Document E1D70VD2Bb3kLeq6va0YRn6L

November 29, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 139 West Madison Street Suite 900 Chicago, Illinois 60602 ' Dear Mr. Lawton: I realize that by this time the Illinois Pollution Control Board may have already acted on the proposed asbestos regulations. As most of the domestic brake lining and clutch facing manufacturers are members of this Institute, we are particularly concerned with Part VII, Paragraph 702, of your Proposed Regulations on Asbestos: The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975 and sold for uso in Illinois is prohibited. We were able to alert our domestic members as to the seriousness of those proposed regulations. We ere aware that some of them expressed their views directly to you. In today's mail I recaived the attached from the British Friction Materials Council, an organization similar to ours in 8rit4Jn I think it is a well written,-carefully worded and, I believe, well documented presentation. Having worked in the brake lining industry for over seventeen years with asbestos linings and metal1ics, T believe their Item #2 is most pertinent. If one measures the amount of free asbestos fiber in brake lining dust, they say it is about 1# of the total products of wear. Wore you to go to a brake relining shop and collect the weer remnants, you would not detect fibrous raaterii in the wear products. The dust appears more to be like a talcum powder or flour with no fibrous structure evident. We trust that this work by the British Council bo considered when you are draft ing your final regulations. Sincerely, EWD/iob Enc: E. i. Drislane Executive Secretary FMSI 02884 October 24* 1*974 Hr. E. M. Fenner, Director Technical Relatione Du 1 j i h mental Affairs Dept. Johns-tiaavllle Corp. P. 0. Box 5106 . Denver* Colo. 80217 . Dear Ed: Attached is copy of revised draft of the Asbestos Friction Materials Work Practices sad a narked up copy of the original to indicate changes* all of ehtch 1 flonrtl er art nor. . Best regards* 1. K. Weaver w attach. ec-Meesrs. J. Marsh E. Drialane * C. Clarke PFMSI- 0C35 Recommended Work Practices for Users and Fabricators cf Asbestos Friction Materials ;j:is reco3=sndation of "Work Practices" is prepared by the Standards and Technical Cccrdttee of the Asbestos Information Associate n/liorth America. The intent is to advise manufacturers and fabricators, who use asbestos friction materials, of Work Practices best suited to maintaining a working environment within the levels required by 1910.93a of the OSliA Standards (copy attached). 1. Asbestos Friction Material Products covered by this work practice recommendation: 1.1 Clutch Facings 1.2 Brake Lining Segments 1.3 Brake Blocks l.A Disc a rake Pads 1.5 Brake Band Materials 1.6 Automatic Transmission Discs ' 2. Operations to which the recommended work practices say apply: 2.1 Clutch Assembly and Rebuilding Operations ' 2.2 Brake Assembly and Relining Operations 2.3 Automatic Transmission Assembly and Rebuilding Operations ' 3. Requirements of OSHA 1910.93a. 3.1 The Asbestos Standard (1910.93a) applies to any manufacturing, fabrication - or handling process or operations involving articles or materials composed wholly or in part of asbestos fibre. 3.2 It is the employer's responsibility to maintain "Exposure to airborne concen tration of asbestos fibres" at or below the levels described in 191C.93a. Exposure levels may be controlled by isolation, enclosure, exhaust ventilation and dust collection. Standard 1910.93a 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 become airborne at levels in excess of the standard shall be provided with exhaust ventilation. 3.1 Wet Methods - When practicable asbestos products shall be processed-wetted sufficiently to prevent emission of dust to the atmosphere. (Limited or not required where wetting would reduce end efficiency of the product.) 3.5 Protective Equipment and Clothing - Whenever it is necessary for employees to perform their normal work in an environment where airborne concentration of asbestos fibre exceeds the allowable level of Standard 1910.93a, the employer must provide respiratory protection and clothing in compliance with the standard. The employer must also provide change rooms and separate lockers for work clothes and street clothes. 3.6 Air Sampling and Monitoring - The employer is responsible as described in - 1910.93a. TT Storage a-"- i-.ar.dl- - It is rescmmcr.ats:: trat is:esL:s-:rr.-,,a_.-.i. be stored in seaic: ; containers, Handling of asbe3to5-cor.tair.in shall be done in a manner to minimize generation of airborne as Si. 3.8 Caution Signs and Labels - The employer shall use caution signs and labels in accordance with provision of Standard 1910.93a* 4. I>_iaust and Oust Collection Systems 4.1 v.'herever exhaust and dust collection systems are used to attain concentrations cf airborne asbestos fibre below the levels allowed in Standard 1910.93a, the systems shall be inspected and cleaned at least weekly. 4.2 Lesion, installation and maintenance of exhaust and dust collection systems shall be in accordance with American National Standard Fundamentals Govern in' Design and Operation cf Local Zxhaust Systems (AJ.'SI 29*2) or equivalent standard. >C Housekeeping ir. Manufacturing and Fabrication Areas: 5.1 All surfaces, machinery, equipment, etc. shall be kept free of accumulation of asbestos dust, preferably by vacuum cleaning or other method that will prevent asbestos dust or fibre from becoming airborne. Vacuum cleaners should be equipped with a disposable collection bag and a microfilter. 5.2 Y/aste and scrap material, such as dust, chips, off-cuts, edge trimmings 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 Standard 1910.93&* ,. Seccmended Procedures for Manufacturing and Fabrication Operations Involving ` Asbestos Friction Materials: ' 6.1 V.'herever feasible, friction materials that are specially treated to reduce dust emission should be used. 6.2 Materials 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 feasible. 6.3 Wherever feasible, materials should be obtained from the manufacturer cut, machined and/or drilled to suit final requirements to avoid necessity for additional fabrication operations. 6,L On large volume operations with fixed working points or machines, local exhaust systems should be installed in accordance with American National Standard ANSI Z9.2 or equivalent standard. 6.5 When cutting, drilling, grinding or machining operations are of short duration portable dust exhaust, units may be suitable. Vacuum cleaning equipment. some times may be adapted for this purpose, provided the filter system is of adequate efficiency. 6 6 Where dust control by means of local exhaust is net feasible, flooding cf * the* work and t'nc tooling with water or other liquid ray be effective in suppressing duat emission. 6.7 Fragments and dust should be recoved 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 nay be necessary to remove it by wiping with a danp cloth or mop or by.vacuus cleaning with a brush head . * attachment prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. 6.9 Where it is impractical to cort rol airborne dust by means of an exhaust system or by wet processing, workers rust be protected by approved respirators and protective clothing. Personal Protection 7-1 Develop good personal hygiene practices. Washing thoroughly before eating will prevent ingestion of foreign matter. Food should not be stored or eaten in the work area. ' 7.2 It is well documented that smoking is injurious to your health. The ill effects of smoking ray be accentuated for those working where airborne asbestos dust ray be encountered. Smoking should be avoided!. 7.3 Use of approved respirators shall be mandatory-when required by CSKA Standard 1910.93a. Protective clothing shall be provided and worn wherever employees are exposed to ceiling 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 Ko person shall be assigned to perform any work for which respiratory protect ive equipment is heeded unless he has been medically examined and determined fit. 7,5. Care should be taken to minimise 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 asbestos dust, as prescribed in Standard 1910.93a. hecc=r.enced r-ork Practices for Users and Fabricators of Asbestos Friction 'laterials -Iireroduafeifln This recommendation of "Work Practices" is prepared by the Standards and Technical Coasittee of the Asbestos Information Association/North America, wari:i_i0 ..ith las SeeurHiianl Safety--and-Health ^Department, Off!?* *r `The intent is to advise manufacturers and fabricators, who use asbestos friction materials, in manners of Work Practice best suited to the maintaining-ka working environmental. i-gre within the levels required by 1910.93a of the OSHA Standards 1. Asbestos Friction 'material Products covered by this work practice recommendation- <viiKtL; ^ 1.1 Clutch Facings 1.2 Brake Lining Segments l.fj- Oise Brake Fads 1.S' Brake Band Materials l.g, Automatic Transmission Discs ' . . `Te V.HKH , 4 Ijanufactuging Operations rngirin the recommended work practices nay apply: 2.1 Clutch Assembly and Rebuilding Operations 2.2 Erake Assembly and Relining Operations 2.3 Automatic Transmission Assembly and Rebuilding Operations zrrk--~~r.~ riOfinr'~*ir n~ InrTg~-in~ nori/p- l~-imtn;r`-anr ^rrilp iimti j> Requirements of OSHA Standard 1910.93a 3.1 The Asbestos Standard (1910.93* fabrication or handling process aJNfT v wholly or an part of asbestos- fibre i &S- ftl __ ^ If plies to-^any manufacturing, ' article*composed aasaad.. 3.2 It is the employer1 s responsibility to maintain "Exposure to airborne concentration of asbestos fibres" at or below the levels described in 1910.93a. Exposure levels may be controlled by*, jusclation, enclosure, exhaust ventilation and dust collection. -ss Standard 1910.93a does not limit the means used to maintain compliance. 3.3 Particular tools - AH hand or power operated tools which may cause the release of asbestos fibre to become airborne at levels in excess of the standard shall be provided with exhaust ventilation^^ 3.4 Wet Methods - When practicable asbestos friction mater iny'products.^g-flj. shall be processed^)matted sufficiently to prevent emission-'to .working atmosphere. (Limited or not required where wetting of the product would reduce end efficiency of tfwt product.^ tilWVlffllCA. 3.5 Protective Equipment and Clothing - At-such times that 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 Standard 1910.93a, the employer oust provide Y respiratory protection and clothing In compliance with the standard. Tne employer must also provide change rooms and separate lockers for work clothes and street clothes. >* I w :5> 3.6 Air Sailing and Monitoring - The employer is responsible as described in 1910.93*. tv 3.7 Storage and Handling - It is recojscfended that asbestos-containing products be stored in sealed containers, Surlr.g-rcraess of "-if *ha1r as rr nag-iary^tc handle*mhntm rnntnining products* the hem&irftg shall be done in -a manner to Brest** the least irnunt of air borne asbestos dust. 1.1 ' 1 ft t C ' AJULt CaiZIuvkf/UA. A*~k kj4j^U.U-, L. Sxhaust ana Oust Collection Systems. Qjtc\Li**i i^v2a Lvxu^tvka. c Suwa 1.1 -Wheroin exhaust and dust collection systems are used to attain concentrations of airborne asbestos fibre below the levels allowed in standard 1910.93a, the systems should be inspected and cleaned weekly. 1.2 =*s design of exhaust and dust collection systems fl-ntn'Hatirm -* - -- \ snail be in accordance with American national A<- 7 Standard S~lun-ctA~%i Gvrtvmint/ /\ tAUy*^. O issuJtin*. -/- A-*+. ' i, /ijSuuLuvC * . Housekeeping, in: MlaannuuT^accttuurring and Fabrication areas. 5.1 All surfaces, machinery, equipment etc. shall be kept free of any accumulation of asbestos dust, lint anti^vas-gta, preferable by vacuum cleaning nethcMae or other method that will prevent asbestos dust or fcibre from becoming airborne. Vacuum cleaners should be equipped*with a disposable collection bag and a microfilter. 5.2 Haste and scrap material, such as dust, chips, off-cuts, edge trimmings and broken pieces shall be placed in Jfcsghtfcf sealed . V- containers in preparation for disposal. 'S 5.3 Containers used to store or dispose of asbestos--containing materials shall be labeled in a manner to comply with standard 1910,93*. . .` 6. Procedure reconcnendations for manufacturing and fabrication operations involving asbestos friction materials. FckifAtiT L.1 Wherever possible, friction materials that are specially treated to reduce dust emission should be used. 6.2 Materials 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. * ' FCAUtii.iT Y 6.3 Whenever /p-e|eSsli6sLAce, materials should be obtained from the manufacturer cut, machined and/or drilled to suit final require ments to avoid necessity for additional fabrieationoperatioiu. 6.4 On large volume operations vith fixed working points 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 say be suitable. Vacuum cleaning equipment sometimes may be adapted for this purpose, provided the filJSr 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. * 6.7 Swarf 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 with a damp cloth or mop or by vacuum cleaning with a brush head attachrent prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. '7 6.9 t**-*^-^where it,is impracticable-to control air borne dust by means of an exhaust system or by wet processing, workers must be .protected by approved respirators and protective clothing. 7. Personal Protection. 7.1 Develop good persond. hygiene practices. Washing thoroughly before eating will prevent ingestion of foreign matter. Pood should 4v ,, . not be stored or eaten in the work area. . 50! S1 'Jb^ /7.2 It is well documented that saokins is injurious to your health. ^ N^lvherr eewpled with-*ebest>ea lust problcms-i -the effects--are-eccentoattsdvy*. ^smoking should be avoided! 7.3 Use of approved respirators should,hs encouraged whenever measurable--airborne--asbestos--dust--concentrations--exist, ..and-use--of . rrriTH<-"- shall be mandatory wherever airborne fibre-limits trvi*^ . I* Obtnw- exceed thoae-puacribed-Aa Standard 1910.93a. Protective clothing shall be provided and worn wherever employees are exposed to ceiling 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 pereon shall be assigned to perform any work for which respiratory protective equipment is needed unless he has been medically examined and determined -fit. 7.5 Care should be taken to ciniadze cust Generator, and transfer 0r dus* te the person or his clothing. Clothing not worn curing warkinc hours nust be stored away from contamination, and contaminated vork clothing shall be specially handled to prevent exposure to asbestos dust. T