Document 6RB0akVkX394e3wDRLm30B1em

. FRICTION MATERIALS STAI.IDARDS INSTITUTE, INC., E. 210 ROUTE 4; P~S,N~J.'07652'-i MINUTES OF TilE MEETING of the ,., , ASBESTOS STUDY COMMITTEE Friday_. February 16. 1973, at 9:30A.M. at the Institute Office, E. 210 Route 4, Paramus, N.J. MEMBERS PRESENT I. H. Weaver, Chairman J. C. Henning H. Wagner E. H. Feierabend Raybestos-Manhattan, Inc. Firestone Tire & Rubber_ Co., t.Jorld Bestos Division Carlisle Corporation Molded Materials Division Abex Corporation American Brakeblok Division ~lEMBERS NOT PRESENT T. Bell W. Spurgeon H. K. Porter Company Bendix Corporation OTHERS PRESENT R. C. Wyatt E. W. 'Diislane' . ,' Maremont Corporation Friction ~taterials Standards Institute The meeting was called to order by Mr. Weaver, Chairman, at 9:30 A.M. . MINUTES OF PREVIOUS MEETING The Secretary read a summary of the Minutes of the Meeting held August 17, 1972. These minutes had been released and a motion for their acceptance had been obtained. I Upon motion duly made, seconded and unanimously passed, it was RESOLVED: To accept the minutes of the August 17, 1972 meeting as distributed. LABELING PRACTICES The subject of labeling of finished friction materials was the first item'on the agenda. While interpre~ing the OSHA requirements, it is noted that the hazardous warning label must be used where subsequent.working of the materials would creamairborne concentrations of asbestos fibers in excess of the exposure limits-of the OSHA Standard. In many drilling and grinding operations without dust collectors, Committee MemPers indicated that the 10 fibers/cc ceiling concentration has been exceeded. FMSI 06352 '. Minutes of MeetinS of Asbestos Study C~ttee -2- February 16, 19.73 .. ~e Chairman mentioned a survey made in the Metropolitan :area.-.c:oncerning the relining of .bakery trucks. The survey (cond'.lcted by an 'individual,~filiated with Mt. Sinai Hospital) indicated that during radius grinding and.\i"Plling of brake linings that the airborne concentration of asbestos. fibers .w~.,in excess of the 10 fibers/cc ceiling value. The results of our survey on Member practices for labeling was reviewed ...The results had been updated showing that 15 Members bad replied of .the 25.Members questioned. The results indicate that the Membership is not now labeling in accordance with the OSHA requirements, and while they interpret the OSHA regulations to require labeling where sUbsequent machining is expected,. they are undecided as to exactly '~hat they will do as regards labeling. In the survey, 2 Members indicated that a "binder" treatment makes it unnecessary.for the Member to label: He believes he is complying with the labeling requirement "No label is required where asbestos fibers have been modified by a bonding agent so that during any reasonably foreseeable use processingno airborne concentration of asbestos fibers in excess of the exposure limits owill be released.n It is the view of most Members of the Committee that the 5 fibers/cc (TWA) is exceeded in m~~y areas such as inspection, drilling, and grinding wher~ there is no adequate dust collection machinery. This could happen in garages where subsequent drill:J.ng and grinding is often required and where there is no adequate dust collection equipment. While the Members with OEM accounts are deal:lng with manufacture:La who should understand the OSH..o\ regulations, the biggest problem may be with the small. shops that are exempt from the .requirement& of the OSHA regulations. In an interpretation of the regulations, it is apparent that where sUbsequent .working of the material can raise the airborne asbestos concentrations above the limits tha~ the manufacturer is required to label the meterial. Would labeling of cartons suffice? The Committee felt that, yes, this would be labeling that would meet the spirit of the OSHA Regulations. Would it be necessary to put the warning label on individual segments? A Member mentioned that in many cases the carton, or wrapping, for the brake lining is disposed of before the brake lin:tng moves in to the working area. It was felt that if the warning label were on the carton or skid when it was received by the customer that the customer has some responsibility to pass the information on, and it was not necessary to label the individual segments. In the discussion concerning labeling requirements, the Members had to distinguish between ''where subsequent working will be required" as against ''where there is any possibility that subsequent working will be required. 11 Again the point was made that with undusted linings from a manufacturer it is likely that customer inspection, or possibly opening of cartons, could show airborne fiber concentrations in excess of the 5 fibers/cc (TWA). In discussion of the reasons to support or oppose labeling requirements. the question was raised as to whether objections centered around the cost of the labeling. Members indicated that the direct cost of labeling could be minimal. Most labeling could be put on by the box manufacturer at little additional cost to the fr:tction Baterial manufacturer. The rejoinder to this uas that the Members felt that i.t \~as not the rl:t:rect cost that b'lthered them. Rather, it is the indirect cost oi the customer. reaction t~ the warning label. Will the customer be tempted to purChase his linings from a manufacturer who does not put the warning label on the cartons, giving an advantage to the manufacturer who does not comply with the lm~ or to the foreign manufacturer who is not aware of and cannot be punisheci by the law? FMSI 06353 ' Minutes of Meeting of Asbestos Study Committee February 16, 1973 Upon motion duly made, seconded, and unanimously passed, it was RESOLVED: That {1) where asbestos containing materials do not have the asbestos fiber completely locked in, or (2) where subsequent operations may be performed on asbestos containing materials, the hazardous labeling practice be adhered to in accordance with the Label Specifications in the OSHA Standards for Exposure to Asbestos Dust. The Uichigan requirements for labeling toxic and hazardous materials were discussed. These had been sent to the Nembers of the Committee in December 1972. The Ford Motor Company had called to the attention of manufacturers the labeling requirements for hazardous substances pursuant to Act #282 of MiChigan Public Acts of 1967. In the Hichigan Standards there are specific labeling requirements concerned primarily with flammable and toxic materials. They do not specifically include asbestos. There are certain label requirements such as "DANGER, WARNING, CAUTION." The Federal OSHA requirements for asbestos specify CAUTION, which is the least sensational of the type headings used. Of course, the DANGER warning in the Michigan regulations is for materials that would be almost instantly lethal. However, it is difficult to tie in asbestos to the specific label required. It is felt by the Committee Uembers that adherence to the Federal OSHA requirements should be the first step taken. While the issue cannot be specifically resolved, it is felt that compliance with the Federal OSHA regulations for asbestos would indicate compliance with the Michigan regulations. While it is desirable that any label used by the l1embers should also cover the requirements of various state codes, the first step lmuld be to get the l-Iembers to label according to the Federal OSHA regulations. As regards the Committee's recommendation to the llembership, a decision cannot be made as yet on the size of the label. The OSHA regulations state that the label shall be "of sufficient size and contrast as to be readily visible and legible." }rr. Weaver has received some data on typical caution labels now in use. Mr. Wyatt will furnish the Secretary the label type that his firm is using. Based on the labels now in use, the Secretary will distribute this information to the ltembers of the Committee for their review. With this information, the Committee should be in a position to propose label specifications to meet the Federal OSHA requirements. NEW YORK TUmS l-'.AGAZINE ARTICLE "ASBESTOS-L-TH~ l?A~_Jl <!f L:I:VE;~, -~S-~_AEADLY SIDE" Copies of this article had been distributed to Members of the Committee. In addition, based on requests from Members not associated with the Committee, there were additional copies of the article distributed. As the br&te lining industry as such Has not a specific target, it was felt that no reply to the Times article was called for by the Institute. Ur. Weaver brought to the meeting copies of another article in the Saturday Review of the Society entitled "An Asbestos Town Struggles lUth a ::'..iller. n This particular article concentrated on the Johns-~mnville plant in Manville, New Jersey. This, of course, was not their brake lining facility. Other than the specifics of the individuals from 11anville, the article relied on much of the same background that appears in the article in the Ilew York Times. No action is planned on these articles, but they are almost required reading. FMSI 06354 .\ Minutes of Meeting of Asbestos Study Committee -4- February 16, 1973 H~LTH EXAMINATION REQUIREMENTS OF OSHA All Members of the Committee are'aware of the medical examination requirements in the OSHA regulations. All have taken steps to comply with these requirements. The basics of the .OSHA requirements are a preplacement examination, an annual examination and a requirement as regards termination of employment. These requirements are for ~.rorkers who are 11exposed to airborne concentration of asbestos fibers." Note that there are no specific limits which tell whether an office employee who must make occasional trips into the factory area is exposed to airborne concentrations of asbestos fibers. The treatment of this is possibly best carried out by meeting the spirit; of the regulations in including those employees in the examinations who are exposed to concentrations in excess of 1 fiber/cc (as used by one member). The interesting service by International Compumetics was discussed. The International Compumetics Corporation, located in Princeton, New Jersey, proposes a series of mobile medical tests which would include the full examination , requirement, computerized medical records, at a price that appeared interesting to the Members. They will also provide a $500,000 "Errors and Omissions" insurance policy to the company for their program. Tt-1o of the Committee Members .had investigated International Compumetics and llhile they were not long on experience as regards medical background, they apparently did have some computer capabilities. Also, it was felt that they may have the talent to accomplish what they propose to do. One Member planned to use the ICM services in one of their factories. Another Uember consider.ed using their services in a factory which later was scheduled for closing. Another Committee riember suggested that while the International Compumetics proposals are interesting that it might be possible to do what they have done even more reasonably. They work with their local Tuberculosis Society in scheduling examinations in the mobile unit. The Tuberculosis Society does the X-Ray and pulmonary function examinations. The company doctor, in the maanw~ile, does the balance of the medical examination. Where local tuberculoais units wish to cooperate, this might be advantageous to both the manufacturer and the worker. In a review of the proposal by International Compumetics Corporation it is indicated that they will do everything that is required by the OSllA regulations. The Institute Office will let the Membership know of the availability of the services of International Compumetics Corporation. We will not make a-specific recommendation. The Otairman also mentioned that there was a New York group that had proposed some similar services and that we should also let the Membership know about them. One Member who has already planned to use the International Compumetics Corporation proposal will let us know his evaluation of them after they have finished their tests. In direct answer to the question from Mr. Iverson, President of Internation Compumetics Corporation, we will not give them our mailing list. Rather, we will advise our Members of their services. ASBESTOS BAG OPENING ~1ACHINERY The Institute had sent out to the Membership information on manufacturers of specialized bag opening machinery. The problem here is to keep the asbestos fiber concentrations minimized during bag opening and to properly dispose of any asbestos dust still left in the bags. The list of those manufacturing bag FMSI 06355 I. Minutes of Meeting of Asbestos St~dy Committee . -s- February 16, 1973 opening equipment should be expanded to include the: Taunton Engineering Company 700 West Water Street Taunton, Massachusetts 02780 INSTITUTE SEMINAR ON SAFETY AND HEALTH REGULATIONS A Member mentioned that the dissemination of information on the bag opening machinery was interesting. Perhaps there is more information that can be given to the Members concerning disposal, collection, and other techniques used to comply with the various regulations. In response to a direct question, the Secretary indicated that as long as any proposed activity in the area stayed within the guidelines of .our Constitution there should be no reason why activity could not be planned in this area. These would be specifically covered by a few objects in our Constitution such as maintaining and raising the standards of all products, and the cooperation with the United States Government through its various departments and bureaus, etc. The Members suggested a workshop or a seminar which concerned "Asbestos regulations as they affect the work place or the environment." It was recommended that the Committee's interest in such a seminar or workshop should be approved by the Institute before further action is planned. Upon motion duly made, seconded and unanimously passed, it was RESOLVED: That the Committee is interested in a workshop on the effect of Government safety and health regulations and proposed solutions thereto. The Secretary is directed to have this Resolution reviewed so that the Committee could draw up a formal agenda for such a workshop. It would be the Committee's intention to have the Institute sponsor this workshop in some convenient location as soon as it is reasonably possible. EPA EMISSIONS STANDARDS The Environmental Protection Agency had advised the Secretary that they expected to have the new EPA Emissions Standards regulations published by the middle of February. The Committee Chairman advises that publication of the regulations has been delayed and it is now expected that these regulations will be issued possibly by February 23, 1973. In the regulations there will be source reporting requirements. These have been extended to 90 days rather than the 30 days that had been indicated earlier. Control practices are still the basic means of applying the standard. Control practices will be required where visible emissions exist. It is not known whether waste disposal will be included in the regulations. REPORT OF ADVISORY COMMITTEE ON ASBESTOS CANCERS At the request of the Chairman, the Members of the Committee had been sent a copy of the report of the Advisory Committee on Asbestos Cancers. The meeting was held in Lyon, France, on October 5 and 6, 1972. This report had been reviewed by the Members of the Committee and there were no comments made thereon. The FMSI 06356 Minutes of Meeting of Asbestos Study Committee'~~ -6- February 16 1 1973 Chairman advises that this report was to have restricted circulation and that the International Agency for Research on Cancer had not officially released the report. As we may have been premature in distributing the report, it is suggested. that the Members restrict their circulation of any information contained in that report. THE EPA STUDY OF PARTICULATE EMISSIONS FROM BRAKE.LININGS AND CLUTCH FACINGS The Bendix Corporation has been running tests on vehicles and on dynamometers to entrap the wear debris of brake linings and clutch facings. This study is under contract to the Environmental Protection Agency. Originally, the report was to have been made in 1972. .~: -~~ Dr. Spurgeon. of the Bendix Research Laboratories, advises that a final report should be published on these particulate emissions sometime within the next six weeks. There is no indication as to what these results show, as the work (at this stage) is not for publication. STATISTICAL EVALUATION OF THE MEMBRANE FILTER METHOD The Chairman distributed to the Committee the conclusions and recommendations in a report made for the Asbestos Information Association on the precision and accuracy of the Uembrane Filter Method for measuring concentrations of asbestos fiber. This report was done by the LFE Corporation under contract for the Asbestos Information Association. The evaluation was not reviewed by the Committee Members at the meeting. NIOSH RECOMMENDATIONS AS REGARDS HEAT STRESS This particular area does not pertain specifically to asbestos. However, most of the brake lining and clutch facing manufacturers work with hot presses and various ovens. The recommendations as regards heat stress will affect most of the Hembers. A Member's work in the area of heat .stress measurements was distributed for their review, along with a copy of the NIOSH recommendations. Again, as this information was new to some of the Committee Members the data was distributed and not discussed. ******** There being no further business brought before the Committee, upon motion duly made, seconded and unanimously passed, it was RESOLVED: To adjourn. Adjourned at 1:00 p.m. E. 'W. Drislane Secretary FMSI 06357