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3?SftT ON FKSI ASBESTOS STUDY COKKETTEE ACTX7ITIE5
The Asbestos Stud? Committee vas formed July 1971 wish the assi^.ed purpose to review and cosmsr.t on rules and regulations promulgated by state ar.d federal governments concerning
assesses and Ids applications.
The first Committee seating vas held September 15, 1971 and was chaired by Dr. E. P. Stef! of ?.ayreases-Manhattan, with members from Wsrldbestos, ibex, Bendix^ami Carlisle Corporation and J-M present. The following itess were reviewed and/or discussed: (1) Eslatic.-.ship vith Asbestos Information Association/foortb America. (2) Proposed Ulino: Regulations. (3) Vehicle friction material emission test program to be conducted by
Ser.dix under 2?A_ contract. (4) Fbnitoring for airborne asbestos fibre. (5) Districution end circulation cf literaiure on Asbestos/Health subjects.
The purpose of the Asbestos Study Ccamittee vas restated as followsi "to., gather and dessinate to its nepers infomation about pending regulations concerning asbestos is. the work place (occupational exposure) and in the general environment(particulate eaissio: and to draft comments relative to proposed regulations in defease of reasonableness."
The following is a list of the actions taken by the FKSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971:
September 30 - Issued minutes f first Cousaltteo meeting uith letter cowtfnting on proposed Federal EPA and Illinois emission standards.
October 23 - Issued bulletin and further information on Illinois hearings.
Coveuber 10 - Issued information on membrane filter monitoring method.
Esveaber 14 - Issued bulletin on revisions to Illinois and Federal EPA jn^pesals.
December S - Issued information concerning final draft of proposed Illinois regulation, proposed EPS emission standards, and Federal Department of labor He relations on Occupational Exposure.
On January 26, 1972 arrangements were announced for Bill Eeitze of J-H to conduct an instructicr. session on asbestos fibre monitoring at FKSI headqcartars February 10. On February II this session was presented to nine attendees representing six member companies.
The secend Asbestos Study Committee nesting also was held on February 10 .with. I., K- Weave: E&ytsstcs-Mar.h&tc&n, acting as chairman and members representing VJorldbestos, J-M, Bendix ar.d Carlisle attending. The following items were covered:
1. r.ev-iev cfAlA/MA comments regarding CSHA meeting in Washington on January 26.
I. Herisv cf prepssec OSHA asbestes standard and comparison with British standards and regulations.
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It was resulved tc ferward to
Study Committee nestings.
Material Council comments cn Illinois standards. FKC copies cf minutes of future FKSI Asbestos
t. r.ecsnr.sr.datitr. made that the FM3I Asbestos Study Committee maintain close liaistr. with AIA /lIA.
?.*viev*d background and expected thrust of OSHA -ad E?A regulations. PLAINTIFFS
EXHIBIT
WV-Q606f
WV-06061
3. .".8 Viewed rtiCnitmrg equipment and methods.
?. Recommended future course for Asbestos Study Cosaaittee.
The f:Hewing is a summary of actions taken by the Executive Secretary during the first half cf 1??2 in regard ta Asbestos Study Committee matters:
February IS - Circulated Bulletin 127 regarding various standards for asbestos dust exocsur* and control*, this included copies of the January 12 Federal Register annr-xeemsnt of proposed permanent CSHA standard for asbestos control in the work place.
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February 13 - Issued Bulletin L2S reporting on February 10 demonstration by ttcv Halt of membrane filter aonatoring method.
June 1 - Circulated announcement of Microseopy Seminar scheduled by MeCrone Research Institute in Chicago week of June 26.
June 6 - Circulated supplementary information received from Illinois Institute of Technology Research Institute regarding friction material emissions and issued testable schedule for third Cccaittee meeting to be held late July or August..
**June 12 - ZsTCsd'anaonrcfnmt of OSHA nerr^nert "standards' on' asbestos duafe^cciurs as published in June ? Federal Register.
The latter item has been rather intensively studied by your Chairman, by AX&/fc&, aadno doubt also by concerned individuals in practically all companies represented in. FKSI. The consensus appears `to be that the new regulation is stricter than need be-in respect to the future TL7 of 2 fibres per cc, but is more lenient than was expected in regard to zany other important Batters. Major changes between the new regulation and the earlier emergency standard end earlier proposed permanent regulations are am followss
..4 Automatic reduction of TLV to 2 fibres in four years.
2. Use of protective clothing required above 1C fpcc ceiling limit. Change rooms,
dual locker facilities, and special laundering and clothing handling procedures
required. '
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3- Kcr.itcrir.g required at least every six months at operations exceeding allowable
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1. Physical exam and doctor's approval required before assigning employees to jobs requiring use cf respirators.
7" --aticr. cf references to cancer" and ,sdanger'* on signs and labels. Labeling
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eliminated for products containing locked-ir. fibre.
i. itssific restrictions cn ''dry sweeping" and eliminated.
; ;*dieal erjLtinatior.s, all anticyses exposed to dust.
A Imclcyes access :: medical ar.d mcr.itoring rlevels sieve 717 must be notified ir. writin
c. lists containing only lacked-in fibre need
Vhile zany series difficulties are expected in achieving compliance with, the new regulation
by miners, textile =ar.ufacturer3, and insulation fabricators and installers, it appears
to ce that asst friction material manufacturing operations not relying on textile technelag
should hare relatively little trouble, although some dry mold type friction operations say
else case ortolans.
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?erh*os of * rere serious nature is the potential threat of banning of asbestos in`friction materials, particularly:ln:automotive-vehicles,- to eliminate*emissions fren veer debrisT. It is doubtful that any further action in this direction will be taken until results of the comprehensive study by Sendix Corporation for EFA have been announced. I have been adviged that.this study, originally to have been completed this month, now is not expected, to be finished ur.tij late this year.
M>at of the difficulties that arose in this study to date have occurred in connection with ' the gas collection phase of the program. Since the study involves collection and analysis
of g sseous emissions as well as particulates, precision rotary seals and gas collection systems had to be developed and evaluated, and this has necessitated extensive and time censuring engineering design efforts.
Another vital Sri program also is running behind schedule. That is prcrailgstion of the permanent regulations and standards for asbestos emissions to-the ashiest-atmosphere*----
T have been advised by the FA hazardous Pollutants Breach-that...thgL earliest- date-these standards are ejected to be issued is the beginning 01 August, ane they* could b~dlayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operates. Significant changes are expected in the sections applying to mining and spraying operations. Probably the only significant
change between the proposed regulation and the ejected final regulation &a far an jeanufacturing operations are concerned is the broadening of specifications on fabric filters and vet dust collectors. This should be helpful to industry in permitting soaewhal
rare flexibility ia dust collector selection and application.
Before closing, I should like to recosnend a few of ay thoughts and sug^stions that l have received iron others concerning items that should be considered and reviewed by the Asbestos Study Committee during the following year.
1. CSifcm interpretation of CSHlTstandards" liaison vifcli AiA/faTwill be.
helpful 1-rthia. : * -
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2. leteruiratisft cf technological feasibility of achieving both Z and 5 fibres . throughout tha industry.
j. ^termination cf the overall effect on the friction naterial industry of -.he C2&A stirsards.
5. laveliprsr.t cf guidelines, aids, and educational programs to help customers sourly with the.regulations.
i. Ir.vestigats a suitable standard method for analysis for asbestos in brake lining
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7. Isvalor rathods and recaraendations for safe disposal or recycling of friction
- 7; 11;v as closely as possible nedical and occupational health research conceminr asbestos and asbestos-related diseases and determine whether tVSL or its messier oorrtniss shsuld...ielp. sponsor or otherwise suppofcj* work of-this nature*-- .
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All of lsubject* probably >111 be reviewed at the third Asbestos Study Ccaaittee feting to be scheduled within the neact sonth or so. Please advise us of any Additional itess you or others in your organization say wish to add to our agenda for this upconing seating.
Respectfully submitted, ~.U H.* Vaverr Chaiiwan
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