Document 6wxbvrRbnLe54kNoDa0Dp84wd

.Jo'K.l'.:TlON MATERIALS STANDARDS INSTl'l'U'l't<: INC., E-210 ROUT!~ 114, PARAMUS, NEW JERSEY 07652 ""- ~ November 20, 1978 TO: ASBESTOS STUDY COMMITTEE SUBJECT: REPORT BY OFFICE OF TOXIC SUBSTANCES (OTS) ON ASBESTOS Several weeks ago, Mr. Ike Weaver of Raybestos-Manhattan, Inc. sent along a copy of an OTS review on their "Phase I Report on Asbestos." This was a draft of a report circulated within the Office of Toxic Substances prior to further discussion with other EPA offices. Brake linings and friction materials were mentioned several times in the draft. In this draft, the OTS is considering various areas where asbestos can in some manner pollute the environment. In partijular they mention the proposed Connecticut ambient air standards of 30 ng/m , and they indicate that there are levels of asbestos in many areas exceeding that level. Brake linings and friction materials are indicated as a source both for inhalation problems, and for ingestion (street sweepings discharged into streams). They mention the controversy on the nature and amount of fibers emitted fram friction products. The report mentions a National Cancer Institute study suggesting that fibers greater than 5 micrometers in length and less than 0.25 in width are carcinogenic. The problem with resolution of fibers smaller than 0.25 micrometers in width not being detected by optical microscopy complicates this question when an analyst is attempting to determine the fiber length. They do make a conclusion that use of the optical microscope for regulatory monitoring appears to be inadequate. If it were accepted that only fibers longer than 5 micrometers were carcinogenic, it would run counter to the Mount Sinai position that smaller (shorter than 5 microns and not detectable by optical microscopy) may be more lethal than the long fibers. Also, Mount Sinai studies of wear debris (brake drum dust) have indicated that only in rare instances have long chrysotile fibers been observed and t?at most are shorter than 0.4 micrometers in length. There are sections in this report on epidemiological studies and a statement that asbestos induced cancers are related to the severity and duration of exposure. Later in the paper it indicates that exposure may be significant in "auto supply stores," and I would imagine by this they mean from friction materials. The paper further indicates that if asbestos emissions from brake linings are considered significant, that the Toxic Substances Control Act (TSCA) might be used to control the asbestos content of brake linings, and to promote substitutes. They even suggested an interim step to require manufacturers to report any research results on asbestos substitutes. I have not enclosed the appendix list of materials previously covered in the Kearney report on consumer_products containing asbestos. This was to keep the enclosure to 30 pages. This report is sent for your information. E. W. Dri&lane Executive Director FMSI 06969 G-1? (J{) 1 ' FRICTion HATERIALS STklDAR..l)S Ii~STITUTE, IUC., E-210 ROUTE 4. PARAlfiJS, N.J. 07652 ! ! BULLETIN H 0. 6 3 4 llovel!lber 16, 1978 FP.ICTIO~l HATERIALS WORK PRACTICES GUIDE ~ September 12, 1978 l7e asked Active rlembers concerning interest in a :Friction 11aterials Hark Practices Guide." This guide torill be a small 5-1/2;' x 8-1/211 or 6" x 9" booklet tY"ith 12 pages. It is aimed at the brake shops and medium size customers handling brake linings and clutch facings. The message has to do with good '-1ork practices and handlin~ friction materials. In particular, it emphasizes that the 't10rker should not use an air hose to blow dust from brakes and he should use the proper dust collection equipment if he is machining br&te linings or clutch facings. It also has suggestions on respirator usage. Some of the suggestions in the booklet are in line with those made in a HlOSil Alert and in some cases quote directly from the OSHA standard for controlling asbestos in the l'iorkplace. There are actually only five pages of text along with five illustrations opposite each page. The front cover has an illustration and of course the title. The rear cover indicate sources of additional information for some of the items mentioned in the text. This ''7ill be a professional booklet sotTle"tvhat sinilar to a booklet which -was put out by the Asbestos Cement Pipe Producers Association. It's usap.e is primarily in ~he brake shop as I indicated earlier. Based on Hember interest, \'7e will order in quantities above 30,000, and based on that voltll!le projection the booklet tnll be priced at 9 (U.S. $. 09) per copy. He nO(~ have final copy and are ready for printing. Fould you please place your order for these booklets on: Friction Haterials Standards Institute East 210 Route 4 Paramus, Ne"t-7 Jersey 07652 U.S .A. In order to expedite this shipoent tve are asking that you have your purchase order into the Institute Office by December 1, 1978. E!TD/erc Distribution- Active Hembers- List C Regional Uembers Licensees E. H. Drislane Executive Director FMSI 06970 FR.ICTIOl~ liATERIALS STANDARDS INSTITUTE. INC., E-210 'R()UTE #4, PARAMUS, N.J. 07652 !~ o. 6 3 3 llovernber 14, 1978 REGUL\TMY ./\G.!:IONS CONCEmU:1G ASBESTO~ Over the past several u-2eks the Institute: has received correspondence coa.::.ei.:H"l.Uf:. activity by FederP.l reruliltory -~~r-:nci.e::; DG concern::; nsbestos. Some of these activittes are descri.bed in th~s bulletin. OCCUPATIOHAL St.FETY N~D HEALTH P..DHINISTI'v\:'Im! (OSHA) DIRECTIVE AS C~HCERHS EXPOSGRB A7.~1) UEDICAL EXAUINATI01:1S I have copied fro~ an Asbestos Infornation Association "He"1s and I~otes" of October 31, 197fi concerning this subject. In essence, OSP.A issued a directive to its Regional Ad!llinistrators concerning conpliancc ~.Jith the medical examination requirements of the standard. This is an attempt by OHSA to ans~~et the q:uestion as to lvh:tt consists of exposure to airborne concentrations of asbestos tn the Horkplace. They are adiTisin3 their Regional Administrators that concentrations of 0.1 asbestos fibers (or mo~e) large-:: than 5 ~icrometers per. cubic centimeter Hill be considered e-xposure to asbestos fibers. If these e"posure levels arr=. 0.1 or more, medical examinations are required. You may ~-rish to refer to the text as for.uerdcd by the .'-\Sbestos Information Association. COHSUHEP. P:'.ODUCT SAfETY COI~iiSSIOH (CPSC) !1EHORfJ-!Dilli CO:.lCERlailG 1\SBESTOS lH COi1SUlill!l. PRODUCTS ~-~r. Jim ~eis of John..<>-EanvilJ.e sent along a Consumer Prodl.l~t Safety Commission memorandum concerr;.in3 asbestos. This report based j_ts recoooneudations on the Kearney report ~reich ~as made to identify consumer products containing asbestos. In tllc }(cl3.rney rc,rie:: of procucts it ''"L:l their conclusion that friction mater:i.als ccnt.a:iid.nr:, asbestos are not l:i.kely to be considered a consumer product becaus.e th~y are not under th~ juriedictiC'1l of the Consumer Product Safety Commiso:l.on. This CPSC mcmoran_pum concentrated in the areas of bull~ .asbestos fiber and dry mix texture paints containins asbestos for consur.:cr usage, T:'1i~ report also discussed exposure to asbestos fror.~ ccilin<js :md other structural surfaces. Friction nn.te.rials vmre not r.~arl~ed for further Consumer Product Safety Cmr.mission study. ElNIROi::riiEilT!lL PROTF:C'l'lO!T AGE~JC~r (EPA) f'u~VIEll Qi-1 ASBESTOS The Environmental Protection Agency's office of toxic substances he-a conclud~d a len2;thy rer.ort or:. asbestos. Their concern. Hith asbestos is any area \\There asbestos usa.ge could affect environmental e>q>osure by air, \o:ater or food, Bral-:.e linin!>,S were rnentioned several times in the re:port as regards air and Hater exposure. There ~res no ner:- epidcmiololdcal data as concerned asbestos exposure to friction materials {\'orkers. There ue'::e references to brake linins '-1ear beinB a source of asbestos in ar.ihient urban air. and it mentioned possible exposures to individuals fr~ asbestcscontaininB productG in .automotive supply stores. FMSI 06971 BULLETIN 116 33 -2- November 14, 1978 TOl~ards the end of the report there Has a comment to the effect that if monitoring determines that &sbestos fibers are emitted from brake linings in significant amounts that the Toxic Substances Control Act could be used to control the asbestos content of brake linings and to promote safer effective substitutes. It noted that an interim step could be to require under the TSCA that manufacturers report any research results on substitutes. This report is in excess of fifty pages and it is being distributed to the Asbestos Study Committee for their revi~v. If a member were interested in a copy of the complete report the Institute l~ould be pleased to send one on request. The foregoing items are sent along as a matter of information to the Jliembership. E. H. Drislane Executive Director CC: Active Hernbers - List C Licensees Regional Hembers (U.S. Dues) FMS\ 06972 :F'RIC1'ION MATERlAI..S STA~"J)ARDS INSTITUTE, INC. AsBESTos ExPosuRE AND MEDICAL ExAMINATIONs Matter of employers providing nedical surveillance program as set forth in OSHA asbestos standard for occupational exposure to asbestos dust has been an unsettled subject for several months (N & N Feb.). At issue has been lack of clarification of the term " ... exposed to airborne concentrations of asb~stos fiber ..... as it relates to requirement for medical examinations. Both U.S. Court of Appeals for District of Columbia and Occupational Safety and Health Heview Commission have ruled that current asbestos standard requires such examinations be provided employees exposed to airborne asbestos in any measurable concentration. These decisions related to a Jan. 1977 policy letter from OSHA to an individual employer which stat.ed medical examinations would be required only when emplcyee exposures to airborne asbestos exceed 0. 1 f,/cc. A three-me!nher OS!Ui panel was designated by Asst. Secretary of Labor (OSHA) Eula Bingham to study problem. AIA/NA requesi.:ed OSHA in Mar. 1978 to provide workable and reasonable interpretation at earliest possible date. On Oct. 11,1978, OSHA issued Program Directive 1300-16 to its regional administrators providing uniform in- spection and compliance procedures for medical examination requirements of the asbestos standard. Principal actions in this directive are: . The term ''exposed to airborne concentrations of asbestos fiber_." is administratively interpreted to mean ''exposed to a minimum of 0.1 asbestos fibers larger than 5 mir.::rometers per cubic centimetE~r of air . . . " f.1edical examina1.:ions will be required for any 7 to 8-hour time-weighted average concentrat.ion of 0.1 f/cc, or for a greater concentration. An OSHA spokesman has advised that agency's Oct. l l directive is considered internal policy and, further,directive does not amend the asbestos standard, but rather provides an administrative interpretatio-D of the standard for use by compliance officers. FMSI 06973 Reprinted from Asbestos Information Association News and Notes of 31 October 1978