Document 9JRVLVrwO0K0BzQyGqoGR9mzp

Inter Oflice Ford Tractor Operations Mr. J. V. Durstine May 14, 1980 Subject: Carcinogens Task Force Report Reference: Your Letter, Same Subject, Dated May 1, 198O The attached letter from M. H. Manning to 0. 0. Eeutgen is the Tractor response to your request for comments on the Carcinogens Task Force Report. Attachment 800* 0203 SCF-FORD-1926  48u- Mr. G. 0. Keutfen Vice President . General Manager Ford Tractor Operation* May 14, 1980 Subject: Carcinogens Task Force Report. In response to your, request for comments related to the above subject report, our review indicates that two items require clarification in their application to Tractor Operations. The survey states that the Company has removed lead chromates from paint and that Romeo has increased ventilation to minimise hazards. WHh reference to ventilation, we have made several spray booth Y/rearrangements and minor modifications to existing equipment. Also, the small parts paint booth will be expanded by December, 1980, which will further improve ventilation as well as capacity. These improvements, however, will not eliminate our overexposure condition and we intend to change over to lead and chromate free yellow, except for certain special orders in August, 198O. While I wtrHmfti amounts still remain in our prime paints, exhaustive hygiene tests indicate they represent no exposure hazard. Also, a minor point, we note that the section titled Carcinogenic Substances in the second sub-paragraph on chromium compounds states the OSHA limita in mi11grama rather than micrograms. t \ t 8004 0204 1 DRAFT EXECUTIVE SUMMARY CARCINOGENS IK THE WORKPLACE Introduction At the October 1979 joint meeting of the Engineering and Research and the Manufacturing and Supply Subcommittees, a report on the Occupational Safety and Health Administration (OSHA) Policy for Regulating Workplace Carcinogens was presented by Personnel and Organization Staff. This report noted that final regulations for carcinogens in the workplace were anticipated by the end of 1979. There was discussion on the problems involved in dealing with a great variety of substances and suppliers. It was agreed that efforts to elim inate the use of potential carcinogens where possible should be preceded by analysis of the affected materials and processes. In this regard, a Task Force was established by the Subcommittees to identify potential carcinogens and quantities in use, set targets for elimination of such substances if feasible ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify and further control potentially carcinogenic substance| systematically. Since October, Q81IA has released its Policy which defines Category I potential carcinogens as substances kfiown to be carcinogenic in humans or which have been demonstrated to be carcinogenic An two separate laboratory animal studies. Category II substances are those where data/fy suggestive of carcinogenicity in humans and test animals. The Policy also establishes tne mechanism for issuance of standards governing use of a particular substance. (Normally, once the need for a standard is determined by OSHA, it could take 1 - 2 years before the standard is issued. If an "Emergency Standard" is set, the ruling is issued and immediate compliance is required.) There are a number of court challenges of the new carcinogens Policy. A draft list of candidate substances governed by the Policy was issued by OSHA two years ago. A revised list is expected to be releoscd in July, 1980 followed by a prioritized-extract in September. It is expected that the list will be updated periodically. The Task Force has concentrated on developing the capability for managing the elimina tion/control of Category 1 potential carcinogens in the workplace. A start has been made in identifying specific applications for subsequent elimination or control. Representative Past Company Actions Since 1977, the Company has removed chromates and molybdates from paint (except for school bus yellow and special orders), "Tris" flame retardent from fabrics end instituted further controls on asbestos. In this respect, a Vehicle Engineering directive has been issued that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). As of 1969, sprayed-on structural steel fireproofing has been asbestos-free for new and reworked construction. Several manufacturing standards prohibit asbestos as a constituent.^* Benzene exposure has been reduced to permissible levels or eliminated since 1978. VenU tion was increased to minimize potential exposure to paint-related chrj ' a/j r _--) / iCt*/ Potentially Carcinogenic Substanc2es // W" f 6r<L Based on an MVMA report, the Tass/k fFoorce has to date Identified fhirty-six (36) substances or groups of substances on the earlier OSHA issued candidate list and-m-uso m-the.automotive irdvrtry ft ry ininxu. Eleven (11) of those are currently regulated ?wv. by OSHA as potential carcinogens^ the balance have potential for new regulation. More. restrlctlve"5tHndards have beon-propesed for snmr of -those subirtonns currently tegulated.- 'Thlrty-dne (31) substartees are repof to the Michigan Department o.f -Natura.l Resources . (MDNRHor computation* of water surl illance fees\ Michigan plfeiHs used 1.3 miHion pounds of the eleven (11) potenHal carcinoger on the MDN.R list. The lbcgest use, 6thousand, pounds of acrylonitrile principally at tlid. PPV PainK^lant is planned to be subhanttally vaeduced by Jbfc #1, 1981. The Ust of substances was prioritized by the Task Force, according to impact on the Company and potential for further regulation, to Identify the Task Force view of the top eight (8). The top three of the eight priority substances, asbestos, hexavalent chromium compounds and benzene, were examincd^Specific lists of these bulk materials and parts for production and nonproduetion use have Men developed. The asbestos list has been forwarded 8004 0205 to purchasing for supplier verification of content and avoilahility of feasible substitutes. The benzene and chromium compound lists are being analysed by the product offices and manufacturing to define specific parts usage. Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets, and for nonproduction roofing, millboard and core/mold sealers. Medical evidence links excessive inhalation of asbestos dust to lur.g cancer, mesothelioma and other diseases. The present OSHA limit is 2 fibers per cc of air (2 million fibers per cubic meter) which may be proposed for reduction to as low os 0.1 f/cc possibly this year. Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links certain hexavalcnt chromium compounds to lung cancer and others to liver and kidney damage and other diseases. The present OSHA limit is 52 microgram per cubic meter of air. The Notional Institute for Occupational Safety and Health (N10SI1) has recommended a reduction to 1 microgram per cubic meter. - Benzene occurs primarily in coke oven operations as a by-product and in petroleum fuels. It is a residual constituent in solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has issued a standard of 1 ppm in air as a time weighted average for an ^ 8 hour workday. The standard was not upheld by the Court of Appeal, and is * now before the Supreme Court, which is expected to rule on its validity * _ shortly. A new computer data base is being developed (2nd quarter 1981), Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid identification of potential carcinogen and other toxic substance applications. The links between these systems will provide a method for generating a list of production and nonproduction material specifications which contain Category 1 substances. -J9ping NAAO supplier codes, specification numbers and product names, MATS will identity'additional specifications!. The specification numbers are-then cross-referenced to port numbers which use that materiil. Finally,-the production part-nnrH>ulk-materials list is matched In the . purchasing system to determine suppliers-to bequeried for climinution/control of potential carcinogens/ To date, of the five major MATS subsystems, two have been completed and the others ore being manually operated for potential carcinogen searching. The engineering release system has been audited and is being updated to extend materials identification to all parts. Product Engineering Procedure PEP 3-189 is being rewritten by NAAO to require systematic review of possible use of these substances. Strategy and Workplan The search for asbestos, hexavalent chromium compounds and benzene defined the number of parts and materials containing these substances as listed in tiye table below. Where possible, the applications were divided into three groups: A - Known substitute material without major redesign, B - Known substitute materia) with major redesign and C - No known substitute and advanced engineering required. The data fcldirectional only. There remain many applications which require time-consuming analyses for identification. 8004 0206 Asbestos Chromium Compounds Bulk Materials and Parts Production Nonproduction ABC Total ABC Total 56 21 26 103 / 8- - 8 - - 22 22 98 81 34 213 Benzene ^ P - - 14 14 3 ,5 It? 8 The recommended strategy is to proceed to eliminate Group(A applications of these three substances by Job # 1*. 1985. Where elimination is not feasible^ institute controls on design, process and exposure.' For those applications requiring major redesign (Group B, e.g., drum brake linings) the elimination timetable must reflect Company cycle pluns, new construction or rcnovntion'(GTM. lins-stntcd-tffl-ifltcflt-to-trliminftte-nsbcstos-by 1985); Finally, where no known fcusible substitute exists (Group C), advanced engineering will ho^p to be completed before un elimination timetable can be established, individual timetables remain to be established for the bnloncc of the prioritized substances. / tr -3- A generalized workplan has been prepared on the basis of the evaluation of the substances referred to above. The workplan requires central program management, with action imple mentation by NAAO/DPO Product F.nginccring Offices, Purchasing activities, Vehicle activities, Manufacturing activities, and the Manufacturing and Supply Staffs. It is judged that approximately a yeor 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 to two additional years would be required to implement the most feasible actions not requiring major redesign. Substitution requiring major product, plunt, equipment or process redesign would take 33 months for vehicle or 45 months for major powertrain programs. A specific workplan is required for each application. jsJqri Although a strategy and workplan /proposed in this poper and/Efforts have been started in these areas, there are considerable timing and feasibility watts in each of the identified applications. -Por-the ronst-pnrt-there are no substitution programs-exeept os mandated by regulation. Without funding or directed prioritization over other engineering effort the work on the identified asbestos, hexavalent chromium compound or benzene applications cannot proceed under present economic conditions. Nevertheless, a measured Company reaction is necessary to initiate orderly substitution programs with sufficient flexibility to adapt to engineering and economic limitations. bc'* 6 Recommendations Achievement of the recommended approach requires a Corporate commitment by the Policy and Strategy Committee to foster an integrated, sustained effort throughout the Company over a number of years. Specific responsibility shown below will continue to be reviewed by the Engineering and Kesearch and Manufacturing and Supply Subcommittees to provide a forum for discussion and Corporate overview. To accomplish the strategy, the Task Force recommends: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. (Responsibility: Environmental and Safety Engineering Staff - ESES) 2. Assign hazardous substance program management responsibility to Environmental and Safety Engineering Staff. (Responsibility: ESES) ^ i'nr ^ s/v// 3. Revise Directive B-l01 to reflect adjusted responsibilities No new Policy is required, the matter is broadly covered under Policy C-3. (Responsibility: ESES Program Manager) H&srpr 4. Continue the development of MATS. A budget and headcount transfer from Engineering Staff has been agreed to. (Responsibility: ESES Program Manager) 5. Adopt as the Company potential carcinogen listing the 36 current OSHA-regulated and proposed Category I substances. Establish the top eight priorities proposed by the Task Force as Company priorities. Direct that the listing be updated semiannually. (Responsibility: P&O Staff) 6. Establish elimination timetables for the eight prioritized potential carcinogens for review and approval by the subcommittees. (Responsibility: ESES Program Manager) 7. Proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job 11, 1985 where feasible. (Responsibility: PEO's, BMD's, Purchasing) 8. Present specific action plans and timing for the Group A applications identified to the program manager. (Responsibility: PEO's, Mfg. Staff) 9. Include Group B asbestos, chromium compounds and benzene elimination actions in concept development (Phase 3) of vehicle and powertrain programs and in new plant and renovation projects. (Responsibility: Program Manager, Product Planning, Manu facturing Staff) 10. Recommend advanced program funding to develop designs and/or materials for new production and nonproduction parts to identify feasibility, reliability, cost ond weight Implications of alternative materials/dcsigns (Group C). (ResponsibilityPEO's, BMD's) 8004 0207 Engineering Staff Manufacturing Staff May 14.1980