would get down to the new limit? How can the energy cost be estimated until this same equipment has actually reduced the concentrations down to the new levels? Where regulated areas are established where allowable concentrations =sy be exossdsd, it is diifienir ta got csylaywj -eer th* ^zjbs. clothing. If one were trying to operate a clean room along with proper protective elsthing, employees would want air-conditioning in the- Uinutes of the Meeting Asbestos Study Committee -7- Octofeer 24, 1075 work place for the uncomfortable clothing. To require air-conditioning in the work place while also mint aiming the extensive exhaust systems would be prohibitively expensive--if it can be done at ail--becauae one Is at cross purposes with the other. Costs also will be increased because of the new monitoring requirements. As retards the effect on competition it was pointed out that this may very well be the trigger which *?ould close down some marginal operations with a resulting transfer or jobs outside of the U.S. Even in Great Britain where /such medical indorsation has been gathered they have nor gone to the 0.5 fibers/cc liir.it. It does not appear that Great Britain has sufficient medical evidence to support such a limit. Countries on the continent do not have this 0.5 fiber/cc limit. The Latin American countries have no Halts. As regards the effect on employment and competition, the huye capital expenditures required for the U.S. plants may very well export additional jobs. vhils some of the procedures recommended for handling asbestos end removing the worker from contact with the product may show labor saving results, the actual level of exposure to the remaining workmen from these changes still will be quite high. There would be considerable costs for members in the friction materials industry to requalify brake blocks and heavy duty segments for the require ments of Che iTiiTSA Standard 121 which went into effect during 1975. There has beer, n considerable expenditure of funds for Standard 105-75 (hydraulic brake systems standard) by many members. Any changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard would add additional costs for manufacturers in requalifyin? their materials. The friction materials industry in particular is caught between the forces of improved performance of braking materials along with restric tions on how to manufacture and distribute their materials. There may be considerable testing to requalify materials if there should be a change in processing or compounding. .. As regards the costs to consumers and society in general the industry does not know what can be done if it is necessary to remove asbestos from brake lining* Xae .industry .co.uid be .subject to S - 10 .years of serious dislocation. In addition to the problems with the OSHA standard that appear evident, costs can not be quantified at this tine. Industry needs more time to respond to these far reaching regulations. One of the requirements for record keeping stated that the records oust be maintained for forty years, or for an employment interval plus 20 years, which ever is longer. This is a considerable record keeping requirement. However it was stated that perhaps this is necessary in order for subsequent study of the epidemilogy of asbestos. It was suggested that perhaps this is one of the new proposals that can be lived with. In prior neetings and at prior workshops the problem of correlation of fiber count has been discussed. In general there seems to be some agreement that different experienced counters may total up results showing as much as a 30% variation in counts from the same sample. This is already a problem. However these counts where the 202 variation is evidenced are in the 2 fibers per cc to 5 fibers/cc area. A 30% difference with a 5 fiber/cc count is 1.5 fiber/cc- 035A is asking for a canruaarraxiM: 2S=dt of 0.3 fSwr/tar nfcesr =22b current observations there can be variations of as jroch as 3.5 fibers/cc. As concentrations move cowards 0.5 fibers/cc not only does technology get o e Hiii i --11 i)!'b fvF 9* Minutes of the Meeting Asbestos Study Cdam:: : toe 0- Ostcher 2*. i??5 Industry conditions in 19 75 (under the current 5 fibers/cc limit) are much improved over industry conditions which were in effect through most of Che 1960's. Each additional step approaching zero fibers/cc is a lot more difficult than the steps that were taken to get industry down to the 5 fibers/cc limit. 'Jhile it will be burdensome to move the concentrations to the 2 fibers/cc limit, the steps necessary to get down to 0.5 fibers/cc are not There are requirements in the proposed standard for worker rc-assignment. if many employees are moved to lesser and lesser duties maintaining the same premium pay that they had received for working with the asbestos products, there will be a negative productivity result. It has been industry practice in the past for night shifts and more difficult tasks co command higher pay preiums. This rotation to another job with no loss in pay will be another penalty to productivity. The recommendations that will be made by the FMSI or the AIA are not known at this time. It is believed that the AIA stand will include background on medical information. However, it is most important that the individual companies make a response, they should'not expect that someone else will write it for them. The Secretary will prepare a bulletin to be sent to the membership suggesting that they comment to OSHA on these requirements. It will be pointed out that the comments must be those of the individual member and they should not echo the suggested outline of problems which the Institute will prepare. It was also pointed out that there are a lot of new items in the proposed regulations including items on loading, unloading and storing of asbestos cargo. The carrier--be it a railcar, ship or other--must make a visual inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed. Who does this? Does the carrier do this? Are the carriers aware of this problem? A close reading of the proposed 05HA standards revealed many problems of this nature which will have to be pointed out to others who may not feel that they are affected by the asbestos regulations. THE -SPA MATIONAL ^nSSIOSS STANDARDS FOP. ASglSTOS The Environmental Protection Agency published the amended standards for the National Emissions Standards for Asbestos. This appeared in the Federal kegister October 14, 1975. Ordinarily the EPA amendments would be an item of prime concern to the manufacturers. However the proposed OSHA standards are so extensive and so far reaching they must take priority over these new EPA Standards. It was pointed out that the EPA notice is the adoption of the amendments to the standards. These are not proposed amendments. In particular the waste disposal requirements are of interest to friction materials manufacturers. The friction materials manufacturer is responsible to see that land-fill operators and trucks carrying waste comply with the requirements of EPA on disposal of asbestos bearing materials. The manufacturer is responsible for supervision to see that these requirements are carried out. Merbers reviewed the section 61.25 on waste disposal. There was some difficulty citt interpretation- ?tr. reaver pointed oat chat the resai'reaeairs S covering the asbestos containing material were applicable only if there vere eaissioas to the outside air from tLs waste disposal site. Tzr ceber vcrcs. if there were"sc visible emissions" rea^rgaggrg Call'll szni ceSSCST Minutes of the Meeting .T.'k'CstC'C ^ '*--* * -- -,g -a- C-c-Satar 2*, IS 75 of 61.25 do not ccme incc ploy. however these retiresants for cover do take effect if there are any visible emissions. The most difficult areas of the new EPA standard are in the waste disposal area. There was no other business called to the attention of the committee. Upon notion duly made, seconded and unanimously passed it was RESOLVED: To adjourn. Adjourned: 2:15 PH E. W. Drislane Secretary