Document 6R4m6MmvgY1N3gwJRV0xdrb54

TELEPHONE (201) 849-0440 FRICTION MATERIALS STANDARDS BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INSTITUTE, INC. MAR 2 5 1981 Ms. Joni Repasch Document Control Officer Office of Pesticides and Toxic Substances (TS-793) Environmental Protection Agency Room E-447 401 M Street, S.W. Washington, DC 20460 Subject: Document Control dumber OPTS 84004 Environmental Protection Agency Proposal on Asbestos; Reporting add Recordkeeping Requirements Dear Ms. Repasch: The Friction Materials Standards Institute Is a trade association which Includes most of the brake lining and clutch facing manufacturers in the United States. We have other Members worldwide. As friction materials manufacturers, most of our Members use asbestos as a major constltutent in their products. Our comments on these proposals represent the viewpoints of most of our asbestos-using Members. General Comments While we will address specific sections of the proposals on reporting and recordkeeping later in this letter, we question the timing and necessity of the proposed requirements. We are familiar with Section 8 of the Toxic Substances Control Act (Public Law 94-469). We understand that this section can require our Members to maintain records and submit reports in great detail, where that information is necessary to regulate substances that may present an unreasonable risk of injury to health or the environment. .The friction materials industry agrees that there are health hazards from asbestos in the workplace. These have been addressed by the Occupational Safety and Health Administration (OSHA) and we anticipate further regulation in that area. We do not believe it has been shown there is an unreasonable risk of injury to health or the environment from the sale or use of our products because of the following facts: 1. Asbestos fibers are locked-in to the product in its finished form. 2. There is less than IX asbestos in the wear debris from used friction materials. 3. Small exposure levels in the general environment have not been established as presenting an un reasonable risk of injury to health and the environment. FMSI-0358 FMSI 03562 Ms. Joni Eepasch Environmental Protection Agency 2- We refer you to the enclosed paper '-'Asbestos & Health in the Friction Material Industry," prepared by the Asbestos International Association In London, England. It summarizes what is known concerning asbestos exposure in the friction material Industry, as well as what is known on exposure to friction material wear debris in the general environment. This position paper supports our contention that while asbestos does present a risk to those occupationally exposed, this exposure is now controlled, and that environmental exposure does not present an unreasonable risk--if it presents a risk at all--to the general public. The Institute suggests that before applying the reporting and recordkeeping requirements of Section 8 of the Act, that EPA demonstrate that asbestoscontaining friction materials may in fact present an unreasonable risk. Me recommend that action of the type proposed by this notice be deferred until reasonable people can demonstrate the need for the costly and detailed records that in may cases go beyond the needs of the Agency. This proposed regulation would place one more burden on our Members, and particularly the United States manufacturers supplying brake linings, clutch facings and other friction articles to its already depressed automotive, construction, and Industrial customers as well as to the energy related industry. The proposed requirements would not only be burdensome to our Members, but in most cases it is difficult to see how the information can be put to use by the EPA. It calls for a complete documentary on asbestos beyond the needs for purposeful regulation, if indeed that regulation is necessary. Our industry stands ready to help with information-gathering even where the need has not been adequately shown, if the EPA can sharply reduce the amount of information, the old information, information which is mostly confidential, and extraneous information apparently being requested for support of parties other than the Office of Toxic Substances. In fact we suggest that much of the information is available from other Government agencies and it may be of value to have Interdepartmental exchanges between the Government agencies concerned with the asbestos issue. Section 763,65 - Who must report In Paragraph (f) the proposals exempt "small manufacturers, processors, or importers as defined in Section 763.65(m)." Me agree with the exemption of small manufacturers or processors who employ no more than 10 full-time employees. There seems something inconsistent with the maintaining of jobs in the United States by the exempting of importers, who may be importing from factories with 1,000 employees outside of the United States, where a United States factory with more than 10 employees is not exempt. ` One "small Importer" could be responsible for more friction products, or other products for that matter, in the United States market than a mediumsize United States manufacturer, but the Importer would be exempt where the United States manufacturer would not. This exemption would be more equitable if based on dollar value, tonnage, pieces or other like index. FMSI 03563 T IIs. Joni Hepasch Environmental Protection Agency -3- Section 763.70(a) - Customer Lists Several Hembers indicate that they will invoke claims of confidentiality on distribution of these lists outside their organizations. We question the need for telephone number and technical contact for each customer. In many cases this information is not available. In other cases, this can create an adversary relationship between a customer and a manufacturer. Claims of confidentiality for this type information are valid, as almost all of our Hembers are interested in lists of his competitor's customers. We would suggest the EPA reconsider the confidentiality of this type information. We further believe the detail requested should not be required if provision of these lists is actually written into the final rules. Section 763.71 - Schedule for Reporting The schedule for reporting by our Members, who are all Primary Processors and Bulk Asbestos Importers, and in many cases are Secondary Processors, is unduly harsh. Rather than the 60 days required in sub-sections (a) and (c), and the 30 days required in sub-section (b), we recommend a standard 90 days schedule. Our Ilenbers have facilities at more than one location, and records are in many cases at a location other than the Factory. A 90 day requirement is more realistic when one considers the considerable detail asked by this proposal. Further, many of our Hembers do not have ready access to in-house Professionals to review and approve reports before submission. Our Members are entitled to have their reports reviewed by Outside Safety, Health and EPA Consultants, Legal Counsel, and other Professionals as to its adequacy and to assure that our Ilembers are not harmed by their reporting. Form B(2) - Quantity of Bulk Asbestos Imported. The comments on Form B(2) apply to Form B(3) - Quantity of Bulk Asbestos Obtained. Our major concern is with Form B(2), as almost all our Members use Canadian chrysotile. All Members of the Institute import asbestos, primarily from Canada. The EPA form asks for quantities of asbestos, by type, and chrysotile by grade. The form lists quantities for 10 years, from 1971 through 1980. In most cases, the older the records the more difficult the search. Some Members no longer have data from which to develop quantities before 1976. As the EPA is asking for information on asbestos emissions at the present time, we question the need for 10 years of data, and particularly that of more than two or three years ago. If the EPA were to have information on current consumption that should give sufficient Information for estimating current exposures without the extra work involved in going back over ten years. We suggest, if the data is considered actually of value, that the EPA limit the request to that for 1930. The notice asks for details on types of asbestos and grades of chrysotile. We understand the EPA is searching for information on other types of asbestos, but question the need for grades of chrysotile. This involves considerable searching of records on the part of our Members, if in fact the information exists. We do not believe that anyone to this time has alleged or inferred that the hazards of asbestos are dependent on the grade of chrysotile. We FMSI 03564 Ms. Joni Repasch Environmental Protection Agency -4- suggest that the form be revised to ask only on quantities of chrysotile, and that reference to grades be removed. Form C - Primary Processor Production Our comments on Form C apply in most cases to Form D - Secondary Processor Production, Many of our Members are Secondary Processors in attaching linings to steel shoes or where they perform other assembly operations. We again state that the older the information is, the more difficult it is to develop. We suggest that production figures for the last year only, 1980, be used. These are available. The manufacturer's efforts in compliance with the requirements of this form would be reduced in almost the proportion that the years are removed. Again, we believe the EPA is searching for current exposure information, and that while history is interesting, the requirement to gather it is not necessary to the task. Still further, in the instructions for this form, under '`End Product Shipped," the form calls for information listing the trade name under which the product is marketed, and calls for a listing of all "private brands" under which the product is sold. We fail to see where listing of trade names or "private brands" is pertinent to developing information on emissions or exposures to asbestos. This information is much more difficult to develop for posting to forms such as these. It would multiply the combinations which would have to be listed, when the only relevant information is a product.listing such as we suggest below: Drum Brake Lining (light-medium vehicle), etc. On Page 8225 of the Federal Register notice, "Typical Terms for Products Made From Bulk Asbestos" are listed. Ten different terms are listed under Friction Materials. Most of those are not relevant to exposures in the general environment. We suggest reducing the 10 terms to 7 as follows: Drum Brake Linings (light-medium vehicle) Disc Brake Pads (light-medium vehicle) Brake Blocks (heavy vehicle) Disc Brake Pads (heavy-vehicle) Clutch Facings (all applications) Automatic Transmission Friction Components (automotive)' Friction Materials (industrial and commercial) There are no woven disc or drum brake linings for light vehicle use. For other applications, we question whether information on molded verus woven is pertinent to the question of exposure to asbestos in the general environ ment.' We feel there is but limited usage of asbestos-containing friction materials in consumer products. Still further, all units of measure should be "Pieces." We question particularly whether information on quantities sold under "Private Labels" will be available even in recent years, without painstaking one-by-one analysis of individual invoices. In addition, there may be claims of confi dentiality in this area. FMSI 03565 Hs. Joni Repasch Environmental Protection Agency -5- Form H - Summary of Current Worker Exposure This particular section of the reporting form would cause an undue burden for large facilities which have several hundred workers and a diversity of pro duction operations. Records on worker exposure levels are not maintained in a manner which would permit easy retrieval of the data requested. To simplify this section, it Is recommended that Column 2 - Total Person Hours Per Year at TWA, and Column 3 - Humber of Measurements Used, be elim inated as this data serves no useful purpose and is extremely time Intensive in its preparation. Form K - Pollution Control Equipment We question the need for the Month and Year under the "When Installed" column. Some installations go in over a long period--in 6ome cases as long as 12 months from delivery to final usage. Do you wish the date ordered? The date delivered? The date installed? The date first used? The date put into use on a full-time basis? The year of installation should be sufficient. We believe a definition should be presented so as to clarify what is wanted or needed. Where there is more than one piece of pollution control equipment, even where there are two, three or more installed, the form calls for a separate listing. We suggest that the form be redesigned to permit listing of any quantity of a particular piece of equipment where that equipment is identical to another piece. The quantities could be listed per piece of equipment, with a total column for all equipment of that same type. The purpose of our recommendation is to reduce the paper work burden. ** ** We question the need for this proposed reporting from manufacturers of friction materials based 'on the reasons stated under our "General Comments." We suggest a deferral of the proposals on reporting and recordkeeping until reasonable people can demonstrate the need. We suggest that if the reporting and recordkeeping requirements in this proposal will not be deferred that the proposal be revised to simplify and reduce the paper work burden on our industry. This can be done ini three ways: 1. Cancel the study of history--ask for information for 1980 only. 2. Reduce the detail--such as grades of chrysotile, month and year of instair lation, etc. FMSI 03566 :is. Joni Eepasch Environmental Protection Agency 6 - 3. Eliminate or re-write the proposal on information requests where confiden tiality will likely be claimed Respectfully submitted, FRICTION MATERIALS STANDARDS INSTITUTE EWD/erc 2nc; Asbestos & Health in .the Friction Material Industry E. W. Drislane Executive Director FMSI 03567 ASBESTOS IN TERNATIONAL ASSOCIATION (Limited by Guarantee) 68 GLOUCESTER PLACE, LONDON WiH 3HI, MEMORANDUM TO: Member Associations FROM: Director General AIA/7/3/PROD 12 February 1981 "Asbestos & Health in the Friction Material Industry" The attached position paper on Asbestos & Health in the Friction Material Industry is forwarded for information. It has been authorised by the Executive Committee who recommend that it should be used as a background reference paper to help members deal with questions in asbestos and health which may arise. FMSI 03568 AIA/7/3/PROD ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY The Problem Exposure to asbestos dust Is recognised as a potential occupational hazard. Among work people exposed to high concentrations of respirable asbestos dust, (such as Is known to have occurred before present day dust control measures and work procedures were Introduced) cases of cancer and asbestosle have been reported throughout the world. '' The difficulty of reliably identifying the occupational history of those whose health has been affected many years after has resulted in any contact with asbestos being regarded with caution and all materials containing asbestos being attacked indiscriminately. Since friction material is widely recognised as one of the products for which asbestos is an important ingredient, it has attracted such attention. Indeed, the asbestos industry, in reminding everyone of the vital role played by asbestos in brake linings, has stimulated such attention. Nevertheless the occupational health record of the asbestos friction material industry is good and only a few cases of asbestos-related disease are on record. However, the widespread use of friction material in all types of vehicles has raised the question of potential pollution of the environment with an assumed consequent danger to the health of the general public. The friction material industry, therefore, has two basic problems. The first, the occupational health problem, has in many areas been resolved. However, the industry must continue to ensure that those employed in the manufacture of these materials are not exposed to dust levels"which are ' harmful. An extension of this problem is the need to ensure that workers employed in the subsequent use of friction materials, either in the fitting of the products or the maintenance of vehicles, are not exposed to harmful dust levels. - ' (This page retyped at FMSI because of weakness of original copy) FMSI 03569 The othez problem for the induetry, that of possible environmental pollution, is more difficult to resolve, based as it is on emotional anxieties (which are in no way Justified by the evidence). A climate of concern for the effect on the environment of expanding towns and industries has led to the motor vehiole being included as a significant factor in this pollution. _ This fact together vith the publicity given to asbestos and its classification as a carcinogen,^ have all combined to lead' people to question the use of asbestos-based components in motor vehicles. \ The automotive industry is also under attack for a number of other reasons, (e.g. pollution, vasts of resources and congestion) and would gladly be without the asbestos problem although it mast accept that for some years, current models of motor ears will heed asbestos-containing material for replacements. The friction material industry itself mast therefore dispel anxieties about asbestos-containing pxo&uots in motor vehicles by ensuring that the existing reassuring evidenos is made manifest and is properly . understood. .. . Taokling the Problem > In order to tadkle the problem most effectively, it is important that the origins, investigations and remedial measures involved should be veil understood. This ia especially necessary since the exletenoe of the frlotion material environmental problem is to a large extent based on confusing two very different phenomenal on the one hand the occupational health - experience and dust exposure data related to manufacture (and the ' subsequent fitting and servicing operations sometimes called "para-occupational") . and on the other hand an assumed emission of similar dust into the general environment aa a result of the dailyveexipg down of brake linings and . clutoh facings. An example of this oonfueion may be seen in-the evidence . given to the UK Asbestos Advisory Committee, where Claims that the general public axe at risk -axe supported solely by reference to a survey of motor vehiole maintenance worker*. ^ . It is therefore important to recapitulate the facts relating to health hazards and the conditions wfaloh axe believed to give rise to them. FMSI 03570 Tnese facts will be reviewed under three headings, the first two covering the Occupational areas of Manufacturing.and Servicing, and the third heading covering that of the General Environment. Manufacture of Friction Materials There is ample evidence to suggest that, in the manufacture of friction materials, the concentration of asbestos dust compares favourably with that found in most other modern asbestos operations. Within the last ten years efforts to observe a 2 f/ml* standard have led to further improvements in dust control and there are now many operations where levels well below this maximum allowable concentration are achieved . Very few cases of asbestos-related disease arising from friction materials manufacture have been reported. In evidence presented to the UK Advisory Committee,^ Ferodo Limited, who have been using asbestos in brake and clutch linings since 1910, reported 8 cases of mesothelioma and 5 cases of asbestosis. The mesothelioma cases had all been exposed in the manufacture of railway brake blocks between 1928 and 1933 or during the war years up to 1943, to crocidolite as well as to the chrysotile asbestos more generally used throughout the plant. The asbestosis cases were all involved in mixing processes where masks should have been worn. In the same volume of evidence, a report from the two Cape Industries'* factories manufacturing both textiles and friction material (one since 1901 and the other since 1923) cites 9 cases of asbestosis and no case of mesothelioma. 4 Ferodo report that "many millions of man hours have been worked on finishing operations of asbestos-based materials; though the dust concentrations associated with these were at one time very high, there * f/ml = (asbestos) fibres per millitre FMSI 03571 ha,s not been a single diagnosis of asbeatosis as a result of thiB exposure". In more recent years (1968 - 1976) however, average concentrations were well below 2 f/ml following continuous improvements in dust extraction .methods, An investigation in 1975 hy EeidermannB, Kuhnen, Schutz and Prochazka9 into dust hazards which might be associated with the manufacture and use of asbestos-containing friction materials (updated in the Research 7' Report of the German Perufsgeaoesenschaften quotes concentrations of micro-dust In the range of 0.09 to 0.20 during grinding, drilling, sawing, turning and milling operations (the current TnK* value is 0.10 ng/n^ or 2 f/nlj on this basis the current range is 1.8 f/ral to 4 f/nl), on average just below or just above 0.15 or 5 f/ol. Such operations, unless subject to dust control, will emit duet containing asbestos. A number of surveys of such operations have been oarried out in Ge-rrany UK USA 13*14.15*16,17 ^ elsewhere ^58 and 't is clear that, under some conditions of working and where such operations are carried out continuously, dust concentrations above 2 f/al (or the TRK of 0.10 F^m^) can be reached. There is some evidence of effects on health . among men engaged for a long period on such work. Medical and epidemiological 7 investigations by Professor Voitov}ta, Valentin and others on workers who had been continuously exposed for at least 10 and up to 25 years to asbestos durt suggests a similar risk level for men employed on finishing operations (rv -nly grinding and drilling) in the automotive industry, to the risk vc! of workers in the netmfacturing industry 7,9 . It vt- noted that the automotive industry group studied had had long exposure from a very early age; ' A group of men carrying out brake `` f = Technical Control limit' + Out of 94 workers (including 45 women) in manufacturing, there were 3 probable cases of afibestosis and 11 "possible". Among 63 men employed in finishing operations on brake linings in the automotive industry. 2 probable asbestosis ceseB were found and 10 "possible". ("Possible" means shoving effects on the lung which might be fibrogenie.) FMSI 03572 -5- . maintenance services with exposure primarily during the cleaning and brushing out of brake drum dust gave little evidence of inhalation effects in spite of long years of exposure. Professor Selikoff's investigations 19 quoted indications of abnormalities ' in 32 out of 67 motor vehicle mechanics (6 out of 29 with five or more 1 years intermittent exposure shoved signs on X-ray of changes consistent with asbestoeis). Another report of the same investigation quoted 24% of 95 brake service mechanics showing ohest abnormalities not necessarily asbestos-related and it is emphasised that there were no confirmed cases of asbestos-related disease. Dust levels quoted in connection with this AA A4 , _. investigation (in USA) * * refer to mean concentrations for blow-out of brake drums, grinding of used linings and bevelling of new linings of ' !5.9. 3.8, and 37.3 f/ml respectively - much higher than any found by any other researchers. Uo information is provided as to the duration of those samples - they are frequently referred to as peak concentrations or the mean of a number of such measurements. It is also clear that in the ca3e of blowing out of brake drums, no asbestos fibres were visible by optical microscopy; some chxysotile was identified by X-ray diffraction. Fibres identified by electron miorosoopy were all below the minimum size specified in the definition of asbestos fibre (i.e. 5 y In length). It should be . noted thet the methods of sampling and the .criteria for measurement of occupational environments did not conform to the methods used by governmental agencies end by other investigators in Germany and UK. `' , > For Comparison, concentrations of asbestos dust during brake maintenance reported by Eickish and Knight 10 showed an average daily exposure of 0.68 f/ml (range 0.21 to 1.12) during brake service of 11 oars. During truck brake service, the average was 1.75 f/hl, with peak, during cleaning of the brake drum, of 7.09 f/ml. . - The German investigation in 1975 ^ (now incorporated in the Serufagenossenschaften report ^) reoorded high concentrations* in the brake Bervioe department and * 0.03 to 0.79 mgyfo** and with background workshop atmosphere of 0.03 to 0.05 ag/c?. FMSI 03573 where redlining was done without dust extraction. Although high concentrations of dust were observed during blowing out, no cV.rysotile asbestos could be detected by infra-red spectrometry, end the individual fibres which could be detected optically could not be identified es asbestos. The General, Environment Pur'nr the application of drum brakes, disc pads or clutch facings, ' p;.ell quantit* oo of the surface of the friction rater'*si are vom evey. These materials contain between to 6(^.' of asbestos, and it has been assumed by sons that thereby large quantities of dangerous asbestos dust are being regularly discharged into the atmosphere. This, it is argued, creates a dangerous atmosphere akin to that which has produced asbestos- related disease (especially cancer) in some working environments. Since the estimated consumption of asbestos in friction material i6 annuelly over 40,000 tons ' for Europe and over 50,000 tons in the USA the amounts involved. >ro substantial. An estimate carried out by the Uendix Corporation with the support of the US Environmental Protection Agency (I2"A) calculated that the amount of friction material worn away in brakes end clutches annually in the USA is around 60,000 tons, * (of which 57,000 tons is the asbestos content i.e. 60~,'. In Europe the content of brake livings is nearer 505'). However it is clear from measurements made at a number of locations with heavy road traffic that insignificant quantities of 'espirablf! esbostos duet Rre so emitted. ; ilr? f.-st important' factor in dispelling anxiety is that the asbestos content of the wear products of friction material is not emitted into the atmosphere in the form of respirable asbostos dust. Indeed, a number of ambient air Investigations indicate that it,is difficult nowadays to find aebestos fibres in eny significant quantity, regardless of size, in the atmosphere - even in the vicinity of asbestos manufacturing plants. . Keasurements of the ambient air even in heavy traffic conditions do not show any significant level of asbestos. Again, in underground railway ayetens, where fierce application of asbestos-containing brakes in the FMSi 03574 -7- confined tunnel envii'onronnt might be thought to create the vorst conditions, , pc jjg no significant build-up of asbestos dust has been detected. ' ' * VI',c explanation is simple and is confirmed by a number of careful scientific investigations. The heat generated in the process of applying the brakes or the clutch (the reason in fact why asbestos is' such a vital component) is sufficient to destroy the original- structure of the asbestos fibre. Froma temperature of 450C the chrysotile structure begins to convert to a non-crystalline amorphous phaso, leading to a loss of stability.of the fibre structure. The mechanical strain applied during the braking process has a pulverising end grinding effect, leading to 7. disintegration of the fibre structure. The German report calls it "a kind of micro-milling so that the dust no longer contains any fibres". From a temperature of 650C a new crystalline structure develops called Forsterite, which will be fully developed at temperatures of above 700C. Generally, forsterite cannot be trtced in brake lining dusts. This means that temperatures beyond 650C either do not occur or are only very short lived. The decrease of the chrysotile content, however, indicates that temperatures beyond 450C are reached because the ajnorphous phase of the chrysotile cannot be traced analytically (by either infra rad-apectrometric or X-ray diffratcmatic methods). . Examination of the residue of wear products in brake arums confirms that the dsbestos content is usually less than 1?o of the residue. 27 .It has been suggested that the dust escaping into ambient air may contain a higher proportion-of the fine respirable asbestos than dust left in the drums but careful studies designed to entrap this .escaping portion of the wear _ product show that this is not sc. Various investigations into the amount of .asbestos remaining ,iv the residues from friction processes have been carried out which indicate how minute is the fraction of asbestos released in the application of friction. The latest report, 7 from Germany, confirms that technical investigations in recent years have repeatedly shown that the dust generated by friction of the linings in use - as opposed to dust created FMSI 03575 -a- during the finishing and handling of new linings - as a rule contains only traces of free chrysotile fibre, i.e. of the order of 1?o. The working party was unable to provide dearer infra-red spectrographieal evidence of chiysotile. Under phase-contrast and eloctromnlcrosoopic scrutiny, the dust contained Just a few isolated fibres which could not even be definitely Identified as asbestos. This is consistent with the investigation by UK government and Industry investigations in 196? which reported that the free asbestos content of wear products of drum brake linings rarely exceeded IJo. (in diso brakes the content was oven lower.) . The Bendix'investigations for KIOSH in USA in 1975 gave a range from 1.65/; to 0.0039s ~ only three tests were above 1?s and the overall average was 0.235$. This study also determined that only 5*<$ of the asbestos content of all the v'ear products over the whole range of US motor vehicles became airborne - estimated at 5060 lbst annually.^ ^ The Ford Kotor Company carried out a study 28 based on dynamometer tests which shoved that during brake usage less than 0.02$' of the lining wear was released in the form of free asbestos. Hie study estimated that concentrations of asbestos fibre in the urban atmosphere in the US due to brake usage was lesB than 0.07 x 10 ^ g/a? (.07 nanograms) (less than one millionth of the 2 f/ml occupational control standard). . . TieF.suren.ents carried out at points of heavy traffic concentrations in' the' UK by the Asbestosis Research Council, under the observation of the TUC Centenary Institute of Occupatiorial Health, also found do greater concentration. Sven in the underground railway system, this survey found the asbestos content to be of the order 10 g/m^ to 10 ^ g/m^. (.10 nge - to 100 ngs/m5)2^ ' .' Finally, some obeervations made within the last three years by two eminent. occupational health experts, on occupational risks and risks to the general . public, are worth quoting. FMS1 03576 V- Pr. John Gilson, reviewing esbestos as an occupational hazard in a central group in which he includes friction materials, says"Despite the thousands of products containing asbestos, evidence of ill effects from their use is very small". Ee adds the qualification that occupations -. involving brake shoe maintenance have been shown to be at- risk in the past. "Although most of the asbestos in brake shoes is degraded, the dust in the breke drums still contains a small percentage of asbestos". "The magnitude of the risk (of asbestosis and mesotheliome in those vnrking regularly in this employment) is not tooTM but is likely to be smell." Professor l'ielhute* , 22 ` in his report on public health risks, concludes "There is ' evidence of no excess risk of mesothelioma from asbestos pollution which has existed i.r the neighbourhood of chryRotile and acosite mines. There is ..nc.evidence of a risk to the general public at present". Later he repeats this view in hdr. general conclusion "There is no established evidence that true ambient exposure, as prevalent in Vestem Puropean countries, at this'moment carrion such a definite risk: however, there exist too many wr.oc-rteinties to deny such-a riev, though if the risk was substantial it is likely it would been detected by nov". roykLP?JQUS i ture There can be ?n oec.'-national heaxtK rick in the manufacture of apbeatos- vf eefl friction materials. However, expsrten:? shown that this is a very i '.'f hasitfc r'?k and that it can be effectively controlled by well tested equipment and work procedures, ; , * "tr.nl.-.rds based on extensive experience in the industry have been established and equipment ie available to maintain these standards so that the occupational health risk can be controlled. In many countries these . standards are enforced by legislation,' but in *w case trade and industry have an c.VMraticn,. as with any occupational safety problem, . tnynleui*nt the effective risk p-r-evention measures which have been developed by competent and experienced technicians. FMSI 03577  - 10 - Maintenance Work (Servicing) In certain conditions involving servicing, etc., there nay be a paraoccuptional hazard. The industry can provide Information to ensure that users understand under what circumstances such risks can arise and how they can be avoided.303132,33. The General Environment The available data indicate that the general public is not at risk and means should be found to tell them so. ANNEX - Bibliography 14th January 1981 (Page 10 retyped at PMSI because of weakness of original copy)^ _ FMSI 03578 ANNEX ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY BIBLIOGRAPHY 1. Walther, E., (formerly) Pneumoconiosis Research Unit, Penarth, Wales. "Dust Problems in the Use of Asbestos Products". Proceedings of the International Conference on Pneumoconiosis Johannesburg, S.Africa. 1969 2. Santorelli, Zedda, Aresini and Ghezzi; "Respiratory Physiotherapy of Asbestosis". La Medicine del Lavoro 63 (7 - 8) 269 - 281 July 1972 3. Rubino, G.F.: Institute Medicine del Lavoro, Torino, Italy. "Identification and Survey of Asbestos Occupationally Exposed Populations". September 1975. 4. International Agency for Research on Cancer. I.A.R.C. Monographs on Evaluation of Carcinogenic Risk of Chemicals to Man. Vol.14 Asbestos. Lyon, France. 1977. - 5. "Selected written evidence submitted to the Advisory-Committee on Asbestos 1976-77" Health and Safety Executive, UK. 1977. $ 6. Cross, A.A, former Director General, Asbestos International Association, London. "Progress in the Control of Asbestos Dust in the Workplace". International Conference on Pneumoconiosis, Caracas. November 1979. 7. German Federation of Industrial Accident and Safety Insurance Corporations E.V. Berufsgenessenschaften (Bonn,W.Germany). Research Report - Asbestos. "Investigations intoHealth Hazards through Dusts by Brake-Linings containing Asbestos". (Analytical epidemiological and animal investigations) December 1978. 8. "Hygiene Standards of Airborne Asbestos Dust Concentrations for use with the Asbestos Regulations 1969". U.K. Dept, of Employment H.M. Factory Inspectorate, Technical Data Note 13 (Rev) 1975. FMSI 03579 9. 10. 11. 12. 13. -2 - Heidermann, Kuhnen and Schutz (Dust Research Institute of Federation of Industrial Trade Associations (Berufsgenosenschaften). Bonn, W. Germany), and Prochazka; (Bavarian State, Institute for Industrial Safety, Munich) "Investigations into the Hazards produced by dust of asbestos-containing friction linings". June 1975. Conference on Exposure to Asbestos during Brake and Clutch Maintenance, Brentwood, Essex, England, March 1969. a) Lee G.L: British Leyland, Longbridge, Birmingham. "Removing Dusts from Brake Assemblies during Servicing Alternative Cleaning Methods". b) Hatch,D., Ferodo, Chapel-en-le-Frith, Derbyshire, England "Possible Alternatives to Asbestos as a Friction Material". c) Knight, K.L. and Hickish, D.E.,, Medical Services, Ford of Britain, Brentwood, Essex. "Investigations into Alternative Forms of Control for Dust generated during the Cleaning of Brak Assemblies and Drums". d) Hickish, D.E., and Knight, K.L., (as above) "Exposure to Asbestos during Brake Maintenance". UK Annals of Occupational Hygiene. Vol.13 1970. Bentley, M.L.; Mintex, Cleckheaton, Yorkshire, England. Personal communication to A.A.Cross - Asbestos Dusts - test during drum brake maintenance. May 1974. t Cross, A.A.; Chairman, Environments Controll Committee, ARC England. "Asbestos Dust in Friction Materials". September 1975. Jacko, DuCharme, Somers; Bendix Corpn. and Environmental Protection Agency, USA "Brake and Clutch Emission during Vehicle Operation". Automobile Engineering Meeting, Detroit, Michigan, USA May 14-18 1973* *Former Director General, AIA FMSI 03580 - 3- 14. Rohl, Anderson, Nicholson, Langer; Mount Sinai School of Medicine, N.Y, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair." American Industrial Hygiene Conference, Miami, USA. (Abstract 223) May 1974. 15. Nicholson, Hz Mount Sinai School of Medicine, N.Y. USA. "Asbestos Exposure during Brake Lining Maintenance and Repair" - June 1975 (Believed to be full version of abstract quoted above -14) 16. Rohl, Langer, Wolff and Weissman; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair". Environmental Research 12, 110 - 128 (1976). December 1975. 17. Rohl, Langer, Mlimentidls, Wolff, Selikoff; Mount Sinai School of Medicine, NY, USA "Asbestos Content of Dust Encountered in Brake Maintenance and Repair". Proc. Royal Soc. Med; 70:32-37 Jan. 1977. 18. Kogan, F.M.; Sverdlovsk Institute of Labour, Hygiene and Industrial Diseases, USSR. "Asbestos and Prevention Measures against Dust Harmful to the Health of Workers". (Chapter V). 1975. 19. Marsh, J.H.; Raybestos-Manhattan, Connecticut, USA. Personal 4 Communication. Reports of mesothelioma among brake service mechanics in Boston, Mass, and Santa Clara, California N.I.O.S.H. and Selikoff. August 1975. 20. Lorimer and Rohl; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure of Brake Repair Workers in the US". International Conference on Occupational Health, Brighton, England. September 1975. FMSI 03581 -4 - .21 Nicholson; Mount Sinai School of Medicine, NY, USA. "Comparative Mortality Experience of Three Cohorts of Asbestos Workers." International Conference on Occupational Health, See Item 20. 1 22. Zielhuis, Prof. R.L.; Coronel Laboratory; University of Amsterdam, Netherlands. "Public Health Risks of Exposure to Asbestos". Report of a Working Grou^ b'f Experts prepared for the Commission of the European Communities., Directorate General for Social Affairs, Health and Safety. 1977.. 23. Sebastien, Bignon and Bonnard; Centre de Perfectionnement Technique, Paris, "La Pollution Atmospherique Urbaine par l'Asbeste". Journeas d"Etude sur la Toxicologie Ihdustrielle, Paris. June 1975. . , ' ! 24. AsbeBtosis Research Council, Rochdale, England. Personal communication to A.A.Cross* "Investigation into levels of airborne asbestos dust in the London Underground, etc.". 1978. 25. Johns-Manville; Denver, Colorado, USA. Boston Subway - Cobra Brake Lining Emission 1977. 26. : Winton Laboratories, Surrey, England. "Asbestos in the'Underground - no cause for alarm". ' 27. Dufficy, B.L., Ferodo, Chapel-en-le-Frith, Derbyshire,. England. Personal Communication - Asbestos Content of Wear Products from Friction Materials. June 1969. ./ 28. Anderson, Gealer, McCune, Sprys; Ford Motor Company, USA. "Asbestos Emissions from Brake Dynamometer Tests". (Ref. as 13) 29. Gilson, J.C.; former Director of Medical Research Council Pneumoconiosis Unit, Penarth, UK. Personal communication to the AIA. * Former Director General of the AIA FMSI 03582 -530. "Asbestos Based Friction Materials etc. - Control and Safety Guide No.8". Asbestosls Research Council, Environmental Control Committee P.0. Box 18, Cleckheaton, Yorkshire, England. Dec. 1970 (Latest revision - March 1977). 31. "Safe Working with Asbestos - Friction and Anti-Friction Materials". ARC - See item 30. 32. "Recommended Work Practices - Fabrication and Use of Asbestos Friction Materials".AIA/NA- Asbestos Information Association of North America, Washington USA. 33. "Friction Materials Work Practices Guide". Friction Materials Standards Institute. Paramus, New Jersey, USA. October 1978. 14 January 1981 FMS1 03583