Document 70OzonoEQedjdeRakqykEk7pE

P-ZPCHT OK FrSI ASBESTOS STUDY COMMITTEE ACTIVITIES The Asbestos Study Committee was forced July 1971 with the assigned purpose to review and coomsr.o on rules and regulations promulgated by state ar.d federal governments concerning as'oesocs and its applications. ' The first Committee nesting was held September 15, 1971 2nd was. chaired by Dr. . ?. Stef! of Raybestc s-ivanhattan, with members, from Wbrlcbestos, Abex, Bendix,.. and Carlisle Corporation and J-I-I present. The following items were reviewed and/or discussed: (1) relationship with Asbestos Inforsation Association/North America. (2) Proposed Ulino: Regulations. (5) Vehicle friction material enission test program to be conducted by Bendix under- EPA ccntract. (4) Monitoring for airborne asbestos fibre. (5) Districation and circulation cf literature on Asbestos/Health subjects. ' ` The purpose of the Asbestos Study Committee. was restated as follows: "to-gather and dessinate to its members inforsation about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environnent(particul&te esisslo: 2nd to draft coar.ents relative to proposed regulations in defense of reasonableness." The following is a list of the actions taken by the FKSI Executive Secretary on behalf of the Asbestos Study Cosnittee during the reminder of 1971: ' ____ September 30 - Issued icinutes uf first Coaalttea resting with letter commmtinc cn proposed Federal EPA and Illinois emission standards.- October 25 - Issued bulletin and further information on Illinois hearings. ' Kovember 10 - Issued information on membrane filter monitoring method. November 14 - Issued bulletin on revisions to Illinois and. Federal EPA proposals. December 6 - Issued information concerning final draft of proposed Illinois regulation, proposed EPA enission standards, and Federal Department of Labor Regulations on Occupational Exposure. .* On January 26, 1972 arrangements were announced for Bill Reitze of J--M to conduct an instruction session on asbestos fibre monitoring at Fl-SSI headquarters February 10. On February 11 this session -was presented to nine attendees representing six member . esmeanies. . "hs -second Asbestos Study Committee meeting also -was held on February 10 with I. - H.. "Weave: ?.ayh2 sous-Manhattan, acting as chairman and members representing Worlabestos, J-H, Bendix ar.d Carlisle attending. The following items were covered: 1. Review cfAIA/NA currents regarding GSHA meeting in Washington on January 26. 4. Review cf proposed OSHA asbestos standard and comparison with British standards and regulations. ' . > Review f British Friction Material Council comments cn Illinois standards, was reso ved zz forward to 2FKC copies cf minutes of future FKSI Asbestos -2s meetinzs. ' .-.ecc--` nation made that the Fl'Sl Asbestos Study Committee maintain se Tf.. Airfi/iwi Rsviewe: background ana expected thrust of OSHA _nd Z?A regulations. PLAINTIFF'S EXHIBIT WV-06061 / SCF-ALLF-04011 7. r.eccmoended future course for Asbestos Study Committee. The fcHoving is a c-----y of- actions taken by the Executive Secretary during the first ' half cf 1972 in regard to Asbestos Study Committee natters: February IS - Circulated Bulletin L27 regarding various standards for asbestosdust ensure and control. This included copies of the January 12 Federal Register announcement of proposed permanent CSHA standard for asbestos control in the work place. February 13 - Issued Bulletin L2S reporting on February 10 demonstration by Mr- Reit of membrane filter monitoring method. . June 1 - Circulated announcement of Microscopy Seminar scheduled by McCrone Research Institute ir. Chicago week of June 26. . June 6 - Circulated supplementary information received from Illinois Institute - of Technology Research Institute regarding friction material emissions and issued tentati* schedule for third Committee meeting to be held late July or August. ^ 'June 12 - IiTued 'annnurcement of OSHA permanert'`standards'oh asbestos dust exposure as published in June 7 Federal Register. t ~. ~~ . The latter item has been rather intensively studied by your Chairman, by AIA/fcA, and no doubt also by concerned individuals in practically all companies represented in~ FKSI. The consensus appears'to be that the new regulation is stricter than need be-in respect to the future TLV of 2 fibres per cc, but is more lenient than was expected in regard to many other important matters. Major changes between, the new regulation and the earlier emergency standard and earlier proposed permanent regulations are as follows: 1. Automatic reduction of TLV to 2 fibres in four years. 2. Use of protective clothing required above 10 fpcc ceiling limit. Change rooms, dual locker facilities, and speciallaundering and clothing handling procedures required. _ ._ ___ ... ___ 3- Monitoring required at least every six months at operations exceeding allowable 1. physical exam, and doctor's approval required before assigning employees to jobs requiring use cf respirators. Elimination of references to !'cancer" and "danger" on signs and labels. Labeling eliminated for mroducos containing locked-ir. fibre. 6 ecific restrictions on ''dry sweeping" and use of compressed air for cleaning iminated. ical examinations, including pulmonary function test's,required annually for emolcyaes exocsee to dust. 1 and monitoring records required. Employees exposed to '3 notified ir. vritir.r. c. "..asts containing only lockedi-in fibre.need not be sealed nor labeled. --Oft -ericas difficulties are expected in achieving compliance with.the new regulation by miners*, textile manufacturers, and insulation fabricators and installers, it appears ' to =* that host friction material manufacturing operations not relying on textile technolog should have relatively little, trouble, although some dry mold type friction operations may also pose proclans. .... . -- -..... -- -- - - ------ Perhaps of a acre serious nature is the potential threat of banning of asbestos in."friction materials, partirclarlyriniautoTOtive-vehiclesr t eliminate- eraissions-frou wear deteisri- lt is doubtful that any further action in this direction will be taken until results of the comprehensive study by Sendix Corporation for EPA have been- announced. ' I have been advised that.this study, originally to have been completed this month,' now is not expected, to be finished until late this year. .' Yost of the difficulties that arose in this study to date have occurred in connection with the gas collection phase of the program. Since the study involves collection and analysis of g aseous emissions as well as particulates, precision rotary seals and gas collection systems had to be developed and evaluated, and this has necessitated extensive and time consuming engineering design efforts. . Another vital E?A program also is running behind schedule. That is promulgation of the permanent regulations- and standards for asbestos emissions to-the ambient- atmosphere*^-------- . 7 have been advised by the EPA Hazardous Pollutants Branch that the, earliest- date .these . standards are ejected to be issued is-the beginning of August, and-thegr eodld be-delayvd - until early Sectember. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatins. Significant changes are expected in the sections applying to milling and spraying operations. Probably the only significant change between the proposed regulation and the expected final regulation as far as manufacturing operations are concerned is the broadening of specifications oh fabric filters and vet dust collectors. This should be helpful to industry in permitting somewhat rare flexibility in dust collector selection and application. ' . Before closing, I should like to recommend a few of my thoughts and suggestions that I have received frca others concerning items that should be considered and reviewed by . the Asbestos Study Committee during the following year. 1. Umifcrn'interpretation of OSHHTstandards~ Liaison with JLLff/fol~vilI' be . ~ heirful irrthis. 2. lateminstioa cf technological feasibility of achieving both 2 and 5 fibres . throughout the industry. . '' 3. 12tsmir.ition cf the overall effect on the friction material industry of the CSKA standards. . 5. leveltpnsnt cf guidelines, aids, and educational progress to help customers contly with the.regulations. .. 6. Investigate a suitable standard method for analysis for asbestos in brake lining v,-22r debris. . Isvslop nsthtds and recommendations for safe disposal or recycling of friction naterial grinding vaste. l. as closely as possible medical and occupational health research concerning asbestos and asbestos-related diseases and determine whether P/31 or its member .. companies should-help.sponsor or otherwise suppobt* work..of_this_nature--, . J-T <1 -k- * AH ol these subjects probably vill be reviewed at the third Asbestos Study Ccmittee seeling to Se scheduled within the next aonth or so. please advise us,of any additional iters you or others in your organization may wish to add to our agenda for this up- coning nesting. . . . ' .. Respectfully submitted, X- H. Weaverr Chalxmart I