Document B8Re029xNgwbp3N6omRBZ8qgL

\ .~ October 24, 1.974 Mr. E. M. Fenner, Director Technical Relations Environmental Affairs Dept. Johno-Manvill.e Corp. P. 0. Box 5108 Denver, Colo. 80217 Dear Ed: Attached is copy ot revised draft ot the Asbestos Friction Materials Work Practices and a marked up cop,y ot the original to indicate changes, all o~ which I contdder minor. Best regards, 1. H. Weaver w' attach. co-Messrs. J Marsh E. Drislane ./' C. Clarke FMSI 06725 DRAFT - NOT FOR CIRCUIATiml Revised 10/23/74 Recommended Work Practices for Users and Fabricators of Asbestos Friction Eaterials Tl1is recomrnendation of ''\\lark Practices" is prepared by the Standards and Technical Committee of the Asbestos Information Association/North America. The intent is to advise manufacturers and fabricators, who use asbestos friction materials, of Work Practices best suited to maintainine a working environn1ent within the levels required by 1910.93a of the OSHA Standards (copy attached). 1. Asbestos Friction Haterial Products covered by this work practice recommendation: 1.1 Clutch Facings 1.2 Brake I.inine Seements 1.3 Brz.ke Blocks 1.4 Disc B rake Pads 1. 5 Brake Dand l-:aterials 1.6 Automatic Transrr~ssion Discs 2. Operations to ,.;hich the recommended vmrk practices may apply: 2.1 Clutch Assembly and Rebuilding Operations 2.2 Brake Assembly and Relining Operations 2.3 Automatic TransmissionAssemoly and Rebuilding Operations 3. :Requirements of OSHA 1910.9Ja. 3.1 The Asbestos Standard (l910.93a) applies to any manufacturL~g, fabrication or r.a~dling process or operations involving articles or materials composed v;holly or in pc>.rt of asbestos fibre. 3.2 lt is the effiployer's responsibility to maintain "Exposure to airborne concentration of asbestos fibres" at or below the levels described in l910.93a. Exposure levels may be controlled by isolation, enclosure, exhaust ventilation and dust collection. Standa.rd l9l0.93a does not limit the means used to maintain compliance. 3-3 Particular tools - All hand or power operated tools which may cause the release of asbestos fibre to becorr.e airborne at levels in excess of the standard shall be provided Hith exhaust ventilation. J.4 Het liethods - \:!hen practicable asbestos products shall be proce;.;:;;ed .Hetted sufficiently to prevent emission of dust to the atmosphere. (Li.'Tlited or not required where wetting \:ould reduce end efficiency of the product.) 3.5 Protective Equipment and Clothing - \-Jhenever it is necessary for employees to perform their normal w-ork in an environment where airborne concentration of asbestos fibre exceeds the allovrablc level of Standard 1910.93a, the er:1ployer must provide respiratory protection and clothinr; in compliance vlit.b the standard. The employer must also provide chanee rooms and separate lockers for vmrk clothes and street clot11es. J.6 Air Sampling and nonitoring - The employer is responsible as described in 1910.9Ja. FMSI 06726 3.7 Storage and Handline - It is reconunended that asbestos-containit1g products be stored in sealed containers. Handling of asbestos-containing products shall be done in a manner to minimize eeneration of airborne asbestos dust. ).8 Caution Si~ns and Labels -The employer shall use caution signs and labels in accordance \rith provision of Standard 1910. 93a. 4. Exhaust and Dust Collection Systems 4.1 ldherever exhaust and dust collection systems are used to attain concentrations of airborne asbestos fibre belo"l"r the levels allo"l"ted in Standard 1910.93a, the systerr.s shall be inspected and cleaned at least weekly. 4.2 Design, installation and naintcnance of e~1aust and dust collection systems shall be in accordance with American National Standard Fundamentals Governing Desi8n and Operation of Local Exhaust Systems (AlJSI Z9.2) or equivalent standard. 5. Housekeeping in :lanufacturing and Fabrication Areas: 5.1 All sur~aces, machinery, equip~ent, etc. shall be kept free of accumulation of asbestos dust, preferably by vacuum cleaning or other method that ;..-ill prevent asbestos dust or fibre from becoming airborne. Vacuum cleaners should be equipped with a disposable ~ollection bag and a microfilter. 5.2 1-Iaste and scrap P.'.aterial, such as dust, chips, off-cuts, edge trimrninr,s and broken pieces shall be placed in sealed containers in preparation for disposal. 5,3 Containers used to store or dis}~se of asbestos-containing materials shall be labeled in a manner to :::onp2.y v1ith StanC.ard 1910. 93a. 6. Reco::-c'ae:-:ded Procedures for ].;anufacturing and Fabrication Operations Involving Asbestos Friction l-~aterials: 6.1 ~~'herever feasible, friction materials that are specially treated to reduce du.st emission should be used. 6.2 Eaterials should be removed from containers gently and handled with care to avoid unnecessar:t generation of airborne ,dust. Care should be ta~en not to disturb dust remaining in contaL'1ers and packaging rraterials. Such dust should be rer.1oved by vacuum cleaning wherever feasible. 6 .J vJhercver feasible, materials sh0uld be obtained from the manufacturer cu.t, machined and/or drilled to suit final requirements to avoid necessity for additional fabrication operations. 6o4 On large volume operations with fixed 11orking poihts or machines, local exrmust S2o'sterns should be installed in accordance with American National Standard Al<0I Z9. 2 or equivalent standard. 6, 5 \'/hen cutting, drilling, crindine or machininG operations are of short duration, portable dust exh<...ust. units may be suitable. Vacuum cleaninG equip:tent. sornetir.les may be adapted for this purpose, provided the filter system is of adcque1te efficiency. FMSI 06727 6'.6 'vlhere dust control by means of local exhaust is not feasible, flooding of the l-:ork and the tooling with water or other liquid may be effective in suppressing dust emission. 6.7 Fragments and dust should be removed regularly, preferably by vacuum methods, and must be disposed of in accordance with paragraphs 5.2 and 5.3. 6.8 If surface dust is present on materials, it may be necessary to remove it by wiping vdth a damp cloth or mop or by.vacuum cleaning with a brush head. attachment prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. 6. 9 \:here it is impractical to cart rol airborne dust by means of an exhaust system or by uet processing, ,.,orkers must be protected by approved respirators and protective clothing. 7. Personal Protection 7.1 Develop good personal hygiene practices. vlashine thoroughly before eatine will prevent inGestion of foreign matter. Food shcu ld not be stored or eaten in the work area. 7.2 It is '1-Iell documented that smoking is injurious to your health. The ill effects of smok~ng may be accentuated for those working where airborne asbestos dust may be encountered. Smoking should be avoided!. 7 .J Use of approved respirators shall be mandatory, '1-Ihen required by OSHA Standard l910.9Ja. Protective clothin~:; shall be provided and 1mrn v!herever employees are exposed to ceiling levels exceeding those prescribed in Standard l910.9Ja. Employees must be given thorough instruction in proper use, care and maintenance of personal protection equipment. 7.4 No person shall be assigned to perform any work for which respiratory protect- ive equipment is needed unless he has been medically examined and determined fit. 7.5 Care should be taken to rru.nlmJ.ze dust generation and transfer of dust to the person or his clothing. Clothing not worn during working hours must be stored away from contamination, and contaminated work clothing shall be specially handled to prevent exposul'e to asbestos dust, as prescribed i.n Standard l910.93a. FMSI 06728 heCO!IL'11ended vlork Practices for Users and Fabricators of Asbestos Friction :r.:aterials -Int-r.orluet.-:i:on This recommendation of "'\'lork Practices11 is prepared by the Standards and Technical Committee of the Asbestos Information Association/North America. woi Ling n t h th~..et.y-and--Heal-th-Department, Gffee of !lea~. The intent is to advise manufacturers and fabricators, who use asbestos friction Jl13i.erials, in manners of Work Practice best suited to the maintaining~a working environmentaa Cc-1,-r,a..Lmoep:lier.e l'lithin the levels required by 1910. 93a of the OSHA Standards ,\ o:fJ+, l. Asbestos Friction lu1.terial Products covered by this v1ork practice d:tl~...- ~~ recommendation: 1.1 Cl;Jtch Facings "- 1.2 Brake Lining Segments - l.'j- Disc Brake Fads l.z;- Brake Band J.:aterials 1.[, Automatic Tr2.l1.smission Discs "T" V-i<\\<.1-\ 2. l4anttf1:te-~g Operations ,.ure~ the recomr:1ended work practices may apply: 2.1 Clutch Assembly and Rebuilding Operations 2.2 Brake Ass~mbly and Relining Operations 2.3 Automatic Transmission Assembly and Rebuilding Operations ~s~-aL"l-f14/of'-Canst.r..u.c.:tien-Eqtl-ipment 3. Hequirements of OSHA Standard 1910. 93a ()r- pcl~f>.'(lll t-1 ~ :..'li ., rJ'-< Cl f I'll' c~ ,_.__s,. t..._,:rt:ill ).1 The Asbestos Standard (1910.93a~pPlies to~man~rb1g, fabrication or handling process ~vi~ article~composed wholly or in part of asbestos fibre ie=eena~~. ).2 It is the employer's responsibility to maintain 11Exposure to airborne concentration of asbestos fibres'' at or below the levels 9escribed in l910.9Ja. Exposure levels may be controlled byx ].solation, tmclosure, exr.aust ventilation and dust collection. ~ Standard l910.93a does not limit the means used to maintain complia.nce. 3 .3 Particular tools - All hand or power operated tools v1hich may cause the release of asbestos fibre to become airborne at levels in excess of the standard shall be provided with exhaust ventilationw- J,c-3.4 Wet Hethods - J. Hnen practicable asbestos f..-icti eH--materia.Ypr~ducts.-i:R.J_ shall be processcQ.;_'")wetted sufficiently to prevent emission"'"to ...working atmosphere. (Limited or not required >-rhere wetting of the product vmuld reduce end efficiency of tf!ttt product.) {[u 'v..il-lOJ ~\1 ~{L. 3.5 Protective Equipment and Clothing -A~ ~uch times hat it is necessary for employees to perform their normal work in an environ- ment wherein the airborne concentration of asbestos fibre exceeds the allowable level of ~tandard l910.9Ja, the employer must provide FMSI 06729 ; l ~t(:.I ' ?'~ :f' ~ ~ respiratory protection and clothine in compliance with the standard. The employer must also provide change rooms and separate lockers for '1-tork clothes and street clothes. ,3.6 Air Sampling and Honitoring- The employer is responsible as described in .3. 7 Storage 1910.9,3a. and Handling - It is reco~eId~AJ'tIhb~a~t(..a..s.obF estos-containing products be stored in sealed conta~s, ~ ~Pi~f ~s~nctl&asbestos-containing productsx the ham..l.l-..ffig shall be done in a manner to sroat(? the least ammmt of air- ~b.o'&rnGe.Ma-~~sb~e<si~Wols_()d.u4sAJt...t~h(- 71v ~J,<'(\f-I~O'"'i.".'J-;J7-!t:v:1~.t>=CNA".-d~A:r~~~:t>Nl..LJ~ ~l U17{f0t-.~f)1-<-' ~ 4. F..xhaust ana Dust Collection Systems. t;U..b,-J..a......u v,;.Jt._'ful."w-<.0'\A. tf ilz-u.,t-.I..M.c,t t,,..;._~,._t;;o:~l0'L h.l ~h~ exhaust and dust colle~tion systems are used to attain tclto. -11o.... .... concentrations of airborne asbestos fibre below the levels allowed in standard 1910.93a, the systems ~ be inspected and cleaned weekly. <;,~~L 1~->~:u.~.~.U\TtuN Mt. MA11J""("B\il.\f.LiE 4.2 ~ design1 of exhaust and dust collection systems (~ c-S~ta~no~aru~tt~).-~}1__~l~b)-euY~-dian....ua:.c.-ct.o.t.r.dG-a~nncne.1A~.Mi.ty h~rA-m~'r-ic~atn Nation~l o f-~o"- /- o~ E~J:_ S~ll...fe:Vl-\, ..r'L _e'I:'J...~~.d ~t\J,u:L-,.l,. 5. Housekeeprng, it."l1anuiacturing and Fabrication areas. 5.1 All surfaces, machinery, equiprrnt etc. shall be kept free of ~ accumulation of asbestos dust, lift'l-6:fl~- .u!stQ, preferabl1 by vacuum cleaning r...&t-h&is or other method that \Till prevent asbestos dust ?r X:ibre from becond.ng airborne. Vacuum cleaners should be equipped\with a disposable collection bag and a microfilter. 5.2 \~aste and scrap material, such as dust, chips, off-cuts, edge trim~gs and broken pieces shall be placed in~~ sealed containers in preparation for disposal. ~ 5.3 Containers used to store or dispose of asbestos-containing materials shall be labeled in a manner to comply with ~tandard 1910.93a.. 6. Procedure recommendations for manufacturD1G and fabrication operations involving asbestos friction materials. Ft:.IISitH. 6.1 Hherever pe-5s-ible, friction materials that are specially treated to reduce dust emission should be used. 6.2 Haterials should be removed from containers gently and handled with care to avoid unnecessary generation of airborne dust. Care should be taken not to disturb dust remaining in containers and packaging materials. Such dust should be removed by vacuum cleaning wherever possible. Fr:As.u;t...C FMSI 06730 7.5 Care should be taken to m1nL~ze dust generation and transfer of dust to the person or his clothing. Clothing not worn during working hours must be stored away from contamination, and contaminated work clothing shall be specially handled to prevent exposure to as[?estos dust. FMSI 06731 <!_ , . . . FA.St6LE" 6.3 Whehever p&ss~, materials should be obtained from the manufacturer cut, machined and/or drilled to suit final requirements to avoid necessity for additional fabricationoperations. 6.4 On large volume operations with fixed working poirits or machines, local exhaust systems should be installed in accordance with American National Standard ANSI Z9.2 or equivalent. 6.5 When cutting, drilling, grinding or machining operations are of short duration, portable dust exhaust units may be suitable. Vacuum cleaning equipment sometimes may be adapted for this purpose, provided the fi~r system is of adequate efficiency. 6.6 Where dust control by means of local exhaust is not feasible, flooding of the work and the tooling with water or other liquid may be effective in suppressing dust emission. f,?.J:.~,, ~lJ IS 6.7 Swaxf and dust should be removed regularly, preferably by vacuum methods, and disposed of in accordance with paragraphs 5.2 and 5.3... 6.8 If surface dust is present on materials, it may be necessary to remove it by wiping '1-Jith a damp cloth or mop or by vacuum cleaning with a brush head attachr<:!nt prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. 7 6.9 In-exceptiona1 cases where it is impractic~bl~to control ai~ borne dust by means of an exhaust system or by "'ret processing, workers must be protected by approved respirators and protective clothing. 7. Personal Protection. ~\ t 1 ~~~~ 7.1 Develop good personaL hygiene practices. Hashing thoroughly before eating will prevent ingestion of foreign matter. Food should \' ~l ~\\l k--L,.ra _1 not be stored or eaten in the- work area. . (,>l;} r ~cv~ ;,.\, .-tv..0L ~~"J~-J,_IP\1'0'"',)J--_--,?~,.2 hIetni-s-w-eelle_dtolcu~mre~nt~:."ed"bthiact ms~meokci-ng&sis_ainxjeur-ic.aucs ctoenytouura.hetaeltdh-. _r:\ ~- \,~.t.Ytt.vt"'~ Smoking should be avoided! Ju;-0\~"'\ ~~~J0~1 'J \-~ ~ f Q~r~ 7.3 Use of approved respirators should.be eRG9Urag~her~ver msuccahsurercaphirl.e.-.a:iJr.bt.o~rsnhe-aalslbbeestmosa-ndduastto-rcyonwoceon~t-rhaot.ri.onnes-.e.x-i-sH-tb,r.ea-n-d-lli.lmsie-tosf 1...--Lt..v. C)H}G~-e-'pl"'C"5-e-!4be<i-in Standard 1910. 93a. Protective clothing shall be provided and '1-mrn wherever employees are exposed to ceiling f\;l 0 levels exceeding those prescribed in Standard 1910. 93a. Employees must be given thorough instruction in proper use, care and maintenance of personal protection equipment. 7.4 No person shall be assigned to perform any work for which rcspilatory protective equipment is needed unless he has been medically eY~nuned and determined ~it. FMSI 06732