Document GmoQ7RMX29BpvkaNeaQKEoM7n

PLAINTIFFS EXHIBIT I I II 1 V iI I i I I 4 i 1 VACUUM CLEANER EVALUATION AMERICAN CLEANINC EQUIPMENT CORP. Addison, Illinois 3ayton Biwonmental Consultants, Inc."' INTRODUCTION American Cleaning Equipment Corporation retained Clay> ton Environmental Consultants to conduct an evaluation of a vacuum cleaner identified'as "Model No. 3S0-15A." The primary purpose of the test was to determine the effectiveness of the unit for containment and control of emissions of asbestos during use in cleaning asbestoscontaining dust. It is understood that these vacuum cleaners are intended to be used in automotive service centers for dust cleanup associated with brake rebuild ing operations, including the removal of dust from brake drums end dust produced by grinding and filling of brake shoes. Results of this evaluation, conducted by Mr. Dennis D. Eacbst of Clayton Environmental Consultants on May 19, 1976, are presented in this report. DESCRIPTION OF TEST PROCEDURE The spatial Arrangement and relative locations of the vacuum cleaner, air sampling devices, and operators are shown in Figure 1. The tests were carried out in a rela tively small confined room (room volume was approximately 800 cubic feet) which was sealed to prevent air movement into or out of the room during each test. The only cir culation of air within the room was that generated by the exhaust action of the vacuum cleaner. These conditions were imposed for the purpose of maximising the severity of use conditions. - During each of three tests, the operator of the vacuum Cleaner cleaned approximately ten pounds of asbestoscontaining brake duit (c.-scribe;' below) from a cardboard container placed on the :"*eor e' the room. During each . test, one air sample was taker, in the breatning tone of the operator and two arc* a m p i c s were taken at stationary PQ8005 1582 PRODUCED BY FORD SCF-ALLF-06010 Clayton tmironmental Consultants, Inc. 4 2- - locations equidistant from the vacuum cleaner exhaust port. An additional area sample,' located in the. north, east corner of the room, was taken immediately after the vacuum cleaner iss turned off. The room was then venti lated for approximately two hours to minimize the possi bility of interference with subsequent tests. To reduce the possibility that fibrous dust, which might normally he present in the indoor air, or fibers generated by a previous test might interfere with the analyses of the test samples, "control" samples were taken immediately prior to each of the tests before any hand\ing of the asbestos-containing dust. ' Since it would be difficult, if not impossible, to simu late with a commercial asbestos product actual "brake dust," with respect to particle and fiber size distribu tions end thus to simulate the efficiency with which the fibers were removed by the- vacuum cleaner filtration sys tem, it was desirable to use for the evaluation actual asbcstos-containi r.p. dust generated in a manner similar to that associated with automobile maintenance procedures, c.g., grinding of brake shoes. A bulk sample of dust pro duced by grinding of brak-. shoes was obtained from a local automotive a:;lc plant. This dust had been collected by fabric filters incorporated in the plant's local exhaust ventilation systems. The physical appearance of the dust was that of a very fine, dry, Ri'iyish-brovn powder simi lar in consistency to talcum or face powder. No other dust was mixed with the brake dust during or after en trainment by the exhaust-fi11rat i on systems. The dust was analyzed in the Clayton laboratory for percent fiber and fiber length distribution by phase contrast micro scopy at 400X magnification. The results indicated that the dust was composed of approximately 19.4 percent fiber (i.c. , fiber to particle ratio), and that fiber lengths ranged from approximately four micrometers to greater than fifty micrometers. Apprcximate1y four percent of the fibers were less than si:: micrometers in length, about forty-two percent measured betwter six end twelve micrometers, and the remaining fifty-iour` percent meas ured greater than twelve micrometers in length. sampling and analytical methods both general jrve and breathing zone samples were col lected by droving air at a nominal flowrate of two liters p:r minute through Is 7. mm- diameter cellulose eater mem brane filter.- : Mi ) 1 i oorv, Type AA, nominal pore site ).E % micrometer-} m. .tunica i v a cvrec-pioct c ...> c 11 u v,jt.t t...cover removed,- uaing portable battery-operated pumps (Mine v 8005 1583 PRODUCED BY FORD Clayton Environmental Consultants, Inc. - 3- Safety Appliances Company, Model C). Breathing zone samples were obtained by fa toning the pump to the operator's belt and the fii --r head to the outside of . his collar at approximate b.cathing zone height. Thus, the breathing zone scmple was representative of the time-weighted average* conditions to which the operator was exposed during the sampling period. Each sample was analyzed subsequently for asbestos fibers using the method specified by the National Institute for Occupational Safety and Health. Briefly, fchis .method consists of the following steps: a pie-shaped section of each filter is cut carefully from the filter and mounted on a standard microscope slide using a high vis cosity solution of membrane filter material in a 1:1 mix ture of diethyl oxylate and dimethyl phthalatc to render the filter transparent. Asbestos fibers, defined as particles having an aspect ratio (apparent length to width) of three or greater, which were observable on the surface of the filter were counted using a 10a eyepic-ct* and a 40X objective with phase contrast i 1 lu'*:inatior., A minimum of 100 fields, selected at random on the sam ple, were examined and fibers greater than five micro meters in length were counted. The microscopic analy sis, thet is, fiber count data, was used in conjunction with field sampling data (air flowrates and duration of . sampling) to calculate the concentrations of asbestos fibers in air corresponding to each sample in units of fibers, greater than five micrometers in length, per cubic centimeter of air. This procedure is consistent with the nethdd used by the Occupational Safety and Health Administration in its com pliance effort. Data thus obtained were then compared to applicable standards promulgated by the Occupational Safety and Health Administration (OSHA) and by the Ameri can Conference of Governmental Industrial Hygienists (ACC1H). The present OSHA and ACG1H standards limit eight-hour, tine-weigh ted average exposures of workers to a concentration of five fibers (greater than five micromaters in length) per cubic centimeter of air. Effective July 1 , 1970 , the OSHA limit for cight-hour, time-weightod average exposures is scheduled to be re duced to two fibers per cubic centimeter of air. The present OSHA standard also establishes a ceiling (or pc all) exposure limit of ten fibers per cubic centimeter of air. O.i October 9 , 1 975, OSHA issued proposed rulv- mah ing t u io*. *.*r r ! >- pruent standard* such, thet eight- hour, t i r.e->.:< i .*.'! i :! average exposures would no 1 i r.. i. t r* d to -.3 fiber y.r cubic c o n i ine t or of air, and ctiiij.g exposures measured over a period up to fifteen minutes would be limited to five asbestos fibers per cubic conii ne: ir of r. V'h- proposed standard is bared lary.ly on PRODUCED BY FORD Clayton Environmental Consultants Inc. * -4- PRESENTATION OF DATA Bulk Brake Dust ^ " . Results of microscopic analysis.<> the bulk senple of brake dust for percent fiber and1fiber length distribu tion art- presented it. Titbit I. Exar.ine.tio*. of these data indicate that the bulk sample was composed of 19,4 percent fibrous material (by count) and fiber'lengths ranged from approximately four micrometers to greater than fifty micrometers. . ` Air Samples Results of microscopic analysis pf the filter samples taken during the vacuum cleaning tests ere summarized in Table II, These data indicate that the background level of airborne asbestos in the room prior to any testing was approximately 0,04 fiber per cubic centi meter of air. Control samples taken just before the second and third tests indicated-that airborne concen trations of fibrous dust were <0.06 and 0.27 fibers/cc of air, respectively. Airborne concentrations of fibrov dust as measured by the stationary monitores ranged fro:.'. 0.08 to 0.42 fibers per cubic centimeter of air for all tests. The personal breathing zone samples indicated that airborne concentrations of fibrous dust in the oper ator's breathing zone ranged from 0.09 to 0.33 fibers per cubic centimeter. CONCLUSIONS Interpretation of the samp ling data leads to the follow ing conclusions: , 1. General airborne concentrations of fibrous dust, as measured by area monitors strategi cally locate'd in the enclosed roofti, ranged from 0.08 to 0.42 fiber per cubic centimeter during vacuuming tests, well below the proposed 0SHA ceiling concentration of live fibers per cubic centimeter of air, the rest stringent occupational health standard applicable to short (15 minute: or less) exposures. Ir. fact, the cor.co: : rnt ions were below the pro posed limit . ieht-hour-, ,,t i me - we i gh i o d . ' a v- rage < xpo -.: r i of 0.3 fiber/-, c. Due to tb. i. ,,i v.'m. Eevi-rity of the test conditio:;:- (small, confined loom, no dilution of room air, vacuuming c; a very large quantity of br.-.he du :t, thi-s-r d-.tn ' ndi ct e that under 8005 1585 PRODUCED BY FORD Ctatlon I'miionmenl.il l<mnjll.inl\ lot. - 5- normal conditions of use, emissions of fibrous (ar.be r< t or) dust from the tested vacuum cleaner arc not "likely to result in room air concen trations; in excess of present or proposed OSiiA standards, assuming proper use and maintenance of the vacuum cl:-a tier and its filtration s ystCB. 2. Airborne concentrations of fibrous dust in tho breathing zone of the operator ranged from 0.09 to 0..13 liber/cc during vacuuming test proce dures, egain veil below the proposed OSKA ceil ing limit for short-term exposures, and also below the proposed OSHA limit for eight-hour, time-weighted average exposures. Again, due to the severity of the test conditions, it is concluded with reasonable confidence that, under norma1. use conditions, workers using the vacuum cleaner arc not likely to be exposed to concentrations of airborne- fibrous (asbestos) du.-. c in excess of present or proposed OSIIA standards, assuming proper use and re in ter: an ccof the vacuum cleaner and filtration system. 8005 1586 PRODUCED BY FORD FICURE 1 Diagram of Tost Room Used for Evaluation of Vacuum Cleaner Floor to Ceiling Height - Eight Feet PRODUCED BY FORD TAilLL 1 CLAYTON ENVIRONMENTAL' CONSULTANTS, INC. MICROSCOPIC SIZING DATA FOR GLASS FIBER DUST Date 5/19/76 Plant American Clc-aninc Process' " . Sample No. Bulk brnV.t dust ronipment Objective Phaco 40 S , corp. Eyepiece Perinlan J 0 >: Total Magnification 6 0 a .S' Ratio, fibers;total particles * 121 ; 625 Fibrous Content, Percent 19.4 Ar.y particle which has an aspect TCtio of 3 or greater is considered 8 fiber. 8005 1588 PRODUCED BY FORD ' J-'r? >*" I taui/: U-A CLAYTON ENVIRONMENTAL CONSULTANTS, INC. INDUSTRIAL IIYC1F.NE SAMPLING SUMMARY -,i>t Amcricsti Cleaning Equipment Corp. Add i ;mi, Illinois I 1 V / (- Sampl c Number - Mater la 1 (s) riSro'i-- 3u.it Ramp ling Period Start Stop Samp 1e We Ight Sample Volumc (Liters) Concentration Fibers/ cc .'> Ji \ V AA-07 A A-04 FIRST TEST Control, center of room, elevation four feet Southeast corner of room, four feet from vacuum exhaust. elevation four feet 12:00 09:09 11:58 12:11 11:39 12:11 394 34 0.04 0. 09 >!\) M'.'l 3/V) AAA A-0 5 A.A-<)f Personal breathing zone of operator Nortbeajl corner of room, elevation four fee't Northeast corner of room, after vacuum shut off 11:50 11:58 12 :1A 12:11 12:11 12:23 31 0.09 34 0.09 29 0. 10 8005 1589 Oi *-<\ C* V PRODUCED BY FORD oA o <7* __ 1 -/IV 1/ 1# 5/ 19 AA- 02 AA- 12 AAr 11 SECOND TEST Control, center o room, elevation four feet Northeast corner of room, elevation four feet Southeast corner of room, four feet from vacuum exhaust, elevation four feet 1A : 2 3 13:53 1A: 22 14 ; 22 14:33 14:12 14 : 33 14:33 50 29 0.20 29 , / ` '1 3 / 1' A A-01 AA- 13 Personal breathing zone of ope rator NortheaJt corner of room, after vacuum shut Dlf 14:22 14:36 14:33 14:50 26 0.33 37 0.08 Fibers greater than five micrometers In length, and an aspect ratio (length to width) of 1:1 or ercater. . "D O -t r\ri,': If-r. CLAYTON ENVIRONMENTAL CONSULTANTS, INC. 1NPVSTKIAI NVOIKNV SAMIM.TNC SUMMARY r : ei i < :tu i i`n'i|'rvrt Corp. Mn tiTi.il ( 8 ) rilirmt-i Oust A'l i` i . Ml: no : : . 3.1:?;* ! f J*i: !f f * tier l ! '. S i n p 1 i n > :rr 'ii Start Step S.i mp l c Weight Sample Vo l time (Liters) Cone entratIon F i brtV cV 'aiRU TEST 1- : 2f- 16 : *>6 ! i; AA- ' A Cim: co 1 , r.t.er oi roo:v. olcviii Ip:i lour Toot 16 :07 16::: :i'>rilna;t curm-r of ruu:::, /l? AA- 10 elevation four loot Sou tli onr. t corner o( roor.i. t t /!'. A A- 1 5 lour l ot from vaejes o xli au l , .1 v- v ;t t i o J ? u r i r.; 2 3 16: 36 16 : 76 fool _____ / 1.V AA- 17 AA- IS i'crsonal breath ini* zone ol' opt r.iior . . Uortlic.ist corntr of room, n T t o r vncuu:n n t off 16:25 10: 33 16: 36 . 16:50 f iri 0.37 29 0.10 29 O.A 26 o.22 32 0. IB -- CO o o vn -- w o o ) V_ . Accept ** b 1c 03IIA e i|;ht-Iumi v , I iinoacijjhteil nve'nuo conccntratl'm (THAI OSI1A c ip.ht-hour, t line-ec 1 t cu o vc rr conccntr.itlon limit effective 7/1/76 03HA co 11 inf; limit Proposed OSHA standard 5 10 y.5 (rv/A) 3 ( relllnj;) _________ : PRODUCED BY FORD