Document 7MEGOmbp6KgGy9JMgmN7YrmbB

October 5, 1976 N . Mr. Marc Collins Airflex Plant Eaton Corporation '9919 Clinton Road. Cleveland, Ohio 44111 Subject: Airborne Asbestos X* v V v:v: .... o Dear Merc, , . . ,f\"i XX . I have your letter of October l, 1976 arid vill'^dbmmep't' On.-;it and the other topic or our conversation, possible a^6it<is :dusfc. ^xposure by people who change or grind brake linings .y-v. ` ' '" Taking the' last item first., I can offer^tho following facts and opinions. ..... ' -J* \ i'?' The August 14th, 1975 issue of|the^all (street Journal carried an article' that is the cause of a lot ofr,donterrjation frora people who are exposed to the problems associated with the.,use of asbestos. A copy of the article ia attached for vybUr 'review.." In the article, a NI<$H;?apokeaf&fiin tHakoa a statement that X do not agree with and is the baeis'^for a .XbjX'of unnecessary fears regarding the use of asbestos-containing products.. In the second paragraph of the article, HEW repgftedly ..aaid )tbat, "garage personnel who change or grind brake lininga;%rb being exposed to potentially hazardous levels of airborne asbef.to^-." .If statement had been made that, "garage... personnel who ehahge andp^lnd brake linings --" rather than, *--- who ' change or grlj^bfake.linings--", I would not object. As written, it, Implies th&t^tiab Berb^.Ac't of changing brake linings exposes personnel to high levels of-airborne asbestos. This, in my opinion, is not the case as|:I:4iill ahoni later. However, I cannot disagree that the act.:of grirxli'jn^.a^bes.to^'^Contalnlng products may; cause some liberation of ...' asbeatos, ,v&Lia. may become airborne and could lead to people in the - iaanf^ate^araa 'to become exposed to potentially hazardous levels of airborneasbestos. More about this later on. . ,;ln/the next to the last paragraph of the article, the information la,. glven (and I do not disagree with It in general) that aabeatoa dust "6e generated where truck and bus linings are ground to fit brake . or are resurfaced after use. However, I do disagree with the ( J 1I SCF-EC-1611 FAW 11855 .Marc Collins ' -2- October 5, 1976 statement that, "the changing of asbestos brake linings for automobiles was also dangerous because mechanics usually use an air hose to blow out the loose dust after removing the old lining," The implication here la that the brake lining debris that is trapped in the drum contains significant amounts of asbestos that can become airborne after being - blown out of the drum by the air hose. This too will be touched upon shortly. . Exhibit 1, copy attached, is an abstract along with the reference' ..... regarding brake lining decomposition products. Mr. Lynch, the E^ufchor, '{ was a member .of the U.S. Public Health Services when he prese^t^ his finding in May, 1968 that the high temperatures involved in biding ^ converts asbestos to other minerals and that the very amail amounts; of., free .fiber appear to be an inconsequential health hazar^.i J ' f'^'v . 'V V t. Exhibit 2 is an abstract of a submission made by Caterpillar Tractor Company to the Illinois Pollution Control Board omOcbobe.r"49/,^ 1971 as its documented argument against the banning of ashestoa-odntwining friction materials. Beginning on Page 13, a section titled "B. Brake Wear Products" is pertinent to our present discussion." :'Here, Caterpillar draws laforroation from Mr, JerepiSah Lynch,wh"o ;publiofied-' an article in tha Air Pollution Control Association JourhaT entitled "Brake Lining Decomposition .Products". {ThiaTmay haye;been part^df the study referred to in Exhibit 1, but the findings Bi^^je^rt^d|^^greater detail.) The gist of the article is that little*oq. no ffh^'fgsbes.toa la present in the dust taken from drums and only ii%igjiificahtJamount`s of asbestos may become airborne during braking. operati<^. (Incidentally, we do not know if there even was a page-,.lA-in this ^presentation. The cpnti;J7uity of the thought content suggests' that-sthere never was a page 14 -- that - an error occurred in numbering the pkgea.) '* * V> .*;v * Exhibit 3 is an EPA supported, long term project that was presented in May, 1973. The rodst~info^ative figure from this comprehensive article is that leas than.jth.,3% of"asbestpa fiber originally present may be emitted to the atmosphe.r^sCduring brake life, the remainder will have been con- . verted to other^miheralHproducts. .... 'Sj The^iiifohoatipnirpresented in the three exhibits leads roe to the ines^pabi^'-con'olUsiSn that if there were significant amounts of free asbestos generateclduring braking that both OSHA and EPA would tyave made all.ffdon<ibrnad',':aware of this. On the contrary, all experimental data points' to.tfte fact that insignificant amounts of free asbestos is generated |>d/eijt.hej\eraitted to the atmosphere or trapped within a brake drum and :'the amount is not large enough to raise the fears of even the most oilitant^of the anti-asbestos forces. . -- . far as J. W. Penney 4 Sons Company i3 concerned, ray thoughts are ttiit vary little, if any, asbestos is released to the air during clutch imgageioant. While there may be some dust or smoke- observed during severe Marc Collins -3- October 5 1976 clutch (or .brake) engagement, the bulk of this is carbonized material from the binder or non-aabeatoo mineral material from the fillers. 'While this friction material may contain about 50% by weight aabeatos, the high temperatures Involved in braking or clutching will cause the asbestos to be transformed Into a non-aabeatos mineral. it is my opinion that If OSHA had any Information suggesting that the amount of airborne asbestos liberated during brake or clutch opera tions being at potentially dangerous levels, they .would have monit^r.^d this la the Great Northern Paper Company plant rather than asking them,;> \ Vthe question of how much la released to the air during clutch/operatlon.;.. In summary, my opinion after reviewing all facts available to' k / is that for all practical purposes, there is-no measurable:, amourit- of1 airborne asbestos liberated during a clutch or brake eQg^gemerit':;ahd this should not be a cause for concern among people using your bifak^s'hnd clutches. - In Mr, Rose.now'o memo to you dated September*7, ,.197.J he states that some countries in Europe are striving to/<?utlaW; th use of asbestos, I have not heard of this before. Would it-.b^^pb^aihi'a'for Mr. Rosenow to get me some .information concerning thfa^:`' P'yp'~ _ v | I trust that the information ieradequa tkj fopyour intended purpose. If I can be of further assistance^"jj&ease let -me know. - Best regajrds, to / E. J. Sydor General Manager '4 * r?-``