Document 5L7E1aGQnpqkqnEyQk3Zo14eD

Inter Office' PLAINTIFF'S EXHIBIT FD-1009 Engineering and Research Staff May 1,1980 Messrs. H. Bickenbach P. T. Brosnahan C. C. Drouillard W. H. Gay M. L. Jurosek E. R. Karrer Kordick R. Learned M. H. Manning H. A. Nida W. E. Scollard D. C. Travis cc J. W. Durstine Subject: Carcinogens Task Force Report to E&R and M&S Subcommittees The Task Force on Carcinogens in the Workplace was established by joint action of the E&R and M&S Subcommittees, with representation from affected line and staff activities. The Task Force was chartered to coordinate plans and efforts to identify and quantify carcinogenic substances in use; to develop action plans, take aggressive steps and set targets for elimination of as many carcinogens as possible; and to organize to identify substances systematically. The Task Force will present its report to the Subcommittees on May 27, 1980. Attached is a draft of the report. Your comments are requested bv Mav 9. 1980. so that we may meet the timing of the several pre-reviews scheduled. -------------------- - Attachment SCF-FORD-1865 8004 0768 V V EXECUTIVE SUMMARY CARCINOGENS IN TIIP WORKPLACE Introduction The Ta'.k Force on Carcinogens in the Workplocc wns established by the Engineering and ItcseuTch und Manufacturing and Supply Subcommittees to identify carcinogens mid qunntilics in use, set turgcls for elimination alieud of regulation, take steps to find substitutes, develop a directive und workplan und organize to identify substances systematically. The Task Force assignment responded to evidence thut cancer may be a serious occupational concern and to the Company's und public concern with regard to protection of the environ ment and public health. Additionally, the Company hus been subjected to a growing number of luws which regulate material u>c, trunsport, handling and disposal. In summary, internal and external pressures regarding huzurdous substuncc control nnd compliance have increased substantially since March, 1977, when Directive U-101 assigned responsibilities within the Company. Past Company Actions Since 1977, the Compony hus removed lead chromates and molybdates from paint (except special order). "Tris" flome rcturdont from fubries nnd instituted controls on asbestos, including u Vehicle Engineering diroclivc thut newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coaled). Sprnyed-on fireproofing has been asbestos-free since 19C9 for new and reworked construc tion. Several manufacturing standards prohibit asbestos os a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazards from paint-related enromium compounds. Carcinogenic Substances The Task Force has identified sixty-seven (67) carcinogens In use in the automotive industry. Twenty-six (26) of those aro currently regulated byOSHA; the baloncc hove been proposed for new regulation. More restrictive standards have been proposed for some of those sub stances currently regulated. Thirty-one (31) substances are reported to the Michigan Department of Natural Resources for computation of water surveillance fees. Michigan plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNK list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur rently required to be reported in the other states. The list of carcinogens was prioritized by the Task F?rce according to impact on tho Company to identify the top eight (6). The top three of the eight priority substances, asbestos, chromium compounds and benzene, were examined in detoil. * Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets and for nonproduction roofing, millboard and corc/inold-mnkiu;; materials. Mcdoul evidence links inhalation of asbestos dust to lung cancer, mesothelioma and other diseases. The present OSHA limit is 2 fibers per cc of uir (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/cc os early as this ycor. - Chromium compounds are used primarily in paints and inks for production ond nonproduction use. Medical evidence links hexovalent chromium compounds to lung cancer, liver ond kidney damage and other diseases. The present OSHA limit is 52 mg per nr of air which is proposed to be reduced to 1 mg/m . - Benzene occurs primarily in coke oven operations as a by-product. It Is a residual constituent of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has proposed a limit of 1 ppm in air time weighted average in 8 hours. Specific lists of bulk materials and parts for production and nonproduction use hove been developed. A new computer data base is being developed, Materials and Toxicology System (MATS), which links hcolth, engineering, and monufacturing data bases to facilitate rapid identification of carcinogen applications (2nd quorlcr 1981). The engineering release system has been audited end is being updated to extend materials idcntificotion to oil parts. Product Engineering Troceduro PEP 3-189 has been rewritten to require systematic review of suspect carcinogens and input to tho data base. . 8004 0770 EXECUTIVE SUMMARY ' (Continued) Strategy and Workplan The search for asbestos, chromium compounds and benzene defined the number of ports and materials containing these substances as listed in the table below. Where possible, the applications were divided into three groups: A * Known substitute material without major redesign, B - Known substitute material with major redesign and C - No known substitute or advanced engineering required. The data is directional only. There remain muny suspect applications which require time-consuming analyses for identification. Bulk Materials and Ports Asbestos Chromium Compounds Benzene Production A B C Total 34 49 22 - - 25 - IS 105 25 15 gNonproduction Ay TotuT 8m- 8 98 81 3 .- 34 5 213 8 Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three corcinogcns by Job HI, 1985, in light of competitive and regulatory pressures, and Company experience. Where elimination cannot be contained, institute controls on design, process and exposure. It is judged that the elimination timctablo is pruclicul for Group A asbestos, chromium compounds and benzene-containing ports ond materials. For those applications requiring major redesign (Group B, e.g., drum broke linings) the elimination timetable would have to be adjusted to reflect Company cycle plans although G.M. has stated on intent to eliminate asbestos by 1985. Finally, where no known substitute exists (Group C), advanced engineering will have to be completed before a diminution timetable can be established. A generalized workplan has been prepared on the basis of the evaluation of the corcinogcns already referred to. The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle acti vities and the Manufocturing ond Supply Staffs. It is judged that approximately a year is required to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is judged that one additional year would be required to implement the most feasible product octions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro grams. Recommendations t Achievement of the recommended strategy requires an integrated approach throughout the Company ond a sustained effort over a number of ycurs. The Task Force recommends: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2. Assign Carcinogen Program manager control responsibility to Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish corelnogen elimination timetables for the $7 known carcinogens for review and opprovol by the subcommittees. (The Task Force has requested General Managers and Chief Engineers to recommend directional timetables.) 4. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job #1, 1985. 5. Request that NAAO Product Engineering Offices and Manufocturing Staff present to the subcommittee specific action plans and timing for the Group A applications identified. 6. Provide advance program funding to develop designs and/or materials for new parts to Identify reliability, cost and weight implications of oltcrnotive designs (Group C). 7. Adopt as the Company corcinogen listing the 67 current OSHA-rcgulotcd end proposed Category I substances. Establish the top eight priorities proposed by the Tosk Force as Company priorities. 8004 0771 Engineering Stoff - E&RS Manufacturing Stoff May 2,1980 DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2, 1980 8004 0772 OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE p MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production - Nonproduction . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Asbestos, chromium, benzene . Asbestos Summary . Chromium Summary . Benzene. Summary ; Carcinogen Search - List specs, and parts - Identify items having no substitutes - Identify substitutable items .. Eliminate when redesigned or reordered - Develop substitutes for others (advance engrg. funding) . MATS . Carcinogen Search Results . Carcinogen strategies . Generalized Workplan . Proposed Chemical Substances Control . Proposed Priority Actions Exhibits . List of "67" Carcinogens . MATS ( Appendices Asbestos-containing parts and materials Chromium-containing ports and materials Benzene-containing parts and materials I 8004 0773 DRAFT CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established during the 4th quarter, 1979 by joint action of the EdcR and M&S Subcommittees. The Task Force Charter was to coordinate plans and efforts among Company activities, to identify carcinogens in use, and eliminate or control them in future products and manufacturing operations. Task Force findings and recommendations arc summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendices. Background Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.S. might be associated with occupational factors. Accordingly, Personnel and Organization Staff, Employe Health Services, has exerted a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. Public concerns relating to the control of toxic/hazardous materials, are shared by Ford, due to the Company's regard for public health and the protection of the environment and potential impact of legislation on our products and manufacturing operations. Also, the right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. . Resolution of workplace exposure concerns relating to the management of toxic/hazardous substances, materials, and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater presentment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques as well as by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines up to $25,000 per day, and a citation normally consists of multiple related violations. Litigation is also a growing concern. At present the Office of General Counsel has three suits pending, involving deaths allegedly due to the inhalation of carcinogenic substances. ; Some Workman's Compensation expense has also been incurred. The greatest potential for ' major expense, however, lies in the possibility of punitive action by the court. Internal and external pressures regarding hazardous substance control and compliance have , incrcuscd substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been ^ issued, additional standards are anticipated, and the level of economic risk has increased. .a s I Federal Register 45(15): 5031, January 22, 1980. -1 - May 2,1980 8004 0774 draft FEDERAL AND MICHIGAN ACTS ItrrjUMTINO TOXIC/IIAKARPOUS MATERIALS HAVING IMI'ACT ON TIIK COMPANY piouiie i Regulatory Aeu Occupational Safety and Health Aet 1(70 D.O.L (OSIIA)' Harardous Material* Transportation Aet I97S D.O.T. (IITMA) Tonic Substances Control Aet 1(76 E.P.A. (TSCA) Reiourea Contcrvalion and Recovery Aet - 1(71 E.P.A. (RCRA) Clean Air Act and Clean Iv'atcr Aet Amendment* (CAA) 1(77/71 E.P.A. Michigan Act 7(1, P.A. 1972 Michigan D.N.K. (MDNR) Packaging A Stacking . Federal Harardous Subttancc* Act 1(70 , Polion Prevention Packaging Aet 1970 . Consumer Product Safety Aet 1972 . Waite Management . 'Hanardou* Waite Minngemcnt Aet - 1(79 Mich., P.A. 64 . Solid Waste Management Aet - 1976 Mich., P.A. 641 Eipccted to be reviled during 1(10, to lower permissible esposure limit from present 2.0 fiben/cc to 0.6 or 0.1 fiberi/ec of air. FIGURE 2 CORPORATE STAFFS RESPONSIOILITY FOR TOXIC/KAP.ARDOUS MATERIALS (DIRECTIVE 0-101) surf EStt Responsible Activity SSECO PAO 111 JiT MFO. STAFF SAFETY Plant Engrg. Office Mfg. Engrg. A System* Plant* EARS Prog. Anal. A Matll. Engrg. Research Staff , SUPPLY Tran*. A Traffle OSHA TSCA Compliance Reporting REGULATORY ACT ~------- RITkS------- A Stale Solid/ Ha*. Wastes Compliance Reporting IIMTA # Compliance Reporting Identification of Control* Material Inclusion in EPA Inventory Monitoring Enforce Control* Facility Controls Non-Prod. A Prod. Development Mall*. Review Process Control* Non-Prod. Mall*. ' Development Review Process Control* Non-Prod. Mall*. Implementation Review Facility Control Implementation Develop new malls., mfg. processes, A measurement device*. Production Matin. Review Chemistry in Data Hase DOT label in DoU Rate Disposal Moth. A Fee. Dev. Waste Charse- ,ttrlxatlon Packaging Storage Material Character I- lotion Compliance Reporting CLEAN AIR A WATFR Compliance Reporting Monitoring .MICH UVl Corny: 'incc Reporting Chemistry m Dsta Disc Ptellities Roup* ConsolDevelopment idation Process Contr. Development Permit Reporting Usage Reporting May 2, 1980 8004 0775 DRAFT PAST COMPANY ACTIONS Production Materials In response to OSHA regulations in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977, in response to an Inquiry by NHTSA. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements fr.r employe protection and medical examination. Car Engineering released a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermol insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied, in 1977, the Compony replaced M-2CG0 Series of maintenance lubricants with the lead naplithenate free M-2C142 materials, and deleted the use of asbestos bearing molding compound at Sheldon Roud. In 1978, an adhesive used at San. Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories was revised to eliminate benzene, the volume of lead-chromate employed in vinyl plant operations was reduced and vcntilation/protcctivc measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used in painting. (The substitution of non-hazardous paints is targeted for Romeo for late 1980.) -2 May 2,1980 8004 0776 t>n ANT ?r*v**N DRAFT FIGURE 3 PAST COMPANY ACTIONS Production . Removal of lead and chromium from paints. ' . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. Nonproduction . Removal of asbestos from, - Structural fireproofing - Thermal insulation , - Molding compounds * . Substitution of vacuum for air blowing in brake and clutch maintenance . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations - 2f May 2,1980 8004 0777 TASK FORCE CHARTER To implement the chapter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategics to eliminate the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. The complete Task Force Charter is shown in Figure 4. In 1977, OSHA issued a draft policy listing numerous chemicals that could be classified as "Category I" and "Category Ii" carcinogens.- According to OSHA's draft policy, Category I substances are known to bo carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are so classified where data is suggestive or carcinogenicity in test animals and humans, or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. - A listing of 67 Category I substances in use in the automotive indus try has been prepared. (Exhibit I). - For materials regulated by Michigan Department of Natural Resources, quantities hove been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used asbestos only as articles, 81,377 pounds of chromium compounds, and 385,028 pounds of benzene. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances wore examined in detail. -3- May 2,1980 8004 0778 DRAFT FIOURE 4 task roRcccharter The Tusk Force wos chartered by E&K and M&S Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts lo: 1. Identify substances in use (OSIIA Cutcgorics 1 and II). 2.' determine quantities used (for materials regulated by Michigan Department of Natural Itesourees). 3. Set targets for elimination of as many Category 1 substances us possible. 4. Take uggrcsslve steps to find substitutes for us many Cutegory 1 substonces as possible in anticipation of government regulations. 5. Develop a policy and action plan for eliminating potential carcinogens whore possible. 6. Organize to identify substances systematically. FIGURE 5 USA OF. OF MICHIGAN CRITICAI. MATE III \I.S AS REPORTED TO MAIV (AllJUSILD IIY rill. PLANTS IN llll.ltt MDNR REPORTS) Motcrlal Acrylic Acid Lbs. of Usage ~ asiTuf " Jlpv - point Principal Users Acrylonitrile 641,133 PPV - Paint Aniline 90 MCC, Dbn. Glass, T&C Sterling Antimony 830,671 PPV - Vinyl Arsenic 11,157 T6cC Vandyke, PPV - Vinyl Asbestos (not reported as a material - present in articles only) Denzeno 365,028 AAD Dearborn Assy., Cen. Service Cadmium 3,311 PPV - Vinyl Chromium 81,377 PPV - Paint. EED - Ypsl. Cloroprene 24,676 AAD - Utica Cobalt ` 210 PPV - Saline Copper 321,704 AAD - Dearborn, PPV - Saline, MSD * Mom Cyanides 923,069 MSD * Monroe Diehlorobenzcnes 2,542 FTO - Highland Park FormalJehyde 488,965 MCC, PPV - Paint * Hydrazone liydroqulnone Hypochlorite Lead Lithium Nickel 130 1 15.841,758 626,027 123 126,624 PPV PPV - Vinyl MSD - Monroe AAD - Wayne/Dearborn, PPV - Point ED - Northviilc, T&C Sterling MSD - Monroe, T&C Sterling Phenol 5,839 Mich. Cost, Cntr. Selenium 127 T&C Sterling Silver ' 25 T&C Sterling Silicon-Dioxide Coated Lead Chromate Styrene Tetraeioroethylene 2,317 1,413,986 1,095 PPV PPV - Milan, PPV - Vinyl AADOO, Mich. Prov. Ornd. Thiourea * 18 PPV - Vinyl . Triaryl Phosphate Esters Trichloroethylene 160,022 91,849 Steel, T&C Sterling EED - Rawsonville Vinyl Chloride Zinc 118 1,085,724 PPV - Vinyl PPV - Paint, AAD, FPSD, FTO * Michigan locations not reported to MATS: Detroit Industrial Engine Research Ac Engineering Center Research - Glendale Troy - Tractor Vulcan Forge Dearborn Glass Deorborn Specialty Foundry Wlxon Assembly ' ' - 3f - Mey 2,1980 CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that arc contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6. The current exposure limit for these substances is also provided. It is Important to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed are presented in order of priority os established by Task Force consensus. The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3, respectively) as test cases because they are considered by Operations and Staffs to have the greatest impact on the Company. NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to eliminnte/control these materials, in a practicable manner in anticipation of Government regulations, were formulated. A plan to extend the strutegy formulated for asbestos, chromium and benzene, to os many Category I substances in Company materials as possible, was established. -4 May 2,1980 8004 0780 DRAFT FIGURE 5 TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES Substance____________ 1. Asbestos 0l> Chromium Compounds 3. Benzene 4, Cadmium/Cadmium Oxide 5. Cob) Tar Volatiles . Benzo (a) Pyrene . Benzo (a) Anthracene 6. Ethylene Chloropolymer 7. Beryllium 8. Trichloroethylene Occurence within Compnny Current Exposure Limits Friction materials, gaskets, scalers Chrome plating, paint pigments 2 fibers/cc 0.1 mg/m3 Product of coking operations, foundry operations, petroleum products, paints, thinners 10 ppm Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions . 0.1 mg/m3 3 0.2 mg/m 3 0.2 mg/m 3 0.2 mg/m Vinyl Aluminum foundry operations None established 2 yg/m3 Degreaser 100 ppm 8004 0781 - 4f May 2,1980 DRAFT (^ V CARCINOGENIC SUBSTANCES r w .A..S..B..E...S..T..O..S. * During the past several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHA, is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group, and OSHA have recommended that limits be tightened to as low as 0.1 in 1980. Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban on all non-critieal uses may occur as early as 1985. 4, \t 5 May 2,1980 / 8004 0782 DRAFT CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Ftbers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Fibcrs/cc) 0.1 0.S 5 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core & Mold Making Materials Safety Apparel 5f May 2, 1980 8004 0783 3 J DRAFT r CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (c.g., sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of their handling of materials, primarily in paint making and application. Protective measures are employed to assure regulated limits are not-exceeded. 3 The current statutory limit is 52 mg/m although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. I 6 May 2,1980 8004 0784 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems . Respiratory Tract- Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds X X X X X Other Chromium Compounds X X x X - ' FIGURE 11 Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) Exposure Limits 52 yg/m3 a/ 1 Vg/m3 1/2 of above * 25 yg/m 10 Hr workday `50 yg/rn3/15 Minutes 1/2 of above a) Measured as chromium. No differentiation is made regarding valence or type of disease due to exposure. FIGURE 12 Classes of Materials Containing Carclnogenie Chromium Compounds Production Topcoat Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks - 6f - May 2,1980 8004 0785 DRAFT v. CARCWOGENIC SUBSTANCES BENZENE Benzene is a leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene inuy enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel ,, making processes, and employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of .. gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption ) was necessary since there is no possible way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-rcintcd materials arc of primary concern as they most likely contain benzene at levels that require consideration. (Sec Exhibit III) % May 2,1980 8004 0786 DRAFT CARCINOGENIC SUBSTANCES BENZENE . FIGURE 13 ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENE Contact Dermatitis Eye Irritation Narcotic and Central Nervous *System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyscrasias (disorders) ' Time-Weighted Avg. Ceiling FIGURE 14 EXPOSURE LIMITS Regulation 5 ppm/15 min. Proposed 1 ppm/8 hr. _ 1 ppm/ 2hr. "Sample collected nt 1 liter/minute . 1 FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealers Marking Fluids and Wood Preservatives Rust Preventives Finishing/Polishing Compounds Thinners, Enamels and Lacquers Lubricating Greases and Oils . Primers, Paints and Coatings Lubricating, Hydraulic & Multiple Purpose Oils Cleaning Solvents and Compounds Liquid Fuels and Hydraulic Fluids Misc. Organic Compounds Hydraulic Fluids Coke Oven By-products ( S` - 7f - May 2,1980 I 8004 0787 DRAFT CARCINOGEN SEARCH Three Category I carcinogens were examined to determine material specifications, parts and nonproduction uses, was tedious and inexact. Existing data bases containing Engineering, Manufacturing and Purchasing information were found to be incomplete and not readily accessible. In the absence of one reliable system, the detailed steps in Figure 16 were under taken. For production materials, each PEO reviewed the malcrinl/usagc list for completeness and established a list of parts and bulk materials of their design responsibility suspected of con taining the subject substances. These lists were returned to Engineering Staff. EicRS con solidated the lists (See Appendices) and provided them, along with the approved source and material identifications to Purchasing and Supply Staff for supplier contact to determine substance usage and to find out if there is a known substitute. Nonproduction materials were identified by similar methods, except for the PEO review. MATERIALS AND TOXICOLOGY SYSTEM (MATS) C. To overcome the deficiencies of manual and semi-computerized search methods, the Materials und Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (P6cO Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental 4: Process Engineering Review System (Mfg. Staff). # These Systems can be linked together with some manual effort to search for uses of suspect carcinogens in Company products os follows and diagrammed in Figure 17: 1. Materials containing suspect chemical compounds can be identified in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, ports lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list, Purchasing can determine quantity used and Manufacturing Env gineering can determine processing methods. V Other functions of MATS include Approved Source Lists for production and nonproduction, materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide nonconfidcntial list of hazardous material usage and precautions for each plant. ^- ' -8 May 2,1980 8004 0788 DRAFT CARCINOGEN SEARCH FIGURE 16 . Carcinogen Identification . - Reviewed all likely material specifications and manufacturing standards. - Reviewed the IH&T CATALOG of Hazardous Materials. a - Reviewed NAEPIS to identify Industry Standard Materials - Reviewed the Michigan Critical Materials data - Surveyed previous assessment of production materials. - Communicated with material suppliers. - Analyzed the production material list (PEO). . Carcinogen Usage - Reviewed the NAEPIS cross-reference for production material/part usage. - Reviewed processes/uses involving the substances in nonproduction materials. - Confirmed the NAEPIS usage list for completencss/verificetion. MATERIALS AND TOXICOLOGY SYSTEM FIGURE 17 - 8f - May 2,1980 8004 0789 DRAFT CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium, benzene, a partial list of production and nonproduction material applications has been assembled. These were classified os: Known substitute material available for application without major redesign; Known substitute material available for application with major redesign; No known substitute. Advanced Engineering Project required; Even in group A, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. -9 May 2,1980 8004 0790 Asbestos -2/ Cr Compounds -3/ Benzene draft CARCINOGEN SEARCH RESULTS FIGURE 18 Production Mnterlals/Parts-^ AB 34 49 - :- - c 22 25 15 Total 105 25 15 Asbestos - Cr Compounds4-'/ Benzene Nonproduction Materials/Parts -1/ ABC 8-98 81 34 3-5 Total 8 213 8 Note: A = Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = No known substitute. Advanced Engineering Project required. NA& Not available ,1/ Data are directional estimates only and refer to materials known ~ to contain the particular carcinogen. 2/ Primary sourco - Car Engineering. 3/ Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered. - 9f - May 2.1980 8004 0791 DRAFT P CARCINOGEN STRATEGIES Three major strategic alternatives were considered for the elimination and control of carcinogenic substances. Twenty-six (26) OSHA Category 1 substances and Forty-one (41) substances that affect the auto industry and are proposed for regulation (MVMA analysis) provide the basis for these alternatives. NIOSH advised substance controls were deemed to be of lower priority. It was agreed by the Task Force and PEO chief engineers that the Company should proceed now to eliminate asbestos, selected chromium compounds and benzene by Job #1, 1985. Where elimination cannot be contained, design, process and exposure controls would continue for specific applications. C Implementation of the recommended alternative can only proceed by ) specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) con be initiated now but cannot with confidence be expected to be fully implemented in the 1985 time frame. Implementation decisions will have to be made for each application in the context of the vehicle cycle plan, component redesign, plans facility renovation/replace ment and the practicality of tho substitute. - t -10 May 2, 1980 8004 0792 DRAFT FIGURE 19 CARCINOGEN STRATEGIES - Continue OSHA Cotegory I carcinogen control by design, process and exposure limits. Eliminate carcinogens where substitutes are known when required by regulation or business pressure, a/ - Proceed now to eliminate OSIIA Category I carcinogens by Job #1, 1985. Where elimination cannot be contained, control the design, process and exposure, b/ - Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. -N a/Current Car Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos. In documented cases precluding alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. b/Advonced funding would have to be provided where elimination cannot be ** contained in the 1985 timeframe. - lOf - May 2,1980 8004 0795 GENERALIZED WORKPLAN The foregoing strategies, even though having been tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination. The first three actions of the workplan have been completed for asbestos, chromium compounds, and benzene. The fourth and fifth actions have been initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. Completing the actions by these dates requires Corporate direction that the elimination/control of these substances is a mandatory priority effort. Without such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogens. Overall program manogement is essential to this effort. -11 May 2,1980 8004 0794 DRAFT FIGURE 20 GENERALIZED WORKPLAN (for cacti Category I Carcinogen) Action Manage Program ft/ Propose list of known and suspect specifications ft / Verify proposed list- ft/ Identify known and suspect part - numbers Request supplier verification of suspect specifications and parts Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) Implement Group A actions Implement Group B actions Implement Group C Actions Audit effectiveness Responsibility Production Nonproduction SSECO SSECO SSECO ' SSECO PEO's PEO's Mfg, Staff Mfg. Staff b/ NAAO/DPO Purchasing NAAO/DPO Purchasing PEO's (NAAO Pch.) Supply Staff Supply Staff Mfg. Staff (Supply Staff) Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO's SSECO Mfg. Staff Mfg. Staff Tech. Ping. Research Staff BMD SSECO Block Timing Prod. (Nonpi Ongoing 1 Month 0 10 1 (/ 2 3 6 12 33 (TBD) 45 c/ Ongoing Ongoing a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. c/ Complete for asbestos, chromium compounds and benzene. - Ilf - May 2, 1980 P.Q8004 0795 DRAFT /r~-k PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed on analysis of the requirements for chemical substances control. . It was concluded that dcsignotion of o Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issued. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an EJeSES location was recommended. In view of budget constraints, it has been agreed that the existing Comm- pliance and Liaison Department would perform the Program Manager function. The Manager should be responsible for implementing carcinogen control strategies coordinating Company response to potential and promul gated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to B-101, establishing a financial measurement of the compliance effort, and assuming development direction and control for the computer information system and implementing the workplan os directed. - The ongoing responsibilities of the Chemical Substances Control Manager will be to coordinate the product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forccasting/rcgulatory"impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force bo discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page. It is further recommended that the Committee bo chaired by the E&SES repre sentative. ' Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. i i 12 - May 2, 1980 8004 0796 DRAFT FIGURE 21 MEMRKRSIUP HAZARDOUS SUBSTANCES CONTROL COMMITTER Chairman - Director Environmental Control Office Environmental and Safety Engineering Staff Purchasing and Supply Staff Personnel and Organization Staff Scientific Research Staff Manufacturing Staff Car Engineering Body and Assembly Operations Ford Parts and Service Division Ford Tractor Operations Powertrain and Chassis Operations Basic Products Operations ` Electrical and Electronics Division Climate Control Division Truck Operations European Automotive Operations Office of the General Counsel FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER -12f- May 2, 1980 8004 0797 DRAFT PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force on Carcinogens in the Workplace recommends that: 1. Establish a Hazardous Substances Control Committee chaired by the Director Environmental Control Office. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. 4. Request that NAAO/DPO Product Engineering Offices and Manufacturing Staff present to the Subcommittee specific action plans and timing for the Group A applications identified. 5. Adopt as the Company carcinogen listing, current OSHA regulated Category I sub stances (26) and proposed for regulation substances (41). Establish the top eight prior ities proposed by the Task Force as Company priorities. 6. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene by Job 1)1, 1985, as outlined in the workplan. -13- May 2,1980 6004 0798 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 Hazardous Substances Control Committee Program Manager ' Direct elimination of Asbestos, Chromium Compounds, Benzene Request Operations Workplans Adopt the priority carcinogen listing Request the establishment of overall elimination timetables. * 13f - May 2,1980 8004 0799 DRAFT EXHIBIT I i K OSH A CATEGORY I CARCINOGENS Reculated Acrylonitrile Amosite Anthophylite Arsenic . Asbestos Benz (c) acephenanthrylene Benz (a) anthracene Benz (a) anthracene, 7, 12-Dimethyl- Benz (a) unthracenc, 7-Methyl- Bcnz (a) anthracene, 7, 8, 12-Trimethyl- Benzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibenz (a, h) acridine Dibenz (a, j) acridine Dibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso- 1-Naphthylam`nc 2-Naphthylam.ne Serpentine Vinyl Chloride Proposed for Regulation Acetamide Acetic acid, Lead (2+) Salt Benzidine Sul Tate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3+) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt Chromic Acid, Lead (2+) salt (1:1) Chromite Chromium ' Chromium (III) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Dicthylamine, N-Nitroso- p-Dioxanc Ethane, 1, 2-Dibrom`o- ' Ethane, 1, 1, l-Trichloro-2, 2-bis (p-chlorophcnyl) Ethylene, chloro-, monomer Ethylene, 'Itichloro- Hematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (II) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid Tannin o-Toluidine Urea, Thio- % ?V,, . \ *' May 2,1980 i ' 8004 0800 I CAS Humber ' draft CAIICINOCiKN SEARCH Materials and Toxicology System EXlfloiT II FIGURE 2 8004 0801 DRAFT CARCINOGEN SEARCH Materials nnd Toxicology System (MATS) EXHIDIT II To overcome the deficiencies of manual and scmi-computcrizcd search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALOG of Hazardous Materials (P&O Staff) containing materials, their toxioologieul evaluation for worker/consuincr protection and the chemical composition, the Engineering Material Approved Source List (K&.RS) containing the material specification title' und the materials approved to that specification; the Nonproduction Mntcrinl Approved Source List (Manufacturing Staff) containing the nonproduction material stundard and the approved materials; and the Environmental 3c Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and lucility engineering cautions on all materials approved to Engineering Specifications und Manufacturing Standards. , Corcinogen Search Strategy Developing the links between the above systems will, in the future, provide a method for locat ing suspect carcinogens in nonproduction materials und production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the following search steps: 1. The Chemical Abstracts Service numbers of the suspect carcinogens and its compounds are identified by IHicT. The system will then generate a list of materials which contain that chemical. 2. Utilizing.the NAAO supplier code, the specification number and the product nome, the system will then identify other suspect materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a cross reference list of all parts which use that material. 4. The list of production parts con then bo matched to Purchasing's Procurement system to determine current sources to be queried for control und elimination of carcinogens. The same list con be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. Functions The primary function of MATS is to maintain and produce the Approved Source List for non production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract. The system is also available to the plants and the Poison Control Center at the Rouge to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g., chromium. Affected Activities AH Corporate Staffs concerned with inaterlals/toxicological/cnvironmcnt controls are currently involved in using/doveloping the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with tho exception of Chassis which currently docs not participate in material control as >cd by PEP 3-189. M . ,ooft May 2,1980 PRODUCTION MATERIALS CONTAINING ASBESTOS P ~ Group A -- Known Substitute Material Available Without Major Redesign Specification Material Basic Part No. Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Gasket Gasket Deadener Sealers -- 7086 4035 350038 350038 9900000 Trans. Ext. Gasket Carrier Gasket . Econ. PDV Box Assy. < Econ. PDV Box Assy. Courier Box Assy. Body ESIKM2G58-C ES3-M2G171-AB ESB-M2G188-A ESB-M3G95 ESB-M4G1-B '' ESB-M4G31-A "i:SB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ES13-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ' ESB-M4G147-B ESB-M4G161-A/C ESB-M4G1C2-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A 'ESB-M4G177-A/B Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- .-- -- -- --. -- Primer for Adhesive -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- .-- .-- -- APPENDIX I DRAFT 5/2/80 8004 0803 Specification (^ESI)-M4G188-A ESU-M4G197-A. ESB-M4G198-C ESB-M5G8-A/C ESW-M5G22-A ESB-M5G25-A ESB-M7C53-A Trnns LSC-M8G62-A KSW-.M3G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division ^ESB-M4G32-A ^ESH-M4G32-B ESR-M18P2-A ESR-.M99P4-B EED ESF-M3D7G-A Material Sealer Sealer Sealer Deodener Deadcncr Deadener Rust Prevent Gasket Gasket Seal Gasket -- Sealer Sealer Sealer Coating Phenolic ESF-M3D113-A ESA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8GJ 09-A ESF-M8G126-A -- CCD ^JiSF-M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket Gasket Gasket Gasket Gasket Gasket Sealer -2- Basic Part No. -- -- -- -- -- -- 7D026 7A13G 4035 7052 7A247 15520 9004650 appendix I DRAFT 5/2/80 Part -- -- -- -- .-- .-- Sprayablc Wax Type Rust Preventative t Trans, lnt. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal , Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer 19560 19560 19554 19515 Caulking Cord Rope Sealer Perfect Seal Underrating 18B374 8K621 17BG16 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator I/C Lamp Socket Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket 19D970 A/C Comp. Gasket 2A792 P/B Cable Opening Cover 8004 0804 3- NONPRODUCTION MATERIALS CONTAINING ASBESTOS ------------------------------------------------------------------------ *-- Croup A -- Knqwn Substitute Material Available Without Major Redesign APPENDIX I draft 5/2/8O Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts - 15 lb. Asphalt Saturated Asbestos Roofing Felts - 30'lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder * Hard Asbestos Millboard Asbestos Filament Reinforced Paper O \ 8004 0805 APPliNOIX I DRAFT 4 - 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS O Croup B -- Known Substitute Material Available With Major Redesign Specification Material Basic Part No. Part Lisjlit Truck ESE-M8G10G-B ESE-MSGUO-A Gasket Gosket 5B2C6 5B266 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Trans ESW-.M3D117-A ERW-M3D07-A Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Phenolic Phenolic -- -- -- -- -- -- `-- -- -- -- -- 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 * Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Truns. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy. Trans. Cliltch Plate Assy. Chassis F.SB-M8G10G-A ESA-M8G140-A -- Gasket Gasket -- 5B266 5B266 2022 2021 Resonator Gasket Assy. Tcsonator Gasket Assy. Front Disc Brakes L, 1 , 8004 0806 -5- m-rr.mn.N i DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS r* Group C -- No Known Substitute. Advanced Engineering Project Required. ' Specification Light Truck ES-C8AA-2B282-A ES-DC0A-2B072-BB ES-C8AA-2B282-A LS-D20A-2B072-BB Vendor Print Vendor Print i:s-r.OTA-2ni20-AA IJS-D6 l'A-2B) 18-AA ES-C8TA-2B282-A ES-C8TA-2210-D ES-CSTA-2010-C "ES-D8TA-7550-A -- O-- -- * Ti'nns Vendor Vendor Vendor Heavy Truck -- -- -- -- -- -- -- -- -- -- > Material -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- . Basic Port No. Part 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 . Lining Front Wheel Broke Outer Lining Front Wheel Broke Inner Shoe and Lining Inner Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch Clutch Plate Clutch Plate Parking Broke Lining 4797 4A435 7550 Rear Axle Diff. Clutch Plate A.^j. Hear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A596 7550 7E434 Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Broke Compressor Fan Clutch Assy. Clutch and Brocket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Broke Assy. 8004 0807 Chussis ESE-.M80149-A -- . Gasket -- -6- APPENDIX 1 DRAFT 5/2/80 5F263 2284 2285 Exhaust Manifold Gasket Rear Drake Shoes v ( 8004 0808