Document 85O2eEg627Z62eYkYBx3awyZB

Inter Olfice Engineering and Research Stall May 1, 1980 Messrs. D. D. Baker D. L. Block, M.D J. H. Douma P. D. Fadow W. H. Fike S. M. Frey S. Gratch D. F. Hagen M. H. Hamburg G. C. Hedges C. D. Lauer E. T. Mabley J. H. Ogden J. A. Pflug H. W. Potoczak P. E. Prill J. G. Rivard V. H. Sussman J. D. Velte cc H. P. Freers G. 0. Keutgen H. A. Nickol Subject: Carcinogens Task Force Report to E&R and M<5cS Subcommittees The Task Force on Carcinogens in the Workplace was established by joint action of the E&R and M&S Subcommittees, with representation from affected line and staff activities. The Task Force was chartered to coordinate plans and efforts to identify and quantify carcinogenic substances in use; to develop action plans, take aggressive steps and set targets for elimination of as many carcinogens as possible; and to organize to identify substances systematically. The Task Force will present its report to the Subcommittees on May 27, 1980. Attached is a draft of the report. Your comments are requested by May 9, 1980, so that we may meet the timing of the several pre-reviews scheduled. Attachment J. W. Durstine 8004 0122 EXECUTIVE SUMMARY CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established by the Engineering and Research and Manufacturing and Supply Subcommittees to identify carcinogens and quan tities in use, set targets for elimination ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify substonccs systematically. The Task Force assignment responded to evidence that conccr may be a serious occupational concern end to the Company's and public concern with regard to protection of the environ ment and public health. Additionally, the Company has been subjected to a growing number of laws which regulate-material use, transport, handling and disposal. In summary, internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 assigned responsibilities within the Company. Past Company Actions Since 1977, the Company has removed lead chromates and molybdates from paint (except special order), "Tris" flame retardant from fabrics and instituted controls on asbestos, including a Vehicle Engineering directive that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). Spraycd-on fireproofing has been asbestos-free since 1969 for new and reworked construc tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to miinn|immize hazards from paint-related chromium compounds. Carcinogenic Substances The Task Force has'idcntifiecKsixty^seven (61)'carcinogens in use fin the automotive industry. A i 1 Twenty-six'(267)of those are currently regulated byOSHA; the .balance Ijayfc-been proposed v U 'n ^prjlcw regulation. More restrictive standards have been proposeSTor someof those sub-' stances currently' regulated. Thirty-one (31) substances are reported to the Michigan - Department of Natural Resources for computation of water surveillance fees. Michigan y plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur rently required to be reported in the other states. The list of carcinogens was prioritized by the Task Force according to impact on the Company to identify the top eight (8). The top three of the eight priority substances, asbestos, chromium compounds and benzene, were . examined in detail. ^ - Asbestos is used by the Company primarily' in vehicle brakes, clutches, gaskets and for nonproduction roofing, millboard aryl core/mold-making materials. Medical evidence links inhalation of asbestos du/t to lung'cancer, mesothelioma and other diseases. The present OSHA lirrdt is / fibers Per cc f air (2 million fibers per . cubic meter) whichj* propgosed tsjfeor/ducSiTtq.Ojl f/ccas early as this years A/'c'f n Chromium compounds are used primarily in paints and inks foe production and nonproduction use. Medical evidence links hcxavalent chromium>mpounds to lung cancer, liver and kidney damage and other diseases. The present OSJ1A limit is 5_ per m3 of air, wfricH4a prepeoed te w ' " -------~VTtrsr~-HifS Htect'*' <'? to 1 m&n* t> a Benzene occurs primarily in coke oven operations as a by-product. It is a residual constituent of solvents, primers, adhesives, Rubricating oils, fuels and hydraulic^ ^fluids. Medical evidence links inhalation andcontacT'wrfTT benzene to leukemia, blood disorders and other diseaseSj/DSHA has propooed animit of 1 ppm^m-ftir time weighted average 8 hour* v-'yjCcCiu,. r - - -- . ~ 1___ ( ->^'0 Specific lists of bulk materials and parts for production and nonproduction use nave beenTMA developed. A new computer data base is being developed, Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid dcntification of ea^cjnpgctyj'.pp Heat ions (2nd quarter 1981). The engineering release system has been'audited' and is' being updated to extend materials identification to all parts, roduct Engineering Procedure PEP 3-189 has been rewritten to require systematic review f suspect carcinogens and input to the data base. U- -><- V p .*< 8004 0123 8004 0124 -2- EXECUT1VF. SUMMARY (Continued) Strategy and Workplan The search for asbestos, chromium compounds and benzene defined the number of ports and materials containing these substonces os listed in the table below. Where possible, the applications were divided into three groups: A - Known substitute material without major redesign, B - Known substitute material with major redesign and C - No known substitute or advanced engineering required. The data is directional only. There remain many suspect applications which require time-consuming analyses for identification. _____ Bulk Materials nnd Parts Asbestos Chromium Compounds Benzene Production ____ A B e Total 34 49 22 - - 25 * - 15 105 25 15 __ Nonproduction A B C Total 8 . 8 98 81 34 213 3 - 58 Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three carcinogens by Job. ____.ISflS, in light of competitive and regulatory pressures, and Company experience. Where elimination cannot be contained, institute controls on design, process and exposure. It is judged that the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing parts and materials. For those applications requiring major redesign (Group B, e.g., drum brake linings) the elimination timetable would have to be adjusted to reflect Company cycle plans although G.M. has slated an intent to eliminate asbestos by 1985. Finally, where no known substitute exists (Group C), advanced engineering will have to be completed before a elimination timetable can be established. A generalized workplan has been prepared on the basis of the evaluation of the carcinogens already referred to. The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle acti vities and the Manufacturing and Supply Staffs. It is judged that approximately a year is required to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is judged that one additional year would be required to implement the most feasible product actions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro grams. Recommendations Achievement of the recommended strategy requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force recommends: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2. Assign Carcinogen Program managSl) control responsibility to Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables ' for the/fifxhown carcinogens for review and approval by the subcommittees. (The Task f Force nfis requested General Managers and Chief Engineers to recommend directional * timetables.) .4 Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job HI, 1985^ 5. Request that NAAO Product Engineering Offices and Manufacturing Staff present to the subcommittee specific action plans and timing for the Group A applications identified. 6. Provide advance program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). 7. Adopt as the Company carcinogen listing the^7 current OSHA-regulaled .and proposed. . Category 1 substances. Establish the top eight priorities proposed by the Task Force as Company priorities. Engineering Staff - E&RS Manufacturing Staff May 2, 1980 DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2, 1980 8004 0125 OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production Nonproduction . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Asbestos, chromium, benzene . Asbestos Summary . Chromium Summary . Benzene Summary . Carcinogen Search List specs, and parts - Identify items having no substitutes - Identify substitutable items .. Eliminate when redesigned or reordered Develop substitutes for others (advance engrg. funding) . MATS . Carcinogen Search Results . Carcinogen strategies . Generalized Workplan . Proposed Chemical Substances Control , Proposed Priority Actions Exhibits . List ofr67" Carcinogens . MATS \ / Appendices . Asbestos-containing parts and materials . Chromium-containing parts and materials . Benzene-containing parts and materials 8004 0126 DRAFT FEDERAL AND MICHIGAN ACTS REGULATING TOXIC/IIA7.ARDOUS MATERIALS HAVING IMPACT ON THE COMPAN V fiouke 1 Regulatory Act* Packaging A Stacking Occupational Solely end Health Act - 1970 D.O.L. (OSIIA)* --" r Federal Ha7.ardous Substances Act - 1970 .. Maaardous Materials Transportation Act - 1975 D.O.T. (IITMA) . Poison Prevention Packaging Act - 1970 Toxic Substances Conltol Act - 197$ E.P.A. (TSCA) Consumer product Safety Act - 1972 Resource Coaservation end Recovery Act - 1976 E.P.A. (RCRA) I' Waste Management Cleon Air Act end Cleon Woter Act Amendments - (CAA) 1977/71 E.P.A. ( . ^Haiardous Waste Management Act - 1979 Mich., P.A. 64 tMichigan Act 293, P.A. - 1972 Michigan D.N.R. (MDNR) ! oLh^I S7sf)t P/AfvS (/*} tfiSZ/j C4/0J<(c) ' , fhicHtt*tier $1/ p,A Albert Solid Waste Management Act - 1978 Mich., P.A. 641 yV a Expected to be revised during 1980, to lower permissible exposure limit from present 2.0 fibers/cc to 0.5 or 0.1 t fibers/cc of air. FIGURE 2 CORPORATE STAFFS RF.SPONSIRHJTY FfUfcTaXjC/HAZARnOUS MATERIALS -EOfTtECTIVE B-10T)_^ Stiff ESES Responsive Activity SSECO MPO. STAFF SAFETY Plant Engrg. Office Mfg. Engrg. A System* Plants EARS Frog. Anal. A Matts. Engrg. Research Staff SUPPLY Trans. A Traffic OSHA TSCA REGULATORY ACT . RCRA * State Solid/ . Hat. Wastes HMTA Compliance /Reporting CorUpBEnce Reporting Compliance Reporting 5 A is- A P i- Identification of Controls Monitoring Material Inclusion in EPA Inventory Chemistry in DOT Label Data Base in Data Base Enforce Controls Facility Controls Non-Prod. A Prod. Development Matls. Review Process Controls Non-Prod. Matls. Development Review Process Controls Non-Prod. Matls. Implementation Review Disposal Meth. A Fac. Dev. Waste Chareetcrizatlon Packaging Storage Material Characteri sation Facility Control Implementation Develop new metis., mfg. processes. A measurement devices. Production Metis. Review Compliance Reporting CLEAN/UR" MICH A WATER..- DNR ; Compliance CoTnpUanA'e Reporting Reporting Monitoring Chemistry in Data Base Facilities Rouge ConsolDevelopment idation Process Contr. Development Permit Reporting Usage Reporting -If* 8004 0127 May 2, 1980 DRAFT 8004 0128 CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established during the 4th quarter, 1979 by joint action of the E&R and M&S Subcommittees. The Task Force Charter was to coordinate plans and efforts among Company activities, to identify carcinogens in use, and eliminate or control them in future products and manufacturing operations. Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendices. Background Scientific investigations into the occupational factors involved in the development oi cancer, conducted in recent years, have provided evidence that occupational related eanoer is a serious concern. It has been estimated that in coming decades up to 20% and pertraps as much as 40% of cancer in the U.S. might-ho associated with occupational fapjRjrs. Accordingly, Personnel and Organization Staff, Employe Health Service?,'has `exerted "a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. Public concerns relating to the control of toxic/hazardous materials, are shared by Ford, due to the Company's regard for public health and the protection of the environment and potential impact of legislation on our products and manufacturing operations. Also, the right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Resolution of workplace exposure concerns relating to the management of toxic/hazardous substances, materials, and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques as well as by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines up to $25,000 per day, and a citation normally consists of multiple related violations. Litigation is also a growing concern. At present the Office of General CounseLha_thre_e j&uits pending, involving deaths allegedly due to the inhalation of carcinogenic substances. Rome Workman's Compensation expense has also been incurred. The greatest potential for major expense, however, lies in the possibility of punitive action by the court. < Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. a Federal Register 45(15): 5031, January 22, 1980. -1- May 2, 1980 draft FIGURE 3 PAST COMPANY ACTIONS Production . Removal of lead and chromium from paints. . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. Nonproduction . Removal of asbestos from, - Structural fireproofing - Thermal insulation - Molding compounds . Substitution of vacuum for air blowing in brake and clutch maintenance . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations 8004 0129 - 2f - May 2, 1980 DRAFT 8004 0130 PAST COMPANY ACTIONS Production Materials In response to OSHA regulations in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardan/treatment for fabrics, was removed during 1977, in response to an inquirWby NHTSA. In response to initial OSHA regulations in 1972, the Company BeterrTurie3~plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. Car Engineering released a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2CG0 Series of maintenance lubricants with the lead naphthenate free M-2C142 materials, and deleted the use of asbestos bearing molding compound at Sheldon Road. In 1978, an adhesive used at San. Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories was revised to eliminate benzene, the volume of lead-chromate employed in vinyl plant operations was reduced and ventilation/protective measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used" in painting. (The substitution of non-hazardous paints is targeted for Rfmeo for late 1980.) /V. 5-^ A + /'' * ' y^j -2- May 2, 1980 DRAFT FIGURE 4 TASK FORCE CHARTER The Task Force was chartered by E&R and M&S Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts to: 1. Identify substances in use (OSHA Categories l and II). 2. Determine quantities used (for materials regulated by Michigan Department of Natural Resources). 3. Set targets for elimination of as many Category 1 substances as possible. .4 Take aggressive steps to find substitutes for as many Category I substances as possible in anticipation of government regulations. 5. Develop a policy and action plan for eliminating potential carcinogens where possible. 6. Organize to identify substances systematically. FIGURE 5 USAGE OF MICHIGAN CRITICAL MATERIALS AS REPORTED TO MTiylADdFSTED BY THE PLANTS IN THEIR MDNR REPORTS) 3004 0131 ________Material^ Acrylic Acid Lbs, of Usage 251,707 PPV - Point Principal Users Acrylonitrile 641,133 PPV - Paint Aniline 90 MCC, Dbn. Glass, T&C Sterling Antimony 830,571 PPV - Vinyl Arsenic 11,157 T&C Vandyke, PPV - Vinyl Asbestos (not reported as a material - present in articles only) Benzene 385,028 Cadmium 3,311 Chromium 81,377 Cloroprene 24,676 Cobalt 210 Copper 321,704 Cyanides 923,069 Dichlorobenzencs Formaldehyde 2,542 488,965 Hydra zene llydroquinone 130 1 Hypochlorite Lead 15,841,758 626,027 Lithium 123 Nickel 126,624 Phenol 5,839 Selenium 127 Silver 25 Silicon-Dioxide Coated Lead Chromate 2,317 Styrene 1,413,986 Tetraeloroethylcne 1,095 Thiourea 18 Triaryl Phosphate Esters 160,022 Trichloroethylene 91,849 Vinyl Chloride 118 Zinc 1,085,724 Michigan locations not reported to MATS: Detroit Industrial Engine Research i<. Engineering Center Research - Glendale Troy - Tractor AAD - Dearborn Assy., Gen. Service PPV - Vinyl PPV - Paint, EED - Ypsi. AAD - Utica PPV - Saline AAD - Dearborn, PPV - Saline, MSD - Monroe MSD - Monroe FTO - Highland Park MCC, PPV - Paint PPV PPV - Vinyl MSD - Monroe AAD - Wayne/Deorborn, PPV - Paint ED - Northville, T&C Sterling MSD - Monroe, T&C Sterling Mich. Cast. Cntr. T&C Sterling T&C Sterling PPV PPV - Milan, PPV - Vinyl AADGO, Mich. Prov. Grnd. PPV - Vinyl Steel. T&C Sterling EED - Rawsonville PPV - Vinyl PPV - Paint, AAD, FPSD, FTO Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixon Assembly - 3f - May 2, 1980 DRAFT TASK FORCE CHARTER To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate the use of these substances and initiated'plans to find substitutes for substances ahead of government regulations./The complete Task Force Charter is shown in Figure 4. / In 1977, OSH A issued a draft policy listing-numerous chem/cals that could be classified as "Category I" and "Category II" carcinogens. According to OSHA's draft policy, Category I substances are known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are so classified where data is suggestive or carcinogenicity in test animals and humans, or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. A listing of/67Category I substances in use in the automotive indus try has beern5repared. (Exhibit I). For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used asbestos only as articles, 81,377 pounds of chromium compounds, and; 385,028 pounds of benzene/gv^>~-A**A/vl^ Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances were examined in detail. r s V 8004 0132 -3- May 2,1980 DRAFT FIGURE 5 TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES Substance 1. Asbestos 2. Chromium Compounds 3. Benzene 4. Cadmiuni/Codmium Oxide 5. Coal Tar/jVolatiles -- Bcnzo (a) Pyrene Benzo (a) Anthracene; ^ 7. Beryllium 8. Trichloroethylene Occurence within Company Friction materials, gaskets, sealers Chrome plating, paint pigments Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions inyl Aluminum foundry operations Degreaser Current Exposure hi m i ts 2 fibers/cc ) 0.1 mg/m0 10 ppm 0.1 rng/nv 0.2 mg/m3 Jh^mg/rrn3 \ ^None- g-stablistird 2 pg/m 3 100 ppm 8004 0133 - 4f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that are contained in materials used by the Company or generated as a result of Company operations, is shown iiCFIgure 6^ The current exposure limit for these substances is also , provided/^tt-is-rnTportant to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed are presented in order of priority as established by Task Force consensus. The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3, respectively) as test cases because they are considered by Operations and Staffs to have the greatest impact on the Company. NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to eliminate/control these materials, in a practicable manner in anticipation of Government regulations, were formulated. A plan to extend the strategy formulated for asbestos, chromium and benzene, to as many Category I substances in Company materials as possible, was established. 8004 0134 -4 - May 2,1980 draft CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer . Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Pibers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Pibers/cc) 0.1 0.5 5 j 8004 0135 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core & Mold Making Materials Safety Apparel - 5f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES ASBESTOS * 11 j During the past several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHA, is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group^and OSH A~have-recommended that limits be tightened to as Jow_ as,. 0.3 in 1980. Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban on all non-critical uses may occur as early as 1985. Sr & -y 8004 0136 -5- May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds X X X X X Other Chromium Compounds X X X X FIGURE 11 Exposure Li 2 5i-vg/r'n ** FO Ilrwoc&iifly 52 ug/m a/ C< I >7 ftp Exposure lriftnt~(NXQSfU ^ lW/m3 K-ftfitWw :pg/m3/15 Minutes . .-'A v-'.-'j : 'me 4/2-of above */ios/i 2t'c f,t' (>-">e & 7 h-'* Aim,r c nf4, J ^ a) Measured as chromium. No differentiation is made regarding valence or type^ of disease due to exposure. FIGURE 12 Classes of Materials Containing Carcinogenic Chromium Compounds Production Topcoat Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks - 6f - May 2, 1980 8004 0137 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (e.g., sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of their handling of materials, primarily in paint making and application. Protective measures are employed to assure regulated limits are not exceeded. 7'he current although NIOSH has recommended lower levels . ,, materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. 8004 0138 -6- May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE FIGURE 13 ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENE Contact Dermatitis Eye Irritation Narcotic and Centra) Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyserasias (disorders) ||( - \ Time-Weighted Avg. 'GoiUng ........... FIGURE 14 EXPOSURE LIMITS Regulation /Opf>*i S-ppffl/15 min-. ed ^ 1 ppm/8 hr. / 1 ppm/ 2hr. / 'Sample collected at 1 liter/minute FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealers Rust Preventives Thinners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases and Oils Lubricating, Hydraulic 6c Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids 8004 0139 - 7f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE Benzene is aj leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, and employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSH A standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no possible way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as sn unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. (See Exhibit III) -7 - May 2, 1980 8004 0140 DRAFT CARCINOGEN SEARCH FIGURE 16 . Carcinogen Identification Reviewed all likely material specifications and manufacturing standards. Reviewed the IHdcT CATALOG of Hazardous Materials. * Reviewed NAEPIS to identify Industry Standard Materials Reviewed the Michigan Critical Materials data Surveyed previous assessment of production materials. Communicated with material suppliers. Analyzed the production material list (PEO). . Carcinogen Usage Reviewed the NAEPIS cross-reference for production material/part usage. Reviewed processes/uses involving the substances in nonproduction materials. Confirmed the NAEPIS usage list for completeness/verification. MATERIALS AND TOXICOLOGY SYSTEM FIGURE 17 8004 0141 - 8f - May 2, 1980 DRAFT CARCINOGEN SEARCH 'j u^j l Three Category I carcinogens were examined to determine materi^/speeifieations, parts and nonproduetion uses, was tedious and inexact. Existing data bases containing Engineering, Manufacturing and Purchasing information were found to be incomplete and not readily ( accessible. In the absence of one reliable system, the detailed steps in Figure 16 were under taken. For production materials, each PEO reviewed the material/usage list for completeness and established a list of parts and bulk materials of their design responsibility suspected of con taining the subject substances. These lists were returned to Engineering Staff. E&RS con solidated the lists (See Appendices) and provided them, along with the approved source and material identifications to Purchasing and Supply Staff for supplier contact to determine substance usage and to find out if there is a known substitute. Nonproduction materials were identified by similar methods, except for the PEO review. MATERIALS AND TOXICOLOGY SYSTEM (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (P&O Staff); the Engineering Material Approved Source List (E6cR Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental <5c Process Engineering Review System (Mfg. Staff). These Systems con be linked together with some manual effort to search for uses of suspect carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing suspect chemical compounds can be identified in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list, Purchasing can determine quantity used and Manufacturing En gineering can determine processing methods. Other functions of MATS include Approved Source Lists for production and nonproduction, materials Jlflichigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials ffiE_planLi^octor|' and(Ss>uge Poison'ControLCentet? UAW contract agreement to provide non/confideuaial listof hazardousYnaterial usage and precautions foreach plant. 8004 0142 -8- May 2, 1980 /# LA /UaA&o tr^A A>-c / 'l)tsc-zvwv.-v^ i "J^K Xy.f C^r (fa** - 41 -^4 * ^' /J /ftieivK ^ t- -4; <<^/ ^>J4/'^CJ>>vU%v~^Ui_. "tl 7^ *,/" ^ y^u^/ ^.-c^AC^ *yo yiy -.^i <-+& i . y /j) ^ e Ayp'^ fi,CLL ^ yy~ ^^3c_ -' ^tj 1 2 t. */ S&~:fa,-1 ^* ^ * /' 8004 0143 Asbestos2- / Cr Compounds3- / Benzene draft CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts AB 34 49 -- . - C Total 22 105 25 25 15 15 Asbestos Cr Compounds-4/ Benzene Nonproduction Materials/Parts -1/ ABC 8-98 81 34 3- 5 Total 8 213 8 Note: A = Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = No known substitute. Advanced Engineering Project required. NA= Not available 1/ Data are directional estimates only and refer to materials known to contain the particular carcinogen. 2/ Primary source - Car Engineering. 3/ Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered. 8004 0144 -9f- May 2,1980 DRAFT CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium, benzene, a partial list of production and nonproduetion material applications has been assembled. These were classified as: Known substitute material available for application without major redesign; Known substitute material available for application with major redesign; No known substitute. Advanced Engineering Project required; Even in group A, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. 8004 0145 -9- May 2, 1980 DRAFT FIGURE 19 CARCINOGEN STRATEGIES Continue OSHA Category I carcinogen control by design, process and exposure limits. Eliminate carcinogens where substitutes are known when required by regulation or business pressure., a/ - Proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985. Where elimination cannot be contained, control the design, process and exposure, b/ - Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. 8004 0146 a/Current Car Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos. In documented cases precluding alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. b/Advanced funding would have to be provided where elimination cannot be contained in the 1985 timeframe. - lOf - May 2, 1980 DRAFT CARCINOGEN STRATEGIES Three major strategic alternatives were^tnnsidetedJfiEcthe elimination and control of carcinogenic substances. /Twenty-six (261/OSHA Category I substances and (forty-one (4?5^ibstancW-thai-ftffrtrtne auto industry and are proposed foh'~regul*lin-'(MVMA analysis) provide the basis for these alternatives. NIOSH advised substance controls were deemed to be of lower priority. It was agreed by the Task Force and PEO chief engineers that the Company should proceed now to eliminate asbestos, selected chromium compounds and benxene by Job #1, 1985. Where elimination cannot be contained, design, process and exposure controls would continue for specific applications. Implementation of the recommended alternative can only proceed by specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) can be initiated now but cannot with confidence be expected to be fully implemented in the 1985 time frame. Implementation decisions will have to be made for each application in the context of the vehicle cycle plan, component redesign, plans facility renovation/replace ment and the practicality of the substitute. 8004 0147 - 10 - May 2, 1980 'V DRAFT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) - N fb- Manage Program tj, J Propose list of known and suspect specifications o/ Verify proposed list- Identify known and suspect part-fi/ numbers - Request supplier verification of suspect specifications and parts ~ Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) - Implement Group A actions - Implement Group B actions - Implement Group C Actions - Audit effectiveness n Responsibility Production Nonproduction SSECO SSECO SSECO ' SSECO PEO's PEO's-7 Mfg. Staff Mfg. Staff b/ NAAO/DPO Purchasing NAAO/DPO Purchasing PEO's (NAAO Peh.) Supply Staff Supply Staff Mfg. Staff (Supply Staff) Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO's SSECO ftO Mfg. Staff Mfg. Staff Tech. Ping. Research Staff BMD SSECO Block Timing Prod. (Nonprod.) Ongoing 1 Month (A) 1 (A) 1 (A) 2 3 6 12 33 (TBD) 45 e/ Ongoing Ongoing a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. c/ Complete for asbestos, chromium compounds and benzene. - Ilf- May 2, 1980 8004 0148 DRAFT GENERALIZED WORKPLAN The foregoing strategies, even though having been tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination. The first three actions of the workplan have been completed for asbestos, chromium compounds, and benzene. Jhe fourth and fifth actions have been j initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the r substances should be completed in the first quarter of 1981. Completing the actions by these dates requires Corporate direction that the elimination/control of these substances is a mandatory priority effort. Without such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogens. Overall program management is essential to this effort. 8004 0149 - 11 - May 2, 1980 DRAFT FIGURE 21 MEMBERSHIP HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control Office . Environmental and Safety Engineering Staff . Purchasing and Supply Staff . Personnel and Organization Staff . Scientific Research Staff . Manufacturing Staff . Car Engineering . Body and Assembly Operations . Ford Parts and Service Division . Ford Tractor Operations . Powertrain and Chassis Operations . Basic Products Operations . Electrical and Electronics Division . Climate Control Division . Truck Operations . European Automotive Operations . Office of the General Counsel FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER 8004 0150 - 12f - May 2, 1980 DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the requirements for chemical substances control. It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issuej/.^ The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an E&SES location was recommended. In view of budget constraints, it has been agreed that the existing Commpliance and Liaison Department would perform the Program Manager function. The Manager should be responsible for implementing carcinogen control strategies coordinating Company response to potential and promul gated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to B-101, establishing a financial measurement of the compliance effort, and assuming development direction and control for the computer information system and implementing the workplan as directed. The ongoing responsibilities of the Chemical Substances Control Manager will be to coordinate the product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forecasting/regulatory'impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page. It is further recommended that the Committee be chaired by the E&SES repre sentative. Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. ? -12- Mav 2. 1980 8004 0151 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 1. Hazardous Substances Control Committee 2. Program Manager ' 3. Direct elimination of Asbestos, Chromium Compounds, Benzene 4. Request Operations Workplans 5. Adopt the priority carcinogen listing 6. Request the establishment of overall elimination timetables. 8004 0152 - 13f - May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force on Carcinogens in the Workplace recommends that: 1. Establish a Hazardous Substances Control Committee chaired by the Director 'f./ __ ^ Environmental Control Office. The Task Force would be discontinued. 2. Assign(Carcinogen^Program Manage^ control responsibilities to the Compliance and , Li a ison Depart men1, EnvlrumiienrtgTand Safety Engineering Staff. 3. Reque^Envtronmental and Safety Staff to establish carcinogen elimination timetables for ^fic 67Jcnoym^arcinogens for review and approval by this Subcommittee. 4. Request that NAAO/DPO Product Engineering Offices and Manufacturing Staff present to the Subcommittee specific action plans and timing for the Group A applications identified. 5. Adopt as the Company carcinogen listing, current. OSH A_ regulated Category I sub stances (261 and proposed for regulationjubstanceslil)., .Establish the top eight prior ities proposecTbyTTTg'Task Force as'Company priorities. 6. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene by Job #1, 1985, as outlined in the workplan. 8004 01 53 -13- May 2, 1980 8004 0154 DRAFT EXHIBIT I OSHA CATEGORY I CARCINOGENS Regulated Acrylonitrile Amosite Anthophylite Arsenic Asbestos Benz (e) acephenanthrylene Benz (a) anthracene Benz (a) anthracene, 7, 12-DimethylBenz (a) anthracene, 7-MethylBenz (a) anthracene, 7, 8, 12-TrimethylBenzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibenz (a, h) acridine Dibenz (a, j) acridine Dibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso1-Naphthylam ine. 2-Naphthylamine Serpentine Vinyl Chloride Proposed for Regulation Acetamide Acetic acid, Lead (2-*) Salt Benzidine Sulfate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3+) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt Chromic Acid, Lead (2+) salt (1:1) Chromite Chromium Chromium (III) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Diethylamine, N-Nitrosop-Dioxane Ethane, 1, 2-Dibrom'oEthane, 1, 1, l-Trichloro-2, 2-bis (p-chlorophenyl) Ethylene, chloro-, monomer Ethylene, TrichloroHematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (II) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid Tannin o-Toluidine Urea, Thio- May 2, 1980 DRAFT CARCINOGEN SEARCH Materials and Toxicology System (MATS) EXHIBIT II To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALOG of Hazardous Materials (P&O Staff) containing materials, their toxicological evaluation for worker/consTimer protection and the chemical composition, the Engineering Material Approved Source List (E&RS) containing the material specification title and the materials approved to That specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction material standard and the approved materials; arid the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. , Carcinogen Search Strategy Developing the links between the above systems will, in the future, provide a method for locat ing suspect carcinogens in nonproduction materials and production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the followingySeareh steps: 1. The Chemical Abstracts Service numbers of the suspect carcinogens and-rtS" compounds are identified by IH&T. The system will then generate a list of materials which contain that chemical. .2 Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other suspect materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a crossreference list of all parts which use that material. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. 00 o o o KA \A v t\ Functions The primary function of MATS is to maintain and produce the Approved Source List for non- production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract.. The. system is also available to the plants and theQPoison ControTCenterVt'The'Rouge to be searched ) by supplier or specification for complete medicalJ TiandlifigT shipping, waste treatment and disposal instructions on a material. i -------------------------------------------- ---- \V , TK\ ./ The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g., chromium. Affected Activities All Corporate Staffs concerned with materials/toxicological/environment controls are currently involved in using/developing the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with the exception of Chassis which currently does not participate in material control os required by PEP 3-189. H3 May 2, 1980 PRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification Material Basic Part No. Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Gasket Gasket Deadener Sealers -- 7086 4035 350038 350038 9900000 Trans. Ext. Gasket Carrier Gasket Econ. PDV Box Assy. Econ. PDV Box Assy. Courier Box Assy. Body ESB-M2G58-C ESB-M2G171-AB ESB-M2G188-A ESB-M3G95 ESB-M4G1-B ESB-M4G31-A ESB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A ESB-M4G177-A/B Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler Sealer Scaler -- Primer for Adhesive ---- ---- -- ---- -- -- ---- ---- -- -- -- ---- ---- -- -- ---- ---- -- ---- -- ---- ---- ---- -- .-- --~ ~-- 8004 0156 appendix I draft 5/2/80 Specification ESB-M4G188-A ESB-M4G197-A ESB-M4G198-C ESB- M 5G 8- A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A Trans ESE-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A Material Sealer Sealer Sealer Dcadencr Deadener Deadener Rust Prevent Gasket Gasket Seal Gasket -- Scaler Sealer Scaler Coating Phenolic ESF-M3D113-A ESA-M4D140-A ' ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A -- CCD ESF-M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket Gasket Gasket Gasket Gasket Gasket Sealer -2Basic Part No. -- -- -- -- -- -- 7D026 7A136 4035 7052 7A247 15520 9004650 19560 19560 19554 19515 18B374 8K621 17B616 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 19D970 2A792 APPENDIX I DRAFT 5/2/80 Part -- -- -- -- -- .~ Sprayable Wax Type Rust Preventative Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer Caulking Cord Rope Sealer Perfect Seal Undercoating A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator I/C Lamp Socket Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket A/C Comp. Gasket P/B Cable Opening Cover 8004 0157 -3- APPENDIX I DRAFT 5/2/80 NONPRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts - 15 lb. . Asphalt Saturated Asbestos Roofing Felts - 30'lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper 8004 0158 -4- APPENDIX I DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group B -- Known Substitute Material Available With Major Redesign Specification Material Basic Part No.Part Light Truck ESE-M8G10G-B ESE-M8G140-A Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Gasket Gasket Phenolic Phenolic -- ~ -- -- -- -- -- -- -- -- __ 5B266 5B266 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy. Trans. Clutch Plate Assy. Chassis ESB-M8G106-A ESA-M8G140-A -- Gasket Gasket -- 5B266 5B266 2022 2021 Resonator Gasket Assy. Tesonator Gasket Assy. Front Disc Brakes 8004 0159 -5- APPENDIX I DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group C -- No Known Substitute. Advanced Engineering Project Required. Specification Material Light Truck ES-C8AA-2B282-A ES-D20 A-2B072-BB ES-C8AA-2B282-A ES-D20A-2B072-BB -- Vendor Print -- Vendor Print ES-EOTA-2B120-A A -- -- ES-D6TA-2B118-A A -- ES-C8TA-2B282-A ES-C8TA-2210-D -- ES-C8TA-2010-C -- ES-D8TA-7550-A -- ---- ---- ---- Trans Vendor Vendor -- Vendor -- Heavy Truck -- '-- ---- -- ---- ---- ---- ---- ---- -- ---- ---- -- Basic Part No. 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 4797 4A435 7550 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A59B 7550 7E434 Part Lining Front Wheel Brake Outer Lining Front Wheel Brake Inner Shoe and Lining Inner Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake Inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch Clutch Plate Clutch Plate Parking Brake Lining Rear Axle Diff. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Brake Compressor Fan Clutch Assy. Clutch and Bracket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Brake Assy. 8004 0160 Chassis ESE-M8G149-A Gasket ~ -6- APPENDIX I draft 5/2/80 5F2S3 2284 2285 Exhaust Manifold Gasket Rear Brake Shoes 8004 0161