Document 5Dg51kYwzMZ608EoVQRGERxMN

Personal & Confidential ?lay 19, 197S To:- Messrs. F. A. Cappucci - Trevose R. A. Gerde - Memphis V W. Jones - Wood Dale W. W. Phipps - Hayward Subject: ASBESTOS DUST Apparently several of the warehouse personnel are showing some concern relative to asbestos dust because of the nature of the beast. This is further compounded by the fact that we may have to re-box and even de-edge code. Because of this we will need your help and perhaps you can give us some answers to the following questions along with any other comments you might have: 1. How much time do you spend re-boxing product now? 2. How much de-edge coding are you having to do, and if so, what is your procedure for removing the edge code? 3. What equipment in the way of grinders, wire brushes, etc., do you use? Would also like your comments relative to sweeping tip the dust from the warehouse floors, racking, etc. Obviously, you want to gain this infosnnation as subtly as you can and return it to this writer's attention under confidential cover. Might we ask that you get this to us no later than June 2nd. Thank you. /me cc: B. Iwarsson R. L. Cutler C. B. Mallory E. P. Boff Blind Mote to B. Iwarsson/C. B. Mallory Attached is some information that west coast people sent us which I thought might be of interest to you. EPH. SPNY 004778 SPNY 004779 OH Interna! Note F.M. fill no From .........----------- To Hr.J. Marchant Brake Lining Wear Dust Reference the query from fir. Rogers of Nutum Corporation, the evidence which we have collected over several years shows that there Is very little crystalline material and virtually no fibrous material in lining wear dust. - On heating, chrysotile asbestos first breaks down to-a non-crystalline magnesium silicate anhydride, which is non-flbrous. At higher temperatures^ not usually regliiLuring braking, the anhydride is converted to crystalline^orsteritei) but this is also non-flbrous. {The conversiun temperature Is otirtj. We have recently had independent analyses carried out on two samples of . wear dust - one from a disc brake and the other from the main dust collection point for the dynamometers in Test House, and I attach a copy of the report of the Government Chemist. The findings confirm our own analyses. The - _ samples incidentally were taken in the presence of the Factory Inspector for this area. A particle size analysis of the Test Housb dust, using microscopy methods, showed the following : Particle Size (microns) ' % Present Up to 1 2 3 A 5 81 S 2 1.7 ' 0.3 We define a fibre as having a minimum length of S microns, with an aspect ratio of at least 3 to 1. In the present sample, even the S micron particles did not reach this ratio, and the sample does not therefore appear to contain any fibres within the definition. These results are in agreement with those quoted by Jocko end GuCharme of Bendlx, who found that mare than S9,7i: of the asbestos used in friction materials is converted to a non-fibril form. rTheir report 60-04-0020, dated March 73 - Brake Emissions : emission measurements from brake and clutch linings from selected mobile sources - was prepared for end should be available from : . Environmental Protection Agency Office of Air and Water Programs Ann Arbor, Mich. 48105________________ . 2- I believe that wo can state with confidence that brake lining wear dust normally contains substantially less than It of fibrous asbestos. i i '; - SPNV004780 (UM) HIWO fan yi* OMJtXM. OpM. "' .* ri" tax. rout K) Ministry-o/-Tethnology q LABORATORY OF THE GOVERNMENT CHEMIST Cornwall House, Stamford Street, Londow S.E.I . 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LUP k-ZO tc-o 04 /o" X-*\u.w cI/AMosJ^Aow. i<l ka- (Kt. u.ccj-p-U^^ Us-sctoMA.^ * *6'lo <X UnK^VOS- Ss-.'j.y^.nA'c 'imaJ- AC ^ f^Ajf [rOr ^v '--eLxj}'- Oj^u-.v-^>3^ '`-.".'->W; ^LOUA>-d>fe-'- -:^> '--V ~ '#4O*,a/V I 7o AXtZji (" Vv'/ v) UA, <At^- bvJr /vcxaJ-- j ^ r^c?v t'OCL'-r^ IjC-A, ^ --------------- --^ o- ^ CA. a '--^ for Coyeffl/7?c/jr Cftcm/it /^U/^U'V' ^ r * ----- r ' SPNY 004781 Subject: Asbestos In the spring of 1978 Joseph A. Califano. Secretary of Health, Education, and Welfare/ launched a campaign to inform doctors, workers, and others about the risks of asbestos exposure. The information program for health professionals began in April 1978 with a letter to the nation's physicians from the U. S. Surgeon General. The campaign furthermore included television, radio, and print public service advertising. Additionally, about 40 million social ' security and other federal retirement beneficiaries have or will be receiving information with their checks. Efforts will also be made to use the labor and military press and similar specialty outlets. This new public awareness campaign will also manifest itself in new regulations, such as that governing transportation of hazardous materials. As of April .30, 1979, domestic transportation of asbestos will be subject to a regulation which calls for pallets and shrink wrapping of pallet loads in addition to individually packed bales. The HEW public awareness campaign is now in progress but a similar campaign is being contemplated by OSHA. Should such a campaign be effectuated by OSHA it is a virtual certainty that we might be faced with exposure limits lower than 2 fibers per cubic centimeter. The probability of this happening is, however, somewhat remote at this time since OSHA, conforming with the President's guidelines, is anticipating severe budget restraints and personnel cutbacks in 1979.' In "addition tothT^^'0SHA'"is'^urreritly1,,Sxpending all its ' energies on petitioning the benzine decision and its position concern ing regulation of hazardous materials in the future very much depends upon the outcome of the benzine case. Nevertheless, I believe it behooves us to formulate our thoughts regarding our posture as it concerns exposure limits lower than what we currently have. It is assumed that new regulations will call for a maximum of 0.5 f/cm3 as compared to the current level of 2 f/cm3. Recognizing that 0.5 f/cm^ is below our ability with current dust collection methods, it appears as if we have three alternatives: 1. Eliminate asbestos as a raw material. .2 Redesign our manufacturing processes to permit adherence to this standard. SPNY 004782 2- - 3. Challenge the decision in court in order to either maintain the 2 f/cin^ or to buy us additional time for the purpose of developing new materials. Since alternative number one still is not ready for application in all product lines and all part numbers, and since alternative number two will be prohibitively expensive, it appears to me that only alternative number three is viable. It is estimated that taking this issue to court may cost in excess.of one million dollars. This cost can be split between the members of the Asbestos Information Association, thereby reducing the expenditure to each corporation to a maximum of approximately $60,000. Within the AIA the board of directors is currently doing its homework towards the implementation of this solution. However, should the limit be established at somewhere around 0.5 f/cm^, I need to have the authority to commit our corporation to this amount of money on fairly short notice. As I said, this is only the contingency plan and, for the time being, it looks as if OSHA has its hands full with the benzine ruling. We might, therefore, have enough time to develop an asbestos-free formula for all product lines. Your immediate comments to the above will be sincerely appreciated. BI: j t B. Iwarsson SPNY 004783