Document J367ZL74kJ7vQGVaQnB7oDjE2

FMSI 02798 ASBESTOS STUDY COMMITTEE 1971-72 FMSI 02799 .^ICTION MATERIALS STANDARDS INSTITUTE,INC., E. 210 ROUTE 4, PARAMUS,N.J. 07652 BULLETIN N 0. 462 December 6, 1972 TO: ACTIVE MEMBERS SUBJECT: SURVEY - OSHA LABELING REQUIREMENTS On November 6, 1972 we sent out a request for Information and interpretation of the OSHA regulations concerning labeling requirements for asbestos type brake lining and clutch facing shipments, where subsequent machining (cutting, grinding, drilling, chamfering, grooving) was likely to be done on these products. Twenty-five questionnaires were sent out. Eleven replies were received. Replies were received from a reasonable cross-section of the membership. As the replies were confidential, the forms submitted by the members have been destroyed. The survey will be a tool used at the next Asbestos Study Committee Meeting. It is suggested that members of the Committee attending the next meeting be versed in their own Company's position on labeling. EWD:llz cc: Asbestos Study Committee E. W. Drislane Executive Director (^ FMSI 02800 RICTION MATERIALS STANDARDS INSTITUTE, INC., E.210 ROUTE 4, PARAMUS.N.J. 07652 ASBESTOS STUDY COMMITTEE - LABELING SURVEY (25 Requests 11/6/72, 11 replies 12/6/72) Question Yes No Undecided 1.1 Now label replacement shipments 1 10 1.2 Now label O.E.M. shipments 19 2.1 Plan to label re placement shipments? 53 3 2.2 Plan to label O.E.M. shipments? 52 3 3.1 Interpret OSHA to require labeling where subsequent machining is expected? 9 2 Not Applicable 1 1 Comment A,B C A. Member replying YES, states; "If such practice is required and/or adopted by FMSI." B. Member replying NO, states: "Our material has been treated with a binder - therefore no raw asbestos is present." C. Member replying YES, states: "We will label if it is determined that our bonding or binding material does not meet the standard." FMSI 02801 Mr. J. H. Kelly Bendix Corporation 1217 S. Walnut Street South Bend, Indiana 46621 November 28, 1972 Dear Jack: This concerns our discussion concerning labeling requirements where brake linings are being shipped to customers. In attempting to determine what practice one must use, OSHA has stated that if one is meeting the spirit of its regulations it will not be cited for violations. As a result of this, it becomes necessary to interpret some of the OSHA regulations. I am enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association (AIA/NA). You will note on these reports that Mr. Armstrong, from Bendix corporate headquarters, attended these meetings. There is absolutely no question concerning the requirements for labeling where loose asbestos is being shipped. The big problem develops where members are shipping what the AIA and OSHA refer to as locked in asbestos products - brake linings, brake blocks, clutch facings, etc. When customers of yours drill linings, chamfer linings, cut linings, or grind linings, they may very well raise the asbestos concentrations in the atmosphere to above the OSHA standard. Some members have indicated that the drilling and grinding operations are problem areas in brake lining factories with existing exhaust systems. Therefore, if a customer of yours started drilling or grinding without having proper dust collectors, he would problbly be in violation of the OSHA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to warn the customer of this possibility. The form which the warning takes is still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for a violation. Therefore, * z you eetridr put in every one of your skids, or cartons, or pallets, a warning notice to the effect: "Power tools without dust collectors should not be used for machining, cutting, or sanding this product." If a notice such as this were enclosed with every carton, or stenciled on the outside of the carton, it is likely that you would be meeting the spirit of the regulations. If you were to write your customer aad tell him about this with every shipment made, you would probably be also meeting the spirit of the regulations. If you send a one time letter to your customer saying this, it is hard to say whether you would be meeting the spirit of the regulations. (2 FMSl 02802 Mr. J. H. Kelly Bendix Corporation 2- - November 28, 1972 I am enclosing a copy of the warning label suggested In the OSHA regulations where loose asbestos fibers are being shipped, and the "Instruction Sheet" suggested where a customer Is to do further machining on clutch facings, brake lining, etc. I hope this is enough information for you. Dave Stone attended our most recent Asbestos Study Committee Meeting where the subject of labeling was brought up. Your Mr. Armstrong is aware of some of the controversy concerning labeling. The current survey indicates that no members are now labeling shipments. A slight majority of those responding to date Indicate that they interpret the OSHA regulations to require some kind of a warning where subsequent work is to be done on brake linings. This is controversial item for the Institute in that some members feel that one or two companies are trying to railroad them into labeling. Another group of companies feel that we should comply with the spirit of the law now and it is not fair If they do the proper labeling and their competition does not. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE KWDtllz Enc. E. W. Drislane Executive Director FMSI 02803 October 30, 1972 Mr. I. H, Weaver Raybestos-Manhattan, Ine. 123 E. StSegal Street Manheim, Pa, 17545 Dear tkei Enclosed are two copies of a survey on OSHA labeling for our Members* Please look this over, I will not distribute till you give me the go-ahead. EWD/ltac Sincerely, E. i. Drislane Executive Director d-3 FMSI 02804 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, NjJ. 07652 October 30, 1972 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey of members on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust. - A key paragraph in the standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products contain ing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is the shipment of asbestos containing brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/cc TWA, or 10 fibers/cc ceiling). The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do you plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3. Do you interpret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? Would you please complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to me at the Institute Office. E. W. Drislane Executive Director FMSI 02805 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N.J. 07652 OSHA LABELING REQUIREMENTS 1l Current Labeling Practice 1.1 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. 2, Planned Labeling Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA caution label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. Interpretation of OSHA Labeling Reputations 3.1 We interpret the OSHA labeling regulations to require caution labels on friction material. shipments that will have subse-, quent working (drilling, grinding, etc.). Yes ______ () ______ () .... () . (____) ______ () No () CD () CD () BY. COMPANY. DATE FMS1 02806 A,FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 Route Paramus, N.J. 07652 BULLETIN NO. 4 5 7 October 20, 1972 TO: ACTIVE MEMBERS ASBESTOS STUDY COMMITTEE LICENSEES SUBJECT: Occupational Safety and Health Standards (OSHA) In the October 18, 1972 issue of the Federal Register, the Department of Labor issued a complete set of Rules and Regulations for the OSHA Stan dards. As regards asbestos, the section (1910.93a) pertaining thereto is unchanged from that sent to the membership with our Bulletin 442 of June 20, 1972. The Department published these to bring in all amendments to the standards through September 22, 1972. The purpose was (l) to publish the OSHA Standards fully and reflect changes made during the year, (2) to correct typographical and clerical errors in the original standards, and (3) to publish an index with the standards. As these full standards are a bulky 250 page issue, it is suggested that members interested in acquiring up-dated standards request them from: Superintendent of Documents U. S. Government Printing Office Washington, D. C. 20402 If interested, order the Federal Register of October 18, 1972, with payment of 20 cents payable to Superintendent of Documents. E, W. Drislane Executive Director FMSI 02807 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARMJS, N.J. 07652 November 6, 1972 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey ofmembers on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust. A key paragraph in the standards had to do with labeling requirements: (2) Caution labels---(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products contain ing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is the shipment of asbestos captaining brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/cc TWA, or 10 fibers/cc cei1ing). The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do vou plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3. Do vou interpret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? Would you please complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to me at the Institute Office. E. W. Drislane Executive Director FMSI 02808 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N.J. 07652 OSHA LABELING REQUIREMENTS _ 1. Currant Labeling Practice 1.1 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. 2. Planned Labelino Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA caution label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. Interpretation of OSHA Labelinp Reputations 3.1 We interpret the OSHA labeling regulations to require caution labels on friction material shipments that will have subse quent working (drilling, grinding, etc.). Yes ______ () ______ () ______ () ______ () ______ () No () CD () () () BY. COMPANY. DATE FMSI 02809 friction MATERIALS STANDARDS INSTITUTE, INC., E.210 ROUTE 4, PARAMUS, W.J.07652 October 10, 1972 MEMBERS OF THE ASBESTOS STUDY COMMITTEE SUBJECT: ASBESTOS PUBLICITY - DR. SELIKOFF Attached is an article from the New York Times of October 5, 1972. Of particular Interest is that paragraph concerned with "wearing away of asbestos brake linings in automobiles and trucks." The reporter says this is a"significant source of airborne asbestos." This paragraph is not directly related to the headline and lead article concerning the Incidence of cancer of the stomach, colon and rectum (as well as lung cancer) in workers exposed to asbestos. Ordinarily, there will be an article of this type in the Times about every month with Dr. Selikoff generally the source. EWD:llz Enc. E. W. Drislane Executive Director FMSI 02810 Wider Link io Cancer Fount in Asbestos Workers . a* men of similar mmm . nd wit exposed to a* A team of cancer researchers borne asbestos fibers. reported yesterday that ashes- At that time there was aj toe, already implicated as a suggestion that other types of cause of lung cancer in work* cancer might also be mote: era repeatedly exposed to the common, but not until now,! material, might also have the scientists said, was these caused a ehre-fold increase in sufficient statistical evidence tai the incidence of cancer of the confirm the suspicion. stomach, colon and rectum in However, now that mom the same workers. time has elapsed since the itf-i The findings which the idea- tial exposure to asbestos, thej ttsts said confirmed a long-held researchers found that 41 work suspicion, raises the possibility ers had died of cancer of the: the low levels of air stomach, colon or rectum--*: borne asbestos particles known about three times the numbaf be exist in urban air may inetease the risk of cancer among| Hat public at large. The researchers also said that, their findings might lead to a hatter understanding of gastroMesttnai cancer, the causes of which are not known. that would have been expected! under normal circumstances. " Among the same number.wf men in a similar age group net: unusually exposed to asbestos,! only 12.5 should have died of| the same cugses. Earlier studies have shi that in the process of appl; The report was given in asbestos insulation during Lyon, France, before the Inter construction of buildings national Agency for Research ships, countless tiny partidta OA Cancer, an arm of the of the material become dis World Health Organization, by lodged and float into the esr.L ^ BC. Irving J. Selikoff of the In urban areas it has hqfmjl yCTT Mount Sinai School of Medi skown that another significant)! cine and Dr, E. Cuyler Ham- source of airborne asbestds tef mend and Herbert Seidman of the wearing away of asbtttow the American Cancer Society's brake lining in auti * " Environmental Cancer Re and trucks. The act of ai search Project. the brakes In Such vel The findings are based off a fine asbestos. study of 632 members .. .t is then kicked into? the New York and New *lr by the drafts of branches of the insuMta Mtfffc- , workers' union who wwSggl Examination of the lungs Vl With various forms of asMMNUjpersons and animals widely used fireproofing BWMto such air has shows* 9Mt fltt tbthtDheheereregF.aiaarlwStrolnh.eome,srlaeiukknae1nord9rctfs4ifhl.c3aea,StrnuhsewdsevehmeDseeroranno.nldfiHtythoedoaeraefmenadssd1tht9mut7htdM1efy,l1TM1t'periemmaPpLrbeootaie.rcrstdtaleetednQdsedd,ooownnffetaoea*epnrkpssalttloouurd?ndeDgvgnyret.loypif,nerSfiorteed*Kmskaaoinfff;) rimiitgrf that inadJfedWposure among World War 1X| weaken wen dying of ngmdupbuilders. He warned that Sight 9m areuch persons should be await Of their increased risk of cage Mr and should get more fre quent check-ups so that the1 disease can be diagnosed when it is mere treatable. sjorff FMSI 02811 FRICTION MATERIALS STANDARDS INSTITUTE,INC. E-210 ROUTE 4, PARAMUS, N.J. jR)7652 August 30, 1972 To: Asbestos Study Committee Subject: "Health Hazards of Asbestos", by J. C. Gilson Enclosed is an article "Health Hazards of Asbestos" by J. C. Gilson. Mr. I. H. Weaver, Chairman of the Committee, felt this was a good overview of the entire asbestos health situation as it now stands, and suggested that it be distributed to members of the Committee. EtD/erc Enclosure E. W. Drislane Executive Director CC: British Council AIA/NA (Swetonic) Committee Members FMSI 02812 'M EM'O from the desk oj I.H. WEAVER I think the attached article gives a good overview of the entire asbestos/ health situation at it now stands. I suggest you distribute copies to the other members of the Asbestos Study Committee. Ike FMSI 02813 J. C. GILSON Inhaled fibres of asbestos can cause fibrosis of the lungs and two kinds of cancer. Protection of asbestos workers calls for monitoring and controlling their working environment and linking these records with records of their health HISTORICAL Asbestos was the first inorganic fibre to be used in compo sites. More than 4000 years ago clay pots in Finland we:e strengthened by adding anthonhyllitc fibres'. In classical times asbestos cloth was used to preserve the ashes of the eminent. The oldest known piece of asbestos cloth front tire New World, dating from about 1740. is a small purse made of Iremoti'.e in the Sir Hans Sloune collection of minerals in the British Museum (Natural History). The modern asbestos industry is about 100 years old, starting neatly simultaneously in Canada and the USSR, but it was not until 30 years later that the first medical reports appeared in France and England, indicating that there might be a specific type of damage to the lungs following inhalation of the dust. By the late 1020s ir was clear from surveys made in this country and in USA that a high proportion of older workers in the asbestos textile industries were becoming severely disabled by a specific t>pe of chest disease due to the dust. This was mimed asbestosis. DISEASES CAUSED BY ASBESTOS DUST Research carried out in the 19.30s, supported by the greatly expanded investigations during the last 15 years into tire types of disease caused by asbestos, now provides a much clearer pictme of the specific hazards and how damage to health can be avoided in the future. Table 1 lists the diseases. Table 7 Diseases caused bv asbestos dust Asbestosis Cancer AsIk-sios Corns Fitirosisof lungs Bronchial (lung) Mesothelioma Skin Asbestosis In ashestous the dust causes scarring and thickening o! the tissues of the lung. I he two parts paiticularlv aftected are the linest ait passages (respiratory bronchioles) where they branch into the nTiniiia.l air sacs (the alveoli), arid the surlaee ot the lung (pleura). The thickening of tile ti.v.ucs trtdu-. r d try tire asbestos dlls! al feels I lie function o' the i Hi;' in time wav., fir.' volume when lulls I'Ti.uvt a' 'he eno o: lull in-i'O.ovn |.. less ih.m lumriil the in-ucs ' i>i,t_frt. \!R( I'ru nn i >, tin T ts[s l/ntf, f |.tiki<<wi'!: 1 dll!), (rl.H i -IJ-.'ll ( I b i X VV . I k ' \i) <V;; become stiller than normal so dial the compliance is reduced. The thickening in the alveolar walis. when the disease is extensive, also reduces the gas transfer for oxygen, so that the blood leaving the lung is no longer fully saturated with ibis gas. The transfer of carbon dioxide from the blood to the air in the lungs is not, however, appre ciably affected. The reduced oxygen transfer is partly compensated lor by an increase in the frequency of breath ing so that the subject notices breathlessness on slight exertion. These alterations of lung function are used to assist in diagnosis of asbestosis and measure the severity of the damage. Asbestosis takes a number of years to develop, even under very dusty conditions, but once established it is a progressive disease not materially affected by avoiding further dust exposure. The less the dust exposure, the longer interval before the onset of disease, the less its severity; and the less chance of being affected. This-dose response relationship is used to fix the acceptable dust levels - threshold limit values - for tlrose working with asbestos. The article by Holmes in this issue describes how these standards are applied in practice. Prevention by avoiding'exposures to a dangerous quantity of dust is an essential step towards the safe use of asbestos. Asbestos cancers Some years after the recognition of asbestosis as an impor tant problem in the asbestos textile industry, articles began to appear in the medical journals'*1 *su*g*gesting an association between asbestosis and lung cancer. A survey in 1955 firmly established that those who had worked in the asbestos textile industry before the improvements in dust control, introduced in the 1930s, had a 10-fold excess risk of developing lung cancer5, lire survey, however, also indicated that the improvement in dust control introduced at a particular factory after 1933 had very materially reduced the risk. Later surveys at this factory have confirmed this6. The lung cancers seen m asbestos winkers are similar to those caused by cigarette smoking. Recent research indi cates that there is likely to be a synergistic effect of cigarette smoking and exposure to asbestos dust7. The precise quantitative inter-relationship between asbestos, enqueues, and other factors is not fully established, but present evidence indicates that those who smoke cigarettes ami are exposed to asbestos dust have a risk of developing lung . ancer at lean fifty times gieater than noii-smokeis v.li ' Vc not exposed to asbestos dust. !u the last 15 years there has been much new infermain';' about the bilk between expo>uie to asbestos at id aitoiliei previously very tare type of cancer afk-ciing rite 57 FMSI 02814 surface of me lung and the gut1'. Reports of these meso tfa'.Uomas a they are called have increased steeply over fie last 10 years. There is general agreement in most industrialized countries that there has been a real increase of t..is form of cancer '. In about KO'/o of cases there is a history of exposure to asbestos dust at some time in the past. A feature of these tumours is the long interval between first exposures to asbestos dust and the detection of the cancer. It is raltfly less than TO years and may be up to 50 or more years. In some instances the exposure to the dust has been short, only a few months, but the highest incidence of tumours has occulted in those most heavily exposed to asbestos dust. Cigarette smoking seems to play no part in these tumours, but some research workers think there may be other co-factors present as well as asbestos10. The only other specific injury caused is the formation of asbestos corns on the fingers when the fibies lodge in the skin. The removal of the fibre usually cures the corn and no cancers of the skin relatable to asbestos have been reported. PRACTICAL IMPLICATIONS OF THE BIOLOGICAL EFFECTS OF ASBESTOS Inhalation of the fibre For all practical purposes the risk from asbestos is limited to inhalation of the fibres. Thus control of the aii borne dust levels and their monitoring by instiumcnts, winch will measure that part of the dust which can gain access to the deeper paits of the lung, is an essential step in the safe use of all types of asbestos. Although asbestos fibres can be ingested in minute amounts in beverages winch have been filtered through asbestos, ot water supplies", there is no firm evidence that such tiny traces have any ili-eflects. Feeding massive doses of asbestos to animals has so far failed to produce any mesotheliomas or other cancers. Size and shape of fibres Recent research has helped to clarify the probable influ ence of fibre length and diameter in producing asbestosis and the bronchial cancers. The fibrosis is thought to be caused principally by the fibres between about 5 and 100 gnu nr length. Fibres much largci than this in the er:viie-1:nioi11 settle out quickiy and are not inhaled. Further si/e separation occurs in the air passages, the important si/c paiametoi being fibre diameter since it is this dimen sion laltiei than fibre length that governs the falling speed of the fibres. Thus fibies gieater in diameter than about 2 gim (these also tend to be the longest) mostly fall or impact in the uppei respiratory tract and are carried away with the sputum. In the narrow airways any long fibres remaining are deposited by interception and fibres longer than about 100 gnu seldom teach the finest bronchioles I Ins means that for the coutio! of asbestosis. and probably bronchial cancers, the dose of fibres between about 5 gnu and Kit) grin in length and up to about 2 grin in diametei is the traction of the dust which lias to be measured. Foi the mesotheliomas the evidence about the bio logically important si/e is much less complete. I'sing inloimnl mu I torn many sources, such as die aerodvnjimc IhIisvkmii ->t line 111 ia s]/e aiuj shape ol I lines w Inch aie lel,uned in .be lungs of amnub- and man lollovv mg expoMiie to diffeient types ot asbestos, and the epi demiological studies of the incidence of these tumours in man for different types of fibre, it seems probable that the important fibres are likely to be those which arc straight, small in diameter flip to about ! gun) and perhaps 10,uni in length. It is not vet known whether the ultra-fine fibres only visible under the electron microscope are biologically important. Such fibres are present in large numbers in the lungs of those who have been exposed to asbestos, but their combined mass is extremely small. It is too early yet to use this information to establish with confidence a separate dust standard to prevent the development of these mesotheliomas. This is a field of intensive research at the present. ' Some of the new evidence suggests that the size and shape of the fibre are more impoitant than its chemical composition, provided it is relatively insoluble, it may be that extiemely fine fibres of many different materials can penetrate cells without immediately killing them, but once inside can damage' the mechanisms of cell divisions. An implication of this view is that care should be taken to avoid exposure to dusts of all types of fibre less than 0-5 gun dia meter and several micrometres in length. Types of asbestos and occupations within the industry The last 10 years have shown the importance to health of the type of asbestos inhaled and the occupation of the winkers within the industry. Earlier medical reports did not differentiate between one type of asbestos and another, and most of the surveys were concerned with asbestos textile workers. A full assessment of the risks would ideally be based on studies of workers only exposed to each type of fibre and in all the operations within the industry in which this fibre was used. In practice die information is much less complete than this. Exposures to line type of fibre have usually oceimed only in the mining and fibre separat ing. This work usually takes place in countries where the medical records are scanty and the labour turnover is rapid. A notable exception is in the chrysotile mines in Quebec where a very comprehensive survey has just been com pleted12-14. In the manufacturing countries several types of fibre are often mixed together or have been processed concurrently so that employees have been exposed to several types of fibre in unknown quantities. Past records ot dnstinc" s me rarely available foi teiating to the incidence of the diseases. Thus the current assessment of the lelativt risks in the past from different types of fibre and occupa tions is based on mloiination which is far from complete. I'se can be made of experiments in animals, especially rats, because most of the diseases seen in man can be pioduced in these animals. New information is rapidly accumulating which may give a clearer indication of the way in which difierent types of asbestos produce their biological effects. T here is general agreement that asbestosis ar.d bronchial cancers can be caused by ail types of commercially used jsbestosfamositc. anthophyllite, chrysotile, and crocidolite) if the dust is inhaled in sufficient quantities, but it now seems likely that the risk from chrysotile may be less than Willi the other iypes of fibre. There is also evidence that the ink is lowest in muling and increases along the fibre sepai.limp, and manufaclmmg processes This is thought to he Jug (o the higiici p'oportnm ofaubornc dust consisting id le.pu.d'lc libies able to penetrate into the deepest part ot the lung. In piactice this means that the cleaner the fibre and the inoie completely it is separated into individual CW r'iHfnru'rrri' ft., i. mo FMSI 02815 fib.,;* ami smali handles, the premier the iisk. Theie is also poos' evidence of a dose response relationship lor asbestosis and bronchial cancers and thus, if the dust levels are kept within the new slaud.itds. the risks of asbestos's and bron chial cancers in lire fuluie should be very small. The risk of developing mesothelioma* Iras a different relation to fibre type. It is probably highest with croeidolite ami lowest with chrysolite. No cases clearly related to anthophyllite alone have been reported, despite careful search. The risk with amosile probably lies between croeidolite and ch ry so tile. The evidence for a dose response relationship is less clear in the case of mesotheliomas and hence the threshold limit value is more difficult io assess. In the Asbestos Regulations 1969,s the standard for croeidolite is set at one-tenth of that for oilier types of asbestos. COMPARISON OF OCCUPATIONAL RISKS What is the magnitude of the risk of developing ill-health from asbe-tosf No single index provides a sausiactory measure of injury to health. Thus the excess risk of death before a specified age may be a useful index for those diseases causing sudden or rapid death, but it is an inappropriate index for diseases cauung a long period of disability but little shortening of life. I he cancers associated with asbestos exposure fall into lire first group and asbestosis the second group. In different occu pational groups comparisons of mortality are easier to make than those of illness. But even for mortality the compari sons are not straightforward. For example, the more the selection is limited to a definable group with a high past exposure, the worse the risk will appear. Allowance has also to be made for tne effects of age, length of exposure, and how long the occupational group has been followed. When such allowances are made the excess mortality from `all causes' in groups of workers heavily exposed to the more damaging, types of asbestos dusts in the past is closely comparable, to that of coalminers who have developed the severer form of coalworkers' pneumoconiosis or that of deep-sea fishermen who have the highest rates of acci dental deaths of any occupation. However, the excess mortality from `ali causes' in these occupational groups is less than that of male smokers of twenty cigarettes and more a day compered with non-smokero This is the positron for deaths from 'all causes', hut deaths fiom specific causes, such as mesotheliomas, asbes toses. oi lung cancels relative to that of the gcncial public, are of course proportionately much more increased. Tins is because mesotheliomas and asbestosis are extremely t.itc in those who have not worked with asbestos. Confusion sometimes occuis between the pioportion of individuals exposed who develop a disease and ihe excess risk o! a particular disease in exposed individuals compared with tlie general public. The first may be relatively small and the second extremely high. THE FUTURE As m many occupational diseases proof of die efficacy of new piewu'iw mc.ismev including die validity o[ the cuiieni tl.ieshohl limit values, can only come hum linking inhumation ol thief types die niauutavturmg process and the types ol libie and other materials used lire mea surements of exposure; the medical lecords of those exposed. Computers now make it easy to store this infor mation, but we still need the foiesight and administration to see that it is achieved. If it is not done we may still in 20 yeais or so be in no better position to answer important questions which are at present unanswerable because of the paucity of past records. CONCLUSION The recent increase in the number of cases of asbestosis and other diseases related to past exposure to asbestos is the result of relatively heavy exposures to the dust, particularly in parts of the asbestos industry not covered by the 1931 Asbestos Regulations. Much new information about die biological effects of asbestos has been acquired iccently. The new Asbestos Regulations 1969 based on this information, if correctly applied, should greatly reduce the risks in the future. The selection of which types of asbestos to use in new piocess.'s should take into account their biological effects it the risk of dust exposure is likely to occur during manu facture or in the use of the products. When working with extremely l ine fibres of any material which may become airborne, caution is needed. An exami nation of the possible biological effects is required if the product is to be widely used and risks of damage to health are to be avoided in the future. Proof of the efficacy of present preventive measures depends on much better record keeping than has been the case in the past. REFERENCES 1 Noro Leo. American Industrial Hygiene Association Journal, Vo! 29, p 195 (19b8) 2 Mercuether L. R. A. and Price C. W., `Report on the effects of asbestos dust on the lungs and dust suppression in the Asbestos Industry*. London, HMSO (1930) 3 Dreessen W. C., Dallavalk J. M., Ldwards T. L. Miller J. W.( Sayers R. R,, `A study of asbestosis in the asbestos textile industry'. IJS Treasury Department, Public Health Service. Public Health bulletin No 24 1 (August 1938) 4 Merewether L. R. A. Annual Report. Inspector of Lactories. London, HMSO (1947) 5 Doll Richard. I'riiish Reo of industrial Medn mt, Vui 12, P SI (1955} 6 Knox J. ! .. holmes S.. Doll R., and Hill i. I)., firitish Journal of Industi ial Medicine, I ol 25, p 292 (I9(/Sj 7 Sclikolf I. J.. Journal oj the Anuncan Medical Association. Voi ?t)f p 10-4 i (9nS) S Wagner J. ('., Gibon J. Berry G.. and Timbrel! V., British Medical Bulletin Vol2?,p 71 {1911} 9 (bison J. 'Asbestos health hazards', in Shapiro. H. A. (editor), `Pneumoconiosis', Pioccedmgs of the Inteniaiionil Conference, Johannesburg, 24 Apnl-2 May 1969, p 173. ( ape Town etc., Oxford Univcrsiu Press (1970) 10 Webster L, `Asbestos exposure in South Africa', ibid, p 1 20 ! I Cunningham H. M. and Pontefract R.. Nature, Voi 222, p 222 (1971} 12 Becklake Margaret R., Lou rnier-Massey (Jisclc, McDonald J. C.. Sicmiatycki J., and Rossiter 1'., bulletin dc Physio- Palhologie Respirctnire, Voi ft, p t>37 (1970} 1 3 McDonald J. Corbett, McDonald Alison D., Gibbs Graham W., .Sicmialwki Jack, and Rossiter ( hatles I Archives of Cin/ot/Mt nml Health. Voi 32. p tt 77 (1971} 1 i Joiloin Cities. Gibb-. G \Y., Macklem P. T.. McDonald J. ( Ih.ki.ihc M.ug.if. I R . \meruiin Review of Respiratory Ih-tcw* I ol Hit. p *35 (fu 7!} I'1 Sutu'my I rot t iincn ts 1 969 No 69th L actories, The A. sbestos I'/ul.honx !'H,9 I . union. IIMSO 11 909 ) FMSI 02816 Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 (212) .664=8236 Gcl July 5, 1972 TO: ` AIA/NA MEMBER COMPANIES ' AIA/NA ENVIRONMENTAL CONTROL SUB-COMMITTEE AIA/NA LEGAL COUNSEL James Armstrong - Bendix Corporation E. C. Bratt - H. K. Porter Company, Inc. G. G. Gabrielson, Jr. - Nicolef Industries, Inc. Bernard Gross - American Bilt Rite Rubber Company J. Hall - GAF Corporation H. M. Jackson - Johns-Manville Corporation W. N. Johnson - Union Carbide Corporation A. R. Hooker - The Flintkote Company C. A. Neumann - Kentile Floors Incorporated G. W. Nickel - Armstrong Cork Company Clifford Seymour - The Carborundum Company J. R. Stetson - Congoleum Industries, Inc.. Philip Weinstein - Evertex Incorporated G. W. Wright, M.D, - St. Luke's Hospital Gentlemen: A meeting was held in Washington last Thursday between the AIA/NA and representatives of the OSHA standards development and compliance sections. Attending on behalf of the AIA were John Marsh, Raybestos-Manhattan; Paul Weiner, GAF; Hugh Jackson, Johns-Manville; Frank Zimmerman, National Gypsum; Bradley Walls, AIA/NA Legal Counsel, and M. M. Swetonic, AIA/NA Executive Secretary. OSHA was represented by John O'Neill and Harry Gilbert of Standards Development; and Ray McClure of Compliance. The purpose of the meeting, as was discussed at the Association meeting on June 22, was to clarify a number of points with regard to the interpretation and enforcement of the asbestos standards. Because the standards are to go into effect this week, we considered it imperative to provide you with the basic points of interpretation and compliance established at the meeting. A more complete report on the meeting will be forthcoming in the near future. Sponsored by Atlas Asbestos Co.. Cement Asbestos Products Co.. Ccrtaln-tced Products Corp . Flintkote Co.. GAF Corp., Johns-Manville Corp.. National Gypsum Co., Panacon Corp. and Raybestos-Manhattan, Inc. 1 d) FMSI 02817 . -2- The> following are the main areas discussed and the decisions reached: 1. LABELING: The AIA/NA is applying for a temporary industry-wide variance on the exact wording of the labeling requirements of the standards, in order that existing supplies of boxes, cartons, bags, etc. containing a label with wording somewhat different than that called for in the standards will be permitted . until they are used up. As long as the label currently being used contains basically the same information as the required one, it will be acceptable to OSHA until stocks are used up. ' Products to be labeled should follow the list ing submitted by Dr. Fred Pundsack of Johns-Manville to OSHA following the March hearings. A copy of Dr. Pundsack's list, with minor alterations, is attached for your ' information. No product which requires labeling will be. permitted to be used without any label until existing stocks of non-labeled bags, etc. are used up. A stick-on label of some type would be satisfactory. The size, color, placement, etc. of the label is left to the discretion of the employer, as long as the label is "readily visible and legible." A good rule to follow would be: if you are trying to hide the label, OSHA will probably not accept it. 2. CLOTHES LOCKERS: Separate clothes lockers are required only for employees working at levels in excess of the five fiber TWA. 3. It was the intention of OSHA to require Type "C" supplied-air respirators and protective clothing only for insulation and fireproofing spray applications. AIA/NA will apply for a modification of the law to exclude other types of asbestos-spray applications from these requirements. -More- FMSI 02818 . -3- 4 . RESPIRATORS: There is a mistake in the standards in paragraph (d)(2)(ii) "Powered Air Purifying Respirators." The first sentence of that paragraph now reads: "A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator etc." The sentence should'read: "A full facepiece powered air purifying respirator, or a respirator etc." The phrase "or a powered air purifying respirator" should be deleted. 5. MONITORING AND PHYSICAL EXAMINATIONS: Company monitoring and physical examinations should be conducted on all employees who regularly work with asbestos and are exposed to airborne fiber, as well as on maintenance men, company industrial hygienists and other employees that the company feels require monitoring and physical examination because of the nature of their work or because of their close proximity to dusty asbestos operations. This would exclude office personnel, most people working in non-asbestos using sections of an asbestos manufacturing operation, etc. 6. CITATIONS: A company's own monitoring or other records will not be used as evidence to issure citations, nor will they be used to give a plant a clean bill of health. 7. OSHA INSPECTIONS: OSHA industrial hygienists will take dust samples, if at all possible, for a full eight hours, perhaps divided into two four hour samples. In addition, samples will be taken on more than one day, so that a more accurate count can be produced. Ceiling sampling periods will be at the discretion of the OSHA hygienist. Ceiling samples as short as five minutes may be taken if deemed appropriate. Under some circumstances -More- FMS1 02819 -4- (an obviously very heavy dust concentration), only ceiling samples may be taken, but this would not be normal practice. Employers will be given specific dust counts only if they are in excess of the standard. Counts taken by NIOSH hygienists will be reported to OSHA, but will not be used by OSHA for purposes of issuing citations. . ' 8. EMPLOYEE NOTIFICATION: On the question of notifying employees if they are found to be working in dust concentrations above the limit, neither O'Neill or McClure would make a decision whether the notification clause in the standard would be satisfied by the posting on a plant bulletin board of stations above TWA, or whether a more individualized approach, such as sending the employee a registered letter, would be required. To answer this question, we were asked to write to the solicitors office in OSHA for a ruling. Unfortunately, a prior informal conversation between Paul Weiner of GAF and a member of the legal staff of OSHA indicated that the answer to such a question would be in favor of the registered letter approach. As a result, we have decided not to submit this question for a ruling, but will leave it up to each company in the industry to decide in what manner it wishes to abide by this requirement, and wait to see if bulletin board notification will be challenged by OSHA regional inspectors. In general, the concensus of the AIA group that attended the Washington meeting was that the industry could expect reasonable treatment from OSHA as long as the industry did not try to circumvent the intent of the regulations. For example, the various requirements in the standard for protective clothing, change rooms, separate lockers, etc. have as their purpose the preventing of excessive amounts of asbestos dust being carried home on an employee's clothes from work. As long as this purpose is achieved, the industry will be given wide latitude as to the types of protective clothing, footwear and headgear required; the location and size of change rooms; -More- FMSl 02820 -5- the distance between separate lockers, etc. In short, the industry is free to interpret many sections of the regulations as it sees fit, as long as the spirit and intent of the law is observed. Sincerely, Matthew M. Swetonic Executive Secretary NOTE: The following is the new address and telephone number of the AIA/NA effective immediately. Asbestos Information Association/North America 22 East 40th Street Suite 1611 ' New York, New York 10016 212- 689-3378 FMSI 02821 Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 (212) eet-seee (b$<i July 12, 1972 TO: ' AIA/NA MEMBER COMPANIES AIA/NA ENVIRONMENTAL CCOO!NTROL SUB-COMMITTEE AIA/NA LEGAL COUNSEL James Armstrong Ber.dix Corporation E. C. Bratt H. K: Porter Company, Inc. G. G. Gabrielson, Jr. Nicolet Industries, Inc. Bernard Gross American Bilt Rite Rubber Company J. Hall GAF Corporation H. M. Jackson Johns-Manville Corporation W. N. Johnson Union Carbide Corporation A. R. Hooker The Flintkote Company C. A. Neumann Kentile Floors Incorporated G. W. Nickel Armstrong Cork Company Clifford Seymour The Carborundum Company J. R. Stetson Congoleum Industries, Inc. Philip Weinstein Evertex Incorporated G. W. Wright, M.D. St. Luke's Hospital Gentlemen: Inadvertently, the list of non-locked-in asbestos containing products which was to have been attached to our July 5 mailing was not included. Attached, therefore, is the list as originally promised. It has come to our attention that a number of companies still have questions concerning whether certain asbestoscontaining products which they manufacture should or should not be labeled. The standard is rather indefinite in that it calls for warning lables on products which "during any reasonably foreseeable use" may create airborne concentrations of asbestos in excess of prescribed limits. The Occupational Safety and Health Act itself states that "any standard promulgated ... shall prescribe the use of labels or other appropriate forms of warning as are necessary to insure that employees are apprised of all hazards to which they are exposed, relevant symptoms and appropriate emergency treatments, and proper conditions and precautions of safe use or exposure." Quite obviously, the rather simple FMSI 02822 Sponsored by Atlas Asbestos Co., Cement Asbestos Products Co.. Certain-teed Products Corp., Flintkote Co.. GAF Corp., Jolios-Manville Corp., National Gypsum Co.. Panacon Curp. ond Raybcstos-Manhattan, Inc. 2- - warning label prescribed in the regulations does not meet all of the criteria described in the law, which only adds to the problem. Each company will have to decide for itself whether a particular product requires a label or not. Obviously, there should be uniformity on this subject, because if one company decides to label a certain product, and another company decides not to label the same product, the latter company whould be placed in a most untenable position with OSHA. It is our understanding that OSHA is planning to use the list of non-locked-in products submitted by Dr. Fred Pundsack of J-M at the March hearing as its labeling criteria. If this list is followed, difficulties with OSHA should be few. Nevertheless, there are always products which do not fit any list, or which may produce levels in excess of the standard at one step in the application or handling process. For example, the field cutting or trimming of asbestos-cement pipe might produce levels in excess of the standard, but only for the man doing the actual cutting and only very intermittently or rarely. Thus, to place a warning label on asbestos-cement pipe would be quite misleading in that it would alarm all those handling the product, when only one man has a potential excess exposure. Our recommendations to you on labeling would thus be as follows: 1. If the product is included on the list of nonlocked-in products, it should be labeled. 2. If a product is not included on the list of non-locked-in products but you consider it to be a border line case, or if the product has an occasional handling or fabrication problem, the following options are open: a. Label it and be on the safe side. b. Do not label it and hope OSHA doesn't question your decision. c. Conduct tests to determine if the use of the product does indeed produce levels in excess of the standard. Chances are that -More- FMSI 02823 -3- most product uses of this type will meet the eight hour TWA standard of five fibers, and that most problems will be in meeting the ten fiber ceiling standard. If tests determine that neither standard is exceeded, the product obviously need not be labeled. The test results should be kept in readiness in case an OSHA inspector questions your " decision. d. If the eight hour time weighted average is above five fibers per cc, then the product should be labeled. , e. If the ceiling value is above ten fibers per cc, which is- the more likely of the two possibilities, then the use of the product should be examined to determine (1) how far above ten fibers per cc is the ceiling value, (2) does this particular work practice or use of the product occur frequently, intermittently, or only rarely, (3) can the product be applied, cut, trimmed, etc. in another fashion such that the ceiling level does not exceed ten fibers per cc. After these questions have been answered, it will be up to the individual company involved to weigh each answer carefully and to arrive at a decision based on the simple proposition: Does this product or its use place the health of workmen in jeopardy? Obviously, if the answer is "yes," the product should be labeled. If, on the other hand, you honestly believe that the ansv;er is "No!" then you should not feel constrained to label the product, nevertheless you must be prepared to defend your position with OSHA should they question it. There are a number of ways that you can place your company in a better defensive position should OSHA challenge your decision not to label a particular product. The basic idea would be for you to alert the purchasers of this particular product that one or more operations in the handling, application, cutting, etc. of the product might produce levels in excess of the standard and that -More- FMSI 02824 4- precautions should be taken. This could be done through personal contact between industrysalesmen and customers, or in the form of an instruction sheet delivered with the order that might specify certain work practices or types of machinery that should be used to keep dust levels, low. The instruction sheet, for example, might say nothing more than "Powered bench saws without collectors should not be used in cutting this product. If this is impractable, operator should be provided with a U.S. Bureau of Mines approved respirator." An approach of this type, or one somewhat similar, would indicate to OSHA, should the question arise, good faith on your part. With regard to the coordination of industry labeling practices, if your company has decided to label a product not included on the attached non-lockea-in list, I would appreciate being notified of this decision and the rationale behind it as soon as possible, so that a uniform position can be established with other companies in the industry manufacturing the same product. If you have any questions or problems with regard to labeling, please feel free to contact us at any time. I would not advise your asking OSHA for a decision on whether or not to label a certain product. Almost assuredly they will tell you to label any border line product, and that decision will become binding for the rest of the industry as well. Very truly yours, Matthew M. Swetonic Executive Secretary Enclosure FMSI 02825 NON-LOCKED-IN ASBESTOS-CONTAINING PRODUCTS REQUIRING A WARNING LABEL ACOUSTICAL PRODUCTS I Dry spray type Foamed asbestos CALCIUM-SILICATE SHEETS Low density sheets (less than 50#/ft^) CEMENTS > Dry Gypsum joint cements Insulating cements INSULATIONS Low density calcium silicate binders Corrugated paper Low density magnesia binders High temperature blocks & bricks PAPERS & FELTS . Commercial grades (unsaturated) Roofing felts (unsaturated) Gaskets (unsaturated or not encapsulated) Millboards (unsaturated or uncoated) STUCCO & PLASTER Dry mix cement stucco Dry mix decorative plaster TEXTILES (unsaturated or uncoated) Braided Cloth Listing Nicks Yarn products ASBESTOS FIBER BAGS FMSI 02826 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N. J. 07652 BULLET I N NO. 4 4 6 July 11, 1972 TO: ALL MEMBERS SUBJECT: EQUIPMENT/TRAINING FOR ASBESTOS MEASUREMENTS At the recent Annual Membership Meeting it was brought to my at tention that many members had not received information on equipment for measuring airborne asbestos in the work place. Most of the following information is a re-hash of earlier information - partic ularly Bulletin #428 of February 18, 1972, OSHA STANDARDS. OTHER PAPERS RELATIVE TO ASBESTOS IN THE WORK PLACE 1. Occupational Safety & Health Administration (OSHA) Standards per Williams - Steiger OSHA Act of 1970. Federal Register, May 29, 1971 2. OSHA Standards for Exposure to Asbestos Dust, Federal Register, June 7, 1972 3. "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method". Asbestos Textile Institute P.0. Box 239 Pompton Lakes, New Jersey 07442 (Price $1.00/copy) The Institute distributed copies of these to the members during the past year. The most pertinent are Item 2 (OSHA Standards for Asbestos) and Item 3 (Measurement of Airborne Asbestos..."). GENERAL METHOD (MEMBRANE FILTER METHOD) A pick-up is worn by a worker in the area to be measured. A battery operated vacuum pump draws in air over a specified period--say 60 minutes, 90 minutes or four hour*. Asbestos fiber is trapped by the filter and then sealed and sent to the laboratory. The sample is examined using an optical microscope where asbestos fibers are counted. Details on the optical count are given in the book "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method". FMSI 02827 Bulletin ;is446 2- - July 11, 1972 EQUIPMENT & SUPPLIES Depending on the size of operation, at least two pumps costing about $150 each are required: (a) Mine Safety Appliance Co., Pittsburgh, Pa. 15208 (b) Willson Products Div., Reading, Pa, 19603 (c) Unico Environmental Instruments, Fall River, Mass. 02720 A battery charger (one for each 2 pumps) is suggested. The charger would cost about $50. Pad and filter inserted run about 70$ a piece, and are available from the Millipore Corporation, Bedford, Mass., 01730. A binocular microscope with phase contrast illumination set for 400/430X magnification is required. While a Bausch & Lomb microscope costing $1,200/1,500 is basic, binocular microcopes with additional fix tures should be worth the additional cost. (Seek professional advice on this.) Most of the above information is verbatim from the book "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method." OUTSIDE SERVICES AND TRAINING It may be feasible to have outsiders do the full job - from sampling through examination and reporting. Others will do the analysis work only where the samples are mailed to the laboratories. Tracerlabs in California will do analysis work for about $50.-60. per analysis. Johns-Manvi1le will do the full job for a fee (Contact Mr. W. Reitze, Manager Industrial Hygiene Engineering Service, Johns-Manvilie Corporation, P.0. Box $5108, Denver, Colorado $80217) George Clayton Labs, Southfield, Michigan will do the full job for a fee. There are other labs that may do the entire package or the analysis work only. Johns-Manvilie indicated it would be willing to train personnel in the technique in a two day period. They would take one trainee or at most two trainees, to one instructor for $200. a day. These sessions would be at Phindern (Somerville) New Jersey or Waukhegan, Illinois. Again, the contact would be with Mr. Reitze in Denver. It is most important that those concerned with the 0SHA Standards enforcement receive this basic information. Should additional informa tion be required, please advise. E. W. Drislane Executive Director FMSI 02828 REPORT ON FMSI ASBESTOS STUDY COMMITTEE ACTIVITIES The Asbestos Study Committee was formed July 1971 with the assigned purpose to review and comment on rules and regulations promulgated by state and federal governments concerning asbestos and its applications. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. P. Stefl of Raybestos-Manhattan, with members from Worldbestos, Abex, Bendix, and Carlisle Corporation and J-M present. The following items were reviewed and/or discussed: (1) Relationship with Asbestos Information Association/North America. (2) Proposed Illinois Regulations. (3) Vehicle friction material emission test program to be conducted by Bendix under EPA contract. (4) Monitoring for airborne asbestos fibre. (5) Districution and circulation of literature on Asbestos/Health subjects. The purpose of the Asbestos Study Committee was restated as follows: "to gather and dessimate to its members information about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environment(particulate emissions) and to draft comments relative to proposed regulations in defense of reasonableness." The following is a list of the actions taken by the FMSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: September 30 - Issued minutes of first Committee meeting with letter commenting on proposed Federal EPA and Illinois emission standards. October 28 - Issued bulletin and further information on Illinois hearings. November 10 - Issued information on membrane filter monitoring method. November 14 - Issued bulletin on revisions to Illinois and Federal EPA proposals. December 8 - Issued information concerning final draft of proposed Illinois regulation, proposed EPA emission standards, and Federal Department of Labor Regulations on Occupational Exposure. On January 26, 1972 arrangements were announced for Bill Reitze of J-M to conduct an instruction session on asbestos fibre monitoring at FMSI headquarters February 10. On February 10 this session was presented to nine attendees representing six member companies. The second Asbestos Study Committee meeting also was held on February 10 with I. H. Weaver, Raybestos-Manhattan, acting as chairman and members representing Worldbestos, J-M, Bendix, and Carlisle attending. The following items were covered: 1. Review ofAIA/NA comments regarding 0SHA meeting in Washington on January 26. 2. Review of proposed 0SHA asbestos standard and comparison with British standards and regulations. 3. Review of British Friction Material Council comments on Illinois standards. It was resolved to forward to BFMC copies of minutes of future FMSI Asbestos Study Committee meetings. 4. Recommendation made that the FMSI Asbestos Study Committee maintain close liaison with AIA/NA. 5. Reviewed background and expected thrust of 0SHA and EPA regulations. FMSI 02829 2- - 6. Reviewed monitoring equipment and methods. 7- Recommended future course for Asbestos Study Committee. The following is a summary of actions taken by the Executive Secretary during the first half of 1972 in regard to Asbestos Study Committee matters: February 18 - Circulated Bulletin 427 regarding various standards for asbestos dust exposure and control. This included copies of the January 12 Federal Register announcement of proposed permanent OSHA standard for asbestos control in the work place. February 18 - Issued Bulletin 428 reporting on February 10 demonstration by Mr. Reitze of membrane filter monitoring method. June 1 - Circulated announcement of Microscopy Seminar scheduled by McCrone 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 tentative schedule for third Committee meeting to be held late July or August. June 12 - Issued announcement of OSHA permanent standards on asbestos dust exposure as published in June 7 Federal Register. The latter item has been rather intensively studied by your Chairman, by AIA/NA, and no doubt also by concerned individuals in practically all companies represented in FMSI. The consensus appears to be that the new regulation is stricter than need be in respect to the future TLV of 2 fibres per cc, but is more lenient than was expected in regard to many other important matters. Major changes between the new regulation and the earlier emergency standard and earlier proposed permanent regulations are as follows: 1. Automatic reduction of TLV to 2 fibres in four years. 2. Use of protective clothing required above 10 fpcc ceiling limit. Change rooms, dual locker facilities, and speciallaundering and clothing handling procedures required. 3. Monitoring required at least every six months at operations exceeding allowable TWA concentration. 4. Physical exam and doctor's approval required before assigning employees to jobs requiring use of respirators. 5. Elimination of references to ''cancer" and "danger" on signs and labels. Labeling eliminated for products containing locked-in fibre. 6. Specific restrictions on "dry sweeping" and use of compressed air for cleaning eliminated. 7. Medical examinations, including pulmonary function tpsts,required annually for all employees exposed to dust. 8. Employee access to medical and monitoring records required. Employees exposed to levels above TLV must be notified in writing. 9. 'Waste containing only locked-in fibre need not be sealed nor labeled. FMSI 02830 -3 - While many serious difficulties are expected in achieving compliance with the new regulation by miners, textile manufacturers, and insulation fabricators and installers, it appears to me that most friction material manufacturing operations not relying on textile technology should have relatively little trouble, although some dry mold type friction operations may also po se problems. Perhaps of a more serious nature is the potential threat of banning of asbestos in friction materials, particularly in automotive vehicles, to eliminate emissions from wear debris. It is doubtful that any further action in this direction will be taken until results of the comprehensive study by Bendix Corporation for EPA have been announced. I have been advised that this study, originally to have been completed this month, now is not expected to be finished untij. late this year. Most 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 aseous 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 consuming engineering design efforts. Another vital EPA program also is running behind schedule. That is promulgation of the permanent regulations and standards for asbestos emissions to the ambient atmosphere. I have been advised by the EPA Hazardous Pollutants Branch that the earliest date these standards are expected to be issued is the beginning of August, and they could be delayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatins. Significant changes are expected in the sections applying to mining and spraying operations. Probably the only significant change between the proposed regulation and the expected final regulation as far as manufacturing operations are concerned is the broadening of specifications on fabric filters and wet dust collectors. This should be helpful to industry in permitting somewhat more flexibility in dust collector selection and application. Before closing, I should like to recommend a few of my thoughts and suggestions that I have received from others concerning items that should be considered and reviewed by the Asbestos Study Committee during the following year. 1. Uniform interpretation of OSHA standards. Liaison with AIA/NA will be helpful in this. 2. Determination of technological feasibility of achieving both 2 and 5 fibres throughout the industry. 3. Determination of the overall effect on the friction material industry of the OSHA standards. 5. Development of guidelines, aids, and educational programs to help customers comply with the regulations. 6. Investigate a suitable standard method for analysis for asbestos in brake lining wear debris. 7. Develop methods and recommendations for safe disposal or recycling of friction material grinding waste. 8. Follow as closely as possible medical and occupational health research concerning asbestos and asbestos-related diseases and determine whether FMSI or its member companies should help sponsor or otherwise suppotet' work of this nature. FMSI 02831 -LAll of these subjects probably will be reviewed at the third Asbestos Study Committee meeting to be scheduled within the next month or so. Please advise us of any additional items you or others in your organization may wish to add to our agenda for this up coming meeting. Respectfully submitted, I. H. Weaver, Chairman FMSI 02832 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, PARAMUS, N.J. 07652 June 20, 1972 TO; MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: OSHA STANDARD - POSITION OF INDUSTRY, NIOSH AND ADVISORY COMMITTEE Mr. I. H. Weaver, Chairman of the Committee, felt the attached tabulation proposed by AIA/NA comparing items in the OSHA Standard against the Inudstry position and the recommendations of NIOSH and the Advisory Committee on Asbestos Dust would be of interest to all members of this Committee. Copies of this tabulation are attached for your information. EWD:11z E. W. Drislane Executive Secretary FMSI 02833 P ft P ft CO d tr: CoO 1--1 d p H fc, C5 O -P -P rl VwP GC O *H |4 "7 > d O P -d CP '-0 to 0 ' 7 rl rj` r >G 10 rb O -* O G O O0 O *0 M -- O ;-! 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FMSl 02835  123 E. STIEGEL STREET, MANHEIM, PENN. 17545 RaybestosgfManhattan I .H . WEAVER CORPORATE DIRECTOR ENVIRONMENTAL CONTROL June 16, 1972 Fir. E. W. Drislane Executive Secretary Friction Materials Standards Institute, Inc. Bergen Mall uffice Center E.210 Route flk Paramus, N.J. 07652 Dear Ed: Attached is my report on the past year's activities of the Asbestos Study Committee which I hope will be satisfactory for your presentation the week after next. I regret I won't be on hand at the meeting and certainly appreciate your pinch-hitting for me. If you have any questions or recommendations concerning revisions or additions or deletions to the attached report, please call me. I expect to be in the office Monday, Tuesday, Wednesday and Friday next week and Monday, the 26th. After that I will be away until July 17. Also attached Is a copy of a tabulation prepared by AIA/NA comparing each major item in the final OSHA standard against the industry position and the recommendations of N10SH and the Advisory Committee on Asbestos Dust. I think this might be worthwhile copying and forwarding to the other members of the FMSI Asbestos Study Committee.I I am not returning the form you sent me regarding the schedule for the next meeting as all of the dates listed on this schedule still are open as far as I am concerned. Unless you advise otherwise I will wait until I get back from vacation to return this schedule to you, as by that time I expect to know a little more regarding my plans for the last week in July and "the month of August. T'O era pHq T W aver e FMSI 02836 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N. J. 07652 BULLETIN N 0. 4 3 9 June 12, 1972 SUBJECT; Occupationsl Safety . Health Administration Standard for Exposure to Asbestos Dust. On June 7, 1972, OSHA published theirstandard on exposure to asbestos dust in the work-place. Exposure Limitations The standard remains at 5 fibers (a fiber being longer than 5 micro meters) per cc of air as measured by the membrane filter method--for an 8 hour time weighted average. This is effective July 7, 1972. As of July 1, 1976 the 8 hour time weighted average will be reduced to 2 fibers per cc of air. There is a ceiling concentration of 10 fibers per cc at any time. This new standard has details onthe use of respirators, ventilation, wetting down of asbestos, clothing, lockers, laundering, caution signs, medical exams, etc. are covered in this standard. The Institute would be happy to send a copy of this Standard to members on request. E. W. Drislane Executive Secretary Distribution; Active Members a' FMSI 02837 FRICTION MATERIALS STANDARDS INSTITUTE, INC.,&-210 ROUTE #4, PARAMUS, N. J. 07652 June 6, 1972 C. TO: Members of Asbestos Study Committee SUBJECT: Asbestos Fibers Emissions - Friction Materials A seminar was held at the Illinois Institute of Technology Research Insti tute back in April of this year. Dr. Colin Harwood of IITRI was one of the advisors to the Illinois Pollution Control Board who was in favor of the pro posed 1971 regulations as written--that is to include a ban on the" use of asbestos in the brake lining of vehicles manufactured after January 1, 1975 and sold for use in Illinois." The pages from the IITRI paper are: pages 22, 25, 26, 27, 28, 46, 49, 65, 66, 67, 68, 69, 70, 71, 72, 73. Your Chairman, Mr. I. H. Weaver, sent this data to me for distribution to the Committee. He commented on the paper: "The main issue I would have with Dr. Harwood's conclusion would have to do with whether or not the free fibers or fibrils released from friction material decomposition are truly hazardous in any way, and I also believe he tends to underestimate the problems in non-asbestos containing braking systems. " Your Chairman believes that a meeting of the Committee should be called. I'm asking for a reply on the attached form, for which weeks not io call a meeting. From this I will try to arrive at a meeting date (perhaps late vXjly or late August). EWD/lmc E. W. Drislane Executive Secretary FMSI 02838 MEETING SCHEDULE - ASBESTOS STUDY COMMITTEE TO; Friction Materials Standards Institute, Inc. E-210 Route #4 Paramus, N. J, 07652 Gentlemen: Concerning a proposed meeting of the Asbestos Study Committee, PLEASE DO NOT SCHEDULE IT FOR THE FOLLOWING WEEKS: July 24-28 August 7-11 August 14-18 August 21-25 August 28-31 Additional Comments: By. Company. Date FMSI 02839  123 E.STIEGEL STREET, MANHEIM, PENN. 17545 Raybestosjptenhattan I . H. WEAVER CORPORATE OIRECTOR ENVIRONMENTAL CONTROL June 1, 1972 Mr. E. W. Drislane, Executive Secretary Friction Materials Standards Institute, Inc Bergen Mall Office Center, E.210 Route #4 Paramus, N.J. 07652 Dear Ed: The attached material concerning automotive emissions of asbestos fibre was received from Illinois Institute of Technology Research Institute yesterday and probably will be of interest to other members of the FMSI Asbestos Study Committee . I suggest that you circulate it to them. This material was forwarded by Dr. Colin F. Harwood of IITRI as a supplement to information presented at a seminar on asbestos they conducted April 4 through 7* Very little attention was devoted to automotive emission sources during the seminar. The main issue I would have with Dr. Harwood's conclusion would have to do with whether or not the free fibres or fibrils released from friction material decomposition are truly hazardous in any way, and I also believe he tends to underestimate the problems involved in non asbestos containing braking systems. Since it appears unnecessary and probably impossible to schedule an Asbestos Study Committee meeting in June and I will be away the first two weeks in July, I think it might be prudent to tentatively schedule a meeting late in July, preferably during the last week. By that time I expect there will be a number of subjects worthwhile reviewing. If you agree, kindly canvass the other members and pick a date. As far as I know, I will be available airtime during the week of July 24. I am also open the week after that in the event this suits the others better. Best regards. I. H. Weaver w FMSI 02840 attachments such that the dust created is arrested at the source and collected in filter bags. Commercial devices are available but normally firms with a sincere interest in pollution control, design and fabricate their own devices. Two examples of such ^ devices are shown in Figures 6 and 7. These control hoods work on the high velocity, low volume principle and can be readily adapted to industrial vacuum cleaner systems. When arrest-at-the-source systems are not possible, tech niques similar to those employed by the asbestos spraying industry may be utilized. Rules which relate more specifically to fabrication of asbestos products may be found in such publi cations as: 1. "Recommended Practices for Fabricating, Handling and Construction industries," Health and Safety Council-Asbestos Cement Products Association. 2. "Recommended Health Safety Practices for Handling and Applying Thermal Insulation Products Containing Asbestos," National Insulation Manufacturers ' Association (NIMA). 3. The Asbestos Research Council - Control and Safety Guides (London, England). 4. "Recommendations for Handling Asbestos," Engineering Equipment Users Association (EEUA), E.E.U.A. Hand book No. 33. 3.3.3 Friction Material Applications Typical friction materials contain 30 to 50% asbestos and may be up to 70%, and the industry that manufactures these ma terials is ranked third (1969) in the consumption of asbestos fibers. Crysotile is the preferred variety because it has better frictional properties than amphibol asbestos and does not exert so much wear on the opposing surface. The major uses of asbestos-containing friction materials include brake linings, brake discs and clutch facings. These products have been applied to a wide variety of industrial and commercial products. 11T RESEARCH INSTITUTE 22 FMSI 02841 Sources of Emission - Emission of asbestos from friction materials results from normal day-to-day usage. An idea of the scope of this source can be gained from the estimation that the average automobile wears out 3 to 4 sets of brake linings, and " 1 to 2 sets of clutch facings during its lifetime and that commercial public transport vehicles wear out many more sets. Data concerning motor vehicle brake linings for the whole of the United States are given in the following: Vehicle miles during 1968 1,010,000,000,000 Mileage life of brake linings 27,500 Brake lining sets on new vehicles 10,718,000 Pounds of asbestos per set of brake linings 3 Tests performed on brake linings have indicated that under conditions of normal usage, considerable alteration of the asbestos occurs. It is reported that most of the dust collected from brake drums appears non-fibrous and is sxmilar in appearance to thermally degraded asbestos. The suggestion is that hxgh temperatures at the brake lining/drum contact points actually reach degradation levels. Tests on brake linings, brake discs and clutches have demonstrated that the quantity of fiber emitted is some function of the severity of the braking conditions (see Table 3). How ever, even at the level of 1%, the total emissions must be considerable when the total tonnage in use is considered. Further, the emissions are likely to occur at places of high density population and restricted ventilation. That is, in busy main streets of towns surrounded by large buildings. The effect of different braking conditions and different types of friction materials on asbestos emissions is the subject of a study being sponsored by the Environmental Protection Agency. Other studies are being conducted in California and some work on roadsides has been done at Mt. Sinai, New York. The EPA study will establish the extent and nature of the asbestos 11T RESEARCH INSTITUTE 25 FMSl 02842 Table 3 ASBESTOS EMISSIONS FROM BRAKE LININGS (Test Results by Electron Micrograph) Product Brand 1. Automobile A drum brakes 2. If B 3. If C 4. H C 5. D French 6. II E 7. II .F German 8. II G 9. II G 10. It H 11. Automobile clutch J 12. Automobile disk brake K 13. Bus drum brake L 14. M 15. Truck drum F brake (light) Test Method Friction No. of Samples 6 Conditions Presence of of Tost-F Free Fibers 300-000 Few 7. Free Fiber* <1 Friction Friction Friction Friction 6 250-800 None 0 5 300-700 Few <1 1 700-900 Numerous --10 5 300-800 Few <1 Friction Friction 5 300-700 5 300-800 Few Few <1 <1 Friction Friction Friction Dynamometer Dynamometer Dynamometer Friction Friction 2 1 2` 1 1 1 2 10 100-500 600-700 100-600 normal driving normal driving city driving 450-550 300-800 Few Numerous Few None Few None None Few <1 --15 <1 0 <5 0 0 <1 *Weipht estimated from fiber volume. 26 FMSI 02843 emitted from brake drums, disc brakes and clutches of vehicles operating under real conditions. Hopefully the situation will be more clearly understood at the end of those studies. _ Emission Control Techniques ' Emission at Overhaul - To avoid blowing the accumulated dust into the atmosphere at the time of overhaul devices have been suggested for extraction of the dust from brake and/or clutch housings by suction. Of the devices tried, a simple hand-held vacuum cleaner has proven to be the most flexible unit. Changes to the original design have been limited to the addition of a disposable paper bag inserted in the original cloth bag. The paper bag may be easily sealed before removal to prevent emission. Substitution - Beyond the adaptation of better cleaning practices during brake and clutch maintenance, as mentioned above, additional controls seem to be limited to improve design of brake and clutch assemblies and/or substitution of other materials for asbestos. The high temperature properties and exceptional tensile strength of asbestos have resulted in very compact and economi cal design. These same unique properties which make asbestos applicable to friction materials also make the application of substitute materials very difficult. The tensile strength and modules of rigidity of asbestos as compared to several candidate substitute materials follows: o Tensile Strength lb/in. Asbestos 550,000 Fiber yarns 180,000 Steel wool 50,000 Mineral wool 25,000 2 Modulus of Rigidity lb/in. 30,000,000 3,000,000 100,000 60,000 There is no doubt that substitution of other materials for asbestos is possible, but the design changes required to accom modate the stresses and temperatures involved would result in 11T RESEARCH INSTITUTE 27 FMSI 02844 larger, more expensive components. Brakes - The recent adoption of disc brakes by the auto motive industry makes material substitution more plausible. Disc brakes are capable of greater energy dissipation than similar sized drum brakes because the design results in con siderably lower heating rates. This is due to the fact that at any one time the friction pad contacts only a section of the disc surface. The lower operating temperatures permit the use of friction materials which do not contain asbestos. Another feature of disc brake design which has reduced the need of asbestos materials is the lower strength requirement of the friction material. Clutches - The substitution of other material for asbestos in clutch facings of traditional design could only be done by changes in size and design. Two changes in clutch design which have reduced the requirement for asbestos-containing friction materials are the advent of the automatic transmission and the redesign of manual clutch friction surface. The clutch surface of the automatic transmission is im mersed in an oil bath which virtually eliminates airborne pollutants. Further, the cooling affect of the oil bath reduces the requirement for high-temperature capability materials. Automatic transmission clutch facings may be made from either sintered metals or fibrous cellulose materials. Many manual clutches have redesigned friction surfaces which consist of numerous small circular pads or discs attached to the clutch face as opposed to the standard annular ring friction surface. These small pads act in the same manner as the disc brakes friction pad. Thus, lower stresses and oper ating temperatures associated with the new design reduce the need for asbestos-containing friction materials. 11T RESEARCH INSTITUTE 28 FMSI 02845 .10 qPF.r.TFIC PROBLEMS 10.1 Emission Levels In understanding control techniques and their efficiencies, it is important not to be confused with efficiencies quoted"on a weight basis and those based on a particle count basis. Firstly, considering efficiency based on a weight basis, it is relatively easy to get a very high efficiency with parti cles whose size is in excess of 5^. with a variety of control devices (see Figure 10). However, the efficiency does drop off considerably with decrease of particle size, for example, see Figure ll for 1n particles. (it should be noted that these graphs refer to spherical particles - information on fibrous particles is not presently available.) Now consider what these apparent high efficiencies mean 3 in terms of numbers of fibers. It can be assumed that 10 average fibers of asbestos weigh approximately 1 ng. If 1 g of asbestos material approaches a filter rated at even as high as 99.999% efficiency, then the quantity passing 4' 3 through will be 0.00001 g, or 10 ng. And since 1 ng ^10 7 fibers, then a total of 10 fibers will pass through the filter for every 1 g of material impinging upon it. This is a situation not frequently brought out, but is very significant when exposure levels are monitored in terms of fibers per cubic centimeter. Thus the quoting of efficiency in terms of mass efficiency is a "red-herring" statement that flatters to deceive. It bears no obvious relation to the number of fibers being emitted. However, based on tests which actually measure the number of fibers being emitted, it would seem that both fabric filters and high efficiency wet scrubbers are capable of reducing the fiber counts to acceptable levels. British experience is that 0.2 f/cc is routine and Johns Manville finds that 1 f/cc is an acceptable value when the results are averaged over a time period. NT RESEARCH INSTITUTE 46 FMSI 02846 The medical evidence as to the size of fiber responsible for adverse health effects is not positive nor is the question of whether fibrils of fibers are most hazardous. Until the , medical questions are fully resolved, it would seem premature to impose inflexible or overly rigid regulations. This has been the view held by the Federal occupational health authorities in assessing their standards. It would seem that thei approach in limiting exposure to that which is possi ble using good modern technology is sensible. The same may be said for their monitoring techniques. . 10.2 Water Pollution Recycling of waste water is possible and is practiced in certain segments of the industry. The question of the damage done to streams, rivers, and lakes by indiscriminant dumping of asbestos containing waste waters needs careful study. One must remember it is a natural material which will appear in water in any case. On the other hand, there is evidence that asbestos particles ingested into the stomach may cause stomach cancer,, Again, until medical evidence is clear, it would seem sensible to recycle water whenever this can be accomplished. IIT RESEARCH INSTITUTE 49 FMSI 02847 ASBESTOS AIR POLLUTION RESULTING FROM THE WEAR OF BRAKE LININGS By Colin F. Harwood, Ph.D. ABSTRACT Asbestos containing brake linings have been cited as a source of ambient air asbestos pollution. This paper reviews the suggestion and an estimate is presented which indicates that the asbestos emission from brake linings is significant. The ways in which this emission may be reduced or eliminated are briefly reviewed. IIT RESEARCH INSTITUTE 10 West 35th Street Chicago, Illinois 60616 in RESEARCH INSTITUTE 65 FMS1 02848 ASBESTOS AIR POLLUTION RESULTING FROM THE WEAR OF BRAKE LININGS INTRODUCTION - Recent interest in asbestos and the realization of its health hazard have raised the question of the extent to which people are exposed.to asbestos on a non-occupational basis. Measurements have been made on urban background levels and it has been shown that small but definite concentrations are to be found in areas quite remote from any apparent source. Since virtually every motor vehicles carries several pounds of asbestos contained in its brake linings and since these are worn away to some degree every time the brakes are applied then it is reasonable to expect that they could present a significant emission source. This is especially acceptable when one considers the 100 million or so vehicles on the nations roads. The paper investigates the possible extent of such emissions and presents an estimate of the contribution to urban asbestos concentrations. Possible means of reducing such emissions by use of an alternative or sealing the system are briefly reviewed. The Extent of the Emission 12 The best information available at the present time ' indicates that the percentage of asbestos contained in the dust normally emitted from brake linings is of the order of 1%. However, under conditions of severe breaking, this may rise to 15%. ' The average brake friction material contains of the order of 50% asbestos, thus an explanation is necessary to account for the discrepancy between the measured and theoretical values. The most likely explanation results from the known facts with re gard to heat generated at friction surfaces. The work of Bowden and Tabor has shown that when two surfaces are placed together the contact area is dramatically less than the apparent area. I IT RESEARCH INSTITUTE 66 FMSI 02849 This means that very large energy transfer takes place at these contact points and extremely high temperatures are reached. In the case of brake linings, some evidence of these temperatures has been generated in unpublished work by the General Motors 4 Company . In this study, a small hole was cut through a brake shoe and the radiation collected from the ex posed shoe surface was monitored. The results suggested that under light braking temperatures of the order of 800-900C were found, while during heavy braking the temperature reached 1700-1800C. ^ The significance of this data to the present case is 5 that it is known that asbestos decomposes above 500C to give forsterite (Mg^iO^), talc (Mg^Si^O^Q(OH)2) and watervapor. Acceptance of the value of 1% ofasbestos emittedallows an estimate to bemade of theeffect of thisemission on the " quality of the atmosphere. Estimation of Urban Concentrations of Asbestos From Brakes Assumptions a. There are approximately 100 million* motor vehicles. b. Motor vehicles have an approximate average weight of 4 lbs of friction material, when new, of which 50% is asbestos. c. The average motorvehiclewill require replacement of the brakes after three years of use at which time they will have lost 50% of their weight by abrasion. d. The dust emittedwillcontain 1% ofasbestos fibers. e. Of the wear dust, 80% is emitted and 20% is lodged within the system. . ' claims there are 109,000,000 licenced vehicles in cluding 90,000,000 passenger vehicles and 19,000,000 trucks. IIT RESEARCH INSTITUTE 67 j j i j j I j ; j I f ! i [ j f i | l i ! J ; : i ; i FN1SI 02850 The total weight of brake linings in use is 100/~5000 = 200,000 Tons. The quantity worn off these linings per year follows from the assumptions made in c. as 200,000 x 1 ^ 50 x Yo(j _ " 200,000 6 Tons/yr. This wear dust contains 1% asbestos, hence emission is 200,000 _1_ 6 X 100 2QQ0 Tons/yr. Allowing for the fact .that 20/ is not emitted, the total emission is thus 2000 80 6 x 100 1600 270 Tons/yr. Effect on the Atmosphere There are no facts relating directly to asbestos on which one may judge the effect of these emissions on urban air. However, there has been a considerable amount of study done on the diffusion of other materials from automobiles, particularly lead and carbon monoxide. At a recent ACS Symposium in Minneapolis^ evidence was presented which placed the level for lead emission at. 0.01 |i.g/m3 in Thule, Alaska and 2.5 jig/m3 in New York City. Next to busy highways a level in excess of 3 60 )ig/m may well be possible. In the light of this data the 3' value of 2 |ig/m for average urban air conditions, suggested 4 by GM , seems eminently reasonable. Considering that 1.25 x 10 tons of lead are emitted in total from automobiles then the following factor is used. Avg. Cone, asbestos in city air from automobiles _/-v_ Quantity of asbestos emitted 2 uq/m^ city air x. n _5 . 1.25 x 10 tons Pb from cars Applying this figure to the present case and assuming that 200 tons are emitted in city areas, then we get that: I I T RES E ARCH INSTITUTE 68 FMSl 02851 The avg. cone. _A_ 200 x------------ --:--e 1.25 x 10 3.2 x 10~3 pg/m3 or 3.2 x ng/m3 ^ A similar result is obtained using the dispersion factor for carbon monoxide. However, the values for lead are preferred since it is a particulate emission rather than a gas. The Significance of This Value The question of whether asbestos containing brake linings constitute a significant source of ambient air background, asbestos levels can now be considered. Firstly, it is pertinent to review the available evidence_ on asbestos levels in ambient air. Perhaps the most up-to-date information is reported in a recent paper by Thompson and 7 Morgan of the EPA . Their data suggests that values 0.5-15 ng/m 3 are appropriate to urban sites, while 0.1 ng/m 3 is to be 3 found in nonurban sites. They give a figure of 0.01 ng/m for remote sites. The California State Health Department in collaboration with the School of Public Health, Berkeley, California, have tested ambient air for asbestos. Their results suggest values of 0.06 ng/m 3 in remote sites and 3 ng/m 3 near a source. . 8 Nicholson and Rohl of the Mt. Sinai School of Medicine have also been active in the measurement of asbestos in urban ambient air. The analysis of a large number of samples has revealed that 33% of the samples contained 0-0.9 ng/m"*, 55% contained 1.0-5.0 ng/m3 and 10% contained 5-20 ng/m3 and a few Were in excess of this. All of the workers have been at pains to point out that the results are to be considered preliminary. Thus they should k regarded not as final definite figures, but rather as good, 11T RESEARCH INSTITUTE 69 FMSI 02852 considered, preliminary findings. The similarity of the figures reported by the various workers does suggest that at least an order of magnitude has been established. 3 Consider now the estimate of 3.2 ng/m calculated pre ^ viously as the contribution from asbestos brake linings. Firstly, it should be stated that this figure is a conservative estimate and allowance has been made for the many factors which could re duce this figure. Secondly, although there is no reason to doubt the factor for the diffusion of lead, it should be realized that this figure is an average value for the whole of the city air. Consequently, much higher concentrations are to be expected in certain areas of high brake usage. For example, near inter sections, tollbooths, etc. In the light of the evidence here presented, one must conclude that asbestos emitted from brake linings may be a major contributing factor in the overall ambient air concen tration. . Further work is necessary to establish more definitely the major contributors to urban asbestos concentration levels. It is not possible to state with assurance how much these low concentrations of asbestos constitute a threat to the health of the general public. Medical evidence and opinion is widely divergent on this issue. However, asbestos has been rated as a hazardous substance by the EPA and as such it should be treated with due respect. Emissions should be reduced or curbed wherever this is possible. To this end it is worth briefly reviewing how this may be achieved. I^HHOLOGY of eliminating emissions The emission of asbestos to the atmosphere from asbestos containing brakes could be prevented in two ways: its use could be banned altogether, or, the brakes could be sealed. In the *orr,tor case, an alternate would have to be found. 11T RESEARCH INSTITUTE 70 FMSI 02853 Alternatives to Asbestos For a replacement to be as suitable as asbestos, it would have to fulfill a list of desirable features as: Resist high temperatures without degradation or loss of frictional properties. 9 Combine excellent friction characteristics without severe abrasion. Provide great strength - asbestos fibers have a greater tensile strength than steel and yet are more flexible. Have relative economy. Of the materials which have been considered, sintered metal with ceramics and fiberglass have been the most likely candi dates thus far. Sintered Metal - This material has been used and indeed has the desirable quality of being fade-free, for this reason it is still used in some racing cars. Hoveyer, it has several dis advantages. It tends to be noisy and brake screetch is a problem. They suffer from what is known in the trade as "morning sickness", this means that the first stop is very severe, or, that the cold friction is high. Wear is higher than with asbestos and thus the brakes have to be replaced more frequently. Replacing the brakes is more difficult since all brakes are honed to fit the drum. Honing metal is more difficult than asbestos friction material. Ceramic Metal (Cermets) - A sintered metal and ceramic composition has been developed and tried. Its use at this time seems to be restricted to the clutches on heavy-duty vehicles (tractors, etc.); in these cases it is usual to use buttons of the material rather than a complete annulus. Although to a lesser degree, it suffers from the same complaints as sintered metal with respect to noise, wear and severe first &toP< and in addition, it is relatively expensive. However, 11T RESEARCH INSTITUTE 71 FMSI 02854 its anti-fade characteristics have led to extensive testing. For example, the Ford Motor Company put inserts of ceramic metal at the position of maximum brake wear on their 1958 ~ Thunderbird. The concept was abandoned, reportedly due to uneven braking leading to a directional pull when braking. ^ Fiberglass - Attempts to use fiberglass instead of asbestos have been attempted since 1938. So far, no design has met the exacting standards required. As with the other materials, the first stop is harsh. Apparently the design is better for disc brakes than drums. A problem is the sensitivity of the brake to moisture. Owens-Corning are undertaking development research in this area. They are very guarded with regard to the status of their work, but state that they are actively engaged in developing a product. To date, no vehicles are known to employ fiberglass in their brake friction product. Sealed Systems ' Sealed systems have been seriously considered. Normally, cars rely on air cooling and the movement of air round the brake caused by the motion of the car. However with high performance cars, more cooling is required. This is achieved in a simple manner by fabricating a superstructure which scoops up air and directs it inside the brake drum. If a filter were added on the exiting side, this would cause a substantial reduction in emissions. A more elaborate design which has been used is to liquid cool the brake system. This enables the braking system to be completely sealed and thus no emission are possible. The one problem area with this design is that the oil seals must be extremely reliable. However, with a well designed system problems due to overheating could be largely eliminated. I IT RESEARCH INSTITUTE 72 FMSl 02855 CONCLUSIONS An estimate has been made of the asbestos concentrations to be found in urban air resulting from the use of asbestos containing brake materials. The results indicate that brake use may well constitute a major source of asbestos background levels. The quantity in comparison to occupational levels is extremely low. A time weighted average occupational ex posure level of 5 f/cc would be of the order of 100,000 times greater than a background level of 3.0 ng/m^. The medical significance of these results is not known with any certainty. At the present time, no alternative to asbestos contain ing friction products is developed to the stage of finesse required by the industry. It is difficult to believe that modern technology cannot overcome the problems presented by the use of alternates. The use of sealed brake units is a second possibility. Again there do not seem to be any insurmountable technologi cal problems, but no information is available as to the cost and time factors. I IT RESEARCH INSTITUTE 73 FMSI 02856 )%,FRICTION MATERIALS STANDARDS INSTITUTE , INC., E 210 ROUTE PARAMUS, N.J. February 29, 1972 TO; MEMBERS (as listed) SUBJECT- MEASUREMENT OF AIRBORNE ASBESTOS FIBER BY THE MEMBRANE FILTER METHOD As indicated in earlier correspondence, we are distributing one copy each of "Measurement of Airborne Asbestos Fiber by the Membrane Filter Membrane Filter Method", to the members for their information. If additional copies are needed, please contact the Asbestos Textile Institute. EWD/1me CC: E. Feierabend S. Comins M. Jacko IV. Simon J. Graham E. Koss R. Kick L. Carreras F. Gatke 17. Reitze T. Laher J. Greenen Abex - Auto Friction - Bendix - Brassbestos - Car lisle - Chrysler - Delco-Moraine -- Forcee - Gatke - Johns-Janvi 1 le - La sco - Gr izzly E. IV. Drislane Executive Secretary M. Frazier I. Weaver F. Barton V7. SI eeth A. Daly A. Roentgen J. Al len 17. Richards C. Cawley R. Br igleb L. Burgess J. Henning Molded Indust - Raybestos - Reddaway - Royal - Scandura - Silver Line - Standco - Thiokol - Thermo id - Weilman - Wheeling - World Bestos eJ FMSI 02857 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 RTE #4, PARAMUS, N.J. TO: MEMBERS (as listed) February 25, 1972 SUBJECT: ASBESTOS SEMINAR -- I IT RESEARCH INSTITUTE - CHICAGO This memorandum is being sent to those in member companies directly associated with the asbestos regulations, and where a member has not indicated such an individual, to the Delegate. Dr. Harwood of I IT is organizing a seminar in Chicago the week of April 4-7, 1972 on asbestos regulations, etc. If you, or someone in your firm is interested, I suggest you complete the application for attendance, with the fee, and send to Dr. Harwood. The Friction Materials Standards Institute has nothing directly to do with this seminar, and is passing the information along to members for their information. EWD:llz E. Feierabend S. Com ins M. Jacko W. Simon J. Graham E. Koss R. Kick L. Carreras F. Gatke W. Reitze T. Laher J. Greenen E. W. Drislane Executive Secretary - Abex - Auto Fr iction - Bendix - Brassbestos - Carl isle - Chrysler - De1 co-Moraine - Forcee - Gatke - Johns-Manvi1le - Lasco - Grizzly M. Frazier J. Weaver F. Barton W. Sleeth A. Daly A. Roentgen J. Allen W. Richards C. Cawley R. Brigleb L. Burgess J. Henning - Molded Industrial - Raybestos - Reddaway - Royal - Scandura - Silver Line - Standco - Thiokol - Thermo id - Weilman - Wheeling - World Bestos FMSI 02858 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E210, ROUTE #4, PARAMUS, NEW JERSEY BULLET I N NO. 428 February 18, 1972 To: ALL MEMBERS SUBJECT: Demonstration - Membrane Filter Method for Airborne Asbestos Measurement By: W. Reitze, Johns-Manvi1le Corporation. By earlier bulletins, the membership had been advised that Mr. W. Reitze of Johns-Manvi1le Corporation would give a demonstration on the standard method for measuring airborne asbestos fibers. Mr. Reitze made this presentation on Thursday. February 10, 1972 at the Institute Office in Paramus, New Jersey. Those Attending: J. Greenen, President of F.M.S.I. ) R. Hemmelgarn ) ) K. Barnhardt ) J. Henning J. Graham M. Jacko ' W. Richards W. Reitze E. W. Drislane Maremont Corporation Grizzly Brake Division World Bestos Company, Division of The Firestone Tire & Rubber Company Carlisle Corporation Molded Materials Division Bendix Corporation Friction Materials Division Thiokol Chemical Corporation Johns-Manvilie Corporation Friction Materials Standards Institute, Inc. MEASURING AIRBORNE ASBESTOS FIBERS Mr. Reitze discussed the earlier Impinger Method (no longer accepted) where the air sample is passed through a glass tube bubbler and the fiber is trapped with a subsequent count of fibers. The currently accepted method calls for measurement of airborne asbestos fiber by the membrane filter method. Briefly, the pick-up is worn by a worker in the area to be measured with a small battery operated vacuum pump taking in air over a specified period - of different times, say 60 minutes, 90 minutes, or four hours. The asbestos fiber is trapped by the membrane filter and then carefully sealed and sent to the laboratory. The sample is examined using an optical micro scope where a count of fibers is made. The details of the test are described in: "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method" published by the Asbestos Textile Institute. Asbestos Textile Institute P. 0. Box #239 Pompton Lakes, New Jersey ,#07442 (Price $1.00 per copy) The Institute has ordered copies and will send one to each Delegate. If additional copies are desired, it is suggested that the member order the copies directly from the Asbestos Textile Institute. 4 c- 1 FMSl 02859 Bulletin #428 -2- February 18, 1972 Mr. Reitze's demonstration will not be detailed as the booklet mentioned covers the equipment and procedures in detail. COMMENTS AMD SUGGESTIONS The cost of pad and filters inserted are 70$ per piece, from.Millipore Corpora tion, Bedfordj Massachusetts tI-01730. It is suggested that four to six pumps (costing about $150. each) be used so that a supervisor can monitor more than one test at a time. A battery charger will cost about $50. One should have one charger for every two pumps. Seeding (or sabotage) when a worker throws additional asbestos to the intake may ordinarily be detected when the sample is counted under the microscope, but additional tests may be necessary in the same area with different workers. A pump could be mounted in a fixed position near the work place but the proper method is to have the pump attached with the intake facing down near where the worker breathes. A binocular microscope with phase contrast illumination set for 400/430X mag nification is required. A Bausch and Lomb microscope costing about $1,200.-1,500. is the basic instrument. Binocular microscopes with additional features could well be worth the additional cost, but professional advice should be used in the selection of equipment. OUTSIDE SERVICFS AND TRAINING It may be feasible to have outsiders do the full job - from sampling through examination and reporting. Others will do the analysis work only where the samples are mailed to the laboratories. Tracer labs in California will do shalysis work for about $50.-60. per analysis. Johns-Manville will do the full job for a fee (Contact Mr. W. Reitze, Manager Industrial Hygiene Engineering Service, Johns-Manville Corporation, P. 0. Box #5108, Denver, Colorado #80217) George Clayton Labs, Southfield, Michigan will do the full job for a fee. There are other labs that may do the entire package or the analysis work only. Johns-Manville indicated it would be willing to train personnel in the tech nique in a two day period. They would take one trainee, or at most two trainees, to one instructor for $200. a day. These sessions would be at Phindern (Somerville) New Jersey or Waukhegan, Illinois. Again, the contact would be with Mr. Reitze in Denver. It is suggested that the members familiarize themselves with OSHA's proposed standards. A copy of these standards, as issued in the Federal Register on January 12, 1972, is enclosed with Bulletin #427. ", Asbestos Study Committee Delegates & Alternates British Friction Materials Council AIA/NA and L. D. Stickles, Counsel E. W. DRISLANE Executive Secretary FMSI 02860 Room 512 ^Yiateriaid Stunclardi 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. Id. B, Reitze of Johns-Manvi11e 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? Ourflieeting 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. : Ji, H. Weaver J. C. Henning Ec . 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 FN\S\ 0286A FRICTION MATERIALS STANDARDS INSTITUTE. INC. E 210 ROUTE #U 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-Manvi1le Sales Corporation The Bendix Corporation Carlisle Corporation Maremont Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh FMSI 02862 A H*X Abex Corporation American Brakeblok Division 900 WEST MAPLE ROAD. TROY, MICHIGAN 48064 January &Awrd,,,)s9at2 British Friction Materials Council 99, Aldwych London, WC2B 4JY / a/ \r 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 In this data for their files. In the future when you have AmMcaii&iflkfiM FMSI 02863 A H"X British Friction Materials Council - 2 January 14, 1972 comments regarding legislation dealing with brake linings I would suggest you direct your comments to that organization. 1 am also taking the liberty to send a copy of this information to Dr. M. G. Jack of Bendix Corporation, who is doing work along this line and is the representative from the brake lining sub committee on the SAE 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 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. Jack Bendix Corporation - Research Lab. 20800 Civic Center Drive Southfield, Michigan 48075 FIWSI 02864 British Friction Materials Council BAKER, ROOKE & CO. Cl Ac ione: 01-242 0211 AIR MAIL \ \ 362/in/BFMC The Society of Automotive Engineers, 2 Pennsylvania Plaza, Hew York, N.Y.10001, U.S.A. Inc., \Q9, 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 FMSI 02865 PKOPOSL'i; illinou static 13AN ON AoB^/iMG-BASKI) Bk^K LIKINGS 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 QU6t. It is 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 dUBt from vehicles, is about '\% 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. This 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/m^ 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. 5* 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 1. Hickish D.K, and Knight K.L. (1970) Annals of Occupational Hygiene Vol.13 No.1, page 20. 2.SC | jj ! 1 .! Letter to Nature attached. ... British Friction Materials Council 26th November, 1971. -. FMSI 02866 atu!<E VCL :*34 NOVEMBER 12 1371 <w.- 03 / Chrysotile Asbestos in Urban Air The industrial use of chrysotile asbestos is increasing and (ho 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 Asbestosis Research Council we are developing a more sensitive technique. This article is a preliminary account of the estimation of chrysolile near a large, asbestos textile factory at Rochdale, Lancashire. There arc several uncertainties in the technique, so w'c. 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 compered with the 1 to 10 mg range reported by Crable1, 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 nr (10- 1.) of air by an electrostatic device (H. Litton Systems inc.) in which up to 10,000 I. 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 or chrysotile in the atmosphere is not known. Therefore we estimated the collection cflicicncy 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 I. min-', dropping to between 25 and 50% at the rate of 10.000 1. min1, depending on the actual size dis tribution present. As we were aiming at only an order of magni- FMSI 02867 94. Fig. 1 Observed amounts of chrysolite in 5,000 1. of factory air, sampled at different rates. NATURE VOL. 234 NOVCMBER 12 1371 T<til 1 V. o.ither Condition:, liiinny Sampling Date (1970) Site Wind Weather April 22 April 24 April 27 April 29 May 6 May J3 May 28 May 28 May 30 May 30 June 3 June 10 June 10 October 23 October 23 October 23 October 28 October 28' October 28 1 l 1 1 1 1 3 3 4 4 2 2 2 I 1 1 J 1 I SW moderate SW slight Nl; moJcrulc SW moderate S strong N fresh W light W light W light W light SW Ji,-ht SW slieht SW slight W moderate W moderate W moderate N light N light N light Ground haze Ground haze Ground haze Ground haze Overcast, dull Overcast, dull Overcast, dull Overcast Heat haze Broken cloud Broken cloud Broken cloud Broken cloud tilde assessment of asbestos in urban air, we were prepared to 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 tn 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 the 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 clearly 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 wc can say that our samples collected from 1,000 m' of air contained less than 100 jig of chrysotile-Hn other words, there was less than 0.1 |tg of chrysotile per nv* of air. The threshold limit for occupational exposure set by the 1969 Asbestos Regulations2 is 0.1 mg m"3. quartz quartz *26 (CuK) Fig. 3 X-ray diffraction pattern from a typical dust sample near the Rochdale factory. l'ig. 2 Plan of T.U.A. factory. Rochdale. The sampling sites arc indicated by the arrows 1 and 2. t, Position of the chief filler 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. . ` Crable, J. V., Amcr. hid. [lye. Assoc. 27, 293 (19661. 2 Standardsjor Asbestos Dost Concentrationfor {/< ith the Asbestos Regulations I$69, Technical Data Sotc ii (MM Factory Inspec torate, 1963). FMSI 02868 FRICTION MATERIALS STANDARDS INSTITUTE. INC.. 370 LEXINGTON AVENUE. NEW YORK. N. Y. December 8, 1971 TO: MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: RECENT ACTIONS BY FEDERAL AND STATE GOVERNMENTS CONCERNING ASBESTOS There has been considerable output concerning asbestos in recent weeks. We are, therefore, sending to each member of the Asbestos Study Committee the fol lowing: 1. Illinois Pollution Control Board Reputations 1.1 Memorandum of December 3, 1971 on "prosed final draft" of regulations on asbestos. 1.1.1 Note that the section banning asbestos contain ing brake linings after 1975 has been eliminated. . 1.2 Chicago Tribune article of December 2, 1971 concerning asbestos. 1.2.1 Nothing specific about brake lining. 2. Environmental Protection Agency Emission Standards 2.1 Federal Register of December 7, 1971 spelled out the proposed standards for Asbestos, Mercuryand Beryllium. 2.1.1 The proposed standard for asbestos only is included in our excerpts. 2.2 New York Times article of December 4> 1971 concerning the proposed emission standards. 2.2.1 This can serve as a digest of the proposed standards in the Federal Register. 2.2.2 Note that the asbestos standards were set with control practices (filters and traps) rather than by numerical emission values.3 3. Department of Labor - Exposure to Asbestos Dust 3.1 Federal Register of December 7, 1971 - Federal Supply Contracts. 3.1.1 To apply the new Williams - Steiger Act stan dard on asbestos to Federal Supply Contracts. 3.2 Federal Register of December 7, 1971 - Construction 3.2.1 To apply Williams - Steiger Act standards to construction. Messrs: I. H. Weaver J. C. Henning Dr.W. Spurgeon W. B. Reitze J. B. Graham E. H. Feierabend E. W. Drislane Executive Secretary Raybestos-Manhattan, Inc. World Bestos Company Bendix Corporation Johns-Manville Corporation Carlisle Corporation Abex Corporation FMSI 02869 FRICTION MATERIALS STANDARDS INSTITUTE. INC.. 370 LEXINGTON AVENUE. NEW YORK. N. December 8, 1971 TO: MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: RECENT ACTIONS BY FEDERAL AND STATE GOVERNMENTS CONCERNING ASBESTOS There has been considerable output concerning asbestos in recent weeks. W are, therefore, sending to each member of the Asbestos Study Committee the fol lowing: 1. Illinois Pollution Control Board Regulations 1.1 Memorandum of December 3, 1971 on "prosed final draft" of regulations on asbestos. 1.1.1 Note that the section banning asbestos contain ing brake linings after 1975 has been eliminated. 1.2 Chicago Tribune article of December 2, 1971 concerning asbestos. 1.2.1 Nothing specific about brake lining. 2. Environmental Protection Agency Emission Standards 2.1 Federal Register of December 7, 1971 spelled out the proposed standards for Asbestos, Mercuryand Beryllium. 2.1.1 The proposed standard for asbestos only is included in our excerpts. _ 2.2 New York Times article of December 4, 1971 concerning the proposed emission standards. 2.2.1 This can serve as a digest of the proposed standards in the Federal Register. 2.2.2 Note that the asbestos standards were set with control practices (filters and traps) rather than by numerical emission values. 3. Department of Labor - Exposure to Asbestos Dust 3.1 Federal Register of December 7, 1971 - Federal Supply Contracts. 3.1.1 To apply the new Williams - Steiger Act stan dard on asbestos to Federal Supply Contracts. 3.2 Federal Register of December 7, 1971 - Construction 3.2.1 To apply Williams - Steiger Act standards to construction. Messrs: I. H. Weaver J. C. Henning Dr.W. Spurgeon W. B. Reitze J. B. Graham E, H. Feierabend E. W. Drislane Executive Secretary Raybestos-Manhattan, Inc. World Bestos Company Bendix Corporation Johns-Manville Corporation Carlisle Corporation Abex Corporation FMSI 02870 GHQ December 3, 1971 TO: JOIJNS-MANVILLE ENVIRONMENTAL HEALTH TASK FORCE AIA/NA MEMBER COMPANIES AIA/NA ADMINISTRATIVE SUB-COMMITTEE CC: , Dr. Joseph L. Goodman Ike Weaver^. Ed Drislanes^^, C. R. Wikel R. F. Winkworth H. J. Roesch Frank Zimmerman Bradley Walls ILLINOIS POLLUTION CONTROL BOARD REGULATIONS ON ASBESTOS Attached is the "Proposed Final Draft" Pollution - Control Board regulations on changes of a positive nature have been section of the regulations as compared last summer. of the State of Illinois asbestos. Substantial made in nearly every with* the draft published Among the most important changes are the following: * 1. The section banning the use of*asbestos-containing brake linings after 1975 has been eliminated. While it might appear from the comments in the "Explanation" section of the regulations on page 10-11 that this question is not completely settled, it is our belief that the Board will take no further action against brake linings unless the . Federal Government does first, in which case any action taken by the state would be rather academic. ' . 2. The plant emission standard has been raised from a level of .5 fibers per cc to a more acceptable level of 2 fibers per cc. In addition, the standard of .05 fibers per cc at the boundary line of a plant has been eliminated completely. . 3. A "no visible emissions" standard has been included in various sections of the regulations where enforcement of.a stricter standard would have been a problem, if not impossible. 4. The segment of the regulations requiring "total enclosure" of a'structure under demolition before toppling of walls could begin has teen altered to a more-or-less "do the best you can" standard. M FMSI 02871 -2- 5. *. 6. The section requiring the use of a sealant on all "fibrous" materials uSied inside ducts or plenums has been changed to "asbestos-containing" materials only. The section prohibiting the discharge of asbestoscontaining process waste water into the rivers, streams and sewers of the state has been changed to permit such discharge if the waste water "is given the best available treatment consistent with technological feasibility and economic reasonableness." 7. Under the Proposed Final Draft, only manufacturing plants will be ^required to obtain a permit from the state. The first draft required permits for . any operation or activity involving asbestos. The vast majority of the above and other positive changes in . the regulations reflect specific recommendations and corrobora tive evidence presented to the Bqard by Dr. F. L. Pundsack of Johns-Manville and Dr. Joseph L. Goodman of Raybestos-Manhattan on behalf of the AIA/NA at the public hearing on the regulations held October 15 in Chicago, and by Dr. George W. Wright and an industry team at a meeting held with Board staff representatives in September. -Also participating in the overall cooperative industry effort were NIMA and the Friction Materials Standards Institute. Attached is a copy of the specific changes submitted by the AIA/NA at Board request following the Chicago hearing. Because of the many changes in the final draft, the section and sub-section numbers on the AIA/NA recommendations do not correspond to those in the final draft. However, as you can see, the basic changes recommended by the AIA/NA have been adopted by the Board. 't It is indeed an encouraging sign to find that, in this era of national environmental panic, a well-documented and well-presented industry case can produce results as fair and reasonable as those obtained in the state of Illinois. Much credit must go to the responsible yet fair attitude of the Illinois Pollution Control Board, and to all those in the industry who worked long and hard on this project. W. P. Raines l.f FMSI 02872 Chicago Tribune, Thursday, pecember 2, 1971 N Section3A ~~ 3 : Asbestos Pollution i- The new asbestos regulations also would be required to use propped by the Illinois Pollu the best available technology tion Control Board will, for the to limit asbestos discharge into first' time in Illinois' aim at water,-' , V / %-\ \\ , controlling a pollutant "on a In construction* trades, out prson-to-person basis. side spraying of asbestos on The, proposed regulations, buildings would be prohibited which probably will be adopted after March 31, If the materi - in mid-December, provide for al, in wall boards for example, regulating the use of asbestos is used during construction, it as it Is manufactured, used in must be handled under a cover construction^ and used ifr demo or in an enclosure. Visible em lition procedures. During hear issions of asbesto' Would be a ings eiariier this year, several violation of regulations. doctors linked ' asbestos with The regulations will require lung diseases, including cancer. that buildings with asbestos be Covers Wide Variety wetted and the asbestos strip ped by hand during demolition. The regulations will go far ther than Chicago's ordinance, which requires only that asbes tos spraying be. limited to en closed areas. . .. - Under the board's proposal, manufacturing plants and oth er facilities that use asbestos will be required to provide fa cilities where -employes can change their work clothes. Tim Harker, ah aid to the board, said the .provision was added, because testimony indi cated that asbestos workers and their wives have a higher incidence of lung- diseases be cause they often come in con tact with the substance. 1 ' Limit on Emissions '"This is a unique proposal," HaTker said, "because it iden tifies the individual as a pollu t ter.!' , Under the regulations, asbes tos manufacturers would be al lowed to emit no more than two, fibers of asbestos for each cubic centimeter of air. Plants 1.2. ! PROPOSED RULE MAKING 23239 tion also has been given to the need to Other possible' sources of beryllium are minimize the emission of hazardous being investigated, and those sources pollutants that can accumulate in the which can potentially cause ambient con environment. centrations to exceed D.01 pZ/tdA will be In many cases, information on possible Included in revisions to this standard. sources of the hazardous pollutants is not Mercury--Information currently avail available in sufficient detail to determine able suggests that an ambient concen the need for emission standards. Investi tration level in the air below one Cl) gations are underway to fill these gaps in microgram per cubic meter is sufficient knowledge, and the results of these in to protect the public health from Illness vestigations may require modification of due' to inhalation of mercury. However, these standards and inclusion of addi mercury is mobile in the environment, tional source categories for these ahd once released to the atmosphere may pollutants. cycle between air, land, and water for Beryllium, mercury, and asbestos are long periods of time. Natural processes very different in the number and type of and living organisms can change mercury sources and control options available; from one form to another, at times con therefore, each standard has been writ verting mercury into its most hazardous ten in a different manner to optimize forms. Therefore, when sufficient infor effectiveness and facilitate compliance. mation and understanding are available, Asbestos--The -proposed standards for it will be necessary to consider the asbestos are designed to minimize emis broader environmental problems caused sions to the atmosphere. Because there is by mercury emissions to the atmosphere. no suitable technique for sampling and Hie only industries known to be emit analyzing asbestos In the ambient air or ting mercury in quantities and in a fash in emission gases, the standards are ex ion such that these facilities, assuming a pressed ns requirements for the operation negligible background level, may cause of specific control equipment (or other the ambient concentration level to ex equipment of comparable effectiveness!, ceed 1 fig/m! are the facilities producing or in situations where no control system mercury from ore and the mercury cell is available as prohibitions on the use of chlor-aUcali plants. These industries are asbestos. When acceptable source sam covered In this standard. Other sources pling and analytical methods are avail may emit mercury, but present informa able and it is possible to delineate hazard tion indicates that these sources alone ous levels, these standards'may be revised will not cause the ambient concentration to require compliance with a measured level to exceed 1 ^g/m1. EB9HNTM PR0TEST10N AGENCY I 40 CFR Part 611 NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS Proposed Standards for Asbestos, jSeiylliunv-Mercury Pursuant to section 112 of the Clean Air Act, as amended, the Administrator published in the Federal Register of March 31, 1911 136 CFR Part 62] an initial list of three hazardous air pollut ants which in his judgment may oause, or contribute to, an increase'in mortality or an increase in serious irreversible, or incapacitating reversible, illness. Publi cation of the list constituted an an nouncement of the 'Administrator's in tention of establishing, under section 112, national emission standards for certain source categories known to emit, these hazardous pollutants. These' standards are based on Information derived from many sources, including health effects levels, meteorology, technical analysis of control capability, and consideration of economic Impact. The overriding consid erations are health effects. Considers- allowable emission. * The sources covered in the asbestos standard are: Mining, milling, spraying, and manufacturing. Specific examples of emission sources which would be subject to the . proposed standards applicable to manufacturers of asbestos-containing products include, but are not limited to, manufacturers of the following products when those products contain asbestos: Cement,: textiles, paper and board, fric tion products, plastics, floor tiles, gaskets, packings, reefing felts,, and insulation products. Beryllium--A maximum allowable con centration of beryllium for ambient air has been in use by the Department of Defense and the Atomic Energy Com mission for many years. Hits guideline has been used ln,the development of the berylliumstandards. The proposed stand ards offer the owner or operator the option of measuring compliance by either emission testing or measurement of am bient concentration levels in the vicinity of the plant. However, It is anticipated that most sources will elect to comply with the given emission limitation. Buildings or other obstructions in the vicinity-of the source, or location in ^highly urbanized areas, may make it impossible to design and locate, a .sam pling network that provides sufficient assurance that areas of maximum con centration are Measured. The known major sources of beryllium are extraction plants, machine shops ahd foundries handling beryllium dr beryl'- lium-containing alloys, ceramic plants using beryllium, rocket propellants con taining beryllium, and incinerators bum- tog be/yllium-oontainlng waste. These are covered in the proposed standards. Investigations are underway to identify all mercury sources and to quantify their emissions Into the air. As more tnformation becomes available, this subpart will be revised, as necessary, to add, additional source categories. , .. The proposed regulations require ap plication to the Administrator for ap proval for construction or modification of any stationary source to which a standard prescribed to the regulations is applicable. The Administrator will notify the applicant of approval or disapproval of such application `within 60 days of receipt. A fee will bo charged to defray part or all the costs of the review. The: fee structure will be revised tram time to time as experience with the program is developed. , ; ? Omitted from the proposed regulations are provisions for delegations of author ity to States under section 112(d) (1). Nevertheless, it is the Administrator's intention to encourage States to assume the principal responsibility for enforce ment of national emission standards for hazardous air pollutants. Toward this end, procedures for delegating authority will be established early next year, after the States have submitted their plans for implementation of national ambient air quality standards. ' ... ,. In accordance with section 117(f) of the Act, "publication of these proposed standards was preceded by consultation with appropriate advisory committees, independent experts, and Federal depart ments and agencies. . Interested persons may participate in this rulei making by submitting written comments in triplicate to the Environ mental Protection Agency, Office of Air No. 235-------7 FEDERAL REGISTER, VOL. 36, NO. 234--TUESDAY, DECEMBER 7, 1971 JLmf FMSI 02874 23240 , PROPOSED RULE MAKING Programs, Division at Compliance, Re Sec. "" '` . . search Triangle Park, N.C. 27711. Hie Administrator will welcome comments on all aspects of the proposed regulations, including economic and technological is sues and on the proposed test methods. AH relevant comments received not later 61.08 Approval by Administrator. 61.09 Source reporting. ' 61.10 Request for waiver of compliance. 61.11 Waiver. . . 61.13 Emission tests and monitoring. 61.13. Availability of Information. 61.14 State authority. than SO days after the date of publication of this notice will be considered. Receipt of comments will be acknowledged, but the Office of Air Programs will not pro vide substantive responses to individual comments. Public hearings will be held as re quired by section 112(b)(1)(B) of the Subpart B--National Emission Standards for Asbestos . 81.20 Applicability. 61.21 Definitions; . 61.23 Emission standards for asbestos. ., 61.23 Referenced equipment specifications. 61.24 Substitute devices for the attainment t of equivalent emission control. Clean Air Act. A notice of time, date, and place for these public hearings will be published in the Federal Register within 30 days of the publication date of these standards. Not later than 180 days after publication of the emission standards set forth below, the Administrator Is re quired to promulgate such emission standards, unless he finds, on the basis Subpart C--National Emission Standards for Beryllium ; 61.30 Applicability. *' 61.31 Definitions. 61.32 Emission standards for beryllium. 61.33 Test methods and procedures---stack sampling.. . 61.34 Periodic stack sampling and reports.. 61.3$ Waiver of periodic stack sampling and of information presented at public hear ings, tijat the pollutants in question clearly are not hazardous. Accordingly, ail persons having scientific information pertinent either to the question of report requirements. , 61.36 Test methods and procedures--air ' sampling. ' 61.87 Monitoring and reports--air sampling. 61.38 Election. . .. whether^ asbestos, beryllium, and/or Sybpart D--National Emission Standards for mercury are in fact, hazardous within ; Beryllium--Rocket Motor Firing the meaning of section 112 of the Clean 61.40 Applicability. - - Air Act or to the question of the level 61.41 Definitions. of the various substances that consti 61.42 Beryllium emission standards. . tute a risk to public health are urged to present such information either by tes tifying at the hearings or by submitting the data for the hearings record. In ad 61.43 61.44 . 61.45 Test methods and procedure^--air sampling. Test method and procedures--stack sampling. : Monitoring, and reports for air earn* dition, all interested persons are specif / ' ` pling. - ' ically asked to present information on 61.46 Stock sampling and reports. ; . the extent to which promulgation of these emission standards for asbestos, Subpart S--National Emission Standard for beryllium, and mercury will be of bene : ' .. Mercury ' - v'-. fit to the public health. In any testimony or written comments on the specific points mentioned herein or on other matters relevant to this proposed rule 61.50 61.51 61.52 ,61.53 61.54 Applicability. Definitions. ` .1 ' Abbreviations. Emission standard for mercury. Test methods and procedures.--mer- making, all assertions and claims should cilry ore processing facility. .. be fully substantiated by factual infor mation. Summaries of the pertinent data used in developing these standards are avail able free of charge from the Environ mental Protection Agency, .Office of Air Programs, Research Triangle Park, N.C. 6166 Periodic emission testing--mercury ore processing facility. 61,66 Recordkeeping---mercury ore process ing facility. . . 61.57 Waiver of emission test require- ments--mercury ore processing la- cUlty. ,J . . 61.68 Test methods and procedures, met- 27711. cury ceU eklor-Blkall plant. ' _ This notice of proposed rule making is Issued under the authority of sections 112 and 114 of the Clean Air Act, Public Law 91-604,84 Stat. 1713. 61.59 Periodic emission testing--mercury cell tbioNtdhdl ;- ` 61.60 . Recordkeeping---mercury cell chlor* alkali plant. - . 61.81 Waiver of emission test require* William D. Ruckelshahs, ments--mercury -cell ohlor-alkall Administrator, . r facility. . Environmental Protection "Agency: November 30,1971. . Subpart A--General Provisions 6 61.01 Applicability, ' PART 61---NATIONAL EMISSION STANDARDS FOR"HAZARDOUS AIR The provisions of this part apply to the Owner or operator of any source which Is POLLUTANTS operated, or the construction or modifi ' Subptsrt A--General Provisions Sec. . ' .. . 61.01 Applicability. - cation of which Is commenced after the date of publication in the Fedebal Regis ' ter of proposed emission standards for 61.02 Definitions. hazardous air pollutants which are ap 61.03 Abbrevictions. -; plicable to such source. 61.04 Address. * 61.05 Prohibited activities. .' - 61.02 Definitions. 61.06 61.07 Determination of construction or modification. 4 Application for approval for construe* ' tion or modification. As used,in this part, all terms not de fined ip these subparts shall have the meaning given them In the Act: , (a) "Act" means the Clean Air Act (42 TJ.S.C. 1857 et seq,, as amended by Public Law 91-604, 84 StaL 1676K (b) "Administrator" means the Ad ministrator of the Environmental Pro tection Agency or his authorized repre sentative. ., (c) "Commenced" means that' an owner or operator and a contractor to, or affiliate of, such owner or operator have entered into a binding agreement or contractual obligation to undertake and complete, within a reasonable time, a continuous program of " construction or modification. ;: (d) "Construction" -means fabrica tion, erection, or installation of a sta tionary Source. '. (e) "Emission test" means measure- . ment and analysis of emissions or other procedures used for the purpose of deter mining compliance with a standard for hazardous air pollutants. - (f) "Existing source", means any sta tionary source which is not a "new source". . (g) "Modification" means any physi cal change in, or change in the method of operation of, a stationary source which increases the amount of any hazardous air pollutant emitted by such source or which results in the emission of any , hazardous air pollutant not previously emitted, except that routine mainte nance, repair, and replacement shall, not be considered physical changes. (h) "New source" means any station ary source, the construction or modifies- tion of which is commenced after the publication in the Fedebal Register of proposed national emission standards for hazardous air pollutants which will be applicable to such facility. . (i) "Owner or operator" means any person who owns, leases, operates, con trols, or-supervises a stationary source. (j) "Start up of operation" means the . beginning of routine operation of a sta tionary source. ; , ' .:: (k) "Stationary source" means any ' ' building, structure, facility, or instal- latlon which emits or may emit any hazardous air pollutant r ' 61.03 Abbreviations. " The abbreviations used in ihis part have the following meanings:. cfm--Cubic foet per minute. . ft?--Square feet, . ft?--Cubic feet. -- p--Degree Fahrenheit. in.--Incb. 1--Liter. T mg--Milligram. , mi--MUUUter. M--Molar. . pm--Nanometer. \ ' v/v--Volume per volume. . w.g.--Water gauge. , . W/V--Weight perVolume... , /cg/m--Micrograms per cubic met?!, %--Percent. ". -, ' . ' . 61.04 Address.' V; ' ,, All applications, requests, submissions and inquiries under this, part shall be addressed to the Environmental Protec tion AgOncy, Office of Air Programs, Divi sion of Compliance, Research Triangle Park, N.C. 27711. FEDERAL REGISTER, VOL. 36, NO. 234--TUESDAY, DECEMBER 7, 1971 o?./ pMSl 02875 PROPOSED RULE MAKING 232*1 61.05 activities. . , <1) Notice of the information and period to assure that the health of per (a) .Alter the effective data of any emission standard prescribed under this part, no person shall construct car modify any stationary source subject to such standards without first obtaining written approval of the Administrator in accord ance with this subpart, except under an exemption granted by the President un der section 112(c)(2) of the Act. (b) ninety days after the effective data of any emission standard prescribed by this part, no person shall operate any stationary source in violation of such standard except under a waiver granted by the Administrator in accordance with tins subpart or under any exemption granted by the President under section 112(c) (2) of the Act. ' . findings on which such intended denial ' sohs wifi bo protected from .imminent Is based, and -: . endangenneht . ' -: (2) Notice of opportunity for such per (c). As used in this subpart, `Imminent son to-present additional Information or endangerment" means an immediate risk arguments, orally or in- writing, to the of significant harm to the human body. Administrator prior to final, action on - 61,11 Waiver. ' ' " - - ", such request. ., i. (d) A final determination to deny any (a). Based on- the .infonnation pro . request for approval will be in writing vided in any request under 61.09 and ` and will set forth the specific grounds -on any other information, the Administrator which such denial is based. ....... may grant a waiver of compliance with (e) Neither tho submission of an ap the applicable emission standard for a plication for approval or the Administra period not exceeding 2 years. tor's granting of approval to construct or modify shall: ....... , (b) Any such waiver shall be in writ ing and shall: / ;. (1) Relieve an owner or operator of , <1) Identify the source covered. legal responsibility for compliance with ' f2) Specify the termination date of any applicable provisions of this part or the waiver. ... - of any applicable State or local require (3) Impose such reasonable conditions 61.06 Determination of construction ment, or . ... . - .. as the Administrator determines to be or modification, , ' . 12) Prevent the Administrator from necessary to assure installation of the Upon written application therefor by an owner or operator, the Administrator will make a determination of whether actions taken or intended to be taken by such owner or operator constitute con struction or modification or the com mencement thereof within the meaning ofthispaxt. , / v. . .. implementing or enforcing this part or taking any other action under the Act. 61.09 Source reporting. . (a) The owner or operator'of any ex isting stationary source to which a stand ard prescribed in this part is applicable shall, within 30 days after the. effective date of 'such standard, provide the Ad necessary controls within the waiver pe riod and to assure,protection, of the health of persons from imminent endangarment during the waiver period. - - : ; j. (c) Prior to finally ..denying any re-, quest for a waiver pursuant to-this sec tion, the Administrator will notify- the person making such request of the'^d- ' minlstrator's intention : to issue such 61.07 Application for approval for ministrator the following information: denial, together -with: -: construction or modification. ' ' (1) Name and address of the owner or (1) . Notice of the information and find- (a) The owner or operator of any sta tionary source to which a standard pre operator. , ' '* (2) Identification and location of the scribed under this part will be or is ap source. ; plic&ble shall, not less than 60 days prior to the date on which construction or (3) Brief description of the nature, size, design, and method of-operation in modification is planned to commence, cluding description of any equipment submit to the Administrator an appiica- tion for approval of such construction or modification.- - * used for the measurement or control of emissions. ' ; (b). Changes in the information, pro (b) A separate application shall be vided under paragraphs (a) (I) -and (3) submitted for each stationary source. of this section, shall be provided to the <c) Each application shall Include the following: , Administrator within 90 days of such change. ; ', ; ings on which" such intended denial is based, and -- " (2) Notice of opportunity for such person to present additional Information or arguments, orally or in writing, to the Administratorprior tp final; action on such request. - ;i ; , (d) A final determination: to deny any request for a. waiver will be in writing and .will set forth the'specific grounds cm which sUch denial is based. . 6. 61.12 Emission tests and monitoring;. (1) Name and address of the appU- caitfc. , . ; , * . . <2) location or proposed location of the source. (3) Technical information describing tho proposed. nature, size, design, and method of operation of the source, In cluding a description of any equipment to be used for measurement or control of emissions. -" i 61.10' Request for "waiver of complz- - anee. - , " ' (a) Emission tests and monitoring shall be conducted and results reported in accordance with the test methods and fa) The owner or operator of an exist reporting requirements set forth in this ing stationary source unable to operate to ' pQTt. / ' ' ' ' . ' , . ' C compliance with a standard or standards (b) At the request' :of the Adminis prescribed in tiffs part may request a trator, the owner or operator of a source waiver of compliance with any applicable subject to. this part shall provide,; or emission standard under tiffs part for a cause to be provide^ Amission: testing period not exceeding 3 years. , facilities as follows: '; ,1 . (b), Any. such request shall be in writ <I) Sampling ports adequate for test 61.OB AjrproyalbyAdministrator. ing and shall include: > methods applicable to such source. ' (a) The Administrator will, within 60 days of receipt of application, notify the owner or operator of approval or disap proval of construction or modification. Cb) If the Administrator determines, (1) The owner's or operator's name and address. . , (2> Identification and location of the source; .; , . ; (3) Technical information describing (2) Safesampiingplatlozmts). , (3) Safe access to sampling plat- form(s). . . ` - , ' , ---- <4) Utilities for. sampling and testing equipment. ; based on information included in an ap plication submitted under, S 61.06 or other information that a stationary source for which an application pur suant to | 61.06 was submitted will, if properly operated not cause emissions in violation of an applicable standard, he will approve the construction or modifi cation of such source. ,/ <c) Prior to denying any request for approval of construe0on or modification pursuant to this section, the Administra tor will notify the person malting- such request- of the Administrator's intention to issue such, together with: v the nature, size, design, and method of 61.13 Availability ofinforinadon. operation of the source, including a' desertption of any equipment used for measurement or control to emissions. (a) Emission data provided to, or otherwise obtained by, toe Administrator in accordance with the provisions of this * (4) Description of the" controls neces part gbaH be available to the public. sary for camplianoe with the applicable -standard and plans for installation of such controls. : (b) Any records, reports, or informa . tion provided to, or otherwise obtained by, toe Administrator in accordance with toe (5) A time schedule for obtaining, pro- provisions of this part shall be available during, or installing such controls. The - . to toepublic, except that upon a showing schedule should include interim meas ures to achieve compliance; - , satisfactory to toe Administrator by any person that such records, reports, or in- x f6) Description o} the emission control formation, or particular'part" thereof steps or other measures -which will be (other than emission data), ifmadepub- token by the owner during (he waiver lic. would divulge ..methods or processes ; "A ' FEDERAL REGISTER, VOL 36, NO. 234--TUESDAY, DECEMBER 7, 197f <2J FMSI 02876 23242 PROPOSED RULE MAKING entitled to protection as trade secrets of -(f). "Air-swept drilling" means the were treated In fabric filter installations such person, the Administrator shall process of drilling holes in Ihe earth in gs described In 8 61.23(d), .. - consider such records, reports, or in the presence of a forced or Induced air - (c) Emissions to the atmosphere from formation, or particular part thereof, stream, but not a liquid stream or mist- buildings, structures, or facilities within confidential in accordance with the pur containing stream. ' \ ^ which any fabricating or manufacturing poses of section 1905 of title 18 of the (g) "Wet drilling" means the process operation is carried on shall be limited as United States Code, except that such of drilling holes in the earth in the pres follows: ' , . ,, . - - : records, reports, or information, or par ence of a forced liquid stream or mist- (1) Emissions,' in direct' forced gas, ticular part thereof, m$y be disclosed to containing stream. -' streams, of particulate matter resulting other officers, employees, or authorized <h) "Particulate matter" means any from manufacturing or fabricating oper representatives of the United States con material, other than uncombined water, ations shall pot. exceed - the amounts cerned with carrying out the provisions which exists in a finely divided form as a which would be emitted if such forced of the Act or when relevant in any pro liquid or solid: 'v : exhausts were treated in fabric filter In- ceeding under the Act. , (i) "Asbestos tailings'' means any stallatiohs as described in 8 61.23(d) or, 61.14 State authority. solid waste product of asbestos mining where approved by the Administrator or milling operations which contains because of special process conditions, in The provisions of this part shall' not asbestos. 'L : wet collectors as-described In 5 61.23(f). be construed in any manner to preclude (j) "Visible emission" means, for the , (2) Emissions of particulate matter any State or political subdivision thereof pui-pose of this subpart, any emission from any manufacturing or fabricating from: '. which is visually detectable. - operation which continuously generates (a) Adopting and enforcing any emis (k) "Asbestos mill" means any facility visible emissions shall not exceed the sion standard or limitation applicable to engaged in the conversion of asbestos ore amount which would be emitted if the air a stationary source provided that such into commercial Asbestos. containing such emissions: were - treated emission standard or limitation is not (l) "Manufacturing operation" means in fabric filter installations as described less stringent than the national emission the processing of commercial asbestos or in 61.23(d).or, where approved by the standard for hazardous air pollutants ap the production of any product containing Administrator because of special process plicable,to such source. commercial asbestos. . conditions, in wet collectors as described <b) Requiring the owner or operator (m) "Fabricating" means the cutting. in 5 61.23(f). . ; Ni-T of a stationary source to obtain permits, Shaping, assembly, mixing or other al (3) Visible emissions of particulate licenses, or approvals prior to Initiating tering of any manufactured product con matter from any manufacturing or fabri construction, modification, or operation taining commercial asbestos. . ' v i cating operations in an,area directly open of such source. . ! . -1- Subpart B---National Emission Standards for Asbestos 61.22 Emission standards for asbestos. to the atmosphere are prohibited-' (d) Visible emissions to} the'atmos (a) Emissions to the atmosphere from - phere of asbestos particiilate matter asbestos mines shall be limited as follows: resulting from the repair or demolition bf 61.20` Applicability^ ' ' . The provisions of this subpart are ap pliesble to the following sources of at mospheric asbestos: : .. (1) Emissions of particulate matter any building or structure, other than a from air-swept of dry drilling operations single-family dwelling are prohibited: ,, shall not exceed those yrtfich would -be : (e> The spraying of asbestos is limited emitted'from an air-swept or dry drill, , as follows: T -v '> respectively, equipped with a fabric filter (1) The spraying ofany;product which Asbestos mines: ' : device for collection of dust generated contains asbestos on any portion of a- Asbestos mills: - - : a.' from drilling, as described in 8 61.23(a). Braidings, structures:, or facilities within which mar.lfunuirlng or fabricating opera tions involving the use of commercial as bestos are carried on; ... . ' Buildings or structures which have been or will be constructed or modified using asbestos . ' (2) Emissions of particulate' matter from wet drilling operations shall hot ex ceed those which would be emitted from a wet drill equipped with a cyclone gas cleaning device for collection of dust or , building or structure is prohibited.' ` % (2) The spraying of anyproduct which contains asbestos in an area directly open to'the atmosphere is prohibited. (3) Emissions of particulate matter from, spraying of any product which con insulating products: ... ,. mist generated from drilling as described tains asbestos, if .such spraying is not Roadway facilities which would be surfaced in 8 61.23(b). ,. specifically prohibited in subparagraphs or resurfaced using asbestos tailings. ;;. (3) Visible emissions of particulate (D or (2) of. this paragraph,, shall not 61.21 Definitions. matter from any mine road surfaced with exceed the ..amounts which would be asbestos tailings are prohibited: ' emitted If the air containing such emis As used in thls subpart, all terms not ' (b) Emissions to the atmosphere from sions were treated in fabric filter instal defined herein shall have the meaning asbestos mills shall be limited as follows: lations as described , in 8 61.23(d) or, -' : given in the Act and in Suljpart A of this - (1) Visible emissions of particulate where approved by the Administrator be part.. ' ' . ^ , - . >' ' matter from asbestos ore dumps, open cause of special process Conditions, in (a)"Asbestos" means any of six nat storage Areas for . asbestos-containing wet collectors'as described in.S 61.23(f). urally occurring, hydrated mineral sill- 'materials, external conveyors for as (f) The surfacing or resurfacing of cates: Actinolite, amosite, anthophyllite, bestos-containing materials, or asbestos- gny-roadway with asbestos - tailings is chiysotile, crocidolite, and tremolite. <b) "Commercial asbestos" means any variety of asbestos which is produced by the concentration of asbestos ore. containing tailings dumps are prohibited. (2) Emissions of particulate matter from asbestos ore dryers shall not exceed those which would be emitted from as prohibited. . , 61,23 Referenced Equipment .specifi,}" cations. ;,s (c) "Asbestos mine" means any facil bestos ore dryers equipped with fabric (a) Fabric filters referred to in 61.22 ity engaged in the extraction of asbestos filter installations as described In 5 61.23 (a) (1). aie equipped with fabrics having ore from the earth for-the purpose of (cO ; ; '}?,. : .. . , airflow permeabilities not exceeding recovering commercial asbestos: : - . (3) Emissions of particulate matter 40cfni/ft'. ' / ; (d) "Air flow permeability" means the volumetric rate of air flow in cfm, pro duced by a pressure decrease of 0.5 in. w.g. across a new, dean filtering fabric, ' from air; streams used to process as bestos ores or for exhausting particulate matter resulting from milling operations shall not exceed the amounts which , (b) Cyclone collectors referred to in 8 61.22(a) (2) are operated at not less than 7 in. w.g. pressure decrease as meas` ured from the cyclone inlet to the outlet, divided by the area of the fabric in ft'. would be emitted if such air streams were ' (c) Fabric filters referred to in. 8 61.22 The test air stream is maintained at treated in fabric, filter, installations as (b) (2) are equipped with fabrics having nominal atmospheric pressure ' and described in 8 ,61,23(d) . , : : , . , airflow permeabilities not exceeding 30 temperature. - : . (4) Emissions of particulate matter Cfm/ftV , . .' ' ..-V: (e) "Dry drilling" means the process of drilling holes in the earth in the ab sence of an applied liquid stream, mistcontaining stream or air stream.' ' | from any milling operation which con tinuously generates visible emissions shall not exceed the amounts .which would be emitted if such air streams : (d) '^Fabric filters referred to in . 61.22 (b) (3) and (4). (c) (1) and (2), and (e)(3) are equipped with woven cotton fabrics having airflow'penheabilities not FEDERAL REGI5TER, VOL. 36, NO. 234--TUESDAY, DECEMBER 7, 19/1 4./ FMSI 02877 PROPOSED RULE MAKING exceeding 20 cfm/ft*. No bypass devices are utilized, and provisions are made lor eniptying the collection hoppers without creating visible emissions of particulate matter. ' (e) Fabric filter devices do not meet the descriptions in paragraphs (a), (c), and (d) of this section if any of the fol- lowing conditions exist: (1) Leakage of gases, containing par- ticulate matter, from the control system prior to filtration. . (2) Tom or ruptured bags. (3) Improperly positioned bags. (4) Badly worn or threadbare bags. (f) Wet collectors referred to In 61.22(c) (1) and (2) and (e)(3) are of the high-energy venturi type operated with a minimum gas pressure-decrease across the venturi throat of 40 inches wg. - (g) Wet collectors do not meet the description in paragraph (f) of this sec- tion if any of the following conditions exist: -s (1) Leakage of gases containing par ticulate matter from the control system prior to filtration. (2) Operation at less than 40 inches w.g. pressure decrease. . (3) Operation at a scrubbing medium flow rate less than specified by the manufacturer for optimum collection efficiency. these, the owner or operator shall make available to the Administrator performance data on comparative tests, using suitable standard test aerosols, on the substitute device and the device specified by the applicable standard. The performance data shall Include, but not be limited to, the total mass efficiencies of the substitute device and the device specified by the applicable standard, (e) The total mass efficiency of any substitute device for those specified by 61.23 (a), (c), or (d) shall not be less than 99.9 percent. (f) The total mass efficiency of any substitute device for that specified by g 61.23(b) shall not be less than 85 permit. (g) The total mass efficiency of any substitute device for'that specified by 101.23(f) shall not be less than 99.5 percent: 61.24 Substitute devices for the at tainment of equivalent emission control, - (a) Compliance with any applicable standard of this subpart which refers to a centred equipment specification in S 61.23 shall be demonstrated in accord ance with this section if the referenced control equipment is not used. (b) The owner or operator of the emis sion source shall make available to the Administrator sufficient information as may be required to demonstrate that the substitute equipment will provide the degree of control which, in the Judgment of the Administrator, is at least as strin gent as that which would be achieved by using the equipment specified in the ap plicable standard. To the maximum ex tent practicable, the determination of equivalent degree of emission control will be based upon operation at the actual conditions at which the substitute device is or will be operated on the emission source. Factors which will be considered include, but are not limited to, collection efficiency, reliability, and maintenance practices associated with proper opera tion of the substitute device. (c) The owner or operator of the emis sion source shall submit to the Adminis trator performance data Including, but not limited to, total mass collection effl- ciency of the substitute control device under actual operating conditions or conditions which are representative of those of tire existing or planned operat ing conditions. _ (d> In cases for which it is not reason able, in the Judgment of the Administra tor, to require an owner or operator to submit performance data which are based upon actual operating conditions or conditions which are representative of Tl**S industrial Emission Standards o) For 3 Air Pollutants Proposed -ti * vlb. ?.)S r-.-.. By E. W. KEIWORTHY* , ' , SpWtoTfi*N*wYoht11m V \ ^WASHINGTON, Dec. 3--! 27.<Mr. Ruckelshaus, in a news flliara D. Ruckelshaus, ad' conference today, said the de listrator of the Environmen- lay had been caused,-first, by Protection Agency, an' the. "complexltjr.pf .the prob bounced today proposed emis- lem, -Which'was not 'resolve^] -4ibn 'standards for industry on within the E.KA. untiJ Sept. 26', Wee hazardous air pollutants and, second,, by the need there ^ isbestos,, berryllium and after tq get the views of other mercury. agencies. (lllAsbestos fibers which' are <B83d in floor tile, brake linings, ftontro^Practlces asbestos paper, textiles, insuTa- By way pf illustrating the fihg materials and fireprbofing, complexity, MoL ] Ruckelshaus fCfifl, When inhaled over long said'there were no "sfandard- periods, cause 'lung cancer. ized methods"' -for . measuring] '^-Beryllium,, a highly toxic emission levels of asbestos. 9tt&vy metal that can cause Therefore, hesaid.it has been 'pneumonia among those oc-| decided to set the standards cupatlonally exposed, is used in not in iterms*"of-.numerical Machine ' shops, propellant] emlssiorivalues", but in "control Plhnts, extraction plants - and practices thaf -wilt limit cmis foundries. However, the haz sions to an* jpceptdble level." ards bf beryllium exposure are Consequently, the regulations srlgldly controlled by industrial that will' be published in the Health regulations m force for Federal Register next Tuesday "miost i operations in which the will require the! use of fitters adstaldn-uaed.--** to trap asbestos fibers in gases of Chronic .expasure to airborne from.mining, milling,'manufac iliarcury can have '/ profound turing and. fabrication of as- jdfect on the central nervousl besto-containing materials. ejaaem.ihe symptoms otwhichi Further, there will be an ab ace tremor, psychological dis solute prohibition on the spray turbance, insomnia, loss of ing of asbestos fireproofing and -weight and appetite. The stan Insulation, except where such Karos announced today are spraying is done indoors apd directed mostly at mercury the asbestos-laden-air cleaned tofaes; aijd ,chlor-alkali plants before its release into the sur that maka ehlorina and alkali, rounding atmosphere. Spraying] jwtustic. in the open air has been an Must Give Warning * issue in many large cities, par ""Under amendments to fthej Gtean Alf Act signed by Presi dent Hixon, Oft Dec, 31, 1970, ticularly in New York. Most emissions of asbestos come from mining and mill tog, Mr. RdckPlshaus said. The! *ra administrhWhf the ehvirpiunental ageocy ls retiuired tfvpublish within SO days a list estimated average cosfof com plying wito the .standards,. he said, would be nine-tenths pfl ft..alr^jx>llutants;JUiat, in his per cent of the 1969 spiling judgment, might increase either price. . . ' ,| "ptality, serious- irreversible pess-pr. incapacltattagjlmess, For beryllium, the emission standard for most .plants will |l to update this-list periodi- be an average of pne-huridredth |ly- - of a mlcrogram per cubic meter Vithin 130 days .of publish- of air over a. 30-day period, or the list, the administrator a short-term exposure of 23 , qujred to publish proposed micrograms per cubic toeter missions standards for these for a maximum of30 minutes. giutants. Withfa. 30 days of For mercury, the. standards pishing these," he must set are designed tp, insure that at I time and. place, for public mospheric concentrations do 'ngs on .them, and t^en not exceed one microgram per hip 18Q days issue final cubic meter of air averaged qdards; .. over 30 days. f ist March 3l, Mr. Ruckels- For mercury mines, the cost issupd an initial list of of meeting *the standards will tlutants that included ashes- be 2.3 to 3.5 per cent of pro ->] berryllium and mercury. duct worth, and for chlor-al- |t proposed' Standards were kali plants .5 to .9 per cent of to be published on Sept. product worth. ;^ -- mi mutfi W-utf nia-- -- "2.X FMS\ 02879 F.. U-1-Ti ben or utffeA- A*?**TM* *(****&& Title 41--PUBLIC CONTRACTS AND PROPERTY MANAGEMENT Chapter 50--Public Contracts, . Deportment of Labor PART 30-204--SAFETY AND HEALTH STANDARDS FOR FEDERAL SUPPLY CONTRACTS Standard for Exposure to Asbestos Dust Pursuant to section 4(b) (2) of the Williams-Steiger Occupational Safety and Health Act of 1970 (84 St&t. 1592. 29 U.S.C. 653), 5 50-204.50 of Title 41, Code of Federal Regulations, is hereby amended in the manner Indicated below in order to prescribe a new standard limiting the exposure of workers to as bestos dust. The new standard limiting tlie exposure of employees to asbestos dust is that adopted under section G<c> of the Williams-Steiger Occupa tional Safety and Health Act of 1970 and published In the Federal Register on this date. The standard is hereby determined to be more effective than that presently provided under 5 50-204.50 to the extent that it prescribes minimum levels of exposure to asbestos dust. There fore, by operation of section 4(b) (2) of the Act the new standard issued under section 6(c) supersedes the construction safety standard relating to exposure to asbestos dust. ,, Section 50-204.50 is amended to read as follows in order to apply the new standard limiting the exposure of work ers to asbestos dust: 50--204.50 Gases, vapors, fumes, dusls, and mists. (a) (1) Exposures by inhalation, in gestion, skin absorption, or contact to any material or substance (i) at a con centration above those specified in the 'Threshold Limit Values of Airborne ContanUnants for 1968" of -the American Conference of Governmental Industrial Hygienists, except for the ANSI Stand ards listed in Table I of this section and except for the values of mineral dusts listed in Table H of this section, and (ii> concentrations above those specified1 In Tables I and H of this section, shall be avoided, or protective equipment shall be provided and used. . (2) The requirements of this section do not apply to exposures to airborne asbestos dust. Exposures of employees to airborne asbestos dust shall he subject tp the requirements of 29 CFR 1910.93a. (b) To achieve compliance with para graph (a) of this section, feasible ad ministrative or engineering controls must first be determined and implemented in all cases. In cases where protective equip ment in addition to other measures is used as the method of protecting the em ployee, such protection must be approved for each specific application by a com petent Industrial hygienist or other tech nically qualified source. Table II--Mineral Dosw Substance Mppcf Mg/M*. Bfllca: Crystalline: Quarts (respirable) 260 */ lOmg/M** Quarts (total dust) %8IOrHf ^SiOrg2 Crtstobalite: Use the value calculated from the count or mass formulae for Quarts. Tridymite: Use H the value calculated from the for mulae for Quarts. Amorphous, Including natural diatomaceons earth.,..... Silicates (less than 1% crys talline silica): ' Mica.....1....................... . Soapstone................ ...c.i. Talc......................................... Portland cement___ ....... Graphite (natural)................... Coat dust (resplrabto fraction less than 6% SIO*)............... For more than 5%. 810,.............. %SJO,+2 20 80mg/M* , ' . %&i<H 20 ' 20 20 60 16 ,2,4mg/M> or ___ l0mg/M* Inert or Nuisance Dust: Respirable fraction___ Total dust................... %SiOH-3 15 Brng/M* 60 I6mg/M> Note: Conversion factors-- . mppcfX35.3=milUon particles per cubic meter particles per oul , ; Millions of particles per cubic foot of air, based on impinger samples counicdby light-field technics. 1 Hie percentage of crystalline silica In the formula hr the amount determined from air-borne samples, except In those Instances in which other methods have been shown to be applicable. j As determined by the membrane filter method at 480 X phase contrast magnification. Both concentration and percent quarts for the application of this limit are to be determined from the fraction passing a size-selector with the following characteristics: . * ' Aerodynamic diameter 1 (unit density sphere) Percent passing selector ,2 2.8 Iff A0 W. 75 60 25 .0 >, TanheAmSOeasiunrsetmruemntesnut.nIdfetrirteillrsesnpoitreabrleefefrratcot.iothneotfaM ealt dust to determined with a MRE the fignre eorrespondjng to that of2.4 JJg/M* ip the table forcoaffdust is 4.6Mg/2T . Effective date. This amendment shall become effective upon publication in the Federal Register (12-7-71). (Sec. 4(b)(3), 84 Stat. 1593, S3 US.C. 653'; Secretary's Order No. 13-71,36 Fit. 8764) - Signed at Washington, D C., this 2d day of December 1971. G. C. Guenther, ,Assistant Secretary of Labor. (FR Doc.71-17834 Filed 12-6-71;8:47 am) Vl FMSI 02880 re 12-1- bPT or CA<4aA StbS- Com1T<CwcT>*4 Signed at Washington, D.C, this 2d day of December 1971. G. C. Guenther, Assistant Secretary of Labor. |FR Doc.71-17835 Filed 12-8-71:8:47 amj Chapter XVII--Occupational Safety and Health Administration, De partment of Labor PART 1910--OCCUPATIONAL SAFETY AND HEALTH STANDARDS Emergency Standard for Exposure to Asbestos Dust Title 29--LABOR: Chapter 3^111--Bureau of Labor Standards, department of Labor PART 1518--SAFETY AND. HEALTH REGULATIONS FOR CONSTRUCTION Standard for Exposure to Asbestos Dust Pursuant to section 4(b) (2) of the Williams-Steiger Occupational Safety and Health Act of 1970 (84 Stat. 1592, 29 UJ3.C. 653), S 1618.55 of Title 29. Code of Federal Regulations, is hereby amended in the manner indicated be low in order to prescribe a new stand ard limiting the exposure of workers to asbestos dust. The new standard limit ing the exposure of employees to asbes tos dust is that adopted under section 6(c) of the Williams-Steiger Occupa tional Safety and Health Act of 1970 and published in the Federal Register ran this date. The standard is hereby de termined to be more effective than that presently provided under 5 1518.55 to the extent that it prescribes minimum levels of exposure to asbestos dust. Therefore, by operation of section 4(b) (S). of the Act the new standard Issued under section 6(c) supersedes the con struction safety standard relating to ex posure to asbestos dust. Section 1518.55 is hereby amended by adding a new paragraph (c) thereto. As amended S 1518.55 reads as follows: 1518.55 Cases, vapors, fumes, dusts, , and mists. (c) Paragraphs (a) and (b> of this sec tion do not apply to the exposure of em ployees to airborne asbestos dust. When ever any employee is exposed to airborne asbestos dust, the requirements of S 1910.93a of this title shall apply. Effective date. This amendment shall become effective upon publication in the Federal Register (12-7-71). , (See. 4(b) (3). B4 Stat. 1593, 39 US.C. 653; Secretary's Order No. 13-71,38 F.R 8764) Pursuant to section 6(c) of the Wil liams-Steiger Occupational Safety and Health Act of 1970 (84 Stat 1596, 29 US.C. 655), Part 1910 of Title 29, Code of Federal Regulations (36 FJR. 10466, . May 29. 1971) Is hereby amended In the maimer indicated below in order to pro vide an emergency standard dealing with the exposure of employees to asbestos dust. ' In light of increasing informaticm on the results of exposure of employees to ' airborne asbestos dust, Including recent studies by the National Institute for Oc cupational Safety and Health and others, and recommendations by the American Conference of Governmental Industrial Hygienists (ACGIH), it is hereby deter mined that (1) exposure under the pres ent standard for asbestos dust In Table G-3. S 1910.93, of 12 fibers per milliliter greater than 5 microns in length or 2 million particles per cubic foot of air, which is derived from an established Fed eral standard promulgated under the Walsh-Healey Public Contracts Act on May 20, 1969, constitutes a grave danger to employees exposed to this 8-hour . time-weighted average concentration; and that (2) an emergency standard is necessary to protect employees from this excessive exposure. The National Insti tute for Occupational Safety and Health concurs that the proposed change in the asbestos dust standard recommended by * the American Conference of Govemmen- tal Industrial Hygienists should be the substantial base for the emergency standard. * Action concerning the standard will be commenced under section 6(b) in the immediate future. Any notice of pro- . posed rulemaking under section 6(b) will give notice of the emergency standard as a proposed rule and also of any ap- propriate subsidiary proposals which may be required under subparagraphs (5) and (7) of section 6(b) relating to the ex posure of employees to toxic substances. Part 1910 is amended as follows: 1. Table G-3 following ! 1910.93 (36 FJR. 15104, Aug. 13, 1971) is hereby amended by deleting the following: Asbestos--12 fibers per milliliter greater than 5 microns In length ar.-t________ : 3 Mppcf.v TremollLe.& Mppd. fiOmgyM* -%sior . l/z FMSI 02881 P.. act lA/iflt - 4s*ejr*|jr cV'^cTioJ As amended, Table 0-3 reads as be used to meet the exposure limits pre follows: scribed in paragraph (a) of this section. Tablx O S-Miskbai. Dusf!3 Where such engineering methods are not feasible, or do not otherwise reduce the Substance Uppcf MfcW1 concentrations below those prescribed in paragraph (a) of this section, respira Bnica: .e Crystalline; ' Quartz (respirable)............... . tory protective devices shall be provided and used in accordance with paragraph 250 * JOzng/M* " (c) of this section. - .. . %810H-5 %SsOt+2 (c)(1). <i> When the limits of ex Quarts (total dust).... _.... SOmg/M* posure to asbestos dust prescribed in . %8iOH-2 Cristobelitet Use H tbe . value calculated from the count or mass formulae feu1 -- : quartz. * " Tndymite: Use H the v^ue . calculated from the for- mul&e for quartz. . .~ Amorphous, including natural diatomaceous earth.................. 20 SOnig/M1 paragraph (a) of this section are ex ceeded. and when engineering controls required by paragraph (b) of this section are not feasible or do not otherwise re duce the concentration, of asbestos dust below those prescribed in paragraph (a) of this section, the employer shall re quire the use of respiratory protective de -- Silicates (toss than 1% crys- talline silica) t . . Mica....................................... 20 ' Soapstone... Talc......................................... 20 Portland cement...... ............ CO GrafSbita (natural).................. 15 Coal dust (respirable fraction less than 5% BiOa).............. ..................... --' For more than B% SiOj........................... %aiQa vices. The selection of respiratory " protective devices shall be limited to those specified in the remaining sub paragraphs of'this paragraph (c). 20- til) The employer shall require that each employee test his respiratory pro tective device before each use in order 2.4zng/M* to insure a proper fit according to the or lOmg/mpMl*oayneurfaschtaulrlefur'srthinesrtprurocvtiiodnesf.orTehfefecetimve '* *- Inert or Nuisance Dust: -, Respirable fraction.............. Total dust_______ __ _____ ' r %S10j+2 16 6mg/M* 50 ' l6mg/M* training or supervision of employees in the testing of respiratory protective de vices for fit before their use. . (2) For an atmosphere containing not etpNpocftX*S: 5C-3o=nmvellr3s1ioonn fpaacrtotircsle--s por cubic meter , ' , particles per on. - more than 25 fibers per milliliter greater than 5 microns in length over an 8-hour average, or more than 50 fibers per milli Millions of particles per cubic foot of air, based on impinger samples counted by Light-field technics. 1 The percentage of crystalline silica in. the formula Is the amount determined from alr-bome samples,: ex cept to those instances in which othermethods have been sfcown to be applicable. -, ___ i As determined by the membrane filter method at 4S0Xphasa contrast magnification. ' Both concentration and percent quarts for the appli cation of thislimit are to-be determined from the fraction liter over any period' of 15 minutes, a reusable or single-use filter type respira tor, operating with negative pressure duringthe Inhalation phase of breathing, approved by the UJB. Bureau of Mines under the provisions of 30 CER Part 14 (Bureau of Mines Schedule 21B), or a passing a size-selector with the following characteristics: valveless respirator providing equivalent protection, shall be used. . , (3). For an atmosphere containing not Aerodynamics diameter (unit dorolty sphere) Portent passing selector more than 250 fibers per mlllilter greater than 5 microns in length over an 8-hour 2 2.5 90 75 average, or more than 500 fibers per milUUter over any period of 15 minutes, 8.5 50 a powered filter positive pressure, res 6.0 10 . .25 Q pirator approved by the US. Bureau of ttines under the provisions of 30 CFR The measurements under this note refer to the use of an ABC instrument. If the respirable fraction of coal dust is determined with a MRE the figure corresponding' to that of 2.4 Mg/M* in the table for coal dust Is 4.5 Mg/tf, 2. A new 1910.93a is added to'Part 1910. The new 1910.93a reads as follows: . Part 14 (Bureau of Mines Schedule 21B) shall be used. ` (4) For an atmosphere containing more than 250 fibers per milliliter greater than 5 microns in length over an 8-hour average a type C positive pres sure suppUod-alr respirator approved by 1910.93o Asbestos dust. (a) The ,8-hour time-weighted aver age airborne concentration of asbestos dust to which employees are exposed shall not exceed 5 fibers per milliliter' the U.S. Bureau of Mines under the pro visions of 30 CFR Part 12 (Bureau of Mines Schedule 19B) shall be used. ' (5) The employer shall establish a respirator program in accordance with the requirements of American National greater than 5 microns in length, as de . Standard Practice for Respiratirfy Pro termined by the membrance ' filter tection Z88.2--1969. method at 400-450X magnification (4 millimeter objective) phase contrast illumination. Concentrations above S fibers per milliliter but, not to exceed 10 fibers per mllltHter, may be permitted up to a total of 15 minutes in an hour for up to 5 hours in an 8-hour day. (b) Engineering methods, such as but not limited to, enclosure, vacuum sweep (6) The respirators provided each onployee shall be properly inspected. Cleaned, repaired and stored. (d> (1) When an employer has em ployees who are exposed to asbestos dust exceeding the llifilts prescribed in para graph (a) of this section and tbe ex posure results from the operations de scribed in the remaining subparagraphs ing, and local exhaust ventilation, shall of this paragraph (d), the employer shall comply with the requirements of these subparagraphs relating to, the operations involved. The requirements of this para graph are In addition to those prescribed in paragraph (b) of this section. (2) All hand- or power-operated tools which produce asbestos dust such as, but not limited to, saws, scorers, abrasive wheels, and drills shall be provided with local exhaust ventilation' and dust col lectors in accordance with the American National Standard Fundamentals Gov erning the Design and Operation of local Exhaust Systems; ANSI Z9.2--1971. (3) Employees exposed ,to tbe spraying of asbestos or the demolition of pipes, structures, or equipment covered or in sulated with asbestos shall be provided with respiratory protective devices in accordance with paragraph (c) (4) of this section. , ,. (e) Asbestos cement, mortar, coatings, grout, and plaster shall be mixed to closed bags or other containers. <f) Asbestos waste and scrap shall be collected and disposed of to sealed bags or other containers. v> (g) All cleanup of asbestos dust told blowing shall be performed, by vacuum cleaners. No dry sweeping'shall be per formed. ' , '' 3. Section 1910.12 is' , amended by changing paragraph (a), in order to apply the emergency standard prescribed to the new 5 1910.93a, which is published in this document, to construction work which is subject to the Act: The'amendment Is necessary in light of the rule of regula tory construction set forth in 8 1910.5(c)'. As amended, 191042. reads, as follows;: 8 1910.12 Construction work.' _. (a) (1) Adoption and extension of es tablished. safety and health standards for construction.'The: standards pre scribed by Part 1518 of thls:title'and in effect on April 28, 1971, are adopted as occupational safety or- health standards under section 6(a) of the Act and shall: apply, according ' to the provisions, thereof, to every employment and place of employment of ,every employee en gaged in construction^ work!: Each em ployer shall protect the employment and places of employment of each of his employees engaged to construction work by complying with the. appropriate standards prescribed by this paragraph. (2) The standards prescribed in 8 1518.55(c) of this title shall apply In the case of the exposure of any em ployee to construction work to airborne asbestos dust. . , .; .' ' * i '* Effective ' date. These amendments shall become effective immediately upon publication in theFederal Register (12-7-71). r, * (Sec. 8(c), 84 Stat. 1698, 28 U.S.C. 655; Sec retary's Order No. 13-71,38 F.R.87S4) Signed at Washington, D.C., tiffs 2d day ofDecember 1971. . : G. C. Guenther, Assistant Secretary of Labor. (FRDoc.71-17833 Filed 13-8-71;8:47 am] 3.L FMSI 02832 Room 512 friction W^jateriais Standards institute, J)nc. 370 LEXINGTON AVENUE NEW YORK 17, N. Y. September 30, 1971 MUrray Hill 3-0572 To; Members of Asbestos Study Committee Subject: Proposed Emission Standard for Asbestos Gentlemen: In line with the discussions at the September 15, 1971 meeting of this Committee, Dr. Stefl, Chairman, is forwarding the below listed write-ups to the members of this Committee. We do not intend to distribute this data to the membership at large until the Committee has had the opportunity to review both the Federal Proposal and the draft of the AIA Comments and Suggestions. (1) Proposed Environmental Protection Agency Standards for Asbestos Emission. Comment: Dr. Stefl felt it worthwhile that the Committee see this draft copy, but he is certain that the Federal Standards will be quite different. (2) Comments and Suggestions from Asbestos Information Association/North America. Comment: These are the AIA Comments and Suggestions made regarding the initial draft of the proposed Federal Standards at a meeting held in Atlanta in mid-August. Dr. Stefl further advised, and this is to be considered confidential, that he and others from the AIA met with members of the Illinois Pollution Control Board on September 17, 1971. At this meeting he was advised that hearings would be held at three locations on different dates in October, and that AIA/NA would give written comments at the October 15 meeting in Chicago. Personnel on the Control Board had received comments from the motor companies on the brake lining ban. They were not aware of the E.P.A. tests on asbestos emission from brake lining that are being run by Bendix Research Laboratories. Copies of the minutes are enclosed. EWDrislane/icb Sincerely, - P' 'w- Executive Secretary Messrs.: E. P. Stefl J. C. Henning E. H. Feierabend W. B. Reitze E. Spurgeon J. B. Graham, Jr. J. W. Greenen, ex-officio L. D. Stickles, Counsel Raybestos-Manhattan, Inc. Firestone Tire & Rubber Company Abex Corporation Johns-Manville Corporation The Bendix Corporation Carlisle Corporation Maremont Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh 4 ^| \ FMSI 02883 November 29, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 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 use in Illinois is prohibited. We were able to alert our domestic members as to the seriousness of these proposed regulations. We are aware that some of them expressed their views directly to you. In today's mail I received the attached from the British Friction Materials Council, an organization similar to ours in Britain. 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, ! 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. Ware you to go to a brake ralining shop and collect the wear remnants, you would not detect fibrous material in the wear products. The dust appears more to be like a talcum powder or flour with no fibrous structure evident. W trust that this work by the British Council be considered when you are draft ing your final regulations. Sincerely, EWD/icb Enc: E. W. Dr islane Executive Secretary c - 6 y FMSI 02884 FRICTION MATERIALS STANDARDS INSTITUTE, INC., 370 LEXINGTON AVENUE, NEW YORK, N. Y. BULLETIN N 0. 4 1 7 November 10, 1971 MEASUREMENT OF ASBESTOS FIBERS IN THE AIR Since the organization of the Asbestos Study Committee it has been suggested that all members be advised on monitoring asbestos fiber con centrations in the work place. This should be of interest since the Occupational Safety and Health Act of 1970 was effective on April 28, 1971. Mr. William Reitze of Johns-Manville addressed the June meeting on this Act and subsequently we distributed literature concerning the Act and Threshold Limit Values. Mr. Reitze advised that there was a guide published by the Asbestos Textile Institute: "Measurement of Airborne Asbestos Fiber by the Mem brane Filter Method." Source: Asbestos Textile Institute P.0. Box 239 Pompton Lakes, N. J. 07442 Price: $1.00 % Mr. Reitze cautioned, however, that this document might be mislead ing if personnel doing tha work do not have the proper background or training. For this reason, Mr. Reitze would be willing to give a talk and demonstration, including a discussion of materials, methods, costs, personnel requirements, and legal aspects. This would not be a train ing course but would be an information session where those responsible for making decisions could be given enough information to decide which course their firm should follow. There would, of course, be no charge for this presentation. If there are members of your firm who would be interested in such a session please advise. It generally would be planned to have the ses sion, if interest is sufficient, sometime after mid-January in the New York metropolitan area. As Mr. Reitze now must travel in from Denver, it would be important for those interested to indicate rather positvely their intentions as regards attending such a session. Distribution: Active Members Asbestos Study Committee E. W. Drislane Executive Secretary _ JL- FMSI 02885 -ffilCTION MATER!AL$ STANDARDS 1N5TITOTE. INC.. 370 LEXINGTON AVENUE. NEW YORK. N. Y. BULLETIN NO. 4 16 October 28, 1971 PROPOSED ILLINOIS BAN ON ASBESTOS IN BRAKE LINING There has been considerable activity by members of the Asbestos Study Committee as regards the proposed Illinois regulations on "Asbestos and Spray Insulation". To quote from Part VII, Section 702 of the regulations proposed by the Illinois Pol lution Control Board: "The use of asbestos in the brake lininp of vehicles manufactured after January 1, 1975. and sold for use in Illinois is prohibited," In the Board's explanation it notes that the prohibition is worded to avoid the necessity of fitting vehicles manufactured prior to 1975 with "non-asbestos" brakes. However, there is no question but that the ban includes original equipment linings, and there can be little doubt but that replacement linings on these vehicles must also be of a "non-asbestos" type. Further, interpretation of the proposed reg ulations indicates that all vehicles are included: Passenger Cars, Trucks, Off High way Equipment, Farm, Tractors and the like. Also, the Board apparently considers "clutch facings to*be the same as brake linings", While the immediate effect would be on those supplying original equipment linings, the secondary effect would be feltby all friction material manufacturers. In the Board's explanation they state: "These prohibitions have been made with full consideration given to the available alternative materials." From the Illinois hearings this past month, the Institute has received several articles of interest: , (l) Johns-Manvilie memorandum, October 20, 1971, by Mr. Swetonic summa rizing the Chicago hearingpon October 15, 1971. (2) Written presentation by Dr. F. Pundsack of Johns-Manvilie as given at the Chicago hearings. (3) Dr. W. J. Nicholson, Mt. Sinai Hospital, a presentation in support of the Board's regulations, at the Chicago hearings. (4) Chicago Sun-Times October 18, 1971 report on the Chicago hearings. (5) Waukegan newspaper report of October 20, 1971 concerning the hearings in Waukegan. (6) Johns-Manvi11e memorandum, October 20, 1971, by W. Raines summarizing the Waukegan hearings on October 19, 1971. Attached to the delegates copies only of this Bulletin are excerpts: (1) Entire J-M summary of the Chicago Hearings. - Continued - FMSI 02886 Bulletin #416 -2- October 28, 1971 (2) Entire J-M summary of the Waukegan Hearings. (3) Pages 20, 21 of Dr. Pundsack's presentation at the Chicago Hearings. All those who have appeared at the hearings feel it is most urgent that the brake lining manufacturers advise the Control Board of their position on this pro posed ban. It has been learned that the Control Board was surprised over the lack of response to the brake lining ban from friction material manufacturers. Realizing the unreasonable deadline you must work against, comments should be in the hands of the Pollution Control Board bv November 10. 1971. Please write: Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 The comments must be your own. We suggest that the primary force of these comments might be the lack of availability of known substitutes at this time. A secondary point might be that the Federal EPA (Environmental Protection Agency) is currently having studies made concerning the extent of emissions in the general en vironment from brake lirvings, and these results will not be known till mid 1972. Unless you have specific medical background, we suggest you not question the proposed safety standards on^asbestos concentrations. Further, as is the case with most government bureaus, any pleading on cost or economics should be avoided. Please note that the portion of \he proposed regulations that we are concerned with at this time ' is the general environment from brake lining emissions on vehicles in use. While the in-plant environment is also covered in the proposed regulations, we are advising our members primarily on the proposed ban on brake lining on vehicles. Should you write Mr. Lawton, it would be appreciated if you would send a copy to the Institute. If there are any questions, please give me a call. E. W. Drislane Executive Secretary Distribution: Active *% FMS\ 02887 boet Mr. o. j. Websr Mr. 0. 1. Millar Mr. G. L. Wilson - pit. I, Akron <s*r. %, W, Brlalane MSI aJ^"- tJH" <\S-KA-}' wowwbsr k$ \9H Mr farioal T. tawton State of Illinois Pollettea Oonirol Board lif WMt Kadisttk Street Salt* fm SMog@, Tlltoois 60602 fear Mr. Trtt As of brake lining* it cane m s complete shock t World Seat* fttmpmy, Division of fha Firestons Tim & Snbber CosfMHgr, to leara f its* proposed If75 reatortotien of the use of asbestos to the brake lining of vehicle* told for mm to Illinois. Far awafe a widely affacting regtilstion to have tmm proposed met bar town baaed a a mbstantlal mmxmt- of daaaitaf evidence f m unequivecal mature. W# would like te be Mpj&tod a list of references or still better eepiea of all scientific data open ahlah the pro posed relation was baaed or seed as support a that ms mm Bake oar omo analysis of said data and begin oar alternative research progress immediately. If these stadias for whlafe to regulations ware based ape are indeed scientifically reliable, than a three pear waiting period la to qaestlacu Can fm syplato how the three yoar figure was arrived at and toe thinking and reasoning for meh a delay and grace pwtodf FMSI 02888 -2 We wmM ala like te Jws i available that infematien r sjardtof suitable available laternatire na&erlei* end the best alaariisg atrl*la Furthap* ini like %q &ee ttwi sffrtlsbi:# date TfM**w sspporta the *ltimatipe aaterlals in taiAw teata aa PapsrtaMBt a# vehicle tssta nif^ peptlatint Indoor BysiMiSiieter tests* We should like be #*y that refer*# *hl*h m hav seen and are wtra of 4o not suggest that brake lining emissions eeaatitate say teewft health haaarrt. 'therefore, im fssl that ih prepared regulation will net seeespllsh in fast Its intent {that is, is reduce asbestos levels in anblent air) threads such an eaactaent. la senelusisa our sheervation at the present tin is that the proposed repilatiea nay be Meed cm unsupported b4 insufficiently ea^prahefsalve data to wurrsat such eateneire actio by the.*Hnte of Illlis* Very truly yours, mar. ssptqs ommi? jewiilfca Attachment Hanagwr, Telaaiel**eaears& FMSI 02889 MaRGMONT CORPORATION 168 NORTH MICHIGAN AVENUE CHICAGO, ILLINOIS 60601 TELEPHONE (312) 263-7676 November 5, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: I am writing you to register concern on the part of Maremont Corporation relative to the proposed Illinois ban on asbestos in brake lining, effective after January 1, 1975. Maremont currently produces, under the brand name "Grizzly", both pas senger car and heavy duty vehicle brake lining for the aftermarket and has been a part of the Friction Material industry for over twenty years. We are most concerned with this proposed legislation since it is our com bined technical opinion that there is not, at the present time, nor will there be in the foreseeable future, a suitable alternative to asbestos in friction material that will yield the performance characteristics required in today's braking systems. Further, proposed federal improvements in braking sys tems to be effective after 1975 will require those manufacturers now par ticipating in the industry to devote their time and energies to sophisticated improvements within an asbestos based product, making the research for an asbestos substitute a goal beyond the available technical abilities of most manufacturers, should that substitute really exist. Mr. Lawton, I would appreciate your continued review of the matter and hope that Maremont's concern will be given appropriate consideration. Sincerely, AAL/gjk bcc: R. B. Black/J.W. Greenen F. C. Andre A. Laus Vice President and General Manager Brake Systems Division FMSI 02890 AUTO FRICTION CORP. MANUFACTURERS OF BRAKE LINING November 3, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 185 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: It has come to my attention that the State of Illinois is considering regulations or legislation which would prohibit the use of asbestos in the manufacture of brake lining for use in your State. I also understand, that there was a certain amount of disappointment expressed by members of your Board that there was a lack of response from the friction material manufacturers. The reason that we have not responded before this, is that until I read a recent article in Chemical Week Magazine, I was not aware that regulations or legislation was being promulgated. I may state quite succintly two basic objections to this proposed regulation or legislation on the part of our Company: 1. There is a complete lack of availability of a known substitute at this time for asbestos in the manufacture of the broadest range of friction material products for safe and accepted use in automotive vehicles. 2. The Environmental Protection Agency of the U.S. Government has presently commissioned studies to be made concerning the extent of emission in the general environment from brake lining. The results of this study will not be reported until mid 1972. I appreciate this opportunity to inform you of our comments, and remain, Sincerely, AUTO FRICTION CORPORATION Norman Comins Vice President bcc: Mr. E. W. Drisla FMSI, New York NC/ah 651 ANDOVER ST , LAWRENCE INDUSTRIAL PARK, LAWRENCE, MASS 01842, TEL, 617/686-3326 . CABLE: AUTO F FMSI 02891 (201) ARMORY 8-6655 45 EAST 5TH STREET PATERSON. NEW JERSEY 07524 QUALITY FRICTION MATERIALS SINCE 1019 Nov. 8, 1971 State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Att: Mr. Samu&l T. Lawton Gentlemen: As a brake lining manufacturer whose product contains asbestos we are much concerned over the Illinois Proposed Ban on Asbestos in Brake Lining, particulated by Part VII, Section 7O2 from the regulations proposed by the Illinois Pollution Control Boafrd. Our cofnpany, and our industry as an entity, is definitely not interested in producing products which will have harmful emission effects in the atmosphere. But we do believe the above cited section of the proposed law does not have evidence to back up its severity------evidence that proves a harmful emission-factor as a result of/or because of the asbestos content in friction materials. On the basis of reports of testing emissions we believe that although it is within the power of the State of Illinois Pollution Control Board to have asbestos banned from brake linings, we feel that to do so would eliminate an effective and useful brake lining component without justification. We are certain that many of the emission tests have been forwarded to the Board, and that the Board is aware of the tests of emissions now being made by the Federal Environmental Protection Agency. We believe that this data will be most helpful in determining the effects of asbestos-emissions from use in brake lining, and will establish whether these emissions are of any danger or if they are negligible. FMSI 02892 If the emissions prove to be a harmful pollutant our company will certainly support your Board in eliminating this hazard. But until reliable evidence supports this possibility we are reluctant to accept any unsupported position. Our company has been producing brake linings since 1919. (The basic company was formed in 1917.) During this span of over 53-years we have produced hundreds of millions of feet of asbestos brake linings. In our process, we deal closely with raw asbestos fiber. Of course, we use protective measures in handling these materials------as well as other fine powders.' We have never had, in our history, a case of asbestosis or any other asbestos-induced illness among any of our personnel. We believe this record is not uncommon among brake lining manufacturers. We are aware of the fact that in other industries who use asbestos there are systems which do not control or contain the material. However, our chief concern is with the brake lining industry, and the effects in the atmosphere of the use of asbestos in brake linings. We believe that the asbestos is locked-into the brake lining material, and that during its normal usage the heat of the friction converts any residue into an inert non-fibrous material which will not be hazardous in nature. We look to your Board for a full analysis of this matter, and a just decision based upon proved and repeatable data of a factual, non-emotional, nature. Very truly yours, BRASSBESTOS MFG. CORPORATION S:g WILLIAM SIMON President FMSI 02893 Abex Corporation November 8, 1971 Research Center MAHWAH. NEW JERSEY 07430 TEE: 201-529-3450 Mr. Samuel T. Lawton State of Illinois Pollution Control 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: In conjunction with hearings recently held regarding Regulation No. R71-16 "Asbestos and Spray Insulation" proposed by the Illinois Pollution Control Board, we believe it. would be helpful to you to have our comments as a major manufacturer of friction material. The Abex Corporation, through its American Brakeblok Division is one of the major suppliers of friction material for brake and clutch use in the United States. During 1971, our sales of asbestos containing friction material for use in vehicles operating in the United States will be in excess of 20 million dollars. Our interest is specific to Part VII, Section 702 of the proposed regulations which states "The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975, and sold for use in Illinois is prohibited". Our comments are as follows: 1. Asbestos 'fiber is an important component of organic friction material used in brake and clutch facings for vehicles manufactured and used in the United States. Of known fiberous material, asbestos imparts unique strength and thermal properties to friction lining, in addition to pro viding unique performance characteristics essential to safe and reliable braking and clutching of vehicles. 2. We are aware of investigations conducted on the nature of wear products from linings in use, as well as the identification of airborne particles from operating brakes. Air sample analysis conducted by our Medical Department to collect wear product particles during brake operation on our laboratory dynamometers confirms the findings of J. R. Lynch as reported in his study "Brake Lining Decomposition Products" published in the Journal of the Air Pollution Control Association, Vol. 18, No. 12, December, 1968. 3. Abex Corporation, in conjunction with Arthur D. Little, Inc., submitted a technical proposal to the Evironmental Protection Agency in response to that agency's request for proposal No. EHSD 71-NEG 102 "Characterization of Emission from Automobile Brake and Clutch Linings". In this way we are well aware of the investigation work now being carried out by the Bendix (Continued) FMSI 02894 Mr. Samuel T. Lawton -2- November 8, 1971 Corporation under contract to the Environmental Protection Agency. We understand that results from this contract research will not be known until the middle of 1972 at the earliest. It is our opinion that the results of this study will verify again that airborne particulate matter from vehicle brakes and clutches does not con stitute a dangerous health factor in Urban air pollution. We believe that the proposed ban on manufacture and use of asbestos containing friction material is unwarranted and unnecessary. We recommend that Part VII, Section 702 be removed and not made part of regulations proposed by the Illinois Pollution Control Board. Very truly yours G. R. Graham Director Friction Materials Research GRG:nmp BC: Messrs.: N. G. Belury G. L. Romlne F. B. Herlihy E. H. Feierabend E. W. Drislane, FMSI, Inc. W. P. Raines, AIA/North America FMSI 02895 British Priction M aterials Council BAKER, ROOKE & CO. Chartered Accountants telephone: 01-242 0211 99, Aldwych, LONDON, WC2B 4JY 362/m/BFMC The Secretary, Friction Materials Standards 370 Lexington Avenue, New York, N.Y.10017, U.S.A. Institute, Inc., 26th November, 1971 ,y /* ' Dear Sir, 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 perhaps you could let us know their comments. We shall also be grateful if you could make our views known as set out in this enclosure. Your^ i nr Secretaries Enc FMSI 02896 PROPOSED ILLINOIS STATE BAN ON ASBESTOS-BASED BRAKE 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 is 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 1% 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. This 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/m? 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. 5. 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 1. Hickish D.E. and Knight K.L. (1970) Annals of Occupational Hygiene Vol.13, No.1, page 20. 2. Letter to Nature attached. British Friction Materials Council 26th November, 1971. FMSI 02897 r,ATUHt \Cl 13-1 NOVEMBER 1Z 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 Asbestosis Research Council we are developing a more sensitive technique. This article is a preliminary account of the estimation of chrysoTile 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 Crabie1, 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 m3 (10* 1.) of air by an electrostatic device (H. Litton Systems Inc.) in which up to 10,0001, min'1 are drawn through a 20 kV corona discharge. Particles in the air are electrostatically precipitated onto a plate and concentrated into ~I00 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' w-e 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 I. mill"1, dropping to between 25 and 50% at the rate of 10.000 1. min ', depending on the actual size dis tribution present. As we were aiming at only an order of rhagni- r: FMSI 02898 94 Fig. 1 Observed amounts of chrysotile in 5,000 1. of factory air, sampled at different rates. NATURE VOL. 234 NOVEMBER 12 1971 Tobla 1 Weather Conditions during Sampling Date (1970) Site Wind Weather April 22 1 SW moderate Broken cloud April 24 1 SW slight Ground haze April 27 1 NE moderate Ground haze April 29 1 SW moderate Ground haze May 6 1 S strong Ground haze May 13 1 N fresh Ground haze May 28 3 W light Overcast, dull May 28 3 W light Overcast, dull May 30 4 W light Overcast, dull May 30 4 W light Overcast, dull June 3 2 SW light Overcast June 10 2 SW slight Heat haze June 10 2 SW slight Heat haze October 23 1 W moderate broken cloud October 23 1 W moderate Broken cloud October 23 1 W moderate Broken cloud October 28 1 N light Broken cloud October 28 1 N light Broken cloud October 28 1 N light Broken cloud tude assessment of asbestos in urban air, we were prepared to accept this uncertainty in the collection efficiency. The map (Fig. 2) and Table 1 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 site No. 2 is at the same height as the roof of the filter gallery, which is the chief air outlet 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. All 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 the 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 clearly 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 m3 of air contained less than 100 pg of chrysotile--in other words, there was less than 0.1 jig of chrysotile per m3 of air. The threshold limit for occupational exposure set by the 1969 Asbestos Regulations2 is 0.1 png m-a. Fig. 3 X-ray diffraction pattern from a typical dust sample near the Rochdale factory. 1*8-2 Plan of T.B.A. factory, Rochdale. The sampling sites are indicated by the arrows 1 and 2. f\ 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. 1 Crable, J. V., Amer. Ind. fiyg. Assoc. J., 27, 293 (1966). 5 Standardsfor Asbestos Dost Concentrationfor Use with the Asbestos Regulations 1969, Technical Data Note 13 (HM Factory Inspec torate, 1969). / FMSI 02899 s^>y On-- October 22, 1971 Dr. E. P. Stefl Administrative Assistant to President Raybestos-Manhattan, Inc. 205 Middle Street Bridgeport, Conn. 06603 Dear Genes I'm writing this as a matter of record. I believe ! may have mentioned it on the phone. On Wednesday September 29, 1971 (4*00 P.H.) 1 was called by a representative of the Center for Political Research in Washington, D. C. Miss Susan Simon Center for Political Research 1790 M. Street N. i. tashington, D. C. 20036 She had apparently decided (or had been told) to contact the Friction Materials Standards Institute with the impression that we had material or compounding standards. The basic thrust of her question was: "What are the brake lining manufacturers doing about asbestos in the environment?1' I told her we did have a committee studying asbestos in the brake lining industry for (1) general environment emissions, and (2) asbestos in the work place. I mentioned the Environmental Protection Agency's tests to determine the extent of any asbestos emissions in the general environment from the use of brake lining on vehicles, and the proposed regulftions of the Illinois Pollution Control Board. She brought up fiber glass as a substitute. ! believe she is part of the activist anti-everythings, and while our conversation was pelite and restrained, I don't bel iev she had much technical depth - as suggested by the usual "fiber glass substit and the apparent pre-judgment that asbestos in brake linings is a serious contaminant from the emission viewpoint in the general environment. The foregoing is strictly a matter of record. Sincerely, EfD/icb E. I. Drislane Executive Secretary FMSI 02900 Raybestosjp/lanhattan CORPORATE HEADQUARTERS M DR. E. P. STEFL VICE PRESIDENT ADMINISTRATIVE ASSISTANT TO PRESIDENT M Q S O o September 27, 1971 (-0I m30 m m a o m TJ O30 Mr. E. Drislane Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York, New York 10017 o ? 8 Dear Ed: I am returning your draft copy of the minutes of our meeting of the Asbestos Study Committee without change. I think you have covered the matters that were discussed quite well. As agreed upon at that meeting, I am also enclosing a copy of the Federal proposal for the emission standards for asbestos. You will recall that the members of the committee thought it well to see this draft copy even though we now know that the Federal standards will be quite different. Nonetheless it is being sub mitted for information purposes. You are to make copies and distribute such to the members of the committee. In addition I am enclosing a copy of the comments and suggestions that were made regarding this initial draft by the AIA at a recent meeting that was held in Atlanta about mid-August. These comments and suggestions were given to the entire group assembled and we were advised that they would be given consideration in the revised version, which we have yet to see. Again, this is being supplied for information purposes. Further, I agreed to advise all the Committee members as to what happened at our unofficial meeting with some members of the Illinois Pollution Control Board held in Chicago on September 17. Since that meeting covered matters other than the ban on asbestos in brake lining, I will quote you from portions of the minutes I have received regarding that session. I would urge that you advise our committee members that this information is to be considered extremely confidential at this point, especially since the meeting was held in advance of the public hearings. FMSI 02901 2 Those present in Chicago on September 17 were Timothy Harker, Administrative Assistant to the Illinois Pollution Control Board, and Walter Romanok, also of the Illinois Pollution Control Board on a part time basis. Representing them from a technical stand point was Dr. Colin Harwood, whom I believe was instrumental in writing a great portion of the proposed regulations. He is from an Illinois Institute of Technical Research, I believe is the proper title. Representing our side was Dr. George Wright of St. Luke's Hospital in Cleveland, E. M. Fenner, W. P. Raines and Dr. S. Speil of J/M, and myself. The two-hour meeting was quite cordial and useful. Despite Harker's great reluctance to schedule the meeting, and his suggestion on September 13 that it be cancelled, he proved to be quite communi cative and certainly did not evidence hostility. We learned that public hearings will be held in Illinois on Wednesday, October 6, in Granite City at 9:30 A.M. in the court house; on Friday, October 15, in Chicago at the Field Museum at 10:00 A.M.; and Tuesday, October 19, in Waukegan at 10:00 A.M. at the public library. Harker indicated a preference that the asbestos industry, through the AIA/NA, testify as a unit rather than each asbestos company testifying separately. Harker indicated a strong preference that the industry present its testimony at the Waukegan hearing rather than at the Chicago hearing. They expect the Chicago hearing to be "crowded". It is neither necessary nor desirable to appear at more than one of the hearings. Testimony should be given verbally and in writing. Ten copies of the written version should be submitted to the Board in advance. We advised Harker that we would let him know which hearing we would present our testimony at, who would testify for the industry, and the amount of time that we would require. On the matter of the brake lining ban, this subject required surprisingly brief discussion. Harker called it "a weak point in our regulations". He implied--though he did not say so--that it was inserted in order to gain publicity for the proposed regulations and hearings. He said it would "stimulate discussion". Harker did say that one automobile company had told him that their company would be using only asbestos-free disc brakes by 1975 and that the asbestos ban would thus not affect them. FMS1 02902 3 Dr. Harwood said that GM and Chrysler had told him that they saw no way of eliminating asbestos from brake blocks or discs without seriously diminishing the effectiveness of the brakes. Harker seemed impressed by this and commented that the Board didn't want to kill more people than it "saved" by any such ban. We mentioned the Bendix studies being conducted for the EPA relative to the emissions of moving vehicles. The Illinois people seem to know very little aboutWiat the Federal EPA is doing relative to asbestos emission standards and what the Bendix test involvement is. Harker also mentioned that New York City is testing the air in subways and other closed in areas to see what the asbestos fiber level is there, presumably being produced from vehicles. I believe that summarizes what transpired to a great extent at that meeting. In view of the time limitations for these hearings, from the standpoint of getting prepared, it would seem that the AIA/NA will carry the ball for the entire group since I do not think that the FMSI Committee can function with any realistic data at this point. This is a personal opinion of mine and I would appreciate any comments anyone might care to make regarding such a position. In the meanwhile, through Johns-Manville, the AIA has testified at various city and state hearings on the ban of asbestos in spray coating and also testified in Washington in a written foim regarding the hazardous nature of asbestos so I believe we have a format which can be presented from that group in Illinois and be effective. Some of it will be written and in addition we will probably have people testify on the aspects other than the brake lining ban. I believe the portion on the brake lining ban will be limited to the publica tions which I submitted to each committee member at our first meeting. I believe this concludes my report to you and the items that I agreed to take care of. If there are any other areas where I can be of help, please let me know. Very truly yours, E. P. Stefl Attachments ,S. I have just been advised that the AIA/NA testimony will be presented on Friday, 10/15, in Chicago. Perhaps you would care to be present. The team representing us has not been decided nor has the time of day. I will advise you when I know more. FMSI 02903 September 23, 1971 Dr. M* G. Uacko Bendix Research Laboratories Bendix Center Southfield, Michigan #4*75 Dear 'likes While you were at the meeting of the Asbestos Study Committee last week, you asked for some information about the Friction Materials Standards Institute. I believe you were trying to understand the basic services that the Institute performs with out getting Into the detail as spelled out in the Constitution and By-Laws. However to be specific, I am enclosing a copy of the Constitution and By-Laws. The Friction f&terials Standards Institute, is made up of most of the United States manufacturers of brake linings and clutch facings. One of its earliest services was a copyrighted numbering system for the brake linings and clutch facings. In this way if a customer were ordering a set of brake linings to fit a 1963 Chevrolet, he would check our book end select #2065* for the fronts end # 2006* for the rears. Moat brake lining manufacturers would provide this lining with the # 2065* and #2006* number. The various brake lining manufacturers make this lining to the dimensions spelled out for original equipment purposes from information we furnished them. We solicit and compile date on all new brake lining and clutch facing releases and we publish a book every other year, with supplements in the in-between year, which keeps the field up to date on the brake linings and clutch facings used on the cars and trucks they will be servicing. Further, we publish bulletins about six or eight times a year to bring the members up to date on any changes that are happening, when they happen. Because of the multiplicity of brake shoes and the problems In determining which shoe belongs on which vehicle? we also prepare a brake shoe identification catalog. The shoe assignments which we give are used by most manufacturers to describe the lining shoe package which the^distributo in the after market. All members of the Institute are allowed to use the F. W, S. I* numbering system which is copyrighted. Furthot) they can authorize their customers to use the F.M.S.I. numbering system in their oatalogs and on their price sheets. As an example of the type of work the F.M.S.I. ie doing currently in this area, we are working on a brake block identifteatlon book which would allow people in the field to identify the F.M.S,!, number for the block by tasking certain basic measurements* As you will note, our services are oriented to the replacement market* Ear.figqwiQga Members of the Institute over the past ten years were being deluged with State legis lation in the automotive safety area which was then followed by the Federal Government legislation in 1966 setting up under the Department of Transportation, what is now the FMSI 02904 or. Jacko 3endix Research Laboratories - 2- September 23, 1971 National Highway Traffic Safety Admlnstration - M.H.T.S,A, The friction flaterials Standards Inst!tut organised a Committee to help give the various safety aetainstratora guidance so that reasonable regulations would be issued. *har regulation establishing brake lining eertifieatlon tests were sat up by such States as Near York, Pennsylvania, Massachusetts and others, the Friction Material Standard institute worked with the administrators in establishing requirements. Bering various hearings in laghingten for the N.H.T.S.A, n brake system safety regulations, the Friction Material Standards institute would review the proposed standards, prepare teste and compile comments m tho proposed standards. to still ssintain a close watch on Washington end the various States as regards legislation and regulations soncerning brake linings. To this data, clutch facings have not been ouch of an item as regards automotive safety. This particular Committee, as yew ara aware, is newly formed with its obvious emphasis on asbestos. It may take a somewhat similar posture as the Brake Performance Study Committee and C 1 } disseminate information to the members, and ( 2 ) preparfe. formal comments to the various environmental agencies whore they may be drawing up regulations that concern asbestos in brake linings or clutch facings. Slthin tho Institute we con take any reasonable steps that will further the friction materials industry in line with the Constitution and By-Laws. Among other thing, the Institute has organized the aocumulation of information on historical sales by the members of friction articles - brake blocks, disc brake lining, other brake linings and clutch facings. This information is submitted to a Certified Public Accountant who review the original input from the members and prepares the summaries of totals. This information iasfinal form is confidential and Is returned to the members. A I d not believe you ore interested in the Institute concerning our catalog in formation,, ! a not sending any of this type data. Should you wish a copy of our Data Book and Shoo Catalog, please let me know. When I have received an approved copy of the minyte of our recent meeting, I will send you a copy. Dr. Spurgeon of course will be receiving a copy when the minutes are distributed. Sincerely, EfDrislane/orc Ene: Executive Secretary FMSI 02905 SiZi Johns-Manville Environmental Control Systems Division Box 159 Manvllle, N. J. 08B35 (201) 722-9000 August 24, 1971 Mr. Edward Drislane Executive Secretary Friction Materials Standards 370 Lexington Avenue New York 17, New York Institute, Inc. Dear Ed: I would be very happy to serve on the newly formed Asbestos Study Committee. I will plan on attending the proposed first meeting of this committee on Wednesday, September 15, 1971, at 9:30 a.m., at the Friction Matierals Standards Institute's offices. I am looking forward to seeing you at that time. SincereIy yours, William B. Reitze, Manager Industrial Hygiene Engineering Services WBR/vam FMSI 02906 205 MIDDLE STREET, BRIDGEPORT, CONN. 06603 RaybestosQp/lanhattan CORPORATE HEADQUARTERS B DR. E. P. STEFL VICE PRESIDENT ADMINISTRATIVE ASSISTANT TO PRESIDENT August 24, 1971 Mr. E. Drislane Friction Material Standards Institute 370 Lexington Avenue New York, New York Dear Mr. Drislane: Thank you very kindly for your letter of August 20 informing me that I have been appointed Chairman of the newly formed Asbestos Study Committee. I am delighted to accept and will you please advise Mr. J. W. Greenen of my acceptance. Thank you kindly. Very truly yours FMSI 02907 CARLISLE HEAVY DUTY BRAKE BLOCKS AND SEGMENTS Molded Materials Division CARLISLE CORPORATION P.O. BOX 417, RIDGWAY, PA. 15853 TELEPHONE (814) 773-3187 August 23, 1971 5l_~jr Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York 17, New York 10017 Attention: Mr. E. W. Drislane Dear Mr. Drislane: In reference to your letter of August 20 concerning the Asbestos Study Committee, please be advised that I will be pleased to accept an appointment to this committee. Also, I plan to attend your initial meeting on September 15th. Sincerely yours, MOLDED MATERIALS DIVISION JBG/vb cc: Mr. E. R. Zacharias t%i. 3S B. Graham Factory Manager FMSI 02908 August 2, 1971! **% F. E. Messier Fr let Ion Materials Division Tho Bendix Corporation P. 0. Box #1499 Cleveland, Tennessee #37311 Dear Frans Subject! Asbestos Study Committee (Friction Materials) This concern the possible addition of a new committee within F.M.S, I. an "Asbestos Study Committee" as discussed in Bulletin #406. A copy of Bulletin #406 is enclosed. While the bulletin covers the essential points, i did want to make a personal contact to see if Bendix could contribute to such a committee. Our concern is expressed for asbestos in brake 1inings because of several outside stimuli! 1. A proposed Illinois regulation! "The use of asbestos in brake lining of vehicles manufactured after January 1, 1975 and sold for use in Illinois is prohibited*. 2. Possible effects of the new Occupational Health and Safety Act of 1970 as regards asbestos in the work place. .3 Some concern for particulates In the air - particularly asbestos in the air. Fran, I don't really know what approach you would take. I do know that Bendix Research in Detroit has done some studying on particulates (rubber, asbestos, etc.) in the air. Also, perhaps at Trey or Cleveland someone has been made responsible for monitoring asbestos in the factory area* If you have someone in either the factory area dealing with asbestos, or in the medical or hygiene area who could contribute, I'd appreciate word. Let me have your comments on this. Sincerely Secretary EWDrislane/hgd Enclosure FMSI 02909 World Bestos Company DIVISION OF THE FIRESTONE TIRE 6- RUBBER COMPANY HARVEY S. FIRESTONE FOUNDER NEW CASTLE, INDIANA 47362 July 29, 1971 Mr. E W. Drislane, Secretary Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York, New York 10017 Dear Mr. Drislane: Re: Asbestos Stucty Committee e do not have an industrial bygenist at our World Bestos Division so do not have anyone to offer that has specific talents that might be used on this committee. If, however, there is difficulty in getting sufficient talent to serve on the committee, we would be happy to offer the services of our Technical Manager, J. C. Henning. Mr. Henning has a Masters Degree in Chemistry and has served in the Research and Development Department of The Firestone Tire & Rubber Company for a period of ten years before joining the World Bestos Division as Technical Manager, Yours very truly. CJWida C. J. Weber General Manager y your Symbol Firestone | of Quality and Service VC > <r FMSI 02910 Friction Materials Standards Institute. Inc.. 370 Lexington Avenue, New York. N. Y_. BULLET IN fNO. 4 0 6 July 16, 1971 ASBESTOS STUDY COMMITTEE This notice is being sent to all Active Members concerning the President's intention to form a new committee within F.M.S. I. We are considering the establishment of an "Asbestos Study Committee", to consist of a chairman and probably four members. BACKGROUND While the talk delivered by Mr. W. B. Reitze of Johns-Manville at the JUne meeting dwelt mostly on in-plant environment, there was some discussion relating to asbestos factory environments and brake lining particulates in the air. Well before this talk, there had been concern expressed on an Illinois Law which would eliminate the use of asbestos in brake linings. ASBESTOS INFORMATION ASSOCIATION OF NORTH AMERICA This association was recently formed by the asbestos companies of North America. It would be our intention to work with them through our new committee, and essentially speak for the brake lining and clutch facing manufacturers. Obviously, our committee would review and comment on rules and regulations proposed by the State and the Federal Government. There would be no cots to the Institute in any of our work with this association. STAFFING THE COMMITTEE We would like to staff this committee with experienced and skilled personnel, preferably from the manufacturing, or Industrial Hygiene areas. Please give this bulletin your careful review. If you fel there is someone in your Company with the background necessary to serve as a member of this Committee, please advise with a brief description of this person's background. 1C /, * A'' t\ E. W. Drislane Secretary Distribution: B l FMSI 02911