Document BvdMvKqwdxB7XBqM709NdY1Jj

Room 512 friction *YYIateriafd d^tanclardd ,ndliiule *3nc. 370 LEXINGTON AVENUE NEW YORK, N. Y. 10017 MUrray Hill 3-0572 January 26, 1972 To: Members of Asbestos Study Committee Subject: Meeting February 10, 1972 Gentlemen: In separate correspondence, I have indicated that Mr. W. B, Reitze of Johns-Manville will give a session on monitoring asbestos fibers in the air. This session, at which 8-10 people have indicated that they will attend, has been scheduled at the new Institute Office in Paramus, New Jersey for 1:30 P.M. on Thursday, February 10, 1972. As some of those planning to attend this 1:30 P.M. session are also members of the Asbestos Study Committee, it is felt that this is an opportune time to schedule a meeting of this Committee in the morning. While some items on the agenda will be historical - the Illinois Pollution Control Board hearings, Environmental Protection Agency Proposed Emission Standards, and Occupational Safety and Health Act Standards - - the main item for the Committee to consider is the direction it wishes to take. Should it get involved in commenting on proposed requlaticns concerning asbestos, or should it serve more as a monitor to keep the membership advised? Ourneeting is scheduled for: 9:30 A.M., February 10, 1972 at the new Institute Office in Paramus, New Jersey. For help in finding the new office, a 7 page "publication" is enclosed concerning our new location. Sincerely, . EWE/erc Enclosure: E. W. Drislane Executive Secretary Messrs. J, H. Weaver J. C. Henning E. H. Feierabend W. B. Reitze W. Spurgeon J. B. Graham, Jr. L. D. Stickles, Counsel Raybestos-Manhattan, Inc. Firestone Tire & Rubber Company Abex Corporation Johns-Manville Corporation The Bendix Corporation Carlisle Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh FMSI 06611 . C'l FRICTION MATERIALS STANDARDS INSTITUTE. INtl. 210 ROUTE #4 PARAMUS. N.J. #07652 January 14 1972 To: Members of the Asbestos Study Committee Subject: Department of Labor - Proposed Standard for Exposure to Asbestos Dust. I am attaching a copy of the proposed rule making on Standard for the Exposure to Asbestos Dust. This notice appeared in the Federal Register of January 12, 1972 (466-468). This is forwarded to the Committee members for their information. Edward W. Drislane Executive Secretary Messrs.: I. H. Weaver J. C. Henning E. H. Feierabend W. B. Reitze W. Spurgeon J. B. Graham, Jr. J. W. Greenen, President L. D. Stickles, Counsel Raybestos-Manhattan, Inc. World Bestos Company Abex Corporation Johns-Manvilie Sales Corporation The Bendix Corporation Carlisle Corporation Maremont Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh FMSI 06612 Abex Corporation American Brakeblok Division 900 WEST MAPLE ROAD. TROY. MICHIGAN 48084 January British Friction Materials Council 99, Aldwych London, WC2B 4JY A a/ iA' Gentlemen: Your letter of December 8, 1971 addressed to the Society of Auto motive Engineers regarding your views on the proposed Illinois State Regulations concerning asbestos products, has been forwarded to me. I apologize for the somewhat slow acknowledgment of your letter but wanted to discuss it at our Subcommittee meeting which is held during the SAE Annual Congress in Detroit. We appreciate very much your comments and some of the attached infor mation was new to us and of considerable Interest. There are, however, two things with which you should be aware if you have not already been advised. First, the Illinois Pollution Control Board has with drawn the proposal covering the banning of asbestos in brake lining. This was due principally to the fact that a number of brake lining manufacturers presented data along the same lines you furnished in that there is insufficient proof that products of wear from asbestos brake lining do cause any harmful levels of pollution. The second fact that you probably are not aware of, is that the Society of Automotive Engineers do not comment in any way on any proposed legislation. The position of SAE is quite simple in that their task is to develop recommended practices and standards which are for the use of anyone including government agencies. They definitely do not take any stand or any position with regard to any proposed or actual legislation. This very firm policy is the reason why SAE would not forward your comments to the Illinois Pollution Control Board. As it turned out, because that proposal covering the use of asbestos in brake linings after 1975 was dropped, it was not necessary to forward this information. I am taking the liberty of sending a copy of your attachments to the Friction Materials Standards Institute, Inc., as they were active and instrumental in getting this proposal removed. I am sure they will be interested dn this data for their files. In the future when you have FMSI 06613 i~b<"x British Friction Materials Cornell - 2 - January 14, 1972 continents regarding legislation dealing with brake linings X would suggest you direct your comments to that organization. I am also talcing the liberty to send a copy of this information to Dr. M. Q. Jacko of Bendix Corporation, who is doing work along this line and is the representative from the brake lining sub committee on the SAB Particulates Committee studying the amounts and the effect of asbestos in the air. Thank you again for your interest and comments, and if we can be of any further help please do not hesitate to get in touch with us. Sincerely, REN:nm R/E. Nelson Chairman SAE Brake Subcommittee 2 cc: Messrs. L.P.Ziegler, Jr. -- SAE - Detroit E.W.Drislane Friction Materials Standards Institute, Inc. Bergen Mall Office Center (new address) E* 210, Route 4, paramus, New Jersey 07652 Dr. M. G. Jacko Bendix Corporation - Research Lab. 20800 Civic Center Drive Southfield, Michigan 48075 FMSI 06614 British Friction M aterials Council BAKER, ROOKE & CO. Chartered Accountants tiuphoni: 01*242 0211 AIR MAIL 362/m/BFMC The Society of Automotive Engineers, 2 Pennsylvania Plaza, New York, N.Y.10001, U.S.A. Inc., .99, Aldwych, London, WC2B 4JY 8th December, 1971 Dear Sirs, We have been asked by our members in the British friction materials industry in the U.K. to put their views to you on the proposed Illinois State Regulations concerning asbestos and asbestos products. We enclose herewith their comments on the friction material aspect of these draft Regulations. We have no doubt that the American lining manufacturers will be making strong representations to the Illinois authorities for amendments to the proposals and we shall be grateful if you could make our views known as set out in this enclosure. Yours faithfully. Secretaries Enc FMSl 06615 PROPOSED ILLINOIS STATE BAN ON ASBLSTOS-BASED BRaKK LININGS The British friction materials industry views with deep concern the proposed ban on the use of asbestos in brake linings by the State of Illinois. ' It is not aware of any medical evidence that could possibly justify * such legislation. On the contrary it would have the effect of withdrawing from the market products that were used to promote road safety, without producing any significant improvement in the levels of urban atmospheric pollution. It would expect any of the known alternatives to asbestos to produce general particulate pollution of a measurable amount. 1. Whatever materials are used for brake linings the current state of the art is such that the action of braking will generate products of wear. The asbestos content of conventional brake linings is almost entirely converted by the action of braking into forsterite or other amorphous, inert materials which are no longer asbestos. On the other hand, if non asbestos alternatives are used (e.g. iron powder, sintered metal, ceramics, steel wool etc.,) the resulting wear products will be released unchanged. 2. Measurements have been made of the amount of free asbestos fibre left in brake lining dust. It i6 an insignificant proportion of what is in any case a minute amount of total dust. The amount of free asbestos, fibre that has been found in brake lining dust from vehicles, is about 15 of the total products of wear. (l). Indeed estimates vary down to 10-9g/g, i.e. for each gramme of wear products only 10-9 grammes of free asbestos may may remain. 3. We assume that the risk of contracting mesothelioma is the principal cause of environmental concern - there is clearly no possibility whatever as a result of vehicle braking, of a community risk of asbestosis or lung cancer, which are solely occupational risks. For technical reasons only chrysotile asbestos is used in the manufacture of brake linings and disc brake pads. ThiB is not the type of asbestos with which mesothelioma has been mainly associated. 4. Measurements of chrysotile asbestos in the ambient air in an industrial centre in the United Kingdom have shown that the level must be less than 10"? g/m3 because of the limitations of the method used. This means that they must be a thousand times lower than the British Government acceptable level for occupational exposure. Current -investigations using a more sensitive method indicate levels of 10"^ to 10""' g/m^, i.e. 2 or 3 orders lower still. (2). Brake lining wear cannot therefore be a serious source of atmospheric pollution. . 3. In one of the largest brake testing laboratories in the world, housing many dynamometers engaged 24 hours a day in wearing away friction materials, the average monthly asbestos count is 0.2 fibres /cc, a tenth of the British Government's occupational standard. Footnotes FMSI 06616 1. Hickish D.E. and Knight K.L. (1970) Annals of Occupational Hygiene Vol.13 No.1, page 20. 2^\' ( | j Letter to Nature attached. British Friction Materials Council 26th November, 1971.i i - .... t. ... . NATURE VGL 234 NOVEMBER U 1971 93 Chrysotile Asbestos in Urban Air The industrial use of chrysotile asbestos is increasing and the question of whether its concentration in urban air constitutes a hazard has been raised. But measurements of asbestos in air near asbestos factories have proved negative with present analytical methods, so under the sponsorship of the Asbeslosis Research Council we are developing a more sensitive technique. This article is a preliminary account of the estimation of chrysolite near a large, asbestos textile factory at Rochdale, Lancashire. There arc several uncertainties in the technique, so wc. were, expecting to obtain only an order of magnitude estimate. Nevertheless this would have been an important figure to have because of the lack of data on the amount of asbestos in air. As it happened, we were only able to determine an upper limit for the chrysotile concentration which turned out to be three orders of magnitude lower than the threshold value for occupational exposure set by asbestos regulations. Obviously even more sensitive techniques are required and are now being developed. We used an X-ray diffraction technique based on the measure ment of the integrated area under the'(002) peak of chrysotile. The equipment, which consisted of a Phillips 1010 generator, a vertical goniometer with a step scanning attachment, and a proportional counter with pulse height discrimination, could be reliably calibrated down to 10 pg of chrysotile compared with the 1 to 10 mg range reported by Crufcle1, and was cross checked by estimating the magnesium content of the calibration samples by atomic absorption spectroscopy. Sampling involved the collection of airborne solids from 1,000 mJ 110" Id of air by an electrostatic device (H. Litton Systems Inc.) in which up to 10,000 1. min'1 are drawn through a 20 kV corona discharge. Particles in the air are electrostatically precipitated onto a plate and concentrated into ~ 100 ml. of liquid. The collection efficiency depends on the size distribution of the particles and the sampling rate, but the size distribution of chrysotile in the atmosphere is not known. Therefore we estimated the collection efficiency indirectly by running the sampler in part of the asbestos factory where a low concentra tion of asbestos is known to occur (Fig. 1) and we found the collection efficiency to be almost 100% when the air is sampled at about 2,000 l. min-1, dropping to between 25 arid 50% at the rate of 10.990 I. min ', depending on the actual size dis tribution present. As we were aiming at only ah order of magni- FMSI 06617 94. NATURE VOL 234 NOVEMBER 12 1971 Tab!* 1 Vaoxther Conditions ilunny Sampling Date (1970) Site WmJ Weather April 22 1 SW moderate April 24 April 27 i SW slight Ground hare 1 NE moderate April 29 1 SW moderate Ground hare May 6 1 S strong Ground haze May 13 1 N fresh May 23 3 \V light Overcast, dull May 28 May 30 3 W light 4 W light Overcast, dull Overcast, dull May 30 June 3 4 W light 2 SW light Overcast, dull June 10 2 SW sliuht Heat haze June 10 2 SW slight Heat haze October 23 i W moderate Broken cloud October 23 1 W moderate Broken cloud October 23 i W moderate October 28 1 N light Broken cloud October 28 i N light Broken cloud October 28 1 N light Broken cloud ' tude assessment of asbestos in urban air, we were prepared to - -Nr'accept this uncertainty in the collection efficiency. The map (Fig. 2) and Table I show the location of the sampl. ing sites and the conditions in which the samples were obtained. The factory is in a hollow, and sampling sits No. 2 is at the : same height as the roof of the filter gallery, which is the chief air o t from the factory. Sampling site No. 1 is about 30 foot higher than site No. 2. Sites 3 and 4 were in the gardens of houses, site 3 being about 5 km upwind of the factory and site 4 being about 300 m downwind. AU the diffraction traces (for example. Fig. 3) contained strong lines of kaolinite and quartz, probably from the local soil, which made the assessment of chrysotile difficult because ihe broad (001) line of kaolinite (7.18 A) is close to the major (002) line of chrysotile (7.36 A). Fortunately chrysotile is easily decom posed by boiling in 1 N hydrochloric acid whereas kaolinite is unaffected, so it should be possible to measure the amount of chrysotile present by subjecting the samples to acid leaching and measuring the corresponding reduction of the intensity of the composite X-ray band. The fact that this process led to _ no reductions in band intensity for any of the samples indicated that the amount of chrysotile present was below our detection limit. We ought to have been able to detect 10 pg of chrysotile by itself, but dearly the presence of kaolinite may have reduced the sensitivity. But the addition of 100 pg of chrysotile to our collected samples could easily be detected, so we can say that our samples collected from 1,000 nr' of air contained less than 100 pg of chrysotile--in other words, there was less than 0.1 pg of chrysotile per m2 of air. The threshold limit for occupational exposure set by the 1969 Asbestos Regulations2 is O.f mg m"3. epartz quartz *20 (CuK) Fig. 3 X-ray diffraction pattern from a typical dust sample near the Rochdale factory. Fig. 2 Plan of T.D.A. factory, Rochdale. The sampling sites arc indicated by the arrows I and 2. /', Position of the chief filter gallery exhausts. A more sensitive method for estimating chrysotile is required, and we are developing a technique based on electron micro scopy. Preliminary examinations under the electron micro scope of samples collected by the Litton sampler indicate that the actual chrysotile level may be a further three orders of magnitude below the X-ray detection limit (that is, about 0.1 ng). . The samples have so far been collected in the close vicinity of the Rochdale factory. It is now proposed to sample air at certain representative urban and rural locations in UK and estimate their chrysotile content. A. L. Rickards D. V. Badami Turner Brothers Asbestos Co. Ltd, PO Box 40, Rochdale, Lancashire Received April 18; revised September 22, 1971. \ Crablc. J. V., Amcr, bid. Hie. Assoc. J., 27, 293 (19G6). 2 Standardsfor Asbestos Dust Concentration for Use * ah the Asbestos Regulations 1961), Technical Data Sale ii(UM Factory inspec torate. 1967). FMS1 06618