Document 4vXo7qk2mrrE3pKrge4x1vDkx

y\ 5/13/80. Copy to Guy. COK/lp 5/13/80 Copy: W. N. Moore\i^v""\ . C.O. KEUTCEN J. Shaw i,V> /Inter Ollice BOrtflY 13 AH 9 :15 -P.F H/iy/i 0 O^ \Uj rY Metal Stamping Division May 9, 1980 3l*r6ff Tot Frorat Subjectt Mr. C. 0. Keutgen FD-942 H. A. Nlda Carcinogens Task Force Report to E & R and M & S Subcommittees Our review and analyses of the proposed report Indicates that Metal Stamping Division can agree in general with the proposed strategy and work plan and the recommendations. * . 0 With regard to the proposed elimination of three specific carcinogens by Job #1, 1985, we do not believe that it is physically or economically possible i to completely eliminate the use of asbestos material in the non-production .category within that time span.~`FoF example-^ most of our approximate'~27U0 presses~are equipped with a'clutch-brake system utilizing, to some degree, asbestos impregnated material as a friction contact surface. Even if a sub stitute material is available or is developed with similar wearability and heat dissipation characteristics, it is highly unlikely that all of the existing material could or would be replaced in that relatively short time span. Many of these systemsvlast for years of use with minimal maintenance and would only be changed by instituting a directed program Involving excessive manpower and an Inordinate amount of equipment downtime. 0 Similarly, elimination of chromium compounds as well as all derivatives and input materials at our Monroe plating operations is not likely to occur without the development of alternative processes or product revisions to other materials. The institution of controls related to employee exposure and handling will be the only feasible approach with some of these substances in the near future. SCF-FORD-1901 8004 0167