Document 65bKoqweYORBv85KgyQLj1aLg

FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, PARAMUS, N.J. 07652 MINUTES OP THE KESTINO of the ASBESTOS STUDY COMMITTEE Friday, June 1, 1973, at 9:30 A.M. at the Institute Office, E. 210 Route 4, Parana, N.J. HSQKRS PRESENT I. C. Weaver, Chairman H. Wagner E. E. Felerabcnd OTHERS PRESENT S. B. McGinnis (for J. C. Henning) M. Jaeko (for W. Spurgeon) D. E. Stone Raybestos-Manhattan, Inc. Carlisle Corporation Abex Corporation World Bestoe Company Bendix Corporation MEMBERS WOT PRESENT J. C. Henning T. Bell K. Spurgeon World Bestos Company H. K. Porter Co. Bendix Corporation The meeting was called to order by Mr. Weever, Chairman, at 9:30 A.M. MINUTES OF PREVIOUS MEETING The Secretary reed a summary of che Minutes of the Meeting held February 16, 1973. These minutes had been released and a motion for their acceptance had been obtained. Upon motion duly made, seconded and unanimously passed, it was RESOLVED: To accept the minutes of the February 16, 1973 meeting as distributed. LABELING At the February 16, 1973 meeting, the Secretary was directed to distribute information on typical CAUTION labels now in use. The purpoee of this distribu tion was so that the Committee Menbers could review what Is available and would be in a position to propose label specifications to meet the OSHA requirements. One member suggested that the size of'the labeling used should be of sufficient size to be noticeable on a large carton and should be commensurably smaller but 000084 Mlsutu of the Asbestos Study Cosnlttee Meeting -2- June 1, 1973 till noticeable on e analler package, tine metober was uaing an inaert with a CAUTION label staffed into the package. The use of laptinted CACTICH labels on the carton la deeireble becauaa it la essentially a one-tine tooling cost. use of separate labels ia a continuing added direct expense. Host nesbera using separate gunned labels will eventually go over to lrprlntlng the on when ordered. In what nuat be a response or a reaction by others, assay customers are now asking Meabsrs about haw nuch percentage of asbestos is in the brake linings. tm could be a reaction on the customer's part as to whether they would have to put control practices in their factories because of the asbestos that is contained in brake lining. To nest the true spirit of the OSHA regulations, manufacturers doing subsequent drilling, grinding or cutting of asbestos contain ing brake linings should use the care that OSSA suggests. One meafcer felt that where he was shipping drilled ground lining seta that he would not have to imprint these small cartons with the OSSA CAUTION label, pther nenbers are aianlv putting the OSSA CAUTION labeling on everything. When it was suggested tEeE Eh* UnoiLtac should cake a position on this labeling requirement, the members of the Ccenittee were referred beck to the Resolution that wee made on February 16, 1973. This Resolution said, in effect, that OSHA labeling practices should be adhered to where asbestos containing materials do not hava ^asbestos fiber complataly locked In or where subsequent operations may be per formed. The question concerning the drilled end ground set is: While it ia unlikely that subsequent operations will ba performed, la it possible that they may be performed? After e lengthy discussion It was decided that no resolution concerning recom mended CAUTION labels would ba proposed. Rather, the Secretary is directed to send to the Membership copies of typical labels now in use. It was called to the Secretary's attention diet his yellow Bulletin of Kerch 30, 1973 waa in error. In diet notice it stated, "Avoid breathing dust". The word ing should have been, "Avoid creating dust". This error will be called to the attention of the lieeberahip. The Chairmen brought up another point aa regards labels. Thera la a sign that can ba posted in the factory where there ere restrictions concerning asbestos dust la the atmosphere. This ia a standard sign for placing in the factory which says: "CAUTION - Asbestos dust hazard; avoid breathing dust; wear assigned protective equipment; do not remain la area unless your work requires It; breathing asbestos dust nay ba hazardous to your health". Information on the availability of those signs will be sent to the Membership. EPA EMISSIONS STANDARDS FOR ASBESTOS While the new EPA sessions standards appear to be reasonable, there is acne difficulty in interpretation. For example, the standards are noe simply "No visible cessions", but (1) If the control equipment does not met the air clean ing requirements in the regulations, no visible emissions era permissible, or (2) one could even have visible emissions if they verts using s collector with the specifications-recoraarnded by the EPA. In other words, if you hove the EPA's recommended collector you could possibly hove viaibis missions and still be complying with che.EFA requirements. It goes without saying, that interpre tation of the requirements by individuals in the different EPA regions may vary quite a bit. The EPA is saying in their Standards that the wet collector is not aa efficient MAR 000085 uxautes oi uje AibutM Study Committee Meeting 3- Juae 1, 1973 u the dry-beg collector. If an EFA Enforcement Officer eees e vapor froa the stack where a wet collector la used, the;source heat'be able to prove there la no aabestoa being discharged. In other words. It can be Inferred that If a source has wet collectors they nay aora likely be cited for visible emissions. While It Is apparent that the EFA's emissions standards promote the dry collec tion of asbestos In bags, aany problems have been Indicated with these collectors. One of the problems was repeated fires In the collection system. Another masher seated that he too had -Ms problem until cigarette smoking was banned In the factory. Since discontinuing smoking In the factory, he claims they hsve not had more than one or two fires In.the last 25 years. Another mesfcer said that may be, but they have had a Ho Smoking rule for aany years and they sdll have fires. This party blames the fires on the Incentive program where the workers receive a bonus for exceeding certain work standards. This promotes the taking of heavier cuts with grinding wheels and creates sparks which apparently promote the fires In the system. The operation that has not had any fires for the past 25 years does not have an Incentive system and does not permit smoking in the work place. Where the wet collectors are now in use, apparently the EPA Is permitting their use as complying with the requirements. At this point, the dlsposel of the materials picked up by the collectors vas brought up. One member sent the dust to a pelletizing machine. In this process they add 5Z-10Z cement to the pelletizer. A volume reduction In the order of 3 to 1 vas developed. The pellets are taken by truck and dumped as land fill. While the pellets could be broken down into a powder, if they receive reasonable handling they can be readily moved from the pelletizing machine to the land fill operation. It Is this member's Intention to install a vacuum system from the collecting areas to go to a central pelletizing machine. One member described his handling of dust from (1) a central collector, to (2) a screw conveyor, to (3) a truck, and to (4) the land fill. The workers in this case use respirators. The pelletizing operation sot only reduces the transportation cost by three times but eliminates the need for a watering truck and an individual to wet dam the land fill. However, the coats of this pelletizing equipment are substantial. A manufacturer of pelletizing equipment la Ferro Tech Inc., 1231 Banksville Road, Pittsburgh, Pa. 15216. Several members mentioned that In dealing with the EPA Regional Offices they were having difficulties deciding what vas a "new source" and what was an "existing source". Also, where one manufacturer adds one machine to an existing collection systam he may not be In compliance without getting a Waiver of Cot^>liance. Appar ently the EPA will not give a Waiver of Compliance that will take more than 12 months to collate. An applicant must give the steps to be taken and the schedule to be met. When each date arrives, the applicant must advise EFA concerning cosgtledon of that stags of the schedule. One masher felt that we should review the EPA source report form to get a better understanding of what they were calling for. Page one of the report would be used for each factory. As there would moot likely be several points of emission, page 2 would be completed for each stack or collector that emits asbestos. If a manufacturer wished to make an addition or modification In his plant with equipment that might put asbestos into the atmosphere, he must file with the EPA. On page 1 of the report he would cross off the words "Source Report" and type in either "Application to Construct a Hew Source", or "Application to Modify Exist ing Source". In reviewing page 2 of the report under "Process Description", some questions cams up as to how to coreplete this section. One aenber who had worked on this report with the EPA said you should enter here the type of MAR 000086 Minuses or cue Asbestos Study Cosndttse Heating -4- June 1, 1973 machinery used without quantifying. Another Berber Indicated that the EPA Insisted that he list the type of equipment and the numbers of each piece of equipment. Zf the EPA specifically said to list the numbers end types of equipsent In this section It was suggested that they would hews said so on page 2 of the report. The question of putting down the numbers and types of equipment could become very cunbersome where a manufacturer wished to move a grinding machine from a location with one collector to another location where It would be hooked into another collector. The meaber who filed with the EPA worked on reports la 2 different jurisdictions: New York and Tennessee. Be Indicated that at neither location did he enter the nunber of pieces of equipment on this form. (Since the meeting he called to advise that the application filed in Tennessee without quantities was accepted by .the EPA. Els application In New York State had not been either accepted or rejected as of June A, 1973.) Zt would appear that Regional Offices are not In agreement as regards quantification of the equipment under the "Process Description." The question came up concerning Interpretation of question 3, the "Amount of Pollutant." Zn many factories a set of dry nix brake blocks could emit' into a collection system at the mixer, at the briquette press, at the cut-off wheels, at grinding, at drilling, and at Inspection and boxing. The problem Is that this la the same original asbestos which entered the process and might factory taking la one million pounds of cc!on*systems. turn, would make it bestoe is going Into the operation. From die wording of the form. It would appear that this Is exactly what the EPA wants. However, another meaber wee told that this In not whet the EPA Wants. He suggests that if e factory takes In one million pounds of asbestos into the process that it should not report in total mors than one million pounds of ssbestos. Zf he had 10 different emission points, hs would divids the one million pounds of asbestos by 10 to give the "amount of pollutant." Again, their apparently has been a difference In Interpretation from different Regional Offices of the EPA. On page 3 of the report, under "Waiver of Compliance," it was stated that Sections 2a and 2b did not have to be completed unless EPA specifically requests this Information. INSTITUTE SEMINAR OH SAFETY AND HEALTH At the February 16, 1973 meeting, suggestions were made that the Institute consider the sponsoring of s seminar for meobers associated with plant-operations. The Institute Indicated It would be willing to sponsor such e seminar if auffl- . dent Interest developed. A question wee raised as to whether this seminar would apply only to esbeatoe. The Secretary Indicated that such a seminar would apply to any field of Interest but It should be related to problems that can be tied Into State and Federal regulations. Among the topics suggested for e seminar were the following: Air sampling end asbestos concentration determination. The pulmonary function test and X-Ray. Possible extension to Include noise and heat stress. Cooperation between management and workers in meeting the regulations. Asbestos bag opening machinery. MAR 000087 Minute* of the Asbestos Study Committee Meeting -5- June 1, 1973 The Secretary ves directed to sake up a Hat of subject* which eight interest the tfesbership and to canvass the menbara as regards their interest. In addition to the agenda itans to suggest to the Iletfcership, it was suggested that th* canvassing latter aak if an individual froa diet ueitber company would attend, where the Meeting should be held, and when the meeting should bs bald. Zt .was indicated that a meeting in th* lata fall would be desirable and such locations as Chicago, Detroit, Pittsburgh and Paranoia were suggested. When the Secretary has prepared a questionnaire it will bs submitted to Hr. Peierabend for his review prior to distribution to the Membership. The actual agenda will be drafted after the menbers have Indicated their preference. The question was raised as to whether outside speakers would b* involved and it was suggested that we were not Interested in a conmmrclal pitch at the meeting. Johna-Kanvilla had indicated an interest in approaching such a seminar with the idea of promoting their HEAP (High Energy Air Filter) pollution control equip ment. It was suggaatad that perhaps it might be worthwhile to have outsiders make presentations concerning asbestos beg opening equipment, pelletizing, collection, etc. This will have to be worked out et a future Committee meeting. Drake and Clutch Emissions Generated During Vehicle Operation This particular study was run by Bendix Rasearch Laboratories under sponsorship of the EPA. A paper was presented to the S.A.E. by Dr. M. Jacko and Hr. X. DuCharme of Bendix, and Mr. J. Somers of the EPA. The actual report to the EPA Is a massive document explaining every test procedure and every method of collection used in the study. A technical paper was presented by these 3 gentlemen et the SAE Heating in Detroit in Hey, 1973. The study essenially centers on how much asbestos is being put into the atmosphere from brake linings and clutch facings. As Dr. Jacko was In charge of this investigation hs discussed the paper at our meeting. He advised that a condensed version appears in the magazine AUTOMOTIVE EHGINEERING. Among the points that Dr. Jacko mads was that there were problems whera a brake on one side was enclosed and the other brake was open to the regular atmosphere. Modifications had to be made involving cooling of the outside of the shroud so that there would not be too great a temperature difference froa cha left aids to. the right side. This was more of a \prob lea with the disc brakes on the fronts. Actually with the necessary cooling, there was hardly any difference between the drum brake rears aide to aide. Jl^Among the items discussed in the paper were how much aabeatos is used in friction materials. Zt is indicated that there are about 133 million pounds of asbestos in th* friction materials which are used in the United States each year. Thera apparently are some differences of opinion as regards bow much asbestos is involved but it generally falls In the 90-120 million pound rang*. Actually, the amount Subject to wear is about 66-2/3Z of tha actual lining that gats on to the brake (after grinding). Hhen asbestos is being used in brake linings it is discarded in one of three ways: Zt gets deposited on tha surfaces of the brake, such as on the caliper, and around the wheel cylinders. (This Is surface debris). Additional material la collected on the lining surfaces, in the rivet holes, and on tha brake dnm. (This la called snap debris) Additional material becomes airborne and la collected on mesbrane filters. (This is called airborne debris). It la this latter airborne debris that the research ers are seeking to quantify. Based on the samples that were collected, the cooelusions were that eore than 99.7Z of the asbestos in the brake lining is converted to other products. By extrapolating the data that they were able to develop on a passenger car th* researchers indicate chat a total of 5060 pounds of iabestoa la put into the MAR 000088 Minutes of the Asbestos Study Committee Meeting -6- June 1, 1973 atmosphere. Hiis airborne asbestos emission is 3.22 of the total asbestos, emitted from automotive brake lininps and clutch facings in the tJ.S. A question arose as to what happens to the asbestos debris that drops out. Does it eventually get into the atmosphere? It use indicated that based on the study of other materials that apparently there have been build-ups such as lead along the sides of turnpikes. This material apparently goes into the earth's surface and whether it is picked up again is dependent on other factors such as the proximity to streams, etc. A gentleman, from Ford Motor Company was also to present a paper to the SAE meeting concerning asbestos particulate emissions into the atmosphere. Ho paper was available at this time. There were some questions concerning procedures and a source of data on the Ford paper, but in any event the p^er indicated a lwcr total asbestos emission than the Bendlx paper. These two papers should serve as source information when others are attempting to quantify the asbestos emitted into the atmosphere from brake linings and clutch facings. OTHER ITBB The topic of OSHA Inspections and enforcement vas brought up briefly and die menbers indicated that no new actions had been taken by OSUA as regards enforce ment concerning the asbestos standards. The Asbestos Information Association (AIA) is to put out a Compliance Manual concerning control practice. This is still preliminary and there is no advance copy available at this time. ****** There being no further business brought to the attention of the Comslttee, upon motion duly made and unanimously passed, it was RESOLVED: to adjourn. Adjourned: at 2:30 F.M. E. H. Drlslane Secretary .MAR 000089