Document 6a2gOMy3vdk8gxx4DEL5NkY1

FILE NAME Brakes BRK DATE 2017 DOC BRK257 DOCUMENT DESCRIPTION Journal Article - The Brake Industry's Impact on Asbestos Regulation in the 1970s PUBLIC H_A_H HENAND HENAND NOW Ain't Necessarily So The Brake Industry's Impact on Asbestos Regulation in the 1970s David Rosner PhD MPH and Gerald Markowitz PhD Ys ODORING ADA NO foe Pestate Pestate Pestate asbestos a #ledSimiore #ledSimiore #ledSimiore la koku^Agencies Agencies Kedil 68 get a dere dere fl- - - KES Ac h OMES CE every every every every every aC 22 ae LOOT CLS WS Se Leah La os 4 5 * Get the err oT Dap tor ean 94rton 94rton 94rton McS McS McS McS McS McS SET at Sys e soot 0409fleur 0409fleur 0409fleur smp 2 OR KO) OEY ane ah ta cre Co ft TE ABC SS << A >>>>> >>>>> Pec Heach P wet or anval anval p20 p20 2017 < plecaMKOY plecaMKOY plecaMKOY plecaMKOY plecaMKOY plecaMKOY AN OC > C A 120 / 70 At the end of 2016 the US At Protection Agency EPA proposed asbestos the cause of fibrotic lung disease and cancer as one of the 10 industrial chemicals to be evaluated under the newly revised Toxic Substances Control Act Under the new act a risk evaluation ofasbestos is to be completed within three years and if asbestos is found to be an unreasonable risk to humans and the envirominent the EPA is required to mitigate that risk possibly through a 2 ban within two more years By 1970 asbestos was used in some 3000 products such as roof shingles floor tiles house siding ironing boards and particularly in brakes among other consumer items Today this carcinogenic material is banned in the United States in a few products including corrugated paper and flooring felt but it is still legal in brakes and clutches and a host of construction and Industrial materials such as vinyl floor tile 100fing materials and coment pipe among others Consequently it in mullions of honics gas stations and repair shops across the country Historians have documented one major reason for the delay in banning this known carcinogen private industry trade groups stifled earlier efforts 1 at regulation Here we look at the specific efforts of one such group the Fiction Materials Standards Institute FMSI to forestall the regulation of asbestos used in brakes and clutches one ofthe oldest sources of asbestos exposure We examine the industry's reaction to the newly created Occupational Safety and Health Administration's OSHA dramatic reduction ofthe Permissible Exposure Limit PEL in the early 1970s There is literature that addresses the current medical and epidemiological evidence ofthe 5 dangers from asbestos brakes Heie however using internal corporate documents most of which have not been previously reviewed but are now available " at toxicdocs org we explore what the industry understood about the dangers to mechanics from asbestos The concern about asbestos in brakes reflects the broader acknowledgment of the impact of industrial toxins on workers and consumers in the 20th century In the early 1930s ERA Merewether identified the dust produced by the sawing grinding and turning in the diy state of articles composed wholly or partly of asbestos such as motor car brake and clutch linings when mhaled as a cause of asbestosIS the fibrotic condition that slowly > strangles affected workers Merewether's Merewether's early observation that any material that contained asbestos could prove to be a hazard was affirmed affirmed in the immediate postwar period as officials noted that asbestos has been incorporated into protective clothing biake linings cements and other forms of insulation and that exposure to asbestos dust caused by the breakdown of the native muneral was also associated with of " cancer the lung By the mid1960s asbestos was associated with asbestosis lung cancer and mesothelioma a cancer of the lining ofthe lung and abdominal cavity leading the British Ford Motor Company to host a conference in 1969 o the possible dangers presented to brake mechanics and those installing or replacing brake 10 linings In 1970 the Occupational Safety and Health Act establishing OSHA and the National Institute of Occupational Safety and 11 Health NIOSwH as passed Almost immediately the FMSI established an Asbestos Study Committee ASC which focused on the possible impact of OSHA regulations on brake and clutch manufacturers Working with the Asbestos e1 Public Health Then and Now Peer Reviewed Rosner and Markowitz AJPH Published online ahead of print July 20 017 PUBLIC LAm 11 NOW NOW Information Association of North America AIA another trade association it sought to forestall any drastic regulation Among the ASC's first acts was to meet with OSHA officials who had issued an emergency PEL of 12 fibers per cubic centimeter in 1971 and a year later reduced it further to 5 fibers per cubic centimeter with an even greater reduction to 2 fibers per cubic centimeter by 1976 mA NOWLEDGING NOWLEDGING DANGER PRIVATELY The FSMI was aware of why OSHA was considering this reductioAnt its meeting in June 1972 the ASC received a report that Rohl and colleagues had presented a paper at meeting of the American Industrial Hygiene Association which was held at Mt Sinai School of Medicine in New York City According to the ASC the paper revealed that the dust concentrations during the blowing off of brakes are in excess of the five fibers per cc cubic centimeter allowance They acknowledged that exposure to asbestos dust was a possibility if not a probability for workers installing and replacing brakes This raised the question for the ASC as to whether the manufacturers under the new OSHA regulations had an obligation to warn workers of dangers they potentially faced to Hence a new rationale for not warning was developed they publically pronounced that asbestos when locked in to fabrics lacquers plastics or other finished products was not a danger as it could not be released into the air In private however the committee members noted that because their products were friction materials there was an inherent danger in the handling by employees of the products with supposedly locked asbestos during drilling grinding inspection and boxing Furthermore there was the potential for the release of asbestos during the handling of the brake lining or clutch facing by the customer even far from the shop floor One member of the ASC suggested that " notification be put boxes brake linings on clutch facings but this was quickly shot down when another member objected because he felt it was another red flag that would bring more harm to the industry than the alleged good that would come from enclosing such notices Despite public assurances that using locked asbestos was safe EW Drislane the executive director of the FMSI wrote to the ASC about an internal survey that revealed the problem that in many cases subsequent operations will be performed grooving diilling and grinding and that these subsequent operations can produce concentrations of asbestos fibers in excess of the current exposure limits Most members of the Committee believed that the OSHA standard was exceeded in many areas such as inspection drilling and grinding where there is not adequate dust collection " machinery ANIN PSSARY PSSARY SO In 1973 Ike Weaver an engineer with the RavbestosManhattan Corporation and chair of the ASC gave a major address to the entire membership that provides a summary of what the industry understood about the dangers of asbestos He informed them HOWARD, 2h My 4 Og ome, wpb Pas Retimsh EP tty, ***** ***** ***** 336 336 VOR 8 ged F Bag t^" *** *** *** mange em ad KA Xe at bf rom sat be " tebe un ERB HO A det Oe yore P42 OSaakas MA // Bee B allay Adthe ayes bas ater < > the Oregeee eage Sf we Str Reo FE ****** ****** ****** af ake OPK S gest 9 er eege maxx maxx gig~ ty > das et see stat wade a xxxxx xxxxx *** Wet Segesta we sSaey seach Segesta Segesta /,, Manville about the recent meeting of the International Agency for Research on Cancer at which the most important item was the incimination of all major types ofasbestos as causal agents of carcinoma particularly particularly " mesothelioma He further warned that since most of us in the FMSI use substantial amounts of chrysotik asbestos in our formulations association of this material with mesothelioma and other types of cancer is of 1121 serious concern For an industriyndustry that identified friction as the primary characteristic ofits products he knew of no way any ofus can be absolutely sure that his friction products regardless of whether they are sold as original equipment or on the replacement market would not result in excessive exposure Look What Makes the Disc Brake Brake From the 1930s on sawing cutting sanding or abrading asbestoscontaining products in any way was identified as a major concern Here we see an asbestos Manvil e disk brake ad from the 1960s with no mention of any potential danger Published online ahead of print July 2017 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now = -- -- PUBLICIDA PUBLICIDA LH NAND NAND NOW ** eS Fear wt aoe fox Qtnaal >> se di form BE y Sy 8 hadt eas ---- S ios Booger BS ohaty ase CBee x / / /, // /, / / /,, /fiR/F /ap ok vix sts sts ey ange INDO ee of ok * Car Gk ade ed awed a ifs ***** ***** hy matty SONI? 56 358588885eps ****** ****** font o ciao 358588885eps p^"k^'^'^s '^a ' 4 ay ****** ****** V^'ny ^ aby ce ed LO, a ee HR EC eae $ fomrmucegis Hates wath yis dag 8 om arb a ae we Pie oe hee CeO eae 32 /, / / / / 1 5 / <' < 385 " Feds *** " " p ete "Ge *** 1 Bd ' 2 a ta bah peat a wx pay sexux Esse Desser < Pe Are qu yes EK > Gyan xo << >> > # ******** ******** ******** 4 a bth 9 bt or fen * Hyde Busine^" * athe mw pres! tad fi -,, ' alae r { 145 E'S A 13533 * oEM 92 Vo tapi 13533 1 *W MANHATTAN INC * * Heo On, Maine 9 MF Rapes ae Benne HERE Rane ergs ass ass ass to Condor 4 mannarram Greg Rock wyse wyse wyse Bary Me Enel sourc wyse wyse bauasetdsothe * Ppa deneny ry VA 6000 S SPECIALISTS IN ASBESTOS RUBBER AND SINTERED METAL PRODUCTS Here we see an asbestos Johns Manville disk brake ad from the 1960s with no mention of any potential danger In fact the ad emphasizes the safety of the asbestos brakes despite the fact that by this point it was clear that exposure to asbestos dust caused cancer of workers or bystanders to airborne asbestos fibre He was appalled to learn of instances where this problem has occurred He objected to those in his industry who argued that most workers were exposed only relatively intermittently to respirable asbestos dust " say emphatically thus Just am't necessarily so Not only did large volume replacement users perhaps chains such as Midas and Meineke present major potential hazards but even small job shops can needlessly expose people to high fibre concentrations if operations are performed without controls There was the risk for dread disease even when exposures were mummal or of short duration 23 To me Weaver concluded labelling all containers or packagers of containing fiction material is the very least the industry can do to fulfill its moral obligation to its customers their employees and the public and at the same time conform with mimum requirements of the Occupational Safety and Health Act 221 Further evidence about the potential dangers to mechanics including cancer was provided with the publication of the Rohl paper on New York City garages that the ASC had heard about before The ASC acknowledged that some ofthe housekeeping conditions in these shops were deplorable And they acknowledged that conditions in New York were perhaps no worse than in other shops 125 throughout the country COLLAPSINGO COLAPSINGO FINES FINES By the 1970s the FMSI had learned that both national and international expeits NIOSH the International Labor Organization the International Agency for Research on Cancer and other researchers agreed that the PEL was irrelevant to the 21 question of cancer In addition one of the leading figures in industrial medicine and the leading asbestos researcher Irving Selikoff echoed these ideas writing that the only safe concentration is zero fibei per 227 In April 1975as the date for the proposed reduction of the PEL to 2 fibers per cubic centimeter approached the FMSI faced a dilemma They claimed they were already having difficulty meeting the 5 fibers lut and worried that it would be near impossible to me 'tthe 2 fibers limut due July 1 1976 Some on the ASC suggested that the industi should oppose this change and Guv Gabriellson vice president of the Asbestos Information Information Association said that the industry should simply reject OSHA's and > NIOSH's position CROWING PRESSURE PRESSURE ROWING EVIDENCE The situation was becoming dire for the FMSI as they faced growing pressure to acknowledge that there was no exposure below which workers could be protected from induced cancers The pressure came from NIOSH the International Labor Organization and others Selikoff piedicted an epidemic ofasbestos related death and disease in years to come The FMSI Board ofDirectors was alarmed by the growing consensus that no known dose level of asbestos exposure was safe Furthermore Selikoff and his colleagues were activel promoting the view that the hazards were associated with asbestos emissions specifically to mechanics- brake lning wear and from brake service operations The pressures became even greater in July 1975 after NIOSH called a meeting in Washington of an automobile company union representatives the major asbestos companies researchers and a trade 31 association representative They learned that the medical literature revealed at least four cases of these are tumors mesotheliomas in persons who were employed in jobs involvi ig 9932 automobile brake servicing The liability dimensions of the problem facing the industry ' were fightening It has been reported that approximately 900,000 persons are employed in such work in the United 3 Public Health Then and Now Peer Reviewed Rosner and Markowitz AJPH Published online ahead of print July 20 2017 PUBLIC TEATTENANJ TEATENANJ TEATTENANJ TEATTENANJ NOW States It is recommended that stringent industrial hygiene measure to control exposure be implemented as rapidly as possible In a separate article the industry learned that during lining maintenance and repair workmen in garages service stations and brake repair shops are exposed to asbestos and thus may be subject to serious cancer risk Others at some distance from the repair work are perhaps subject to the same hazard RESISTANCE RAMPS UP At the same time that these articles were being published OSHA proposed to reduce the asbestos standard even lower which the FMSI described as a drastic reduction 35 The ASC began to mobilize committee members and the general membership of the FMSI to oppose OSHA's recommendation that the PEL be reduced to 0 fibers per cubic centimeter instead ofthe 2 fibers per cubic centimeter standard that was scheduled to go into effect July , 1976 In June they proposed a three strategy First they intended to educate their membership on how to comply with the fibers per cubic centimeter standard to go into effect in the following month and further to recognize the mpact that will be required to cope with the 05 fibre standard should it be " imposed Second they planned to oppose the more stringent standard with every possible means at our disposal and to enhghten government officials of what informed members within our industry regard as the complete impracticality of the proposed 0 5 standard Finally they planned on cooperating with the Asbestos Information Association and the Institute Office in their response to OSHA on the revised standard an effort they believed had already borne fruit In the end the standard would not be reduced until the mid- 1980s and they congratulated themselves and the AIA on forestalling the reduction ofthe standard The FMSI thanked the AIA for the outstandijnogb they did m rebutting some of the reasons for OSHA's stringent proposals The committee bragged that we have been told that our efforts have been efficacious The influence of the asbestos industry can be observed dnectly by comparing the warnings the FMSI and AIA recommended for gas stations and auto repair shops with those of the government NIOSH in 1976 suggested that a sign be posted at the entrance to the work area of these garages that specifically warned Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remam in Area Unless your Work Requires it Breathing Asbestos Dust May Cause Asbestosis and Cancel The The FMSI and the AIA adopted similar wording with one crucial difference they did not use the word cancer Instead they adopted OSHA's wording from the 1972 standard Breathing Asbestos Dust May be Hazardous to Your Health As a result of the FMSI and AIA's opposition the lowering of OSHA's PEL was significantly delayed In addition they trivialized the dangers to workers by not including cancer in then warnings As a result they belittled and undercut the warnings of NIOSH Irving Selikoff and many other Scientists that workers were putting their lives at risk by working with products made with asbestos For policymakers it is important to understand the tragic history we relate here It took 45 years of work on the part ofphysicians laboratory scientists regulatois and citizens to achieve these monumental victories for public health but all of this work can be undone the current administration in Washington follows through on its threats to undercut the EPA and other federal agencies There are few materials in the modern environment that are documented to be as hazardous as asbestos It would be tragic if all this work was to be undone by new lobbying efforts amed at new administration and EPA admistrator particularly receptive to industry's siren call to deregulate A~"PH ABOUT THE AUTHORS David Roster is with the Center Center for the History and Files of Public Health Department of Sociomedical Scenas Mailman School of Public Health and the Department of History Columbia Universty University New York NY Gerald Markountz is with the Department of Interdisciplinary Studies John Jay College and the Department of History History Graduate Center both of the City University University of New York New York NY Correspondence should be sent to Daval Rosici Center for the History and Etines of Public Health Department of Sociomedical Saemes Columbia University Mailman School of Public Health 7221st 7221st 168th St Room 934 New York NY 10032 ma d289 d289 @jolumbia @jolumbia edu Reprints can be ondered at http //www.aph //www.aph org by chicking the Reprints link His article was accepted accepted May 4 2017 dor 10 2105 AJPH 2017 303901 CONTRIBUTORS The authors contributed equally to the research writing and conceptualization of this article ACKNOWLEDGMENTS We acknowledge acknowledge that many of the primary source documents were gathered in the process of litigation regarding asbestos discases discases These documents ne availble online at http www toxicdocs org a Web site of corporate memos letters reports and other nudles developed through the cooperative eftoits of the Center for the History and Ethics of Public Health Columbia University and the City University of New York We have appeared as expert witnesses on behalf of plantiffs in asbestos lawsuits ENDNOTES 1. This revision is now known is the Frank R. Lautenburg Chemical Safety for the 21st Century Century Act 2 Environmental Protection Agency News Releases From Headquarters FPA Nmics First Chonne als for Re- view Under New TSC A Legislation Agency Answers Call to Move Forward on Chemical Reform Namung Asbestos Among the Fust to Undergo Risk Evaluation November 11 2016 https //www.cpi //www.cpi gov newstele ises chemical unds er new tsca legislation accessed December 29 2016 3 Environmental Protection Agency " US Federal Bins on Asbestos https // www.epa.gov/asbestos/us-federal-bans ww.epa.gov/asbestos/us-federal-bans ww.epa.gov/asbestos/us-federal-bans ww.epa.gov/asbestos/us-federal-bans www.epa.gov/asbestos/us-federal-bans www.epa.gov/asbestos/us-federal-bans content accessed Decemibe 29 2016 See also Kathleen Ruft Asbestos obby Launches Attack to Undermine Upcoming UN Conterence ' on Tride in Hazardous Substances http //www.rightoncimdi //www.rightoncimdi 3963 accessed April 17 2017 + See for example Bairy Castleman Asbestos Medual and Legal Aspects 3rd edition Englewood NJ Prentice Hall 1990 Gerald Markowitz and * David Rosner Unleashed Upon an Unsuspecting World The Asbestos Information Association and Its Role m Perpetunting a National Epidemic American Journal of Public Health 106 no 5 2016 834-840 5 See Castleman Asbestos pp 443 for one of the reviews reviews of the 471 existing scientific evidence of the dangers of asbestos in brake linings 6 These documents ire valible on the Web site toxicdocs org a collection of nearly 6000000 corporate memos studies letters and notes gathered through a variety of law suits over toxi materials 7 David Rosner and Gerald Markowitz A Gift of God The Public Health Controversy Over Leaded Gasolme During the 1920s American Journal of Pubhe Health 75 no + 1985 344-352 William Cnaebner Hegemony Through Through Science Information Engineering and Lead Toxiclogy Toxicology 1925 196m 5 David Rosner and Gerald Makowitz eds Dyng for Work Workers Safety and Health m furentieth Century America Bloomington IN Indiana University Press 1987 140 159 David Eg~-lmanand Marion Billingy Abuse of Epidemiology Automobile Manufacturers Manufacture 1 Detens to Asbestos Inbility International International Journal of Occupational and Livironmental Published online ahead of print July 2017 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now e4 PUBLICATIEVAND PUBLICATIEVAND PUBLICATIEVAND PUBLICATIEVANDPUBLICATIEVAND NOW NOW NOW Health 11 2005 360 37C1astleman Asbestos AnthonyJ Lanzi cd Silicosis and Asbestosts London UK Oxford University University Press 1938 419 See also SB McPheeters A Survey of a Group of Employees Exposed to Asbestos Dust Joumil of Industrial Hygiene and Toxicology 18 April 1936 229 he sumum the problem acted by the dangerous dust diseases silicous and asbestosis asbestosis writing that while it currently cmploys rehavely small number of persons the isbestos industry has had a ukibly rapid expansion by rison rison of the widespread and varied uses of this products which includes c matches matches filter pads punts roofing high pressure jointing electrodes brake linings clutch rings and insulating material ER Merewether Memorandum on the Industrial * Discases of Silicosis and Asbestosis London His Majesty's Stationary Office 1932 12 https www toxicdocs.org toxicdocs.org Wartime Operations Emphasize Emphasize Industn Hygiene Problems of Asbestos Industry Illinois Labor Bulletin 3 1943 10-11 See also VJ Cistrop Fume and Dust Exposure National Safety News 57 February 1948 20-21 52 73 7H 9 Wyers Asbestosis Postgraduate Medical Journal December 1949 631-638 Asbestosis and Cancer of the ung Journal of the American Medical Association 140 August 13 1949 1219-1220 Richard Doll Mortality From Lung Cancer in Asbestos Workers Butish Jounal of Industrial Medieme 12 1955 81-86 Hygienic Guide Series American Industrial Hygiene Association Jounal 19 1958 162 10 E Hickish Exposure to Asbestos * During Brake and Clutch Muntenance Annals of Occupational Hygiene 13 1970 1 E Hickish and K L Knight Exposure to Asbestos During Bike Bike Muntenance Annals of Occupational Hygiene 13 1970 20-21 11 L Leopold The Man Who Hated Work and Led Labor The Life and Times of Tony Mazzon White River Function VF Chelsea Green Publishing 2007 12 Friction Mateuils Standards Institute FMSI Bulletin No 406 Asbestos Study Committee ca 1975 All of the FMSI documents were attained through discovery proceeding in viricty of asbestos lawsuits in some of which we participated and we are making all of them wailable at https www "-orflg 13 FMSI Asbestos Study Committee Minutes February 10 1972 Makowitz and Rosner Unleashed ' Upon an Unsuspecting World 14 FMSI Asbestos Study Comite Committee Minutes June 14 1972 15 FMSI Asbestos Study Committee Minutes August 17 1972 16 Title 29 Labor Chapter XVII-Occupational Safety and Health Administration Department of Labor Part Occupational Occupational Sifury and Health Standards Stand for Exposure to Asbestos Dust Federal Register 37 1972 11321 Cltition Labels shall be affixed to all raw materials mixtures scrap waste debris and other products contaming asbestos fibers or to their containers except that no label required where asbestos fibers have been modified by i bonding gent coating binder or other maternal so that during any reasonably reasonably toreset ible use handling storage disposal processing of ti unsportation no urbome concentrations ofasbestos fibers in excess of the exposure limits prescribed na paragraph b of this section will be Ieleased ' 17 Ibid p 11319 Employers in general strongly contend that finished products that effectively ennap asbestos ubers so that these would not be released in the normal use of the products not be required to be hbelled should 18 FMSI Asbestos Study Comite Committee * Minutes August 17 1972 19 W Dslanc to Asbestos Study Committee Interpretation of OSHA ' Labelling Requirements Requirements November 6 1972 20 FMS1 Asbestos Study Committee Munutes February 16 1973 " 21 FMSI Annual Meeting Minutes June 27-28 1973 Weaver noted that risk is greatest with crocidolite less with amosite and apparently still less with chrysotile ' chrysotile " 22 FMSI Annual Meeting Minutes June 27-28 1973 23 Ibid 24 lbid 25 FMSI Asbestos Study Comite Committee * Minutes June 14 1974 26 The International Labor Organization's Meeting of Experts on Saft Use of Asbestos stated that the 2 fibres standard should be regarded as an interim concentration iclated to fibrogen effects and not to carcinogenic effects for which no standards exist at the present time See Report of International Labor Organization Meeting of Experts on Saft Use of Asbestos in Geneva December 11-18 1973 in Asbestos Study Committee Report June 1974 attached to Minutes of Annual Meeting Jun 18-19 1975 27 FMSI Boud of Directo * Minutes June 25 1974 28 See also FMSI Asbestos Study * Committee Minutes April 28 1975 29 Sue Gerald Markowitz and David Rosner Unleashed on an Unsuspecting World The Asbestos Information Association and Its Role in Perpetuating a National Epidemit AJPH Mav 2016 p 838 30 FMSI Board of Directors Mmutes June 17 1975 Asbestos Study Commute tec Report june 1975 31 Deputment of Health Education Education ' and Woltare CDC NIOSH Minutes of Occupational Ocupational Exposures to Asbestos Dust From Brake Linings Meeting July 21 1973 32 Department of Health Fducation and Weltare CDC NIOSH Minutes of Occupational Exposures to Asbestos Dust From Brake linings Meeting July 21 1973 See also J William Hoyd NIOSH to Deir Colleague Current Intelligence Bulleting 5 Asbestos Exposure During Servicing of Motor Vehicle Brake and Clutch Assemblies Assemblies DHHS NIOSH Publication Publication No 78-127 August 8 1975 in FMSI file At the meeting Dr George Wright representing the Johns Manville Corporation emphasized that manufacturers have a responsibility to ascertain what happens to their products after being sold to others He was not surprised about the high fiber county reported and expressed the behef that one might subsequently subsequently encounter the full spectrum of asbestos disease among gunders 33 Arthur N Rohl Arthur M Lange May S Wolfl and Irving Weisman Asbestos Exposure During Brake ming Muntenance and Repur Luvironmental Research 12 1976 110-128 110-128 In this paper the authors describe the work practices in repur repur shops and the attendant hazards When a vehicle is brought into a tepan shop for brake lining inspection or replacement the wheel is removed and loose dust is removed from the drums and back plates generally by means of a compressed arjet The cloud of dust that is produced is visible for several minutes afterwards Table 3 shows that fiber concentrations ne high in the operitor's operitor's tet under these conditions in werige concentration of 16 fibers and that there are signifiinct concentrations at least 20 ft away It evident that any person 65 7f5t away can be exposed p 118 It was generally found that there was minimal if any effort to contiol dust in most ganges Workmen do not use respurtory respurtory protection There was little awareness of the potential haz~-rd of bike dust pp 117 118 * 34 Arthur N Rohl Asbestos Exposine During Brake Lining Maintenance Rep ce Januny 1976 enclosed m Selikoff to Duisline January 14 1976 Rohl says in handwritten note Di Selikoff his asked me to send you the results of our asbestos fiber counts ' ng biike sepall work This reference to the culv drift of paper published in mid 1976 35 Asbestos Study Committce FMSI Minutes of Annual Meeting June 16-17 1976 36 Asbestos Study Committee Report June 2 1976 37 See US Department of Labor Occupational Safety and Health Health Administration Occupational Occupational Exposure to Asbestos Final Rules 29 CFR Parts 1910 1915 and 1926 F~-n Rule for more complete review of the unfolding attempts at lowering the PEL in construction and other Industries https www.oshi www.oshi gov pls oshiweb show_document FEDERAL_REGISTER FEDERAL_REGISTER p_ id 13404 accessed January 17 2017 38 Asbestos Study Committee FMSI " Minutes of Annual Meeting Junc 16-17 1976 34 Asbestos Study Committee " Report June 1976 40 NIOSH Recommended Intern Procedures for Asbestos Brake and Clutch Servicing enclosed in FMSI Bulletin No 581 October 12 1976 41 Markowitz and Rosnci Unleashed Upon an Unsuspecting World p 837 42 AIA Recommended Procedures for Reducing Asbestos Dust During Bike Servicing ca September 1976 these were sent out by the FMSI on February 23 1977 43 Hearings on the Nomination of Attomey Gencial Scott Pruitt to be Administi itor of the US Environment Protection Agency Before the Semite Committee on Envionment and Public Works 115th Cong 1st Suss 2017 Transcript pw 011817 pdt available at https // www.cpw.setEITO www.cpw.setEITO www.cpw.setEITO www.cpw.setEITO public index.cfm 2017 2017 hearing hearing nomination nomination ittorney d- administrator the-the- s environment protection agency accessed July 17 2017 e5 Public Health Then and Now Peer Reviewed Rosner and Markowitz AJPH Published online ahead of print July 20 2017