Document 99bwE6j17XK1yyw8vzg568jGR

FILE NAME: Ford (FD) DATE: 1979 Aug DOC#: FD143 DOCUMENT DESCRIPTION: Internal Report - Assessment of Asbestos Use and Impending Regulations ASSESSMENT OF ASBESTOS USE AND IMPENDING REGULATIONS Vehicle Materials Development and Planning August, 1979 002937 PRODUCED BY FORD / l ASBESTOS-IMPACT Purpose 'o review and update the engineering asbestos plan. Background ' The 1975 OSEA proposed standard remains dormant. If promulgated it will lower the permissible occupational exposure limit for asbestos from the current 2 fibers per cubic centimeter to 0,5 fiber/cc. Formal hearings that normally precede issuance of a final standard have been delayed for-several reasons: .. A standard for the construction industry has not been prepared. . An economic impact study has not been released, although it has been in draft form for Bix months. __ _ . Continued attack on the proposed standard by asbestos and mining interests as being too restrictive. Contrary to this apparent inactivity, NIOSH has recommended documentation of the "life eye .6 of asbestos from mining to disposal and elimination of all non-- essential uses. A working group in EPA's Office of Toxic Substance is currently performing a "life cycle" analysis of asbestos. First priorities for regulation are paper products (gaskets) and friction materials (brakes). Assessment / study of the current regulatory situation indicates a high probability that tighter ' environmental restrictions on asbestos will be promulgated within the next two years. The fact no firm evidence exists that the current standard is inadequate only means there will be no emergency standard of a disruptive nature. Evaluation of the current standard could take 30 or hO years and still not surface concrete evidence supporting either the government or industry position. The burden is clearly on industry to "prove" the current standard is adequate. Since this is not possible and the government agencies were created to regulate the use of materials, we must proceed on the assumption there will be further regulation of asbestos. . The previous scenario for a staged tightening remains a possibility. This would mean a reduction of the current standard to 1 fiber/cc by mid-1900 and 0.5 fiber/cc by early 19o3- However, this timing is unlikely because most industry currently meets 1 fiber/cc and the proposed standard has been "on-the-books" for nearly four yearB with no action. ^ If, as expected, during the next two years the proposed OSHA standard is promulgated, and/or regulation by EPA of asbestos emissions from brake wear occurs, then the following results can be expected: A. A -drastic reduction in the use of asbestos containing friction materials over the next 3 to 5 years. Comments: . Court challenges will delay implementation of standards for at least 1 year. . - . Transmission and Axle programs will be accelerated for non-asbestos sub stitution. (Attachment I) ( . Costly "crash programs" for brake drum substitutions. * . Attachment II shows the company usage of asbestos containing friction materials. * General list being compiled by VMD&P- additional input required from PEO's for completion 002938 PRODUCED BY FORD 2. B. The use of asbestos containing gasket materials vill remain cost-effective for most applications. Comments: . Raw asbestos comes from Canada7 . Process areas meet 0.5 fiber/cc by encapsulation. . No emission problem because of encapsulation (with exception of disposal). *. Attachment III shows the company usage of asbestos and insulating materials. the possible containing gasket It is less likely that we will see a standard of 0.1 fiber/cc. Streets in ma;'or cities have been measured at levels higher than 0.1 fiber/cc and citing this level as dangerous could result in' "public panic". Competition Several years ago, GM repqrtedly .considered a policy to get asbestos _out of the brake linings because of the toxic concerns. They decided that the effort to find a substitute for asbestos would be better spent to improve the performance and durability of the lining material and opted for a development program with semi-mets by '8l-'8 2 and all linings (disc and drum) by '8,5. The asbestos issue has helped keep the semi-met programs going over the years. There is no "official" GM company policy to remove asbestos from other component areas. However, because of toxic concerns and company awareness of asbestos, gaskets and heat insulators are slowly being replaced with asbestos free materials. Asbestos insulation reportedly has been removed from manufacturing plants and the facilities that manufacture brake linings meet the present standard of 2 fiber/cc. It appears obvious, regardless of company policy, that GM intends to eliminate the use of asbestos. Their approach of "no formal policy" is a result of uncertainties associated with cost and timing for substitutions, and a general awareness that issues must be dealt with before they become problems. Chrysler also has no formal program for asbestos removal. However, in the case of sealers and gaskets, they attempt to use non-asbestos materials wherever possible and in most cases, are now introducing the substitute materials. In the area of brakes, front wheel discs are being converted- to semi-mets as new programs permit, but no plan exists for rear brake drum substitution. ' It is unlikely that crash programs on some friction materials can be avoided when tighter standards are promulgated for the following reasons: . Reportedly there are no asbestos free substitute materials for drum brake linings available for evaluation at this time. _ . Despite the lead body solder fiasco, the engineering attitude (with the exception of Transmission and Axle) remains "wait until the standard is promulgated". (Questions have been raised by various PEO's regarding a policy or position for the use of asbestos. In the absence of other direction, VMD&P makes recommendations later in this paper for a specific asbestos policy.) _ . The automotive industry has not shown sufficient interest in non--asbestos materials to warrant accelerated R&D efforts by suppliers. I * General list being compiled by VMD&P - additional input required from PEO's for completion 002939 PRODUCED BY FORD ( 3. continued) . + pffactive this tine around. However, ontaining gasket materials will "" ^ 2 , S S means regulatory pressures STSSJS V O^IOSH the - e of ^ eort to develop n - s is r " * atperted- raise * * * - -- --- 5C -- , ^.t. Id-- f e r i n e ^ " S e r i a l , for * ? ? * - * * * ^ 1 L d l k e asbestos. The October 7, 1970 z) ia ,, excellent example. The prestos Material Program (Attachment ) , interested in alternate a s s r 55 s rs - of _ - M^T-ntee^ts - SR eSsp oTn sibLilityi :^ ESfiRS" ^ " "_ " 3. A fir. S SS-- S', o S ^ e e r i n f ' ESSES S r "U - i & TM * . ^ trei ,, Be_ . o the laeh f . 2 - "*^ S ffi ^ L C ^ t t S ! ^R esponsibility1 P < *'s ( M TM = e d Rngme.r 0 Vehicle Materials Development and Planning August, 1979 002940 PRODUCED BY FORD ATTACHMENT I c:: ;.:c :-r:: ( *"TT" Tc d t r c lc p a cn -a stestcs u u t e r i a l ccupor.enis to rta_nae these iters currently released vhich contain asbestos. y-inufactur ins controls . ,, - :- -- - - r' L-.fi-,a s.ssesiss necessitated 07 a n tic ip a te d Cl;'.'. ::r auatralic trarsrisoiors. the initial devclapuent ri'ara to evaluate nor.-aoiestos iritttar. m e r u i t ir beir.3 car.iutted vita the Co aransrissltr.: initial Z - ' 1 j-t-;niiita is sch-dulti ; or 1. 1'.. - -- ir.e th e ir reau ircrtr.ts bates cr. t.te 1 : c i- 'tr t e : I..-- aabr-tttr r c i r .t c r t c i i h s r . c l i : r e a a ta r: v i l l =a_-r. rat:ir.~ tut in 1-iC and he c t r p l c t c l v traced tut 002941 PRODUCED BY FORD