Document JZbr0qn78bypv57LzYYwwBVK

FMSI 03551 FMSI 03552 FRIC~ION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, NEW JERSEY 07652 November 17, 1980 TO: HEALTH AND ENVIRONMENTAL AFFAIRS COMMITTEE SUBJECT: MEMBERSHIP ON COMMITTEE This is to advise Committee members on the make-up of the Health and Environmental Affairs Committee. I have attached a roster of those who will be serving on this Committee. Should there be information of importance to Committee members it will be sent to the names appearing on this roster. When a Committee meeting is called we will advise the members indicated. The foregoing is for your information. E. W. Drislane Executive Director FMSI 03553 ~7- HEALTH & ENVIRONMENTAL AFFAIRS COMMITTEE James W. Armstrong, Chairman Bendix Corporation Bendix Center Southfield, Ml 48076 313-827-6350 Charles H. Borcherding Abex Corporation Medical Department 4550 W26th Street Chicago, IL 60623 312-521-3210 David E. Stone Bendix Corporation Friction Materials Division P. 0. Box 238 Troy, New York 12181 518-273-6550 William E. Milligan Carlisle Corporation Molded Materials Division P. 0. Box P Ridgway, PA 15853 814-773-3185 Larry J. Hatfield Nuturn Corporation 311 Plus Park Blvd. Nashville, TN 37217 615-367-9900 George J. Bohrer H. K. Porter Company, Inc. Thermoid Division 1849 East Sabine Street Huntington, IN 46750 219-356-2410 Paul I. Lee Raybestos-Manhattan, Inc. 75 East Main Street Stratford, CT 06497 203-375-3341 Richard Dean Thiokol Chemical Corporation Friction Division N. Enterprise Avenue Trenton, New Jersey 08604 609-396-6500 C:-~ Mailing Li At Only B. J. Pigg Asbestos Information Asso./NA- Arlington, Virginia James F. Reis Johns-Manville Sales Corporation - Denver, Colorado John H. Marsh Raybestos-Manhattan, Inc - Trumbull, Connecticut FMSI 03554 2.7 NOV FRICTION HATERIALS STANDA..TIDS IiJSTITUTE, INC., E-210 ROUTE !!4, PAIW1US, N.J. 07652 RULLETIH N 0, 6 8 8 July 29, 1980 NATIONAL HORKSHOP ON SUBSTITUTES FOR ASBE8TOS On July 14-1~, 1980 the Consumer Product Safety Commission {CPSC) and the Environmental Protection Agency (EPA) sponsored a national workshop on substitutes for asbestos. I attended the July 14, 1980 session at which a formal presentation uas given on friction materials. This presentation ,.,.as given by 11r. Charles Brunhofer of the Bendix Cornora- tion, and em~hasized the use of semi-metallic type linin~s on automotive disc brakes. This was a fomal session v1ith a prenared delivery and a slide program. In the afternoon there were sessions on various subjects which Here called rrouncl ta'l)le discussions. 11 There l<7as a round table discussion concerning friction products in the afternoon which I attended. I did not participate in sessions on gaskets, packings and other such material. But I did sit in on some proP,rams such as the ones on textiles. I don't believe that there ~Tas any major nel<7 information developed at this v10rkshop. Some speakers used their time to espouse substitutes that they ~11ere promoting. Others took the opportunity to take ~7ipes at the use of asbestos to further their products. Some were state of the art type reports and I would characterize the Eendix presentation as such. Hr. Brunhofer' s talk ~<1as ~Tell documented and illustrated and indicated the considerable Nark that Bendix has done on development of sern.i-metallic materials for disc brakes. He reached back into the history of this development ~.Yhich started prior to the days ~Then asbestos ~ras a target of Ht. Sinai and the environmentalists, The material ~.;ras developed for use in a brake package to perform at higher levels of severity, which later tied in ~rl th reduced sizing of brakes from the vehicle manufacturers' down-sizin~ programs. This came ~Tith a move back tmrards solid rotors from the ventilated rotors t<1hich had been used on most United States passenger cars over the past 10-15 years. An abstract of Hr. Brunhofer's presentation follmJs: Friction materials for automotive brakes are co~plex composites containinP, three Reneral types of ingredient materials; reinforcinp, fibers; modifiers that adjust or maintain friction level, wear rate, and noise properties; and organic resin binders. Historically, the foundation or major constituent of automotive friction materials has been asbestos fiber, so chosen because of thermal stability, friction level, reinforcing properties, availability, and relatively lmi cost. ~lumerous substitutes for asbestos in conventional organic FMSI 03555 materials have been evaluated, including both naturally occurring and synthetic materials. Direct substitution of these alternative materials in conventional formulations has resulted in poor friction levels, friction instability, roughness, BULLETIN NO. 683 -2- July 29, 1980 structural failure, increased noise, mating surface deterioration and/or front-to-rear vehicle brake imbalance. Complete reformulation, not simple substitution, is necessary to meet the numerous, complex performance requirements of consumers, manufacturers, and government standards, such as Fl1VSS 105-75 arid FMVSS 121. In the 1960's, a neo;7 class of friction materials called semimetallics was developed to meet severe braking requirements, primarily in heavy-duty disc brake and extreme duty truck block applications. Semimetallics operate satisfactorily against the ventilated cast-iron rotors in the smaller brakes of downsized cars, as '~>1ell as against the solid rotors founrl in the lighter brakes of neu front wheel drive vehicles. Semimetallics rely on steel fiber and pot.Yder metallur~ techniques for reinforcement, and do not require asbestos. The improved performance of semimetallics compensates for their higher costs due to more expensive ingredients, higher specific ~ravity, and more costly processing requirements. Overall development took more than ten years from introduction to significant customer acceptance. The characteristics of semimetallics make them extremely difficult and costly to process as a drum lining segment. Conse<!uently, an additional neH class of friction materials is under development, specifically for drum lining applications. Additional development effort is necessary, not only to confirm the performance c..'fJ.aracteristics of these ne't'Y substitute fiber formulations, but also to develop ne~r processing techniques. These neH-type friction materials '1'1111 be more costly, hcn~ever, due to the ingredients and ne~~ processing techniques. It will be noted that the talks and discussions at this tY"orkshop ~1111 be typed and made a part of the proceedings of the 10rkshop. Copies of the proceedings t'7ill be available from EPA sometime after the next several weeks. I t-7111 attempt to get copies of the proceedings for distribution at that time. During questions following Mr. Brunhofer's presentation as well as at the round table discussion in the afternoon there Here several comments. Statements were made to the effect that t-Thile semi-metallic type materials have been proven on disc brru~es, drum brakes are a completely different problem. Drum brru~e semi-metallics are difficult process because of weak green strengths and the difficulty in bending the material, as well as the brittleness of the material. Lengthy lead times are involved. Hhere the changes ~~ere "evolutionary" they took from 3-4 years. Th:f.s ~Jould be developing a new semi-metallic in an existing brake package for example. !!r. Brunhofer indicated that where the chanP;e was "revolutionary" this t-rould take 5-1/2-8-1/2 years in development. This could be uhere the vehicles 1~ere being do~rn-sized t-Tith a completely new brake caliper and solid rotor for example. In discussions participants indicated that there trill be full semi-metallics on disc brakes by 1985. There also is develooment under way concerning organic drum brake linings using substitute materials for asbestos. The earliest that such non-asbestos drum brruce materials may be in production ~Ms indicated as 1982-1983. Questions ~Y"ere raised about the replacement market, rqhere a ne:-1 vehicle takes a semi-metallic type linin~. Hhat would be used for replacement? Uould the aftermarket install organics t-7here a full semi-metallic was released as original equipment or Hould they install a like material? It was suggested that in practice the aftermarket may very well use conventional asbestos type materials to replace semi-metallics FMSI 03556 BULLETI"d HO. 688 -3- July 29, 1980 but that it Has recommended that replacement be on a like for like basis. That is, rrhere semi-metallic is used as original equipment it t.ras reconnnended that the replacement also be a semi-metallic type. A participant from Dupont recommended the use of Tevlar as a substitute for asbestos, He suegested that it not be used as a one for one substitute because it is quite expensive. He suggested that perhaps one mir~t use 5% Tevlar, plus other lower cost inorpanic fibers materials to replace the balance of the asbestos. One example of an inor~anic material he indicated t-Tas wollastonite. It was indicated that materials of this type are used on clutch facings on !1ercedes, Audi and Porsche. During the round table discussion !fr. Lee Burgess of \'!heeling Brake Block indicated that where substituting for asbestos may be possible for mass production disc brakes. there is an entirely different field rYhere substitution is not going to be simple. He indicated the use of asbestos type materials on heavy equipment such as 1~anitol'TOC and other large off-high~vay equipment. He particularly mentioned submarines and/or defense equipment. Mr. Burgess indicated that these materials tvere almost custom made to the requirements of the customer. Hhere substitute materials are going to be higher in price the costs to the end consumer t-Till be staggeringly high. Fr. Bureess made several points as regards the fact that straight substitution for asbestos is not as simple as the regulators may assume. I am not sure tvhether the items discussed at the round table discussion ~dll be in the proceedings, but if they are they l'7ill also be distributed when received, It tTas not our intention to distribute copies of the sessions other than those for friction materials. A brief write-up by EPA on asbestos and substitute materials for friction materials is attached. At the round table discussion, personnel from EPA (l'7hich included lfr. Al Colli of the Office of Toxic Substances Control) asked generally the same questions that had been asked the Institute earlier concerning non-asbestos disc brake linings. Those answers had been given to the EPA people. A good deal of the session, and particularly that in the afternoon tTOrk session, ~las repetitive, as EPA Has again asking questions asked earlier. EPD/lmc Enc. Distribution Active Members - List C Delegates & Alternates Regional Members (U.S. Dues) E. r.r, Drislane Executive Director FMSI 03557 SECTlON 5 FRICTION MATERIALS Asbestos is well suited for use in friction materials because of its tlwrmal stability, reinforcing abilities, and relatively high ability to withstand friction. k~bcstoA-containing friction materials are used for brakes for light- and heavy-duty vehicles, aircraft, railcars, various types of heavy equipment and clutch facings. Several manufacturers of friction materials have active research and testing programs to develop asbestos-free materials. Although industry's research and development activities are highly secretive, we know that among the materials proposed in the past as substitutes are: glass fiber, steel wool, mineral wool, carbon fiber, cermets (sintered metals). semimetallic materials, potassium titanate fibers, aramid fibers, vermiculite, and silicon nitrides. Some firms may have ceased research on one or more of these materials but others may still be under consideration. Several manufacturers of friction materials have active research and testing program::; to develop asbestos-free materials. Some of the materials propm:u.d a~ substitutes are: glass fiber, steel wool, mineral wool, carbon fihcr, ccrmcts (sintered metals), semimetallic materials, potassium titanate fibers, arnmld fibers, vermiculite, and silicon nitrides. As fricti.on applications vary, so do the materials most appropriate for each use. Semimetalli.c and cermet materials may all be used in direct asbestos substitute applications, semimetallic in disc brakes (it is projected that in 5 years nearly all original equipment disc brakes in passenger cars and light trucks will use semimetallics) and cermets for aircraft brakes (95 percent of al] for new commercial passenger cars ai ar rcraft use cermets). e currently unavaila 23 ble ,2c4omNmoenrcaisablelyst.o2s3 drum brake linings A cost comparison for various materials proposed as substitutes for ashcstos in friction products is given in Table 7. TABLE 7. COSTS OF MATERIALS PROPOSED AS SUBSTITUTES FOR ASBESTOS IN FRICTION MATERIALS 25 Material Price per pound ($) Asbestos Fibrous glass Mineral wool Potassium titanate fibers Graphite and carbon fibers Wollastonite Cotton linters Aramid fibers 0.05-0.15 0.05-0.75 0.15 1.00-1.25 10.00-12.00 0.15 0.15 6.00-8.00 9 FMSI 03558 HEALTH A.iD ENVIRONMENTAL AFFAIRS cryn1ITTEE "!. ' Committee.- Reorganization This Committee was formed by the Board of Directors in 1971 in response to the Occupational ~afety and Health Act of 1970. The -.Committee l-Tas originally formed to keep F!!SI advised of 1SHA activity on asbestos and thus thru 1979 .o1as called the "Asbestos Study Committee. 11 In 1979 the Board requested that the Committee expand its scope to monitor asbestos legislation activity in such areas a8 environmental protection and workers compensation. As a result, the ..c. '" Committee. developed a charter and a name change to the Y:ealth and Environmental Affairs Committee to more descriptively reflect this '. expanding role ~-~~thin the Institute. The Committee has also been broadened to be more repTesentative of the membership. Representatives now on the Committee are: "'< , . ; . Don Lee - .Iutum .,.. N"orld Bestos Division George Bohrer - H.K. Porter Co, - Therrnoid Division ~ichard Dean - Thiokol Corporation - Friction Division ~ , G. lUcholson - Abex Corporation .' ., ' D.. E. Stone - Bendix Corporation H; H Wagner - Carlisle Corporation ' , - h H. T-Ieaver - -R. aybestos rtanhattan EPA Action , ,:on October- 17, 19 79, the Environmental Protection Agency and Consumer Product Safety Commission published an advance notice of _,i; .proposed :rulemaking. The notice was a request for information .,, regarding the use of asbestos in commercial products, an estimate of a persons risk and an estimate as to how many products could be produced asbestos free. '. n,,- The Institute replied to EPA's Advance Notice of Proposed Rulemaking on asbestos products. The comments took exception to the Agency's selection of friction materials for control based on allegations of heavy population exposure. - The EPA has indicated friction materials as being one of the prime products'to be regulated. On !Tovember 16, 1979, the EPA requested specific "Informational needs for friction products containing asbestos a (Eleven Questions for Friction lfaterials Manufacturers). The original list of questions was reviewed and found to be objectionable to the F!fSI. On January 3, 1980 a meetinp, "'as held with the EPA and major changes t~ere agreed upon t.rhich made the questionsa little more palatable. FMSI 03559 In Hay 1980, the Inetitute responded to EPA on their questions concerning non-asbestos disc ~rake linings for passenger cars and light trucks. _ This included state-of-tlie-art information on types, advanta~es and disadvantages, costs and the lead times involved in conversion. It is very clear that the EPA is no~ng toward a b~n on asbestos in at least disc brakes and is a~gressively pushing that objective . ~The EPA is also pushing for a ~reater awareness of the hazards of asbestos particularly relating. to fri-ction .products. It has f6rmulated ap,reements between OSHA and contractors; Public Iiedia Center, San Francisco, California, for the development of educational and informational ~aterials for vocational and technical students being trained in brake -~intenance, their teachers and mechanics. _!' The Institute worked ~dth the Asbestos Information Association ,-,ad !hoc Co~ttee for Friction I1aterials. in the preparation and circulatin~ of questionnaries on friction materials,fndustry labelling practices and training pro~rams relating to asbestos. I~ .. . : ... f "' - - - '""- ,. : ~). ... rl , :..:: f -l _ ~ ~ ~ : ::: --As part of this-Committee 1 st.rork,:--.t~e haveupdated a page in the Institute Catalogs on "Recommended Procedures for Reducing Ashestos Dust.DurinB Brake Servicing~'' Thus; ,are: in a ~ood position to meet_any request for training literature . _ s On Hay 19, 1980 the EPA published re~ulations covering its "Hazardous Haste ~1anagefilent System" for the Olmers and operators of hazardous ~\l'aste treatment, storage and disposal facilities. These regulations are included as part of the regulations under Resource Conservation and Recovery Act (RCRA) whfch was originally inacted in 1976. .- ;The regulations are to be effective--on ~~ovember-:19, 1980. - ,, , Asbestos, is listed as a regulated material but' therp :ts an --.-. exception. Generators of 1'liJO kilograms per month .. or 2200 lbs . Ldo not fall tgithin the system. Those generators-'of nsbes!:o"> m.."'!.terial waste in excess of this limit ~-rill be required to r;enerate amanifest and assure that .the ~:Waste disposal site has approval for the receipt of waste ~ontainin~ asbestos. Asbestos Compensation Lecislative activity to develop a federal fund for. the payment of as.bestos related diseases is still occurring. The Fen"Tick Bill, : which was the first effort, is now considered dead. Senator Hart has introduced legislation but it is still to early to determine if it has support. -2- FMSI 03560 os:w. On January ~. 1980, OSJA issued its lon~ aHaited Generic Cancer Policy. It ~-Tas suspected that OSB'.A ~ould at tertpt to place asbestos into the list of cancer agents and Nhile still possible is becoming less likely. Latest input 1ould indicate the OSHA direction to be of maintainin~ a single regulation on asbestos Hith the eventual lm11ering of the allm-Table level from 2.0 to somewhere in ~he .2 to .5 fi~er range. This is not likely to occur until after the elections. tn April 1980, a joint iiiOSH-OSHA Hark Group recommended to OSHA a reduction in the maximum ~1ork place exposure level for asbestos from 2 fibers/cc to 0.1 fibers/cc. On aay 23, 1980 OSHA issued its final reBulations on access to employee exposure -and medical records. The regulation t11hich goes into effect August 21, 1980 provides that employee exposure records required under the OSHA asbestos standard be provided to the employees, designated representatives (union included) and the Department of Labor upon request. This request includes air sampling results, and medical records and requires the employers to retain these records for the duration of employment plus thirty (30) years. Respectfully submitted, J. T.T. Armstrong Chairnuut -3- FMSI 03561 TELEPHONE 12011 84110440 FRICTION MATERIALS STANDARDS BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INSTITUTE, INC. MJ.\R 25 1981 !:ls. Joni Repasch Document Control Officer Office of Pesticides and Toxic Substances {TS-793) Environmental Protection Agency Room E-447 401 M Street, S.D. Washington, DC 20460 3ubject: Doc\UIIent Control aumber OPTS 84004 Environmental Protection Agency Proposal on Asbestos; Reporting and Recordkeeptng Requirements Dear Hs Repasch: The Friction :laterials Standards Institute is a trade association which includes most of the brake lining and clutch facing manufacturers in the United States. He have other 11embers t~orldwide. As friction materials manufacturers, most of our :!embers use asbestos as a major constitutent in their products. Our comments on these proposals represent the viewpoints of most of our asbestos-using ~Iembers. General Comments Hhile we will address speci.fic sections of the proposals on reporting and recordkeeping later in this letter, we question the timing and necessity of the proposed requirements. We are familiar with Section 8 of the Toxic Substances Control Act (Public Law 94-469). He understand that this section can require our llembers to maintain records and submit reports in great detail, where that information is necessary to reP,ulate substances that may present an unreasonable ~isk of injury to health or the environment .The friction materials industry agrees that there are health hazards from asbestos in the workplace. These have been addressed by the Occupational Safety and Health Administration (OSHA) and we anticipate further regulation in that area. We do not believe it has been shown there is an unreasonable risk of injury to health or the environment from the sale or use of our products because of the following facts: 1. Asbestos fibers are locked-in to the product in its finished form. 2. There is less than 1% asbestos in the wear debris from used friction materials. 3. Small exposure levels in the general environment have not been established as presenting an unreasonable risk of injury to health and the environment. FMSI 03562 Hs. Joni Repasch Environmental Protection Agency -2- l~e refer you to the enclosed paper '!Asbestos & Jealth in the FricUun Material Industry," prepared by the Asbestos International Association in London, England. It summarizes what is known concerning asbestos exposure in the friction material industry, as well as what is known on exposure to friction material wear debris in the general environment. This position paper supports our contention that while asbestos does present a risk to those occupationally exposed, this exposure is now controlled, and that environmental exposure does not present an unreasonable risk--if it presents a risk at all--to the Beneral public. The Institute sug~ests that before applying the reporting and recordkeeping requirements of Section 8 of the Act, that EPA demonstrate that asbestoscontaining friction materials may in fact present an unreasonable risk. He recommend that action of the type proposed by this notice be deferred until reasonable people can demonstrate the need for the costly and detailed records that in may cases go beyond the needs of the Agency. This proposed regulation would place one more burden on our 11embers, and particularly the United States manufacturers supplyint brake linings, clutch facings and other friction articles to its already depressed automotive, construction, and industrial customers as well as to the energy related industry. The proposed requirements would not only be burdensome to our Members, but in most cases it is difficult to see how the information can be put to use by the EPA. It calls for a complete documentary on asbestos beyond the needs for purposeful regulation, if indeed that regulation is necessary. Our industry stands ready to help with information-gathering even where the need has not been adequately shown, if the EPA can sharply reduce the amount of information, the old information, information which is mostly confidential, and extraneous information apparently being requested for support of parties other than the Office of Toxic Substances. In fact we suggest that much of the information is available from other Government agencies and it may be of value to have Interdepartmental exchanges between the Government agencies concerned with the asbestos issue. Section 763.65 - Hho must report In Paragraph (f) the proposals exempt "small manufacturers, processors, or importers as defined in Section 763.65(m)." We agree with the exemption of small manufacturers or processors who employ no more than 10 full-time employees. There seems something inconsistent with the maintaining of jobs in the United States by the exempting of importers, who may be importing from factories with 1,000 employees outside of the United States, where a United States factory with more than 10 employees is not exempt. One "small importer" could be responsible for more friction products, or other products for that matter, in the United States market than a mediumsize United States manufacturer, but the importer would be exempt where the United States manufacturer would not. This exemption would be more equitable if ba~ed on dollar value, tonnage, pieces or other like index. FMSI 03563 Ifs. Joni Repasch Environmental Protection Agency -s- Section 763,70(a) -Customer Lists Several ilembers indicate that they will invoke claims of confidentiality on distribution of these lists outside their organizations, t1e question the need for telephone number and technical contact for each customer. !n many cases this information is not available. In other cases, this can create an adversary relationship between a customer and a manufacturer. Claims of confidentiality for this type informatica are valid, as almost all of our 1Iembers are interested in lists of his competitor's customers. l.Ye would suggest the EPA reconsider the confidentiality of this type information. He further believe the detail requested should not be required if provision of these lists is actually written into the final rules. Section 763.71 - Schedule for Reporting The schedule for reporting by our llembers, who are all Primary Processors and Bulk Asbestos Importers, and in many cases are Secondary Processors, is unduly harsh. Rather than the 60 days required in sub-sections (a) and (c), and the 30 days required in sub-section (b), we recommend a standard 90 days schedule. Our !1embers have facilities at more than one location, and records are in many cases at a location other than the Factory, A 90 day requirement is more realistic ~~hen one considers the considerable detail asked by this proposal. Further, many of our Hembers do not have ready access to in-house Professionals to review and approve reports before submission, Our :!embers are entitled to have their reports reviewed by Outside Safety, Health and EPA Consultants, Legal Counsel, and other Professionals as to its adequacy and to assure that our ~lembers are not harmed by their reporting. Form B(2) - Quantity of Bulk Asbestos Imported. The comments on Form B(2) apply to Form B(3) - Quantity of Bulk Asbestos Jbtained. Our major concern is with Form B(2), as almost all our Uembers use Canadian chrysotile. All 1:1embers of the Institute import asbestos, primarily from Canada. The EPA form asks for quantities of asbestos, by type, and chrysotile by grade. The form lists quantities for 10 years, from 1971 through 1980. In most cases, the older the records the more difficult the search. Some :iembers no longer have data from which to develop quantities before 1976. As the EPA is asking for information on asbestos emissions at the present time, we question the need for 10 years of data, and particularly that of more than two or three years ago. If the EPA were to have information on current consumption that should give sufficient information for estimating current exposures without the extra work involved in going back over ten years. ~e suggest, if the data is considered actually of value, that the EPA limit the request to that for 1930. The notice asks for details on types of asbestos and grades of chrysotile. We understand the EPA is searching for information on other types of asbestos. but question the need for grades of chrysotile. This involves considerable searching of records on the part of our }iembers, if in fact the information exists. We do not believe that anyone to this time has alleged or inferred that the hazards of asbestos are dependent on the grade of chrysotile. t~e FMSI 03564 L'ls. Joni Repasch Environmental Protection Agency -4- suggest that the form be revised to ask only on quantities of chrysotile, and that reference to grades be removed. Form C - Primary Processor Production Our comments on Form C apply in most cases to Form D - Secondary Processor Production. i.lany of our Hembers are Secondary Processors in attaching linings to steel shoes or where they perform other assembly operations. We again state that the older the information is, the more difficult it is to develop. He suggest that production fisures for the last year only, 1980, be used. These are available. The manufacturer's efforts in compliance with the requirements of this form would be reduced in almost the proportion that the years are removed. Again, we believe the EPA is searching for current exposure information, and that while history is interesting, the requirement to gather it is not necessary to the task. Still further, in the instructions for this form, under "End Product Shipped," the form calls for information listing the trade name under which the product is marketed, and calls for a listing of all ''private brands" urider which the product is sold, He fail to see where listing of trade names or "private brands" is pertinent to developing information on emissions or exposures to asbestos. This information is much more difficult to develop for posting to forms such as these. It would multiply the combinations ~Jhich l<lould have to be listed, when the only relevant information is a product.listing such as we suggest below: Drum Brake Lining (light-medium vehicle), etc. On Page 8225 of the Federal Register notice, "Typical Terms for Products Nade From Bulk Asbestos 11 are listed. Ten different terms are listed under Friction Haterials. liost of thos~ are not relevant to exposures in the general environment. He suggest reducing the 10 terms to 7 as follows: Drum Brake Linings (light-medium vehicle) Disc Brake Pads (light-medium vehicle) Brake Blocks (heavy vehicle) Disc Brake Pads (heavy-vehicle) Clutch Facings (all applications) Automatic Transmission Friction Components (automotive)' Friction llaterials (industrial and commercial) There are no woven disc or drum brake linings for light vehicle use. For other applications, liTe question ~.;rhether information on molded verus woven is pertinent to the question of exposure to asbestos in the r,en~ral environment 4 \ve feel there is but limited usage of asbestos-containing friction materials in consumer products. Still further, all units of measure should be "Pieces.a He question particularly whether information on quantities sold under "Private Labels" tvill be available even in recent years, without painstaking one-by-one analysis of individual invoices. In addition, there may be claims of confidentiality in this area. FMSI 03565 Hs . J oni Repasch Environmental Protection Agency -5- Forni H - Summary of Current Horker Exposure This particular section of the reporting form would cause an undue burden for largefacilities which have several hundred workers and a diversity of production operations. Records on worker eXposure levels are not maintained in a manner which would permit easy retrieval of the data requested. To simplify this section, it is recommended that Column 2 - Total Person Hours Per Year at TWA, and Column 3 - Uumber of Heasurements Used, be eliminated as this data serves no useful purpose and is extremely time intensive in its preparation. Form K - Pollution Control Equipment We question the need for the l1onth and Year under the ''l-fuen Installed" column. Some installations 30 in over a long period--in some cases as long as 12 months from delivery to final usage. Do you wish the date ordered? The date delivered? The date installed? The date first used? The date put into use on a full-time basis? The year of installation should be sufficient. We believe a definition should be presented so as to clarify what is wanted or needed, Where there is more than one piece of pollution control equipment, even where there are two, three or more installed, the form calls for a separate listing. We suggest that the form be redesigned to permit listine of any quantity of a particular piece of equipment where that equipment is identical to another piece. The quantities could be listed per piece of equipment, with a total column for all equipment of that same type. The purpose of our recommendation is to reduce the paper work burden. * * :': * * We question the need for this proposed reporting from manufacturers of friction materials based bn the reasons stated under our "General Comments." We suggest a deferral of the proposals on reporting and recordkeeping until reasonable people can demonstrate the need. We suggest that if the reporting and recordkeeping requirements in this proposal will not be deferred that the proposal be revised to simplify and reduce the paper worlc burden on our industry. This can be done in~ three ways: 1. Cancel the study of history--ask for information for 1980 only. 2. Reduce the detail--such as grades of chrysotile, month and year of insta; lation, etc. FMSI 03566 ~Is. Joni ::lepasch Environmental Protection Agency -6- 3. Eliminate or re-write the proposal on information requests where confidentiality will likely be claimed Respectfully submitted, FRICTION HATERIALS STANDARDS INSTITUTE E~JD I ere I!:nc~ Asbestos & Health in .the Friction llaterial Industry .:. H. Dris lane Executive Director FMSI 03567 ,\SBESTOS lNTERNATIONAL ASSOCIATION (Limitcd by Guarantee) fi8 GLOUCESTER PLACE, LOI\"DOI\" W!I-I 3HL MEMORANDUM TO: t-lembc r Associ at ions FROM: Director General AT A/7 /3/l'ROD 12 February 1981 "Asbestos & Health in the Friction Hnterial In_iustry" The attached position paper on Asbestos & Heillth in the Friction Material Industry is forwarded for information. It has been authorised by the Executive Committee w-ho recormnend that it should be used as a background reference p?..per to help members deal with questions in asbestos and health which may arise. FMSI 03568 AIA/7/3/PROD ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY The Problem Exposure to asb'estos dust is recognised as a potential occupational hazard. Among work people exposed to high concentrations of respirable asbestos dust, (such as is known to have occurred before present day dust control measures and work procedures were introduced} cases of cancer and asbestosis have been reported throughout the world. 1 2 3 The difficulty of reliably identifying the occupational history of those whose health has been affected ,many years after has resulted in any contact with asbestos being regarded with caution and all materials containing asbestos being attacked indiscriminately. Since friction material is widely recognised as one of the products for which asbestos is an important ingredient, it has attracted such attention. Indeed, the asbestos industry, in reminding everyone of the vital role played by asbestos in brake linings, has stimulated such attention. Nevertheless the occupational health record of the asbestos friction material industry is good and only a few cases of asbestos-related disease are on record. However, the widespread use of friction mater'f:al in .all types of vehicles has raised the quest:ion .of potential pollution of t;.he environment with 4n assumed consequent danger to the health of the general public. The friction material industry, therefore, has two basic problems. The first, the occupati~nal health problem, has in many areas been reSolved. However. the industry must continue to ensure that those employed in the manufacture of these materials are not exposed to dust levels'which are harmful. An extension of this problem is the need to ensure that workers employed in the subsequent use of friction materials, either in the fitting of the products or the maintenance of vehicles, are not exposed to harmful dust levels. (This page~retyped at FMSI because of weakness of original copy) FMSI 03569 The other problem !'or the industry, that of possible environmental pollution, is more difficult to resolve, based as it is on emotional anxieties (which are in no vay 3ustified by the evidence). A climate of concern for the effect on the environment of expandina towns and industries has led to .the motor vehicle being ineluCled as e sisn;i!'ioant factor in this pollution. .. This fact together witb 'the publicity pven to asbestos ana its ai1classification as a careinopn,4 ~ve combined to lead' people to question the use of asbestos-based components in motor vehicles. The automotive induetr,y is also under attack for a 111ltlber of other reasons, ana(e.g. pollution, ."-a~te (>.! ruouroes congestion) and would gladly be without the asbestos problem ~lthougb it must accept that for some years, current models of motor cars will need aebestos-cQntaining material.~or replacements. The ~iction material industr,v itself must therefore dispel anxieties about aebestos-containing producte in motor vehicles by ensuring that the existing reassuring evidence ia"made manifest and is properly understood. I Tackling the Problem In order t ; tac~~e the problem moat eff~tivaly, it is important that the origins, investigations and remedial measurea i~olvea should be well understc>od. This is especially neceasar.Y siftce the existence of. the Motion material environmental problem is to a lar,ge extent based on contusing >two ver:r different phenome~r' on the one' ~d th~ occUpational health .- experience and Clust exposure &ata rel~tecftO manufacture (and the subsequent fi,~ aaa ae:rviciDg ~:Perations ,aometilaee called "para-occupational") seneral. and en the other hand an as-d eJiission of a.iDtiler dus:t. into the 'or. . . envirolllllent as a result \ o. f the. daiq..WHX'!N down ' br.ake liniJl8S -: . and clutch facings. .An example of tb1e ooJltUai~ ~'be seen in -the evidence given to the tilt Aabeetoa Adviao%7 .Coaaittee, vhere claims that the speral' public ue at risk .are suppe)rted eolel,.J by referenee io a survey of motor vehicle maintenance workere. 5 It is therefore important to recapitulate the 1'.acte ~lat!Dg to health hl.zarda lll'l4 the coXIditione which are bel1eve4 t~ give rise to them. FMSI 03570 Tnese facts will be reviewed under three headings, the first two covt!dug the Occupational areas of Hantlfacturing, and Servicing, and the third heading covering that of the General Environment. ; -,. ' Manufacture of Friction 'Haterials There is ample evidence to suggest that, in the manufacture of friction materials, the concentration of asbestos dust compares favourably with that found in most other modern asbestos operations. \-1ithin the last ten years efforts to observe a 2 f/ml* standard have led to further improvements in dust control and there are now many operations where levels well below this maximum allo~able concentrat~on are achieved6 Very few cases of asbestos-related disease arising from friction materials manufacture have been reported. In evidence presented to the UK Advisory Committee, 5 Ferodo Limited, who have been using asbestos in brake and clutch linings since 1910, reported 8 cases of mesothelioma and 5 cases of asbestosis. The mesothelioma cases had all been exposed in the manufacture of railway brake blocks between 1928 and 1933 or during the war years up to 1943, to crocidolite as well as to the chrysotile asbestos more generally used throughout the plant. The asbestosis cases were all involved in mixing processes where masks should have been worn. In the same _volume of evidence, a report from the two Cape Industries' factories manufacturing both textiles and friction material (one since 1901 and the other since 1923) cites 9 cases of asbestosis and no case of mesothelioma. ~erodo report that "many millions of man hours have been worked on finishing operations of asbe~tos-based materials; th~ugh the dust concentratiop~ associated with these were at one time very high, there * f/ml (asbestos) fibres .per millitre FMSI 03571 ha,s not been a sin.:;le dia.:;nosis. of asbentoRis as a result of this expos,lre11 In more recent years (1968 - 1976) ho'l<'ever, average concentrations were well below 2 f/rti! J'ollovine continuous improvements in dust extraction.methods .tm investiga.tion in 1975 by !!eidemanns, Kuhnen, Schuh and Proc'!"1RZka9 into dust hazards which might be associated with tbe n~mufacture and nse of as~estos-conta~n.ing friction ::~ater:tals (up'l.ated in the ~e>sea.rch ~e,?o::'t of the Ge:::-:-,1::tn :Bern.fseenossenschaften7 quotes concentrAtions of r1icro-dust in the ra~e of 0.09 to o. 20 m:/m3 dnri:ls erinding, o.rilli~e:. ::av1i.!2g1 t11.rnin~ a.nd milling operations (the current 'fiir:'* value is 0.10 ~~'n3 or 2 f/~1: 8on this basis the current ran&~ is 1.8 r/ml to 4 f/~1), on averase just belo"' or just above 0. 15 ms/m3 or 3 f/ml. Such op~rations, unless subject to dust control, will e~it duPt containing nsbcst.os. A number of surveys of sttch operations heve bee-n carried out in Ge:-:r:~ny 79, U!{ 10, 11 12 ' l'SA 13, 14 15 16 17 a=-:1 elsel:-~>ere 3,5,B and H. is clear tl:.8t, under some conrJ5 tions of ..,rorkin~ and where su~h operations e.~e carried o~t continuously, dust concentration!:! ab~ve 2 f/'!!Jl (or the TlUC "Jt of 0.10 mdm") can be reached. There is some evidence of effects on health :>::::mg "'"'n eJ:l5a.eed for a lone poe-rlod on su~h work. J.:edical and epide.-.uolo~lc:!l .:nve-!'t.i.Lc:tior..s b~ ?rofessor Voitowitz, Valentin anC. ot!Jers 7 on ..,rc.rkers who l:Ad been cont5nuou::;ly exposed fo::: at least 10 and up to 25 years to asbestos r.~1~t. SP~::r.sts a similar risk level for men employee: on fi:n.i.s~1inc operations (:";:':L.;y C"jndb!z An<' C::r.'l15nz) in the autmolotive in~~.ustr;;, to the r5sl:: '"'''c-:.. o:~ , .."r':.;rt". 5.n the r'r-nllfactu:::inc industry 7,9. + :!::t ,.r-~ noted th;;~t the automotiv:e industry e;rou.p st~C.ied had had lon::: c:::)<:Jrf~ from a very early ase 9 A T.,u:p of men c;r:tyins out br2>ke :' '::':'?.. = Tecl'>.nic-nl Control Limit -1 0-J.t of 9~ wor}:era (including 43 vomsn) in menuf&ct:zrir.g, there \\'ere 3 probable cases of .asbes'tosis.and 11 11possible". Among- 63 men eJD!:loycd onin finishin-<>: operations bra1re lining;: in the automotive ind1.1St.;r;;t, 2 prob;;tble as'hGstosls cases were found and 10 "possible". {"Possible~' :::eana shovring effects on the iung \>.-hic!l mir;ht be fibrogenic.) FMSI 03572 - 5- malntenanee services with expom1re primarily during the cleaning and brushing o~t of brake arum dust gave little evidence or inhalation effects in spite of long years of exposure. Professor Selikoff'~ investigations 19 quoted indications of abnormalities in 32 out of 87 motor vehicle mechanics- (6 out of 29 with five or more years intermittent exposure showed signs on X-ray of changes consistent with asbestosis). Another report of the same investieation quoted 24% of 93 brake service mechanics showing chest abno~~lities not necessarily asbestos-related and it is emphasised tr~t there ~ere no confirmed cases of asbestos-related d_isease. Dust levels quoted in connection with this investigation (in USA) 20, 21 refer to-mean concentrations tor blow-out of brake \Clrw:ls 1 grinding of used linings and bevelling of new linings of 1_5.9, 3.8, and 37.3 r/ml respe-ctively- much higher than a"cy' found by a:ey - oiher researchers. No information is provided as to the duration of these sa~les - they are frequently referred_ to as peak concentrations or the mean of a number of such measurements. I~ is also clear that in the caae of blowing out of brak~ d1~s, no asbestos fibres were visible by optical microscopy; some chrysotile ~~s identified by X-ray diffraction. Fibres identified by electron microscopy were all below the minimum size specified in the definition of asbestos fibre (i.e. 5 ~in length)8 It should be noted that tbe methods of sampling and the.~riteria for measurement of occupational environments did not conform to the methods used by governmental agencies and by otper i~vestigators in Germany and UK. For con:parison1 concentrations of asbestos dust during brake maintenance =-cp~=ted by Ricki-s-h and Knight 10 s. howed an ave.rage. daily exposure of 0.68 r/ml (range 0.21 to 1.12) d~ing bJ;ak~ servic.~ of 11 cars. During truck brake service, the average was 1~ 75 f/ml, with peak; during cleaning. of the brake arUm, of 7.09 r/ml.. The German investigation in 1~75 9 (now incorporated in the Berufsgenossanschaften report 7) recorded high concentrations* 'in the brake service department 8lll1 * o. 03 to o. 79 JIJ8/m"!; and with backgiound workshop atmosphere or o. 03 to o. 05 !'Jg/o.'. FMSI 03573 ...-}1(,t'e r.<lch5n;n.;; HE'S done without dust r~xtract5.on. Al-l:Lm.lt;h hi.gh concentrat:ions of ~ ...ere observec'l. durine blo~.ins; out, no c1-,r-sotilEa!=11estos C0Uld be oetected by infra-red Spectrol'lf'try, ann the :ind.iV5.dual fibres w~ich could be C!.Etected optically could not he 5flent:lfied as asbestos. 1),,:;:-'nc t~w application of nrum bra1~es, cii!>c :p2C:.e or c!.utch facint;s, f';,ell q;.mr.t i.t; eo of tl,e SLll:'f~ce of the f:t-ict5 on r~'lto:?r' al Are "'"'~ E.\:ej. ~1~)se rn.ateri~ls contr-lin between 3Q;~ 'to 6~: of AE'beEtos 1 Rnd it has been as~u.~ed by sone that th~reby laree llu<mtit5.es of d.:=:ncero.lf? asbestos dust Fn'e bei.ng regularly di:sch;;-:r.t,"Cd into the atr.losphere. 1"nis, i.t is F.\rg'J.ed, creares a f1a.nzerous atmos-phf)re al~i.n to that which l:es prN1uced asl-estosrehted di !":'CP.Se (especially cancer) in soMe "rorkin~ envi:I'\,n"1ents. Since t.he est1!'1Rted oonsumntion of asbestos in friction !'!aterial is annually ove!' 'ln_, c"'"-''o ..~. ons 22 -for .,;.:..,trope ana over c.,::.o , oo.o t ons :.n th e -t's A tl--e P.J!:O'U-'1.t s i:-1'-'C'lve-d ~-ro B'.'.bst:mti.P.l. An estir~ate carried out 1:-y the F.end.ix .. Corpc:!'at i 0::1 "-'i tJ:: the sn:pport of the US Environmental Prc>tection Ae;ency (.:u>A) calculated t!:nt tbe eno1.mt of fr.i ction tllateriel v.:::-:c.. t;!\.'<'~.y in brskes end r.lu-!:ches an.~"r;,lly i:1 tl~e USA 5s B:!'OU::lcl 60,000 1-:1) tons, (':If "'hich }7,000 tol!S ~s th'?. ::osh!stos content i.e. 6o;'. !n Thrope the content o! brake ,.~:1n2:8 1 s narer -x,vr--cj.') Ro\~>ver i t is clear fro:!! !'!'=:<H;uret'l~nts cede at a n>nbe:!' of locations \>lith heavy road t:raffic that ins~-Dlificant quantities 0~ 'es-::-i.,~.<~"hle af.'bc>stos dnr;t Rre s::- e!!l.ittE'd. 2 ~, 24 'l!.;- '~-- ~ t 'c::-:orL<llt frccj:t)r iri d t~.pellin:;;' anxiet.y is that the asbestos ~0nr.o:-nt of t!-~e w~ar :p:!:oducts of: fricti.on material is not emittec\ .into the ahospbere :in t~e for." of .res:pire>ble asbostos dust. I:1!eed 1 a number of rm;bient <lir invedigations ino_;tcate that it, is difficult nowa~daya to find P.sceatos fib:r-es :in any signiflcant quantity, regardless of size, in the ctnospherc:- even in the vicinity of asbestos 1!18nufacturi.ng plants. 24 ofJ-:ef!SU.t"ements the ambient air even in heavy traffic conditions do not (,ho: <my sisni.f5.cant level of asbestos. Again, in underground railway Pyde!:!s, "'here fierce a!):plication of esbestos-.containing brak~s in the FMSI 03574 - 1- confined tunnel cnvl.ronment miB11t be thouc;ht to crcate the '1-.'0rst cond.l tiow'l, no Gicnificant build-up of asbestos dust h::!s b'"en detccted.24,:::'5, 26 ~~c e~~J~nation is simple and is confirmed by a n~1ber of caroful se:ie.ntifl.c investigations. The heat ecnerated in the process of applying the brakes or the clutch (the renson in fact why asbestos 'is such a vital conponent) is euffi(lient to destroy the origJrial'structure of the asb0stos fibre. Froma temperat~e of 450C the chrysotile structure begins to c01:vert to a non-crystalline amorphous phase 1 leading' to a lcsss of st?..bility of the fibre structure. The mechan:lcal strain applied during the bn~~:ing p1~ocess has a pulverising end grinding effect 1 lc;:.ding to disintcc-ration of the fibre structure. The Gerr..n.!1 report 1 calls it "a kind of micro-milling so that the dust no longer contains any fibr.::s". From a temperature of 650C a new crystalline structure develops called Forsterite, which will be fully developed at temperatures of above 700C. Gen'?rally, forsterite cannot be trc.ced in bra\::e linins dusts. This mea11S '' .. . 0 . .. . . . that tGlperatures beyond 650 C either do not occur or are only very short- lived. The d'ecrease of the chcysotile content 1 ho'l-ever, indicates that 0 '.,. . ten::poratures beyond 450 C are reached because the a\norphous phase of the ' cln-ysot.ile can.1'l.ot be traced analytically (by eithe,;r iro..fra red-spectrom&tric or Y.-Tay dirfratcnatic methods). Exam1nation o~ the residue of wen~ products in brake d~~~~ confirm~ that thr:. c!Sbestos content is 11<::udJ ly less than 1?6 of the "!-e~iJue. 27 It has leen !''JGt;ested -l;h;, t tl1e dust escaping lnto a<:lui.cnt air r~y cor1ta5n a higher .!l'0Iwrtic:r. 0f the fine respirable ::.sbesto~:: . . than dust left ~ in the ,.i runs . but c<u'e:ful ~tudies designed to entrap 'uh'!.~..~scaping portion of the wear . " p:-oJtJct show that this is nut so. Various _imrestigations into the ammmt o:f . acbestos remaining .i,, i;he residues from friction proces~es have been car:r.ied '' ' out which indic-ate how minute i!; the fraction of asbestos rele'ased in the ~pplication of friction. 1rhe. latest report, 7 from Germany, confirms. th~t te~hnicttl investigations in receny years have rE\:p~citedly shown that the dust generated by friction or the linings in usP - as opposed to dust created FMSI 03575 - a- durir.g the finishing and handling of new linin&a - as a rule contains only traces of rr~e chrysotile fibre, i.e. of the order of 1%. The working party ~s unable to provide clearer infra-red spectrographical evidence of chrysotile. Under phase-contrast and eloct:ron-nierosoopic scrutiny, t~e .dust contaL~ed just a few isolated fibres Which could not cvr-:n be definitely identified as asbestos. This is consistent with the imestigation by tr'.t{ goverlll!lent and iildustry investigations in 1969 1027 ;.:1ich reported that the f1:ee asbestos content of wear products of drum brake linjngs rarely exceeded 1%. (In diso brakes the content ~~s oven lower.) '.i."'ne Bendix ilwe:stigations -:for Jl!OSH in USA in 19H gave a range from 1.65~~ to 0.00~~- only three tests were above 1~6 and the overall avl:!rage '~as 0.2xf. This study also dete1:mined t~t only 3. 27~ of the asbesto~ , content of all the wear products over the whole ranu~ of US motor vehicles became airborne- estimated at 5060 lbs. annuelly. 13 Tne Ford ~otor Company carried out a study 28 based on dynamometer teats which showed that during brake usage less than 0.027[. of the lining wear was released in the form of ~rae asbestos. Ybe study estimated that concentrations of asbestos fibre in the urban atmosphE~re in the US due to br~~e u3age was less than 0.07 x 10-9 &/m3 (.07 nanograms) (less than one millionth of the 2 f/ml occupational control standard). l7e:;.su.ren.ents carried out at points of heavy traffic concentrations in the UK by the P.sbe_stosis Research Co"l.~cil, under the observation of the TUC G:entenary Inst..itute of Occupatiorial Health, also found 110 greater, concentration. Even in the underground railway system, this survey found the asbestos content to be of the order 10-S g/m; to 10-7 gfm;. (10 ngs- to 100 ngs/m3) 24 Pinally, some observations made within the last three years by two eminent. occupational health experts, on occupational risks and risks to the general . JiUblic, are worth quoting. FMSI 03576 J)r. John Gilson, 29 rcvie\~jncr asbestos as an ocbupat iphal hA7.-rd ;_n a '" U'nr~ral eroup in \-Thich he includes frictlon materials J says 11Despite the tJ'H)'Is<:ric1s of proth,cts containi"ng asbeRtos, evtnen~Je of ill effects from 1..1'-~ir uAe' is very S!-lnll". Ee e.dds Lhc qual5f1cetion that occupations ~.!1.volv:ing brake f-lhoe r:t'iintenance have been sho"n to be at. :tisk in th~ past. "!.lt.!~ou,1h Most of the asbestos in brake shoes is c,.:;t;;raded, the dust in the l1r:::Le drll;'ls st5.11 cont;.Jins a s~tell rsrc~nt.ace of asbestos". "The r.:agni t.ude of the l'.~s}: (of a~lestoso!.s end mesothelio:ne in t~G~e .,,.n:!.'1dP-& J:et,.,Jlarly in t.~~.-:_ s e~!ployc:;E>nt) :is r,ot l:no'm but is Hkely t::> ce s:::~ll." Profesoor :~.o}_~,nis, 22 '.n his rfeport on :public h<:filthrjs}:s, co1clunes "There is tv_:.r\:-:::ce c.f no e>:c~r.,s :ci sk of neflot!;elio~-9 fro:n asbestos pollution which :t~s exi.s'.:-ed L1 t1:e UP~ :j!bourhood of chrysotile l'!r.td ?.t!osi te rr.ines. There is . r.c .c- vi c~E-ilCf' of. a !.'i sk to the c;er:ral p\lbli c At prE-sf:r..t". Later he +'e:peats -~1 -~ s v~.e..r in hj c ::_:;e!':~:::-c>.l ~0nclusjon '":!'lere :is no estf'lblil"hed evidence t}"ta~. ~::...,.:e t:h~ -nt e:...-l1osu:re, f!.s prevalent in "v'estern :'tlro:pe<m CC',,ntr:i.es, -~t tt:1s'm?r,::mt Ch"C"l~~(; r,:nch a def':.n~te risk: ho\IE>ver, there ex:ist to(! many ,l~<;o:;-:::-t~:'l.t~ea to r:~n~' sn.,h" .ri~'k-, t!-:ueh if tl;e 1:ie': \o.<!.s F:u'btd.Rritial it is 1.5.~cc:i_~ i t -..:o,,ll; ),~. T l::P~n i.lt.ectecl l: !lOrr" .,,c:::.=-1 ;~r~c"t~.rr. !.,.:_,.,::-)P!.s. Ec-w.:-ve:::- 1 e:>..--pr::ieL::> h"~ shm:n thP.t t!:ds >.sa .very '!.' ; .:t ;, :Jc-2.U: )'' ?:: and that it can b~ effect5ve>ly controlled by well tested eluipner.v and. work procedures. C:-t::-.n'.~"'rds bese1. o:s e;~-t;;nsive E;x;>er-tence in t!:e indm:try have l>e:en establ5.:::hed c:>n.:l eq_l.liJ>:'llent i~: pv.:~il~ble to ,.,aintai.n these st.anclards so the.t the OCCl:.:p"'tion.'\1 heel th :--i~'k C'an be contru!led. In r::any countr~ ea these standards ere enfc!.~ed by lpeislat5 on; but -:~.,., ..,,..,,. case trade and inc'lustr~r haw~ an cb,ir,aticn, as ,.rit.h any OCC'lpational F.af'ety problem, ..__ ~"'!n'l,:,u!\0~':; th.: effective rip."..~ :1'..,.'"-"t:ntion m~::~!:.'n=cs which have been develope~1 by cor-'r~tent and exper;i enc~d +.ec1'-'liclanb. FMSI 03577 - 10 - Maintenance Work(servicing) In certain condit~ons involving servicing, etc., there may be a paraoccuptional hazard. The industry can provide information to ensure that users understand under what circUmstances such risks can arise and how they can be avoided.30,3l,32,33. The General Environment The available data indicate that the general public is not at risk and means should be found to tell them so. ANNEX - Bibliography 14th January 1981 (Page 10 retyped at FMSI because of weakness of original copy) _ FMSI 03578 ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY BIBLIOGRAPHY 1. Walther, E., (formerly) Pneumoconiosis Research Unit, Penarth, Wales. "Dust Problems in the Use of Asbestos Products". Proceedings of the International Conference on Pneumoconiosis Johannesburg, S.Africa. 1969 2. Santorelli, Zedaa, Aresini and Ghezzi; ~espiratory Physiotherapy of Asbestosis". La Medicine del Lavoro 63 (7 - 8) 269 - 281 July 1972 3. Rubino, G.F.: Institute Medicina-del Lavoro, Torino, Italy. "Identification and Survey of Asbestos Occupationally Exposed Populations". September 1975. 4. International Agency for Research on Cancer. I.A.R.C. Monographs on Evaluation of Carcinogenic Risk of C~emicals to Man. Vol.14 Asbestos. Lyob, France. 1977. 5. "Selected written evidence subt~itted to the Advisory-Committee on Asbestos 1976-77" Health and Safety Executive, UK. 1977. 6. Cross, A.A, former Director General, Asbestos International Association, London. "Progress in the Control of.Asbestos Dust in the Workplace". International Conference on Pneumoconiosis, Caracas. November 1979. 7. German Federation of Industrial Accident and Safety Insurance Corporations E.V. Berufsgenessenschaften (Bonn,W.Germany). Research Report -Asbestos. "Investigations into.He!ilth Hazards through Dusts by Brake-Linings containing Asbestos". (Analytical epidemiological and animal investigations) December 1978. B. "Hygiene Standards of Airborne Asbestos Dust Concentrations for use with the Asbestos Regulations 1969". U.K. Dept. of Employment H.M. Factory Inspectorate, Technical Data Note 13 (Rev) 1975. FMSI 03579 - 2- 9. Heidermann, Kuhnen and Schutz (Dust Research Institute of Federation of Industrial Trade Associations (Berufsgenosenschaften). Bonn, W. Germany), and Prochazka; (Bavarian State, Institute for Industrial Safety, Munich) "Investigations into the Hazards produced by dust of asbestos-containing friction linings". June 1975. 10. Conference on Exposure to Asbestos during Brake and Clutch Maintenance, Brentwood, Essex, England, March 1969. a) Lee G.L: British Leyland, Longbridge, Birmingham. "Removing Dusts from Brake Assemblies during Servicing Alternative Cleaning Methods". b) Hatch,D., Ferodo, Chapel-en-le-Frith, Derbyshire, England "Possible Alternatives to Asbestos as a Friction Material". c) Knight, K.L. and Hickish, D.E., Medical Services, Ford of Britain, Brentwood, Essex, "Investigations into Alternative Forms of Control for Dust generated during the Cleaning of Brak Assemblies and Drums". d) Hickish, D.E., and Knight, K.L., (as above) "Exposure to Asbestos during Brake Maintenance". UK Annals of Occupational Hygiene. Vol.l3 1970. 11. Bentley, M.L.; Mintex, Cleckheaton, Yorkshire, England. Personal communication to A.A.Cross - Asbestos Dusts - test during drum brake maintenance. May 1974. 12. Cross, A.A.; Chairman, Environmenta Control! Committee, ARC England. "Asbestos Dust in Friction Materials". September 1975. 13. Jacko, DuCharme, Somers; Bendix Corpn. and Environmental Protection Agency, USA "Brake and Clutch Emission during Vehicle Operation". Automobile Engineering Meeting, Detroit, Michigan, USA May 14-18 1973 *Former Director General, AIA FMSI 03580 - 3- 14. Roh1, Anderson, Nicholson, Langer; Mount Sinai School of Medicine, N.Y, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair." American Industrial Hygiene Conference, Miami, USA. (Abstract 223) May 1974. 15. Nicholson, ~: Mount Sinai School of Medicine, N.Y. USA. "Asbestos Exposure during Brake Lining Maintenance and Repair" - June 1975 (Believed to be full version of abstract quoted above -14) 16. Rohl, Langer, Wolff and Weissman; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair". Environmental Research 12, 110 - 128 (1976). December 1975. 17. Rohl, Langer, Mlimentidis, Wolff, Selikoff; Mount Sinai School of Medicine, NY, USA "Asbestos Content of Dust Encountered in Brake Maintenance and Repair". Proc. Royal Soc. Med; 70:32-37 Jan. 1977. 18. Kogan, F.M.; Sverdlovsk Institute of Labour, Hygiene and Industrial Diseases, USSR. "Asbestos and Prevention Measures against Dust Harmful to the Health of Workers". (Chapter V). 1975. .19. Marsh, J.H.; Raybestos~anhattan, Connecticut, USA. Personal Communication. Reports of mesothelioma among brake service mechanics in Boston, Mass. and Santa Clara, California N.l.O.S.H. and Selikoff. August 1975. 20. Lorimer and Rohl; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure of Brake Repair Workers in the US". International Conference on Occupational Health, Brighton, England. September 1975. FMSI 03581 - 4- 21. Nicholson; Mount Sinai School of Medicine, NY, USA. "Comparative Mortality Experience of Three Cohorts of Asbestos Workers." International Conference on Occupational Health, See It~m 20. 22. Zielhuis, Prof. R.L.; Coronel Labor~tory; University of Amsterdam, Netherlands. "Public Health Risks of Exposure to Asbestos". Report of a Working Groll\f Cif Experts prepared for the Commission of the . European Con.nnunities., Directorate..- General for Social Affairs, Health and Safety. 1977 . 23. Sebastien, Bignon and Bannard; Centre de Perfectionnement Technique, Paris. "La Pollution Atmospherique Urbaine par l'Asbeste". Journeas_d"Etude sur la Toxicologie ltldustrielle, Paris. June 1975. 24. Asbestosis Research Council, Rochdale, England. Personal communication to A.A.Cross* "Investigation into levels of' airborne asbestos dust in the London Underground, etc.". 1978. 25. Johns-Manville; Denver, Colorado, USA. Boston Subway -Cobra Brake Lining Emission 1977. 26. Winton Laboratories, Surrey, England. "Asbestos intlie'Undergroundno cause for alarm". 27. Duff icy, B, L., Ferodo, Chapel-eri-le-Fri th, De~by~fiire,. ~ngland; Personal Communication - Asbestos Content of Wear Products from Friction Materials. June 1969. ; .. ;, 28. Anderson, Gealer, McCune, Sprys; Forcl Motor Company~ USA . "Asbestos Emissions from Brake Dynamometer Tests". (Ref . ~s 13) .., 29. Gilson, J .c.; former Director of Medical Research Council Pneumoconiosis Unit, Penarth, UK. Personal communication to the AlA. * Former Director General of the AlA FMSI 03582 - 530. "Asbestos Based Friction Materials etc. -Control and Safety Guide No.8". Asbestosis Research Council, Environmental Control Committee P.O. Box 18~ Cleckheaton, Yorkshire, England. Dec. 1970 (Latest revision- March 1977). 31. "Safe Working with Asbestos - Friction and Anti-Friction Materials". ARC - See item 30. 32. ~ecornrnended Work Practices - Fabrication and Use of Asbestos Friction Materials".AIA/NA- Asbestos Information Association of North America, Washington USA. 33. "Friction Materials Work Practices Guide". Friction Materials Standards Institute. Paramus, New Jersey, USA. October 1978. 14 January 1981 FMSI 03583 FRICTIOH ~clATERIALS STA!IDARDS IL1STITUTE, INC., E-210 '.OUTE 4, PARA!lUS, N.J. 07652 BUL L ET I N N 0. 7 1 3 April 3, 1981 INSTITUTE CmfiIEUTS Q_J EPA'S PROPOSALS FOR REPORTWG Ai.ID RECORDKEEPIHG In Jantlary the Institute sent the ?Iembership a copy of the Federal Register Hotice of January 26, 1981, with its proposals for reporting and recordkeeping for asbestos products manufacturers. After this notice was mailed, we had two member inquiries asking if the Institute would be commenting on these proposals. lile then asked the ~~embership for comments and subsequently prepared a letter of comments through the Institute's Health and Environmental Affairs Committee. The final draft was i:ipproved by Ur. Armstrong, the Committee Chairman. and copies were then circulated to the Board of Directors. The proposed comments circulated to the Board were then mailed to the Environmental Protection Agency on March 25, 1981. They requested comments by Uarch 27, 1981. A copy of the Institute's comments to the EPA are enclosed. EWD/erc Enc: cc-Delegates and Alternates Active Hembers - List C E. H. Drislane Executive Director FMSI 03584 - INDUSTRIAL HYGIENE REPORT ASSESSMENT OF ASBESTOS EXPOSURE TO MECHANICS PERFORMING BRAKE SERVICE OPERATIONS INCLUDING RECOMMENDED PROCEDURE FOR ASBESTOS BRAKE AND CLUTCH SERVICING DRAFT REPORT WRITTEN BY: Dennis R. Roberts Ralph D. Zumwalde DATE OF REPORT: April 27, 1981 REPORT #32.4 Industrial Hygiene Section lndustrywide Studies Branch Division of Surveillance, Hazard Evaluations and Field Studies National Institute for Occupational Safety and Health Cincinnati, Ohio FMSI 03585 DISCLAIMER DRAFT Mention of company names or products does not constitute endorsement by the National Institute for Occupational Safety and Health. u FMSI 03586 ABSTRACT -- DRAFT NIOSH estimates that 151,000 U.S. mechanics and garage workers are potentially exposed to asbestos brake friction materials. Therefore, NIOSH conducted eleven industrial hygiene surveys to characterize dust exposures and work practices. Personal, general area, and bulk samples were taken and analyzed for TWA and peak fiber concentrations by optical (opt.) and electron microscopy (TEM). Mechanics TWA and peak exposures varied depending on brake assembly cleaning methods and times. Eight of thirteen mechanics TWA's exceeded NIOSH recommended standards but all were within OSHA regulations. Peak exposures, during brake assembly cleaning, were higher (up to 15 fibers/cc) than respective TWA's (0.01 to 0.28 fibers/cc). Fiber levels for all cleaning methods except vacuuming were near the NIOSH ceiling and compressed air cleaning often exceeded the OSHA ceiling. Background TWA's were similar for all facilities. TEM indicated lower fiber concentrations (>5 um) than opt. in most samples and revealed that 80~ of the total fiber ~opulation was <5 um long. TEM found 3at of the fibers were chrysotile, 20~ forsterite, and 5at unknown; also, the geometric mean chrysotile fiber size ~s 1.7 um length and 1.5 um diameter. The data suggest potential asbestos fiber exposures during brake servicing, principally brake assambly cleaning. Therefore, it is recommended that vacuum cleaning systems and NIOSH approved respiratory portection are used. FMSI 03587 .-~ CONTENTS Abstract : tii I n t r o d u c t i o n -~1 2Brake Materials, Products, and Usage Historical Development of Friction Products 2 Requirements for Brake Linings 3 Types of Brake Linings and Manufacturing Processes 6 Brake Lining Repair and Maintenance Practices S Selection of Facilities Surveyed 10 Description of Brake Servicing Operations 10 Sample Collection and Analysis - - 14 Airborne Samples " 14 Bulk Samples 16 Work Practice Characterization 16 Compressed Air Blow-off -~ 16 Compressed Air/Solvent Mist Blow-off 17 Dry Brushing 17 Wet Brushing - 17 Squirt-off 17 Vacuum Cleaning _ 17 Summary of Survey Results 18 !EM Fiber Characterization. 19 Bulk Brake Dust ............................................ 21 Traae Metal Analyst& . - ................... 21 Discussion ; ~~22 -S"UIIIIlary ......................................... - . 23 Conclusion......................... - .............................. 24 Recornrnendat ions: - .................................. .- 26 References . - 28 TABLES 1. Fiber Air Sample Results 31 2. Comparison Between TEM & Optical Microscopy Analysis 32 3. Fiber Size Data 33 4. Trace Metal Analyses 34 Attachment - Recommended Procedures for Asbestos Brake and Clutch Servicing35 FMSI 03588 ,. -j INTRODUCTION _DRAFT. A major objective of the National Institute for Occupational Safety and Health (NIOSH) is to determine environmental exposures of working populations through occupational health research, field surveys, and industrywide epidemiologic studies. Accordingly, NIOSH conducted comprehensive industria! hygiene surveys to characterize dust exposures resulting from vehicle brake servicing oper- ations and to make a thorough assessment of work practices utilized, as well as docWllent the types of personal protective equipment used. Of particular interest was the potential for exposure to asbestos fibers which could be generated by these types of operations. Limited studies of workers involved in brake servicing have suggested that their work-related exposures may be asso- ciated with asbestos-induced diseases. 1 HIOSH estimates that a workforce of 151,000 brake mechanics and garage workers :in the u.s. is potentially exposed to asbestos. 2 Potential exposures are a result of 128 million pounds of asbestos used annually in the u.s. for the pro- .duction of brake friction materials. 3 Besides as.bestos, other materials (e.g. binders, friction modifiers, fillers, etc.) are used in the manufacture of brake linings, which can likewise have a_ potential for exposure. As noted in one study, thirty materials or compounds that make up the binders, fiber re- inforcers, property modifiers, etc., were identified during brake lining manu- facturing.2 1 . FMSI 03589 .~. ; ""e:' . ..: "' .;., ... ~ .. BRAKE MATERIALS, PRODUCTS, AND USAGE Historical Development of Friction Products4 The requirements of early automobile friction materials were relatively mini- mal. Passenger cars were light and designed for low speed operations. Brakes were of an external contracting type and utilized a variety of materials; this included leather and impregnated cotton products which were commonly used along with wool and felt. In 1903 woven asbestos friction materials were first marketed in the United States by the Keasbey and Mattison Company of Ambler, Pennsylvania. 5 Because of its superior heat resistance _and durability they rapidly increased in use and soon dominated the market. The Model T Ford pro- vides an example of the changing use of materials. Initially, cotton bands, reinforced with zinc, copper, or brass wire and impregnated with oils and bituminous material, were used for the brake bands. These were soon replaced by mixed cotton-asbestos materials and finally by woven asbestos products. The woven asbestos brakes continued to be the dominant produ~t used in automobiles until about 1930. They typically contained 70~ or more wire-cored asbestos yarn, impregnated with drying oils, such .as linseed, and bituminous material ~olded brake linings were developed in the early 1920's and gained increasing use with the introduction of internal shoe brakes in 1927. By 1940 virtually all automobiles were equipped with molded brake linings_, although woven products continue to be used in trucks, heavy equipment and for specialized applications. The molded l~nings in use were cut to length, usually by the manufacturer, and mounted on brake shoes using rivets. Until the mid 1920's brakes were only mounted on rear wheels. However, with the development of internal shoes, four wheel mountings soon became standard, and by 1930, were generally operated hydraulically. 2 FMSI 03590 DRAFT As automobiles were designed for use at even higher speeds, brake linings improved in both quality and performance. Various new materials were introduced as fillers, binders, and friction modifiers._ In 1948 bonded brake linings were developed and soon accounted for approximately 40~ of the original equipment brake market. Howeyee; ~~ey rapidly dominated the replacement market because of the considerable savings in labor during installation. In 1965 the first disc brakes were introduced on American automobiles and rapidly increased in use. In 1975 virtually all original equipment cars had front wheel brakes of this type. However, because of less stringent braking requirements and the difficulty of adapting mechanical parking brakes to the disc configuration, the rear wheel brakes on 95~ of currently sold cars are still of the drum variety. Requirements for Brake Linings A constant or slightly decreasing coefficient of friction (C.F.) with 0. temperatures up to about 1000 F is required for an efficient brake lining; values of from 0.30 to 0.45 C.F. are normally sought. Lower values produce brakes requiring excess pedal pressure and those with ?igher values are too sensitive to pressure and develop excess wear. Ideally, the desired frictional qualities should be m~intained throughout the life of the lining material. During braking, chemical and physical changes occur in the material at the braking surfaces. These changes may produce an increase (build-up) or a decrease (fade) in friction. Satisfactory linings will fade slightly upon repeated applications, but will return to their initial state upon cooling. 6 3 FMSI 03591 DRAFT Low wear of the linings is obviously desirable for economical and practical considerations. However, high wear resistance can be associated with the tendency of the lining to glaze, with a concomitant reduction in the coefficient of friction. This can be overcome by allowing a slow alteration of the brake lining material to occur. Pyrolysis of the organic binders and thermal decomposition of the chrysotile fibers under braking' provide the necessary continuing renewal of the lining surface. ...The lining should be non-abrasive to the drum surface. In addition to causing rapid drum wear, abrasive linings score the drums, which, in turn, leads to a rapid wearing of the lining. Drums made of cast iron and steel are common, with steel being the more susceptible to scoring. Since brake drums have a hardness of from 3.5 to 4.0 on the MOH (mineral hardness range of 1 to 15 in which tale is rated 1 and diamond 15) scale, virtually all lining materials used have lower hardness values. Other necessary or desirable proper;ies of brake linings include: physical strength, dimensional stability, quiet operation, and ~afe and non-offensive degradation products. Of the various properties desired in the linings, greatest attention is paid to build-up/fade and recovery characteristies. Wear problems are not as serious and can more readily be overcome with the materials available. Compounding Ingredients of Brake Linings7 8 9 10 To achieve the desired friction properties, a wide variety of ingredients are commonly used in the manufacturer of automobile brake linings. These 4 FMSI 03592 Asbestos DRAFT Asbestos is used for fiber reinforcement of the friction product. Chrysotile is used almost exclusively and comprises from 40 to 50 percent of the brake lining. Fiber grades 4 through 1 are used, and occasionally, several sizes are mixed or even calcined to improve performance characteristics. Amosite, crocidolite, or other amphibole asbestos varieties are not used because they are too harsh and tend to score the brake drums. Organic binders Organic binders are primarily phenolic type resins selected for high binding strength. Unmodified phenolic resins, when subjected to heat usually become hard and brittle. To prevent this, linseed, cashew nut, or China wood oils or cresols are added. Rubber, which also finds use as a binder, imparts desirable friction qualities and improves the flexibility of the lining material. Friction modifiers Triction modifiers are added to achieve a desirable coefficient of friction over all operating conditions. These modifiers also produce a more homogeneous liuing surface. Included among these materials are lead, zinc, brass, cashew :nut oil, graphite, and oxides of iron and copper. Fillers Fillers such as rubber scrap, barites, clays, silica, coke, coal and other minerals are used. These also have utility in achieving desired friction properties, in some cases through action as abrasives to recondition braking surfaces. It is important to note that one major purpose of the reconditioning ___________,____________________ -----~- FMSJ 03593 . . .i .... DRA.FT- -. "-~.. ":: ... agents is to retard the fo.rmation of forsterite which may accumulate on the urface of the brake lining. Forsterite is a mineral not originally present in the brake material, but is c~~ated by dehydroxylation and recrystallization of chrysotile asbestos at high temPeratures. The hardness of forsterite (hardness 6.5-7.0 on the MOH Scale) is such that it tends to score and gouge brake drums and discs (hardness 3.5), degrading them prematurely. Therefore, recrystalli%ation of chrysotile to forsterite is an unwanted effect. Curing agents Curing agents and/or accelerators are used to assure that appropriate chemical .. ~:......... reactions occur to produce the desired brake quality. Types of Brake Linings and Manufacturing Processes In making the of different types of brake linings various manufacturing processes are utilized to achieve a wide range of po~ential applic'ations. These include: -Wired Back These are made by a calendering process in which putty-like stock is formed ~uto a ribbon about a wire backing. The wire reinforcing serves to maintain strength during the curingprocess. Further, as linings of this type are invariably riveted, the wire reinforcing provides long term structural strength ~nd prevents shearing of the lining at the rivets during braking. Linings of this type were extensively produced prior to World War 11. They are in little use today. .6 t FMS' 03594 :.. : ...- Extruded Linings ! >.~-~ .. "r -~..... ~ These are manufactured by extruding-the soft plastic stock through an appro- priately sized rectangular orifice. To minimize structural weakness in this lining, curing agents are added to produce a hard inflexible finished product. Sheet Linings These are laminated structures formed by winding a 0.001-0.002 inch film of stock about a hot roller. Since the fabrication process is a relatively expensive one, linings of this type are not commonly produced for general use. Dry Mixed Types This process involves the dry mixing of various ingredients capable of passing a 200 mesh screen, and then molding the lining under pressures of from 1000 to 3000 pounds per square inch. The resulting lining is among the most heat stable of friction materials in use today and obtains wide use in.the manufacture of brake blocks for heavy duty service. Millboard Type The manufacture of this type of brake lining material is by a process similar to that utilized.in the paper industry. Wet stock is formed and passed over rollers with various drying and baking operations producing sheets of uniform lining material. The equipment for producing such materials is expensive, but the volume of production leads to an economically produced molded lining. 7 FMS\ 03595 ' . DRAFJ. ... BRAKE LINING REPAIR AND MAINTENANCE PRACTICES To a large extent the changing character of brake lining materials has led to changing work p~actices and differing asbestos exposures over the years. From 1920 until about 1930, when braking was done through the use of external brake bands made from woven materials, the predominant exposure to asbestos would have come from the cutting and fitting of the woven lining material. It is thought that airborne fiberconcentrations were considerably less than those developed in later years when machining of molded materials was common. From 1927, when internal brake shoes were developed using molded linings, until 1948 when bonded brake linings were introduced, all internal brake linings were attached to shoes using rivets. The lining material for use in the replacement market would be precut to appropriate size for various brakes or obtained from rolls of indeterminate length. The precut segments would usually be predrilled at the factory for rapid mounting on shoes .In some circumstances, however, drilling for the rivets and bevelling would be done by .the mechanic installing them. The use of rolled linings required cutting the . friction material to shape, drilling holes for rivets, and bevelling the edges appropriately. In this latter circumstance, asbestos exposure to workers could be considerable. Even when shoes with predrilled and bevelled linings were installed, the processes o~ punching out the rivets on the old shoes and riveting on of the new shoes would give rise to ~reater exposures than that accompanying the use of bonde4 linings. 8 _ ____..._ _ _ _ _ _ ----------~--------....... FMSI 03596 ... . .. :.- With the introduc~j,.on.;of bonded linings, the need for drilling, facing, or .-~ &rinding opei.a.tions during installation decreased significantly. However, for short period of time, in the mid-1950's when automobile shoes were first installed with a fixed anchor, some tapering was necessary on uniform thick- ness bonded linings to achieve a proper fit. Previously, the end of the shoe .-: .;::.a opposite to that of the hydraulic cylinder could be mechanically adjusted Shortly thereafter, tapered bonded linings were available from the factory. Subsequent to 1960, considerably fewer bevelling or grinding operations were performed by an automobile mechanic replacing brake linings. During replacement of internal shoe brakes it was common practice to remove the brake wear dust from the housing by air blowing or brushing. After 1970 increasing awareness of the hazards of asbestos and its presence in brakelihing dust led to wet brushing, wet wiping, dry brushing, or vacuuming work practices in some brake servicing facilities. However, even today such im provements in work practices are not universal. In the 1930's and 1940's most automotive shops were relatively small and most mechanics performed all automobile maintenance and repair activities. In recent years, however, there has been an increasing tendency towards specialization1 with shops existing for brakes and front end work exclusively. Here, while asbestos exposures during brake work on an individual job may be less than those of previous years, some workers are exposed for considerably longer periods of time. 9 --------------~- ------------------------------------~ FMSI 03597 SELECTION OF FACILITIES SURVEYED DRAFT The purpose of the industrial hygiene study was to investigate and characterize contemporary dust exposures resulting from vehicle brake maintenance and repair operations taking into account the work practices utilized. Therefore, it was necessary to locate facilities where a variety of brake servicing techniques were used as well as where there were differences in number of vehicles serviced. Six of the eleven sites selected for the invest~gation were automobile brake service facilities which performed from 2 to 45 brake jobs per week at an average of 65 minutes per vehicle. One of the facilities surveyed only serviced trucks, which often required 6-9 hours per vehicle to service brakes, with an average of three brake jobs p~r week. The remaining four facilities serviced both autos and trucks and performed from 5 to 45 brake jobs per week which varied in service time depending on the type of vehicle. Detaile4 airborne dust sampling surveys were conducted at each facility Description of Brake Servicing Operations ~he servicing procedures found at each facility were basically as follows. The vehicle is driven into a repair stall or bay for a brake system examination. Pending repairs, the wheels are elevat'ed, removed, and then inspected. Loose dust is cleaned from the drums and brake assemblies by vacuuming, wet or dry wiping/brushing, using compressed air, or a combination of these methods. Parts are then replaced or repaired as needed and the brake system is reassembled and adjusted. Test driving the vehicle for proper fitting and adjustment is the final phase of the servicing operation. 10 FMSI 03598 DRAFT A brief description of the indivi~ual facilities is outlined as follows. Industrial hygiene survey data collected at each facility are shown in Tables 1-4. Facility A Facility A," a private fleet service garage, was responsible for complete automotive maintenance and repair with the exception of internal engine repair and exterior painting. The shop normally operates 8 hours per day, 5 days per week. Of the seven employees working at the facility, only three were responsible for brake servicing. Brake servicing operations were performed (two to five jobs per week) in either of two service stalls. Facility B Facility B, a municipal service garage, employed three mechanics that specialized in brake and clutch service and _three employees that operated a separate brake repair shop specializing in brake shoe and drum reconditioning. The brake mechanics serviced all vehicles which included, waste collection, dump, and light trucks, autos, and some 2- and 3- wheeled vehicles. The shop operated 8 hours per day, 5 days per week. Facility C At Facility C, a municipal garage, there was an average of one complete brake service job per day, taking about 5 hours per job, with most of the vehicles consisting of cars or light trucks. There were five employees responsible for brake servicing and the facility operated 8 hours per day, 5 days per week. 11 FMSI 03599 Facility D DRAFT At Facility D, a municipal garage, an average of eight brake jobs per day were performed on cars and trucks._ Brake maintenance was performed by any of the 60 auto mechanics. The hours of operation were 8 hours per day, 5 days per week. Facility E Facility E, a private fleet service garage, performed complete automotive and . light truck maintenance. The shop normally operated two shifts, 5 days per week, and there were usually four full-time mechanics per shift. About one b~ake job per week, per shift was performed. J:acility F Although Facility F was an automobile brake service shop, front-end alignment and tire sales were also part of the shop mechanics' duties. The three full-time mechanics worked from two servicestalls, 12 hours per day, 5\ days -pe~ week. Brake maintenance operations consisted of 10 to 14 brake jobs per week. Facility G Major services at Facility G, an automobile brake service shop, consisted of front-end alignment, shock absorber servicing, and brake maintenance. The normal work week was made up of five, 9-hour days and one, 6-hour day. Three 12 FMSI 03600 DRAFT service stalls were used by the three full-time employees for brake servicing operations during the 4 to 6 brake jobs per week. Facility H -- Major services provided at Facility H, an auto brake shop, were front-end alignment, shock absorber service, and brake maintenance. The three full-time employees worked from two service stalls, 9-hours per.day, 6. days per week. The number of brake jobs per week averaged from 20 to 30. Facility I Facility I was the largest of the automobile brake service shops surveyed. Other services provided by this facility were front-end alignment and shock absorber replacement or repair. rhe five full-time mechanics worked fro!ll four service stalls, 9 hours per day, 6 days per week. Brake maintenance operations consisted of 35 to 45 jobs per week. l'acili.ty J The major services at this facility were front-end alignment, muffler installation, and brake maintenance. Automobile brake repair operations were performed by the shop's three employees and consisted on the average of 4 to S brake jobs per week. Normal brake servicing at this facility took about 1 hour and 45 minutes per vehicle. 13 FMSI 03601 Facility K Facility K, a truck brake maintenance facility, involved a somewhat different operation and exposure~ Servicing operations were more complex and, therefore, involved more employees with fewer vehicles serviced than auto maintenance facilities. The four service bays at the facility were used by seven mechanics. Other service operations included pad grinding, riveting, and punching (pad removed and/or replaced on shoe), sand blasting of old shoes, and milling of wheels. SAMPLE COLLECTION AND ANALYSIS Airborne Samples Personal and general air samples were collected at each facility on different occasions during a 3-year period. Brake servicing operations and areas not in the iamediate vicinity of brake work within each facility, were monitored to provide overall asbestos exposure data. Personal air samples were collected in the breathing zone of the brake mechanics using -Millipore Type AA, 37 millimeter (am) diameter, 0.8 micrometer (p_m) pore size, membrane filters at a calibrated sampling flow rate of 2.0 liters per minute (lpm). The filters were changed periodically during the work shift to prevent particulate overloading on the filter. Time-weighted average (TWA) fiber concentrations were determined for the time spent performing brake service at all facilities and peak concentrations determined for time spent cleaning brake dust from drums and assemblies. Samples for peak exposures were collected using Cast pumps calibrated at 11.0 or 10.6 lpm using identical media as above. At facilities B, C, and D, 14 FMSI 03602 a 2.0 lpm sampling train was used for peak samples. Analysis of the membrane filters for asbestos fibers was conducted in accordance with the procedures outlined by the Occupational Safety and Health Administration11 and the NIOSH Manual of Analytical Methods P&CAM #239. 12 These procedures - require the counting of fibers greater than 5 micrometers (pm) in length and with at least a 3 to 1 length to width aspect ratio utilizing phase contrast optical microscopy at a magnification of 400-450X. Concentrations are expressed as fibers greater than 5 pm in length per cubic centimeter of air (fibers/cc). Random samples from each facility surveyed, as well as those samples having high fiber concentrations, as determined by the optical counting method, were analyzed on a transmiss_ion electron microscope (TEM) utilizing selected area electron diffraction (SAED) and energy dispersive X-ray analysis (EDXRA). Samples were observed at 17,000X magnification with fibers (! 3:1 aspect ratio) sized by length and diameteT. SAED was at- tempted on all observed fibers for possible identification. In addition, EDXRA was performed on ipdividual fibers to determine their elemental composition. SAED patterns and EDXRA elemental spectrum ratios were compared with reference minerals (UICC chrysotile, and forsterite obtained fTom the U.S. Smithsonian Institution). Sample preparation and analysis were performed using the NIOSH method described in the Technical Report "Review and Evaluation of Analytical Methods for Environmental Studies . 13 of Fibrous Particulate Exposure". General area samples for trace metals (lead, zinc, copper, iron, and manganese) were collected at most facilities using Staplex Type TF-1A high-volume samplers at a flow rate of 10 cubic feet per minute, and 15 FMSI 03603 also with a sampling train and flow rate like that used for asbestos fiber collection. Samples were analyzed for metals by atomic absorption spectrophotometry in accordance with the NIOSH methods P&CAM Number 222, 5186, 5341, and 5366. 14 15 Bulk Samples Samples of brake wear dust were collected from the brake drums of several vehicles that were being serviced during the surveys. These samples were analyzed by TEM for characterization and identification of fibrous partieulates and to determine fiber size distributions. WORK PRACTICE CHARACTERIZATION Considerable emphasis was placed during the surveys on detailing work procedures during brake servicing in order to document the types of cleaning practices (i.e. vacuum, compressed air, brushing, etc.) used in replacing brakes. As previously describedin the section ~escription of Brake Servicing Operations" the brake se:vicing work practices utilized were similar for all facilities surveyed; the major difference observed was the methodology utilized for clean-off of brake wear dust from the brake-shoe/backing-plate assemblies. There were six different types of clean-off methods observed during the study. Those six methods are described as follows: 1. Compressed Air Blow-Off. A compres.sed air stream was used to blow away brake wear dust from the brake assemblies and drums. 16 FMSI 03604 2. Compressed Air-Stoddard Solvent Mist Blow-Off. The same as #1 except a spray gun containing stoddard solvent was used to produce a solvent mist for blow-off. 3. Dry Brushing. Brake wear dust was brushed away with a small utility brush (usually 1" diameter). 4. Wet Brushing. Basically the same as dry brushing except the brush was kept saturated with a liquid such as gasoline, water, or stoddard solvent. 51 Squirt-Off. A liquid squirt-bottle containing water was used to wash away brake dust. This was followed by drying off assemblies with a cloth. 6. Vacuum Cleaning. A shop type vacuum cleaner, equipped with a HEPA* filter, wa~ used in combination with compressed air. This system included a brake encapsulation cylinder that completely enclosed the brake-shoe/backing plate assembly. The mechanic operated a compressed air nozzle fixed inside the enclosure to blow off the brake dust, which was immediately drawn into the vacuum sys.tem. A separate vacuum hose was used to vacuum the dust from the brake drums. In Methods 1 to 5, and especially 1 to 3, the brake dust has the potential to enter the ambient air of the facility. Conversely, in Method 6 the dust is contained by.the HEPA filter which may be removed from the vacuum 17 FMSI 03605 cleaning system and disposed of. *HEPA: High Efficiency Particulate Air- 99.7% efficiency for 0.3 ~m diameter aerosols. SUMMARY OF SURVEY RESULTS The optical microscopy fiber count analysis for the TWA, peak personal, and background area samples collected during the study are summarized in Table 1. The TWA and peak fiber concentrations for mechanics tended to fluctuate depending on the brake clean-off method used and the time spent performing the task. For example, regardless of the cleaning method utilized, peak exposures are high (up to 15.00 fiber/cc) when compared to their respective TWA exposures (0.01 to 0.28 fibers/cc). The differences between the TWA exposures and the peak exposures are most likely due to the brake assembly cleaning operation generating a higher dust level than the other repair steps. Peak exposures also varied from shop to shop. This is perhaps best explained by variations in work practices utilized, the inconsistencies in performing brake work that existed throughout the various repair shops, and because clean-off is done intermittently and therefore represents a small percent of the work performed during the shift. For example, the amount of time spent servicing brakes and the number of brake jobs that were performed per shift differed among the mechanics; likewise, there were differences in cleaning methods (e.g., compressed air, brush, vacuum, etc.), and procedural techniques (e.g. distance from brake housing to breathing zone). In addition, there were some mechanics who dropped the brake drums on the floor, causing airborne "18 FMSI 03606 dispersal of brake dust. Environmental conditions at each brake service facility, such as: shop size, ventilation controls, and open windows and doors would also affect individual worker exposure and background concentrations of airborne asbestos fibers. Regardless of the cleaning method utilized, TWA exposures for mechanics at all facilities were relatively consistent, and did not differ significantly from their respective background (ambient levels in facilities) TWA exposures. The similarities between mechanic TWA and background exposures suggest that all individuals in the immediate work environment are potentially exposed to the same fiber concentrations during a normal work shift. This observation is further supported by the fact that the mechanics spend much of the work shift away from the work site and in other areas of the facility. TEM Fiber Characterization Samples were randomly selected for transmission electron microscopy (TEM) with fibers sized by length and diameter. In addition, fiber concentrations (fibers/cc) were determined for total fibers and fibers >5 pm in length. These concentrations were compared to those found by the optical microscopy method and are reported in Table 2. In all but 3 samples, the concentrations of fibers >5 pm in length determined by optical microscopy were somewhat higher than those determined by TEM. This difference could have been caused by particulate loss during sample preparation for TEM, or because of the small number of fibers actually counted on each sample; at low fiber counts, small differences in fibers counted by both microscopy 19 FMSI 03607 methods would have a significant effect in the calculation of fiber concentrations. Besides determining the concentrations for fibers >5 pm in length, total fibers observed were counted and concentrations calculated. As would be expected, the greatest proportion of fibers observed was shorter than 5 pm in length (80 to 90~). Fibers observed by TEM were identified utilizing SAED and EDXRA. Approximately 507. of the fibers analyzed by SAED could not be identified due to ambiguous diffraction patterns. The remaining fibers which were identified indicated the presence of chrysotile (~307.) and forsterite (~20~). The presence of fibrous forsterite was probably due to the dehydroxylation and recrystallization of chrysotile as a result of high temperatures (>6~0C) encountered during braking. 1 2 Some of the fibers which revealed ambiguous diffraction patterns appeared to have crystalline structures similar to both chrysotile and forsterite (probably a transition intermediate2 ) while others were too small for diffraction analysis. EDXRA was performed on the fibers to confirm the SAED analysis that was made for the chrysotile and forsterite fibers. Some of those fibers which gave ambiguous SAED patterns indicated magnesium, silicon, and iron in various elemental ratios. As shown in Table 3, when a fiber size distribution was performed for all fibers observed by TEM, a geometric mean length of 1.66 m, and a geometric mean diameter of 0.14 m were determined. Likewise, for those fibers identified as asbestos (chrysotile) a geometric mean length and diameter of 1.70 Pm and 0.15 pm were determined, respectively. 20 FMSI 03608 Samples of brake wear dust were analyzed by TEM in the same manner as the airborne samples. Identification was attempted on all fibers using SAED and EDXRA. Approximately 45% of the fibers analyzed by SAED could not be identified due to ambiguous or the absence of diffraction patterns. EDXRA was performed on all fibers observed with elemental analysis being successful on about 70% of the fibers. When utilizing SAED and/or EDXRA many of the fibers observed were positively identified as chrysotile {407.) while the remaining were either forsterite (20%) or unknown (40%). Many of the unknowns were thought to be intermediate recrystallized forms between chrysotile and forsterite. In addition, a fiber size distribution was pe~formed which indicated somewhat shorter lengths (0.24-5.88 ~m vs. 0.24-10.0 ~m) and smaller diameters (0.06-0.29 ~m vs. 0.06-1.0 ~m) than those observed in the airborne samples (Table 3). Trace Metal Analyses Trace metal analyses were performed on airborne samples collected at Facilities B, C, D, I, and K with the results reported in Table 4. Samples were analyzed for the following metals: lead, iron, zinc, copper, and ~anganese. As noted in Table 4 the metals were.often non-detectable (n.d.) or found in trace amounts t~at were always below the OSHA and NIOSH expo- sure standards. The range of concentrations for all facilities were: .3 . 3 3 Pb, n.d. - 63.3 ug/m ; Fe, n.d. - 1.5 mg/m ; Zn, n.d. - 352 ug/m ; Cu, n.d.- 8.7 ug/m3; and Mn, n.d. - 3.5 ug/m3 . 21 FMSI 03609 DISCUSSION L,. ..\.b'.-";.1, l:--~. : ~') ~ ...J t --s The human toxicological significance for the inhalation of chrysotile asbestos fibers is well documented; and instances of mesothelioma in auto repair workers have been identif1.ed. 16 ' 17 ' 18 In a detailed examination of 90 union vehicular maintenance workers in New York City, 1 with 10 or more years of shop work, 29% had decreased vital capacity; the percentage increased with age and most markedly after 20 years from the outset of auto work. Many of the workers examined showed signs consistent with asbestosis, with observed changes noted in chest x-rays and indication of restrictive pulmonary function. The prevalence of these changes was significantly higher after 20 years exposure, a result expected after occupational exposure to asbestos. 19 Unlike chrysotile, the health effects of exposure to forsterite, or transition series fibers (chrysotile/forsterite) with altered crystalline structures are not well documented. In studies by Davis and Coniam, 20 and Koshi21 in which fibers of chrysotile, chrysotile/forsterite, and forsterite were injected into the pleural and peritoneal cavities of mice, the results suggested varying degrees of toxic effects. Fiber implantation animal studies conducted by Pott, et. al. 22 ' 23 and Davis, et. a1. 24 suggest that the morphology and size of a fiber, regardless of fiber type, are responsible for its carcinogenicity. Likewise, Stanton, et. al. 25 suggests that fibers <1.5 um in diameter and >8 um in length pose the greatest risk in producing pleural sarcomas. These studies tend to suggest that the physical morphology (size dimensions), and to a lesser degree chemical and surface characteristics of a fiber are the determining factor for inducing a biological effect. The precise fiber dimensional 22 FMSI 03610 L.' .; ........ ~~~~-~~-:i ~ characteristics required for thes~ observed pathologic responses have been difficult to determine experimentally because of the difficulties encountered in producing fibers of specific size dimensions. SUMMARY The TWA airborne asbestos sample results for all facilities were within the current OSHA asbestos standard. 26 This standard states: "The 8-hour time-weighted average (TWA) airborne concentration of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers in length, per cubic. centimeter of air (fibers >5 ~m/cc). The ceiling airborne concentration to which --no employee may be exposed shall not exceed 10 fibers >5 lJfD.Icc." However, two of four peak sample results for samples collected at Facility I (Table 1) during the compressed air cleaning of brake assemblies exceeded the OSHA ceiling standard. The compressed air cleaning method also indicated the highest overall peak exposures (up to 15 f/cc) for all cleaning methods examined. When the overall TWA and peak sample results are compared to the NIOSH recommended standard for asbestos, 8 of 13 of the TWA exposures for mechanics indicated concentrations exceeding the recommendation. This standard recommends an 8-hour TWA exposure of 0.1 fibers >5 ~m/cc (fibers/cc) with a ceiling exposure of 0.5 fibers/cc for any 15-minute sampling period. 23 FMSI 03611 Many of the samples collected yielded such low fiber counts that their coefficient of variation (CVt) was above what is considered reliable (i.e. greater than 0.38). 27 Consequently, the fiber concentration data are best utilized for comparing exposure variations among the different cleaning methods/work practices. CONCLUSION The results of this and other studies 1 2 indicate varying concentrations of asbestos fiber exposure to brake mechanics. The exposure concentrations are apparently affected by the work prac.tices utilized, and the existing environmental conditions and controls at each facility. The results of this study show that 8 of 13 of the mechanics engaged in brake service had TWA fiber exposures above the NIOSH recommendation, however, all TWA exposures were below the OSHA standard. Furthermore, when samples were analyzed by TEM, only 30% of the fibers observed were identified as asbestos with the remaining fibers being categorized as forsterite (2at) or unknowns (507.). As a result of the TEM analysis the interpretation of the asbestos concentrations, as determined by optical microscopy, is questionable. The analysis indicates that actual asbestos fiber concentrations (>5 pm length) are often less than those ~eported (see Table 2). However, this does not preclude the possibility of high airborne asbestos fiber concentrations when all fiber size ranges are considered. As determined by the TEM analysis in this study and from other reported studies28 ' 29 a significant number (up to 1001.) of short fibers (<5 p m in length) are always present (see Table 2) and research 25 has indica- 24 FMSI 03612 ted that a potential health risk $Xists for asbestos fibers <5 m in length. Also, a potential health risk may exist for the unknown fibrous portion (~01.) of brake dust. The results of animal studies in which various size fibers were impl~nted-in animals 22 23 24 30 concluded that the physical morphology (size dimensions), and to a lesser degree chemical and surface characteristics of a fiber, are the determining factor for inducing a biological effect. The mechanics surveyed during this study were either full-time brake mechanics, who performed only brake maintenance service and may have serviced up to five cars per day/six days a week, or mechanics who undertook as few as one brake job per week. Regardless of the number of brake jobs performed (per work shift), the TWA fiber exposures were similar for all the mechanics surveyed. The exposures to mechanics who performed full-time brake work were not significantly higher than the exposures for those who did much less brake servicing. Conversely, the short term (<3 minutes) peak exposures encountered in this study during the dust clean-off of braking assemblies were often higher when compressed air was used. All of the cleaning methods surveyed, except for vacuum cleaning, had peak fiber concentrations that were near or above the NIOSH-recommended ceiling exposure level of 0.5 fibers/cc. However, the compressed air cleaning method was the only type which approached, and in two cases even exceeded, the OSHA ceiling exposure limit of 10 fibers/cc. These findings strongly suggest that brake mechanics are at a higher risk of airborne exposure to asbestos fibers during the cleaning of brake assemblies, except when the vacuum cleaning methods 25 FMSI 03613 are properly utilized. :1 - ~...... ~ ;_,. The peak fiber exposures found for mechanics during the cleaning of brake assemblies were higher than most of the TWA exposure concentrations. However, there is some question as to the accuracy of the fiber counts from the analysis of the peak samples since the number of fibers counted were small, resulting in a large coefficient of variation. 27 RECOMMENDAT! ON S The data from this study suggests that a potential for airborne fiber exposure exists during brake servicing operations, principally during brake assembly cleaning. While the fiber exposures reported do not represent 100% asbestos fiber, a potential health hazard still exists since at least 307. of the fibers are asbestos. Also, the other fiber types may be pathogenic since animal studies suggest that fiber shape and size may be more important than chemical nature in terms of biological activity. Furthermore, the possibility exis t"s for exposure to much higher asbestos fiber concentrations for fibers< 5 vm length. Since there is no known safe asbestos fiber exposure level31 , and clinical evidence from a study of union vehicular maintenance workers reports that over 25% had evidence of x-ray abnormalities consistent with asbestosis, it would seem prudent to conclude that a potential health hazard exists during the performance of brake maintenance operations. Therefore, it is recommended that appropriate control measures for reducing exposures, especially during brake assembly cleaning, be instituted at brake maintenance facilities. This 26 FMSI 03614 r .~ .t:c~..: :4- :~ J ., would best be accomplished by usi~g an appropriate vacuum cleaning system to remove all dust from brake assemblies and drums. Above all, any blow-off of brake dust by compressed air must be eliminated. To further protect the health of the brake mechanics, it would be advisable to initiate a personal respiratory protection program. This would include the wearing of NIOSH approved respirators for asbestos, a program for proper fitting, and a routine maintenance program for the cleaning and replacing of respirator filters. As the exposure data indicates, it would only be necessary for mechanics to wear respirators while performing brake assembly cleaning. In order to minimize asbestos dust exposures to vehicular mechanics performing brake and clutch maintenance NIOSH has prepared guidelines "Recommended Procedures for Asbestos Brake and Clutch Servicing" (see Attachment 1) to be utilized during these types of work tasks. 27 FMSI 03615 REFERENCES 1. Lorimer, w.v., Rohl, A.N., Miller, A., Nicholson, W.J., and Se likoff, I.J. "Asbestos Exposure in Brake Repair Workers in the United States". Mt. Sinai Journal of Medicine, 43:207-218, (May-June 1976). 2. National Occupational Hazard Survey. U.S. Dept. of Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health; estimate, April 1981. 3. Stanford Research Institute (1976). Chemical Economics Handbood, 712.1000C, October 1977. 4. Much of the historical information on the development of fricition products was obtained from interviews by Dr. William J. Nicholson, Mount Sinai School of Medicine, with Edward W. Drisane, Friction Materials Standards Institute, Paramus, N.J., Harry, H. Wagner, Jr., Molded Materials Co., Ridgway, Pa. 5. Keasbey and Mattison products catalog, 1926. Ambler, Pa. 6. Friction materials on automotive brakes. Fleet Owner, (August 1963) 1. Carroll, W.G. The manufacture of brake linings. British Plastics 414-417 (August 1962). 8. Anderson, A.E., and R. Gealer. Ford Motor Co., Detroit, MI. Unpublished notes. 9. White, Andrew J., Brake Dynamics: an introduction to brakes at the inspection station level. Motor Veh. Resh. of N.H., Lee, N.H., Chapter 11, 463-472~ (1968). 10. Rohl, A.N., et al. Asbestos exposure during brake lining. 11. U.S. Code of Federal Regulations, Title 29, part 1910.1001. U.S. Department of Labor, Occupational Safety and Health Administration,Occupational Safety and Health Standards. 12. Taylor, D.G., (1977). NIOSH Manual of Analytical Methods. 2nd Edition, Volume 1, P&CAM No. 239, Publications No .77-157-A. 13. Zumwalde, R.D~, and Dement, J.M., (1977). Review and Evaluation of Analytical Methods for Environmental Studies of Fibrous Particulate Exposures. DHEW (NIOSH) Publication No. 77-204. 14. Taylor, O.G., (1977). NIOSH Manual of Analytical Methods. 2nd Edition, Volume 1, P&CAM No. 222, Publication No. 77-157-A. 15. ~aylor, D.G., (1977). NIOSH ~anual of Analytical Methods. 2nd Edition, Volume III, Sl86, 341, 366 Publication No. 77-157-C. 28 . ~--------------------------------------------------~------------------- FMSI 03616 : .. 16. Newhouse, M.L. and Thompson, H. Mesothelioma of pleura and peritoneum 'following exposure to asbestos in the London area. Brit. J. Ind. Med. 22:261-269, 1965. 17. McDonald, A.D. et al. Epidemiology of primary malignant mesothelial tumors in Canada. Cancer 26:914-19, 1970. 18. Greenberg, M. and Lloyd Davies, T.A. Mesothelioma Register 1967-1968 Brit. J. Ind. Med. 31:91-104, 1974. 19. Bader, M.E., Bader, R.A., Teirstein, A.S., Miller, A. and Selikoff, I.J. Pulmonary function and radiographic changes in 598 workers with varying duration of exposure to asbestos. Mount Sinai J. of Med. 38:492-500, 1970. 20. Davis, J.M.S., and Coniam, S.W. Experimental Studies on the Effects of Heated Chrysotile Asbestos and Automobile Brake Lining Dust Injected into the Body Cavities of Mice, Experimental and Molecular Pathology, Volume 19, pp. 339-353 (1973). 21. Koshi, K., Hayashi, H., and Sakabe, H. Biological and Mineralogical Studies on Serpentine Minerals in Heat Treated State, Ind. Health, Volume 7, pp. 66-85 (1969). 22. Pott, F., Ruth, F., and Friedricks, K.H. TUmorigenic Effect of Fibrous Dust in Experimental Animals. Environ~ental Health Perspectives, Volume 9, pp. 313-315 (1974). "23. Pott, F., Dolgner, R., Friedricks, K.H., and Ruth, F. Animal Experiments Concerning the Carcinogenic Effect of Fibrous Dusts. Interpretation of Results Considering the Carcinogenesis in Humans. Annales d'Anatomie Pathologique, Paris (1976), Volume 21, pp. 237-246. 24. Davis, J.M.G. The Fibrogenic Effects of Mineral Dusts Injected into the Pleural Cavity of Mice, British Journal Exp. Pathology, Volume 53, pp. 190-201, (1972). 25. Stanton, M.F., Layard, H., Tegeris, A., Miller, E., May, H., and Kent, E. 'the Carcinogenicity of Fibrous Glass: Pleural Response in the Rat in Relation to Fiber Dimension. J. Natl. Cancer Institute 58:587-603, {l-larch 1977). 26. u.s. Code of Federal Regulations, Title 29, Part 1910, Section 1910.1001. 27. Leidel, N.A., Bayer, S.G., Zumwalde, R.D., and Busch, K.A. NIOSH Technical Report "USPHS/NIOSH Hembrane Filter Method for Evaluating Airborne Asbestos Fibers". DREW (NIOSH) Publication No. 79-127, February 1979. 29 -- --------,.,.., . -- -- -- ____.___......._..,.....,_._.,.,...., .............~.,_,,...,,,......,.., - --~--- ............. ......_...; .._. ........_......_,_.. _...,___ FMSI 03617 : : ...-. ,_ .. . -4 .-' : ' 28. Bayer, S.C., Zumwalde, R.D., and _Brown, T.A. Equipment and Proc~dures for Mounting Millipore Filtersand Counting Asbestos Fibers by Phase Contrast Microscopy. Available from u.s. Department of Health and Human Services, National Institute for Occupational Safety and Health. 29. Gillam, J.D., Dement, J.M., Lemen, R.A., Wagoner, J.K., Archer, V.E., and Blejer, H.P. Mortality Patterns Among Hard Rock Gold Miners Exposed to an Asbestiform Mineral. Annals of the New York Academy of Scien:es. 271:336-344, 1976. 30. Stanton, M.F., Blackwell, R., and Miller, E. Experimental Pulmonary Carcinogenesis with Asbestos. Am. Ind. Hyg. Assoc. J. 30:236-244, 1969. 31. u.s. Department of Health and Human Services, Public Health Service, National Institutes of Health. Asbestos: An Information Resource. DHHS Publication Number (NIH) 79-161. May 1978. 30 _____._.,..,._. .., . __..~ ------~-~4- ~ ~-~ ~----------------=-- ~ ..-~---:----~--- FMSI 03618 '!f: ; ..' .. . t,. !... . .~ 1.o till ... . ... t' ..,. ... ' ; " :, { ~ .. . . .~ ; .:. ~ ' IJNJ.\f;'f ' . . . ... i ,..'. \' ' I oi' 1 i ~ , .t .. :~ .. .., '~"\ I, ..:;.: :. ... ' .,,!_1,1 ... .,_" . L..; ,:, ..: .;/. -a .. . .,u. . .;;,.......:... ..., ..... :,.;~.,. ~~ :~:;,;:.:, .-l; .......;.:i;..::;;,;.;;i. h' : ' : ;. ; " * I : w..:..~ d. ......: .'. . . . . . .,i;;.i.___......, tabla I Plbae Ale s..pta laaulca foe lraka Aaaa.blJ Clean-off Mathoda ;. C1eaninlt Method Flbauf. Cedprened Air Compressed Air IG I. G Compreued Ah' Compressed Air Compressed Alr IG c G I I Compressed Alr .I Compressed Air I .Comprened Ah Cc;,mpreued Alr I I1 I1 1 1 ;' l I j w .. I !f l Compressed Air Solvent Hht Compressed Air Solvent Hht Compressed Air Solvent Mist Compressed Air Solvent Hht . 1 1 1 I i Dry Brush D Dry Btush ID ., Wet Brush Wet Brush Ic c 3: Wet Btush Wet Brush ~ Ic Ic I0wc Liquid Squirt Bottle Vacuum Cleaning I I I E .,.I. Vacuum Cleaning CD Vacuum Cleaning IE IE IHechanic #1 I 1,82 IHechanic: #1 IHechanic: #1 o0..1n4 IHechanic: #1 0.35 IHechanic: (11 2.69 I IHechanic: #1 IHechanic: (12 2.84 0.91 IHechanic: (12 14.54 IHec:hanic #3 15.00 IIHechanic 11 II o.u IHechantc: 11 I 0.45 IHechani~ 112 0.68 IHechantc 12 0.37 IHechantc 11 !Mechanic: 12 IHechanlc: #1 IHechanic (12 IHechanic (12 IHechanic Ill I IHechanic #1 I IHechanic (11 ,1IHechanlc Ill IHcchanlc: I I I I I I 0.81 0.61 2.62 2.22 0,87 0.67 0.54 o.oo I 34 60 45 30 . 30 I 60 I I 45 30 180 720 I 1260 I I 180 I 180 540 540 I I 600 I I '120 Flbt" '>~ ""' In len~th POl' cubic C<'nllm.-tcr of aamplcd ah TWA Exeosures** I Sample I Sample I I I Time I Volume I rtbeu/ cc* I 4.2 I 0.03 I H2 I 604 I o.ou I 380 I 10.7 I 8.0. 5.3 5.3 I 0.12 0.10 I 0.19 283 I 298 I 270 I I 566 o.1o I596 O,Q8 I540 o.u 4,0 I o.oa I I 343 I a.o 686 I o,o4 . 5.3 12 I 0.07 I 283 I 566 I 0.03 I I24 0.20 I 197 42 t'.19 I 301 I 394 I 0.07 I602 0.03 6,0 I 0.23 I6,() 0.28 I I I I I18 ,, 18 I 0.24 346 I 369 135 I 20 I 0.21 I 326 I 692 I 0.07 738 0.07 270 I 0,07 652 I 0.06 I I 133 227 94 I 231 I 222 I 414 I 382 I . 360 360 I 360 I 395 760 266 454 'l 181 ,. .,.I -' 462 ..... j. 444 828 764 720 720 720 790 756 Table 2 Air Sample Results For Fibers Comparison Between TEM and Optical Microscopy Analyses 0 tical Microsco >5 JJm in length fibers/cc Transmission Electron Microsco >5 )Jm in length Total Fibers % Fibers fibers/cc fibers/cc >5 p.m in length 0.54 6.0 0.58 1.18 0.13 6.84 5.59 0.82 0.01 0.01 0.02 0.38 1.44 0.01 0.26 0.24 0.06 0.12 0.01 0.03 0.0 (Blank) 0.12 0.17 0.18 0.06 0.12 0.25 5.97 0.17 0.67 0.10 0.07 0.33 0.02 o.o o.o 0.19 0.16 o.o o.o 0.09 0.04 o.o 0.01 o.o o.o o.o 0.42 0.10 0.14 0.05 0.50 0.50 11.33 1.01_ 2.35 o. 74 0.43 0.39 0.02 o.n o.o 2. 72 0.48 0.08 1.43 0.09 0.16 0.0 0.01 0.03 o.o o.o 0.86 0.20 0.43 0.15 0.73 * Note: Fibers counte by TEM represent asbestos fibers on y. 50 53 17 29 14 17 83 100 0 0 14 33 0 0 100 25 0 100 0 0 0 48 50 33 33 68 32 FMSI 03620 Table 3 Brake Dust Fiber Size Data Airborne Samples (Asbestos Fibers Only) Airborne Samples (All Fibers) Bulk Brake Dust (Asbestos Fibers Only) ~ Bulk Brake Dust (All Fibers) Number . of Fibers .J Range . I Mean r. Geometric 1- Number - . !Std. Dev. _lof Fibers Ran2e I Geometric I Geometric I Mean Std. Dev. ~---I 151 I o.o6- 1.0 o.15 I 2.36 I 151 I o.24-1o.o I 1.10 I 2.21 I I .( 523 I o.o6- 1.0 o.l4 I 2.11 I 523 I o.24-lo.o I 1.66 I 2.49 I I 8 I o.o6-0.l8 0.10 I 1.53 I 8 I 0.24-1.76 I o.4o I 2.03 I I. 109 I o.o6-o.29 o.o8 I t.53 I 109 I o.24-5.88 I o.49 I 1.95 LI _______________ IL_ __ _ II III I _j _____ ___L Note: All fiber size data determined by Transmission Electron Microscopy. .,r~:; .,, 3-:"T\ f.-... "' 7 ;J .... ;\1 (/) 0 (e..,...n..),. Table 4 Trace Metal Analyses B 1.2 - 8.7 1.7- 2.3 0.2 - 0.3 0.2 - 0.3 0.04 - 0.06 c 19.5 - 24.9 1.2 1.4 0.3 - 0.3 0.2 - 0.2 0.04 - 0.05 I.D 0.4 - 0.8 I 1.5- 1.8 I 0.3 - 0.5 0.1- 0.2 0.03 _ o.o4 I II 1 I N.D. - 63.3 N.D . - 349.3 N.D. - 351.9 N.D. N.D. I I IK j N.D. - 24.0 N.D. - 1.452.8 N.D. - 26 N.D. - 8.70 N.D. - 3.50 Iw.p. , OSHA Exoosure Standard tH!./m 50 10.000* T 5 000** ,.1,000*** J 5,000**** I ----~' 100 -NIOSH Recommended Standard u2/m 5,000_ -- --- - I- N.D. - Not Detected by Analysis * Iron Oxide Fume ** Zinc Oxide Fume *** Copper Dusts and Mists ****Ceiling ~ : , ,. '' .!, I .~ .l t .. 'tt , i a"i~~;:J.f1,,: r''.:~.i/"..<~Ff.. ~..: f ..... !.! -esn: w0 en N N ATTACHMENT I RECOMMENDED PROCEDURES FOR ASBESTOS BRAKE AND CLUTCH SERVICING -=---.,..,.... j,J ~ ...;~\i ~ The National Institute for Occupational Safety and Health (NIOSH) has conducted research on dust exposures which are generated during brake and clutch servicing. Based on data demonstrating the potential for significant asbestos exposures during brake and clutch servicing, NIOSH has investigated various work practices which are utilized in reducing asbestos exposures. These investigations have indicated vacuum cleaning systems to be the most effective method for minimizing asbestos dust exposures during brake and clutch servicing. 1 Vacuum cleaner testing have demonstrated that these units operate reliably within design specifications. 2 Therefore, NIOSH recommends vacuum cleaning as the primary method to be used.for cleaning of asbestos dust during brake and clutch servicing operations. The following are additional procedures recommended by NIOSH to minimize asbestos dust exposures. 1. Where possible, an area shall be designated for brake and clutch repairs and servicing. Entrances into this area shall be posted with the following asbestos exposure warning sign printed in letters of sufficient size and contrast to be readily visible and legible: Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Area Unless Your Work Requires It Breathing Asbestos Dust May Be Hazardous to Your Health FMSI 03623 2. Dust shall first be cleaned from brake drums, brake backing plates, brake assemblies, and clutch assemblies using an industrial type vacuum cleaner equipped with a high efficiency particulate air filter system (HEPA-greater than 99% efficiency for 0.3 pm diameter aerosols). Kfter vacuum cleaning, any remaining dust shall be removed using a water dampened cloth or rag. Under no circumstances shall compressed air or a dry brush be used for cleaning. If vacuum cleaning equipment is not available the wet brush cleaning method may be used until a vacuum cleaning 'system in obta~ned. Where wet brushing is necessary for cleaning, a NIOSH certified respirator approved for asbestos shall be worn. 3. During brake pad grinding, rivetin$, and punching operations local exhaust ventilation and dust collection systems shall be designed, installed, and -maintained in accordance with the American National Standard Fundamentals Governing the Desig~ and Operation of Local Exhaust Systems, ANSI Z9.2 - 1977 to meet the asbestos airborne exposure standard 4. During clutch servicing, a NIOSH certified respirator approved for asbestos shall be worn during the removal and cleaning of the clutch, pressure plate and housing assembly, and during installation ~f the new clutch assembly. Whenever possible, cleaning shall be performed with-an HEPA vacuum system as described in (2) above. 5. All table and floor cleaning in areas where brakes and clutches are repaired shall be done with the HEPA vacuum cleaner as described in (2) above. Grinding and riveting machines- shall also be cleaned with such a 36 FMSI 03624 cleaner and the remaining dust wiped with a water dampened cloth. A NIOSH certified respirator approved for asbestos shall be used during this cleaning. 6. If not in effect. a respirator program shall be established in accordance with the Occupational Safety and Health Administration (OSHA) Standards. Title 29. U.S. Code of Federal Regulations (CFR). Part 1910.134. 7. HEPA vacuum cleaner filters containing asbestos dust. cloths or brushes used for wiping brake and clutch assemblies. and all liquid used for wet brushing shall be disposed of in accordance with U.S. Environmental Pr~tection Agency (EPA) regulations. These regulations state that the asbestos waste shall be disposed of in sealed impermeable bags or other containers at a disposal site which meets EPA criteria for asbestos dispos- al. Also. the waste containers shall display the following warning label or tag printed in letters of sufficient size and contrast to be visible and legible: CAUTION Contains Asbestos Fibers Avoid Breathing Dust Breathing Asbestos Dust May Cause Serious Bodily Harm The EPA regulations for proper asbestos was.te disposal are detailed in Title 40. CFR. -Part 61. ~ubparts A and B. FMSI 03625 8. A NIOSH certified respirator approved for asbestos shall be worn during r~moval of vacuum bags which C"ontain asbestos dust. 9. Consumption of food and beverages shall not be permitted in work areas where asbestos exists. An area designated for food consumption shall be separate from the work area so as to provide maximum protection against asbestos dust contamination. 10. If the employee is exposed to airborne concentrations of asbestos fibers which exceed the OSHA ceiling level, the OSHA requirement regarding special clothing, change rooms, locker, etc. as detailed in Title 29, CFR, Part 1910.1001 (D) shall be followed. The current OSHA asbestos standard is as follows: the s:..hour time-weighted average (TWA) airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers in length per cubic centimeter of air (fibers >5 pm/cc).The ceiling airborne concentration to which no employee may be exposed shall not exceed 10 fibers >5 lJIIl/Cc. OSHA in 1975 proposed an 8-hour TWA of 0.5 fibers >5 pm/cc with a permissible ceiling exposure of 5 fibers >5 pm/cc for any period not exceeding 15 minutes. NIOSH currently recommends that the TWA exposure to asbestos be 0.1 fibers >5 ~/cc with a ceiling exposure of 0.5 fibers >5 pm/cc for any IS-minute sampling period. 38 ------------ FMSI 03626 NOTE: Strict adherence to the above procedures should minimize exposures to employees duting brake and clutch servicing. These recommendations are based on the results of research conducted by N!OSH. Prepared By: Division of Surveillance, Hazard Evaluations, a~d Field Studies National Institute for Occupational Safety and Health Cincinnati, Ohio 39 ~----------...-- ~---=-- ~--------.--- ~------,-- FMSl 03627 Fl(lCTIJi.: .IATERIALS STA:lDlu'WS IdSTITUTE, INC., E-213 i.~OUTE 4, PA..'R.&!US, N.J. 07652 5ULLETii:~ H 0, 7 0 6 January 29, 1981 ENVIROlfl:lELJTAL PIWTECTION AGEaCY (EPA} P~lOPOSALS FOR REPORTING AHD IlECORDKEEPIUG FOR ASBESTOS iJANUFACTUEERS, TIIPORTERS AiiD PROCESSORS The EPA's Office of Toxic Substances has proposed requirements for asbestos prodacts manufacturers, importers and processors on the reporting on asbestos usage. These proposals are authorized in Section 8 (a) of the Toxic Substances and Control Act (TSCA). To indicate how far-reaching these reporting requirements are, one can note the following from the first page of the proposed rules: Importers include those persons uho import asbestos in bulk form, or as part of any product, Thus, persons who import automobiles that contain asbestos brake linines are "manufacturers" of asbestos for purposes of TSCA. A brake lining or clutch facing manufacturer in the United States would be a primary processor as he uses raw asbestos in the friction product. He would also be a secondary processor "Then he assembles brake linings to shoes. A party who imports lined or unlined shoes would be a ''manufacturer" as indicated above. A rebuilder who purchased brake linings for assembly would be a secondary processor. For more authoritative definitions, please refer to Page 8213 of t~e January 26, 1981 Federal Register, copy enclosed. The Institute is enclosing the notice as it appeared in the Federal Register of January 26, 1981. He have enclosed Pages 8200-8214 only. The forms that are referred to take an additional 35 pages (to Page 8249}, If 11embers ~rlsh a copy of these additional pages. please request them of the Institute Office. It should be noted at this time that this tlotice is a proposal. As noted, the EPA ,.;ill accept written comments relative to this proposal ,.,hich are submitted on or before darch 27, 1981. Hhile this is a far-reaching rule if adopted, a rule of this nature ,.10uld be expected based on the reading of TSCA and the inititatives that the Office of Toxic Substances has already taken in the asbestos area. EVID/ ere Enc: E. H. Dris lane Executive Director Copies: Delegates aud Alternates Health and Environmental Affairs Committee Active Hembers ... List C Regional i!embers Licensees FMSI 03628 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE .oi& PARAMUS. N. J. 07852 INO. May 12, 1980. Mr. Richard Guimond Environmental Protection Agency Office of Toxic Substances 401 M Street SW Washington, D.c. 20460 Dear Rich: You will recall that we met with a group from EPA in Washington on January 3, 1980 concerning information needs of your office. We stated that we would circulate our Members to get answers to some of the questions that you had asked concerning non-asbestos lining. Our questions were in the area of automotive disc brake lining only. Respondents asked that their submissions be kept confidential. I am not therefore disclosing the names of those who answered the questionnaire.'!!: I feel they are representative of the industry. ' I have enclosed a copy of the summary of replies that I received relative to this questionnaire. I had earlier sent you information on usage of non-asbestos disc brake lining on passenger cars and light trucks. This listing included information as to whether there was an asbestos backing with the non-asbestos linings, and where the usage was both inner ~d outer, or inner only or outer only with asbestos material at the other position. I believe these answers should give some background as to usase, advantages and problems with the non-asbestos disc brake linings. : EWD/lac Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE l. ! ':' ' B. W. Drialane '.Executive Director -- FMSI 03629 .. NON-ASBESTOS DISC BRAKE LININGS FOR PASSENGER CARS AND LIGHT TRUCKS INTRODUCTION In November 1979. the Environmental Protection Agency's Office of Toxic Substances drafted several questions on what they considered their information needs on friction products containing asbestos. This was general state of-the art information concerning non-asbestos linings. And. this included all linings-~disc and drum. An Institute Task Force met with EPA on January 3. 1980 to review their needs. and one essential change was that the questions would concentrate on disc brake linings only. The questions were then ro~ted to the Members. asking that replies be only made for (1) discbrake linings used on (2) passenger cars and light trucks. Of the nineteen United States Members, twelve were involved with disc brake linings for passenger cars and light trucks. Of these twelve--and not knowing how many of the twelve have worked on non-asbestos disc brake linings-~three replies were received. They represented a decent cross~section with both original equipment and replacement market emphasis. Some were further a'!ong on development of non-asbestos disc brake linings than others. As the request of those replying. names have been omitted. The answers are grouped together under the questions as they were circulated to the Members. 1. What are the basic ingredients used in non~asbestos disc brake linings which were not used in earlier asbestos type formulations? Of particular interest are the materials used to substitute for asbestos-~those that reflect a net change. Without entering into detail on the layered construction with what is usually predominantly resin-asbestos backing, there are essentially two types of non-asbestos compositions. The foremost is what is referred to as semi-metallic, and which is normally compounded using a resin binder similar to that used with asbestos type linings. The other is a synthetic fiber type mixed with resin binders of a conventional type. 1.1 Semi-metallic - This is a resin-bonded metallic type which uses steel fibers (chopped steel wool) predominantly, with or without iron powders (sponge iron). Because of the ferrous nature of the product rust inhibitors may be 11sed~ While materials such as graphite, silicas and the like inay also be used~ these had been used in earlier asbestos type materials .. 1.2 Synthetic fibers This iJt primar.ily fiberglass. These are chopped glass fibers sized to adatt to the needs of a friction material compound. FMSI 03630 2. As regards the substitute materials, if the substitute is fibrous, what are the physical ch4racteristies of the fiber-structure, fiber size, size distribution? 2.1 Steel fibers Rectangular cross-section: 7S - 100 microns wide Circular or elliptical cross-section: 100 - 250 microns diameter Fiber length: 1 - 5 millimeters 2.2 Fiberglass Circular cross-section: 13 microns diameter Fiber length: 3 - 13 millimeters 3. What are the performance characteristics and the problems associated with the use of substitute products for disc brake linings containing asbestos? How do the substitute non-asbestos pads campare with asbestos pads for lining wear, rotor wearI noise, wet recovery, etc.? 3.1 General - Both the semi-metallic and the fiberglass types are inherently more aggressive. That is, they would normally have higher friction levels, more rotor wear, more brake noise. However, in compounding the materials, other ingredients are added to control friction levels, rotor wear, noise and the like. Before new materials can be sold in either the original equipment or replacement markets, the manufacturer must be satisfied that these problemS are tinder control. Where these materials have been sold commercially, it will depend on the manufacturer if his materials--and they will have more than one material--have such properties as wear, noise and friction characteristics better than or equal to earlier asbestos types. 3.2 Advantages - With commercial semi-metallic types, fade resistance and wear resistance has been improved over asbestos materials. This is particularly true where solid rotors have replaced the earlier ventilated . rotors on front wheel drive cars with unit brake loading (and temperatures)' higher than the passenger cars in the early 1970's. Some manufacturers have shown improved rotor conditions and in some cases less noise with semi-metallics, while others still have problems in these areas. ~3 Problems - The higher conductivity of metallic type non-asbestos linings results in increased heat transfer to the brake fluid which can result in brake fluid boil. Generally, inferior physical strength is associated with semi-metallic types which can result in attachment problems particularly if the material is riveted to the steel brake t shoe. Some, because of the inherently more aggressive nature of the material, have experienced "reverse speed spread." That is, a brake will be more aggressive at higher speedS than at lower speeds. Ferrous materials will show oxidation (rust) and this could be a problem both on-the-shelf and on the vehicle if left standing for long intervals. , Some materials--and this depends on the manufacture~ave ~erienced lower friction when the brakes are cold. -2- .. -- fMS\ 03631 3.4 Backing Layer - Where the manufacturer uses a backing layer (currently backing layers contain asbestos) these can improve the thermal conductivity and physical strength problems. However, these asbestos types are also used because the vehicle owner may permit his linings to wear through to the backing materials, before replacement, and the backing materials must have acceptable friction properties to insure adequate braking. 3.5 Synthetic fiber types - These types are in the development stages and have problems with rotor wear, lining wear and the characteristics --. normally associated with a more aggressive lining. 4. Where you are the original equipment supplier of non-asbestos type disc brake linings, would you describe the packaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: 4.1 Full non-asbestos linings 4.2 Non-asbestos friction material with asbestos baCking 4.3 Use of non-asbestos lining at one position (inner or outer) with asbestos type at other position This question was answered in detail in a letter from Mr. E. W. Drislane of the Friction Materials Standards Institute to Mr. Richard Guimond of the Environmental Protection Agency--letter dated April 21, 1980, a copy of which is attached. 5. Describe the historical development of non-asbestos disc brake linings with data and/or time from (1) initial research, (2) successful laboratory prototype, to (3) availability of commercial product. Also, estimate research and development cost for development of commercial non-asbestos disc brake linings (either in total or for each phase of the development). There is a wide variation in the answers to this question. The shortest times and lowest costs are those estimated by a manufacturer who has been working on development of non-asbestos linings over the last year or two. The highest costs and longest times are those from a manufacturer who has developed resin-bonded metallic type disc brake linings which are now available commercially. The estimated time by one manufacturer is a total of four to five years, with two years from initial research to laboratory prototype, with another two to three years from that point to the availability of a commercial product. The low estimate was $250,000. Another manufacturer states that the semi-metallic types have been studied for fifteen years, and its estimate for commercialization would involve a minimum of three years and $500,000. The manufacturer 'who has a product considered commercial (a semi-111etallic type) states that the overall development period took .. about eight years from initial ~esearch, with research and development costs of about $2,000,000 in 1969 dollars. -3- ~.,, FMSI 03632 6. If a vehicle has a non-asbestos pad as original equipment, what problems or advantages do you see irt use of asbestos tYpe pads for replacement? There are essentially two answers to this question. The semi-metallic types have become original equipment on passenger cars in essentially two different environments. One is where the semi-metallic was phased in on a brake originally developed using asbestos linings. These were primarily domestic passenger cars with ventilated rotors. On the other hand, as is best illustrated by the 1980 General Motors X Cars (Citation, Phoenix, Omega and Skylark), recent developments are with solid rotors on front wheel drive cars where the new materials were required due to the increased operating temperatures of the brake. Where non-asbestos disc brake linings--semi-metallic types--were introduced in existing brake envelopes with ventilated rotors, there should be no problem servicing them with standard asbestos type linings. There may be advantages to use of asbestos type linings to ease problems with thermal conductivity or poor physical strength. One manufacturer believes that there may be some problems magnified in the replacement market where semi-metallics are used, particularly where a rebuilder is assembling lining to the shoe. Also, there is some concern on the oxidation problem due to the time it takes for a product to get through the distribution system. However, where a semi-metallic was desisned originally for the solid rotor brake it is felt that the replacement should also be of that type for fade resistance and lining wear properties. 7. Are the composition and manufacture of non-asbestos disc brake linings developed by your company protected by patent? If so, what are the patent numbers? There are some patents in this area. It is suggested that EPA make its patent search for the information they believe relevant. Caution should be exerted to look at patents probably with dates no earlier than 1970, as the earlier patent literature has considerable information on sintered metal friction materials which are used in aircraft, and in special off-highway high torque high-temperature applications. The sintered materials have not been commercially acceptable in conventional vehicular braking systems. -~""" 8. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brake linings? For example, would your company consider licensing of the technology to manufacture non-asbestos brake pads? While respondents indicated that they have licensed others in friction material technology in the past, all such licensing has been done with organizations in international markets and not in the domestic market with direct competitOl's.< Respondents have either not conaidered this question, or indicate that any . situation involving licensing would be reviewed on its own merits. ,. -4- FMSI 03633 9. Can non-ahestos disc brake linings be manufactured in existing production facilities or will new facilities be required? Please estimate the capital and operating costs, and the availability and lead times associated with acquisition of the machinery and tooling. All respondents concur that non-asbestos disc brake linings cannot be manufactured in existing production facilities. There will be additional operating costs as well as capital costs. Estimates on capital costs including tooling run from $2,000,000 to $6,000,000 to convert to manufac- ture of all non-asbestos disc brake linings. Operating costs are estimated to increase by 5 to 10 percent. Estimates on equipment and tooling ' acquisition run from twelve months to twenty-four months. -- 10. What is the projected unit cost differential between these three popular domestic disc brake lining sizes containing asbestos and non- . asbestos sUbstitutes? (FMSI 728A, 7013A, 7017A) Two respondents indicated that the non-asbestos formula would be 200% of the asbestos formula. One respondent indicated (depending on FMSI number) costs of from 275% to 315% of the asbestos formula. -~~ 11. Based on your 1979 production, how much asbestos would-be eliminated in a total conversion to non-asbestos disc brake pads? This question could not be ans-wered directly from the respondents as it would be meaningless without knowing the volume produced by each. Based on the answers and an estimate of asbestos disc brake lining production in the United States in 1979, the Institute attempted to develop a response for this question for the entire industry. Based on estimates of 76,000,000 pieces of disc brake lining sold in the aftermarket, and approximately 40,000,000 pieces sold for original equipment, an estimate for disc brake linings sold in 1979 for passenger cars and light truCks is 116,000,000 pieces. Of the 40,000,000 original equipment, an estimate is made that 30%, or 12,000,000 pieces were non-asbestos types, leaving 104,000,000 pieces of asbestos type disc brake linings sold in the United States in 1979. With an approximation that for domestic cars each lining weighs .35 pounds, and that half the content is asbestos, a projected total use of asbestos in automotive disc brake linings for 1979 is: 104,000,000 X .35 X .50 X 1/2000 9,100 Tons Allowances were not made for the asbestos in the backing for some non-asbestos linings. However, it is not f~lt that this would alter the projections significantly. It is estimated~ therefore, that 9,100 Tons of asbestos ( would be eliminated in a total eonversion to non-asbestos disc brake pads. ~ -s- FMSI 03634 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. APR 21 1980 Mr. Richard Guimond Environmental Protection Agency Office of Toxic Substances Waterside Mall-East Tower 401 M Street Southwest Washington, D.C. 20460 Dear Rich: In our meeting in January we drafted several questions for the Membership concerning friction products ~ontaining asbestos. At our January 3, 1980 meeting we agreed on revision' of some of the wording. Our question #4 was worded as follows: "Where you are the original equipment supplier of non-asbestos type disc brake linings would you describe the paCkaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: 4.1 Full non-asbestos linings 4.2 Non-asbestos friction material with asbestos backing 4.3 Use of non-asbestos lining at one position (inner or outer) with asbestos type lining at other position The Friction Materials Standards Institute gathered some of this information from original equipment sources and we have the enclosed presentation to make as regards that information. I wish to caution, however, that some of the information is not clear-cut. In other words, in certain model years some semi-metallics which have been used on disc brakes were phased in and may not have been production for the full year. We are still attempting to gather the information on the other questions that were_asked. I must admit that replies have been slow. I will continue to attempt to gather sufficient information to provide you with reasonable answers to the other questions that were sent the Membership. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE, INC. EWD/lmc E. W. Drislane Executive Director FMS\ 03635 POLICE AND TAXI USAGE OF NON-ASBESTOS DISC BRAKE LINING ON FRONTS Police and Taxi usage of non-asbestos disc brake linings was as a Police/Taxi option--actual usage depended on customer ordering that option. Ford=Mercury in 1976-78 also had non-asbestos disc rears for the Police/Taxi option. Non-Asbestos Lining ~ith Asbestos Backirtg) AMERICAN MOTORS 1978, Concord Police, Taxi 1978-75, Matador Police Outer only Both I & 0 BUICK 1980-71, 1980-79, Buick Police, Taxi Century Police Both I & 0 Both I &0 CHEVROLET 1980-71, Chevrolet Police, Taxi 1979-77' Nova Police 1980-79, Malibu Police Both I & 0 Both I & 0 Both I & 0 CHRYSLER 1980-76, 1980-78, 1980-77' Chrysler Police, Taxi Cordoba Police LeBaron Police, Taxi BothI &0 Both I & 0 Both I &0 DODGE 1980-77' 1980-79, 1980-77' 1978-77' 1977. Aspen Police, Taxi St. Regis Police, Taxi Diplomat POlice, Taxi Monaco Police, Taxi Royal Monaco Police, Taxi Both I & 0 Both I & 0 Both I & 0 Both I & 0 Both I & 0 FORD 1980-78, 1980-76' 1980-76' 1979-78, Fairmont Police, Taxi Ford Police, Taxi Granada Police, Taxi LTD II Police, Taxi Both I & 0 Both I & 0 Both I & 0 Both I &0 MERCURY 1980-78, 1980-76, 1980-76, ~ephyr Police, Taxi Mercury Police, Taxi Monarch Police, Taxi Both I & 0 Both I & 0 Both I & 0 OLDSMOBILE 1980-71, Oldsmobile Police 19 80-79, - Cutlass Police Both I & 0 Both I & 0 PLYMOUTH 1980-77' 1980,77, 1978, Volare Police, Taxi Gran Fury Police, Taxi Fury Police, Taxi Both I & 0 Both I &0 Both I &0 PONTIAC 1980-71, 1980-79, Pontiac Police, Taxi Phoenix Police Both I &0 Both I & 0 FMSI 03636 PASSENGER CAR AND LIGHT TRUCK USAGE OF NON-ASBESTOS DISC BRAKE LININGS , (See separate listing for Police/Taxi option usage) AMERICAN MOTORS 1980, 1980, 1979, Spirit, Concord 4's Spirit, Concord, Eagle 6's AMX BUICI<. 1980, 1980-79, 1980, 1980, 1980, 1980-76' 1979-78, 1979-78, 1979-76, 1977-76, 1975-73, Buick Electra Riviera Regal, Century Skylark (Power brakes) Skylark (Manual brakes) Skyhawk Regal, Century (Power brakes) Regal, Century (Manual brakes) Skylark Century (Manual brakes) Apollo (Manual brakes) CADILLAC 1980-79' Eldorado (Diesel) 1980-79, Seville (Diesel) 1980-68, Commercial CHEVROLET Non-Asbestos Lining (With Asbestos Back) Non-Asbestos L'ining Ottlt Outer only Outer only Outer only I &0 I &0 I &0 or Outer only I &0 I &0 I &0 Inner only I &0 Outer only Oute;r only Outer only I &0 I &0 I &0 1980, Monte Carlo, Malibu 1980, Citation (Power brakes) 1980, Citation (Manual brakes) 1980-76, Monza 1980, Chevette 1980-76, Camaro 1979-78, Monte Carlo, Malibu (Power brakes) 1979-78, Monte Carlo, Malibu (Manual brakes) 1979-76, Nova 1977-76, Malibu (Manual brakes) 1977-76, Vega 1975-73, ..Nova (Manual brak-es) I &0 I& 0 Outer only I &0 or I &0 I &0 Inner only Outer only Outer only I &0 Outer only Outer only Outer only I Inner Lining 0 Outer Ltbing FMSI 03637 , CHEVROLET TRUCK 1980-78, 1980-79' 1980-79' 1980-79. 1980-79. 1980-79' 1978-76, 1978-76, El Camino C-,K-,P-20 c-,P-30 K-30 P-30 (JF-9) (Front &Rear) G-30 C-,K-,P-20 C-,G-,P-30 DODGE 1980-78, Omni , DODGE _TRUCK 19 78-76, . Mini Bus 1976, W-300 FORD 1980-79, 1980, 1980-79' 1980-79' 1980, Fairmont V8 'Thtmderbird Mustang V8, Turbo 4 Fiesta Mustang V6 FORD TRUCK 1980-76, 1980-77. 1980-76, 1978-76, 1980-76' 1980, F-100 (4x4) F-150 (4x4) Bronco F-250 (Lt) E-250, F-250 (HD), E-350, F-350 E-350 School Bus GMC TRUCK 1980-78, 1980-79. 1980-79, 1980-79' 1980-79, 1980-79, 1978-76, 1978-76. Caballero C-,K-,P-2500 c-,P-3500 K-3500 P-3500 (JF-9) (Front &Rear) G-3500 C-,K-,P-2500 c-,c-,P-3500 MERCURY 1980-79' 1980, 1980-79' 1980, Zephyr V8 Cougar Capri V8, Turbo 4 Capri V6 Non-Asbestos Lining (With Asbestos Back) Non-Asbestos Lining only I &0 I & 0 or I & 0 I & 0 or I &0 I &0 I &0 I &0 I & 0 or I &0 I &0 or I &0 I &0 I.& 0 I &0 I &0 I &0 I &0 Outer only I &0 I &0 I &0 I &0 I &0 Inner only I &0 I &0 I &0 I &0 I &0 I &0 I &0 or or OJj or I &0 I &0 I &0 I &0 I &0 I &0 I &0 I 1& o I &0 I &0 FMSl 03638  OLDSMOBILE 1980, 1980-79, 1980, 1980, 1980, 1980-76, 1979-78, 1979-78, 1979-76, 1978-76, 1977-76, 19 75-69' 1975-74, 1975-73, Oldsmobile 98 Toronado Cutlass Omega (Power brakes) Omega (Manual brakes) Starfire Cutlass (Power brakes) Cutlass (Manual brakes) Omega Toronado Cutlass (Manual brakes) Oldsmobile Commercial Toronado Omega (Manual brakes) PLYMOUTH 1980-78, Horizon PONTIAC Non-Asbestos Lining (With Asbestos Back) Non-Asbestos Lining Only I &0 I &0 I &0 Outer only Outer only I &0 I &0 I &0 or I & 0 I &0 Inner only I &0 Outer only Outer only Outer only I &0 1980, 1980, 1980, 1980-76, 1980-76, 1980-79, 1979-78, .1979-78, 1979-78, 1977-76, 1977-76, 1977-76, 1975-73, LeMans,Grand Prix Phoenix (Power brakes) Phoenix (Manual brakes) Sunbird Firebird (drum rears) Firebird (organic disc rears) LeMans, Grand Prix (Power brakes) LeMans , Grand Prix (Manual brakes) Phoenix Ventura LeMans (Manual brakes) Astre Ventura (Manual brakes) Toyota 1980, . Corolla Coupe I &0 I &0 I &0 Outer only I &0 or I &0 I &0 Inner only Outer only I &0 Outer only Outer only Outer only Outer only I &0 FMSI 03639 TELEPHONE ( 20 II 8411-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. March 6, 1980 Hrs. Joni T. Repasch, Record Clerk Office of Toxic Substances (TS-793) Environmental Protection Agency 401 1:1 Street, S.H. Hashington, D.C. 20460 Subject: D . ~ct Humber OTS-61005, Environmental Protection Agency ANPRH on Asbestos--Friction Haterials Gentlemen: The Friction !lateri<ds Standards Institute is an association of manufacturer!! of brake linings and clutch facings. The Institute would like to comment on the Environmental Protection Agency's Advanced Notice of Proposed Rulemaking in the FEDERAL REGISTER of October 17, 1979, concerning the use of products containing asbestos. In particular, we would like to comment on questions posed on Page 60067 as they relate to Friction Haterials. Friction l1aterials is a broad classification which covers such products as automobile brakes, both disc and drum, truck brakes, fan and transmission clutches, and other devices used in the Automotive, Truck, Bus, Heavy Vehicle, Aircraft and other industries to stop, slow or control moving mechanical parts. He believe the largest usages to be in the Automotive, T-.,.ek, Bus, Heavy Vehicles and Aircraft industry. Friction Ilaterials may contain anywhere from zero (0) to 60% asbestos by composition depending upon the nature of the heat build up generated and required for control of the mechanical device involved. Brake and clutch emissions and information related to the disposition of asbestos is contained in a report prepared for the Environmental Protection Agency, Office of Air and Fater Programs, Ann Arbor, ~Iichigan 48105, entitled Brake Emissions: Emission !!easurements from Brake and Clutch Linings from Selected Hobile Sources, EPA Contract 1!68-04-0020, conducted by t-1. G. Jacko and R. T. DuCharme, Final Report for Period Itay 1971-Harch 1973. The EPA technical officer ~7as Dr. Joseph H. Somers. He call this report to your attention in that it provides the information and data to ans,7er many of the questions posed in the EPA advance notice of Proposed Rulemaking. The answers to the questions of (a) number of people exposed (b) routes duratio~ and frequency of exposure (c) the intensity of exposure and (d) fiber size distributions require several source documents. l.Je suggest you refer to a January 3, 1979 draft by Dr. W. J. Nicholson of Haunt Sinai Hospital entitled "Investigation of Health Hazards in Brake Lining Repair and Uaintenance Harkers Occupationally Exposed to Asbestos~ As that paper >-Tas a draft for comments, we believe you should contact Dr. Nicholson for that information on exposure levels and fiber sizes. FMS\ 03640 Environmental Protection A~ency -2- We are familiar t-rith an liT Research Institute report prepared for the Office of Toxic Substances, in l>hich they attempted to develop a people exposure index based on several factors such as releasability of the fiber, frequency of exposure, duration of exposure, etc. While we will comment analyzin~ the inputs used for the liT Research Institute exposure index, l-7e do not liish to indicate that the mathematical exposure index is a meaningful index. It is constructed lith several assumptions and arbitrary numerical levels l'7hich make it anything but an absolute index. He ,.1ould like to provide an explanation of the brake repair business within the fr~ork which liT Research Institute arbitrarily constructed. By doing this, a better understanding of the actual number of persons exposed and duration of exposure will be presented. Essentially, there are two areas uhere a brake repair worker may be exposed to airborne asbestos dust. They are: (1) In a shop which performs machining operations--such as grinding, drilling, bevellinr,, etc., and (2) In a shop where the brake repair \;orker blows brake ,~ear debl.'is from the drum and brake parts of a car beinr; serviced. To take three factors from the liT Research Institute report from their Table 2 for Brake Linin~s (Releasability 2, User 1, Population Exposure 2), these factors cannot be put in the same equation for perhaps 99% of brake wcrl:. Hhere the User and Population Exposure is high,i.e., the national chain, the corner ~ara~e--the shops involved most often do not have access to machining equipillent and thus the releasability code 't>ould be 3 rather than 2--"fibers locked in and not likely to be released in normal use." Contrariwise, in the shops that have machining operations,i.e., fleets, municipal gara~es, where the releasability factor may be 2--"fibers locked in but releasable' during machining--the overall ~v-ork force exposed is small. The liT Research report gives all brake repair a duration factor of 1 (12 hours per day). The averase brake re?air '"orker :fn a busy shop could do three or four brake jobs a day. The only exposure he '~ill have--since most brake repair shops do not machine the friction materials-~'10uld be from the dust blown from the brake being serviced. Hhile t7e agree for common sense reasons that blowing dust of any type should be discouraged, the brake wear debris has only a small fraction of asbestos--less than 1% iM most studies. Even with the blm~inr, out of debris from brake drumst the duration cannot be 12 hours. The duration is more likely less than one minute per brake. \-lith the advent of disc brakes on the fronts of most cars, this means less than 2 minutes per vehicle if the rear drum brakes are relined. ~~en the time, the low asbestos content in the wear debris, and the fact that four brake jobs per day ~-Jould be a busy shop, the 12 hour duration assigned to all brake repair is not justified. 'He t.-rould like to co!llltlent on the do-it-yourselfer. He has the best of all worlds. (1) He doesn't have machininr. equipment so his repair job cannot have a releasability factor of 2; (2) He doesn't have access to an air hose so his duration must be near zero; (3) The do-it-yourselfer probably does no more than one brake job a year so he cannot have the frequency assignment of 365 (daily) given to the brake repair worker. FMSI 03641 Environmental Protection Ar,ency -3- Hhile additional examples could be given Hhere the same factors or codes could not be assigned to all groups of brake repair workers, the point is that all brake workers cannot be categorized under one set of exposure codes. In other words, the liT Research Institute report took the ''Population Exposed" and "User" characteristics \"thich are based on perhaps 900,000 10rkers in the brake repair area, &ld assigned the~ all the second most objectionable code for releasability and the worst codes for frequency and duration. The exposure criteria should be analyzed by the segments of the v,york force and not by the total ~iork force if one is to assirrn correct codes for releasability. duration and frequency. ~,1hi le estimates are necessary, we have prepared a table to indicate what lle estimate the exposure factors (or codes} to be in brake repair facilities. ESTI}~TED EXPOSURE FACTORS IN BRAKE REPAIR FACILITIES BY TYPE Estimated NUI!lber of Brake Repair Ty2e Brake Reeair Operation Releasabilit:y: Freguenc:x Duration ~"Wod.e-rs Fleet Garages, l'tunicipal Garages, lvith machining operations (2-20 jobs per month) (2-10 brake repair \vorkers) 2 1-2 1-2 10-30.000 Fleet and Taxi Garages without machining equipment (2-20 jobs per month) (2-10 brake repair 1imrkers) 3 1-2 2 10-30,000 Hational and P.egional Chain, Tire Company, Car Dealer (10-50 jobs per month) (2-10 brake repair workers) 3 1 3 50-100,000 Gas Station, Corner Garage (2-10 jobs per month} (1-2 brake repair workers) 3 1-2 3 400-800,000 Do-It-Yourselfer (1 joh per year) 3 4 "A 1-5,000,000 FMSI 03642 Environmental Protection Agency -4- A simple conclusion is {1) !!here the releasability, frequency, and duration is highest, the smallest population is exposed, and (2) tfuere the population "exposed;; is high, releasability, frequency and duration are low. In the fleet and municipal garap;es, uhere exposures are highest, these shops should be taking steps to comply with OS11A regulations. Shops of this type should be in compliance l~th OSHA regulations and thus will have the necessary eXhaust ventilation equipment and procedures to maintain exposure levels bel~~ those suggested in the IIT Research Institute report and in the table shm~ above. In summary, the shops trhich may potentially have the greatest population exposed do not have the asbestos eA~osure factors of the fleet and municipal garages with grinding equipment. It is suggested that a voluntary action program, with labeling and education be aimed at these smaller facilities. Compliance with OSHA regulations should be emphasized at the larger facilities, and particularly those tTith machinine operations and thus new regulation from the EPA is not necessary. Sincerely, FRICTION HATERIALS STAtmARDS INSTITUTE, INC. EWD/erc E. l.J. Dris lane Executive Director FMSI 03643 February 19, 1980 Mr. Albert Colli Environmental Protection Agency Office of Toxic Substances Waterside Mall - East Tower 401 M Street SW Washington, D.C. 20460 Dear Al: Thank you for the copies of your minutes of the meeting that we had with EPA on January 3, 1980. I do not believe that we have basic differences, but the questions drafted to correspond to your Enclosure III are as shown on the attached two pages. As I indicated, I don't believe there are any significant differences, but Question 2 for Enclosure III did not include a question regarding the evaluations on health effects of non-asbestos disc brake linings or materials used therein. As indicated at the meeting, no one has that information and the question was re~orded to determine the physical characteristics of the fibers should they be the cause of health problems. Also, where you have Questions 4 and 5, we were more specific in our Question 4. The questions had to directly address the problem and be more specific than was indicated in your Questions 4 and 5. I believe the rest of the questions go along with the wording in your Enclosure III. After my return from Washington I went over these questions and the wording to be used with both Mr. Moalli and Mr. Armstrong. It was agreed that this wording that 'liTe show was as we understood it from the meeting. If you feel that the differences in the wording are of sUbstance and could present a problem please let me know, as we have already sent our questionnaire to the members using the wording indicated in our write-up. If there are problems with the foregoing please let me know. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE EWD/lmc E. W. Drislane Executive Director FMSI 03644 February 19, 1980 Mr. Jim Armstrong Bendix Corporation Bendix Center Southfield, Michigan 48076 Dear Jim: I am enclosing a copy of EPA's version of the "minutes" of the meeting held with EPA personnel in Washington on January 3, 1980. Without going into the wording of the covering letter and the minutes, any differences are in the wording of the questions as we agreed at the January 3 meeting. The questions indicated in Enclosure III do not appear to differ in substance from the questions the way we drafted them. There may be some question as regards Question 2 concerning the effects of non-asbestos disc brake linings and the materials used therein. My notes specifically indicated that we were not asking this question but instead were asking concerning the fibrous characteristics of the materials. Also, for example, our question number 4 and question number 10 are more specific then the questions indicated with their Enclosure III. I have replied to Mr. Colli with the comments indicated with the copy enclosed. The foregoing is sent to you as a matter of information. Sincerely, FRICTION MATERIALS STAt'IDARDS INSTITUTE, INC. EWD/lmc E. W. Drislane Executive Director FMSI 03645 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 OFFICE OF TOXIC SUBSTANCES Mr. E. W. Drislane, Executive Director Friction Materials Standards Institute Incorporation Bergan Mall Office Center E. 210 Route 4 Paramus, New Jersey 07652 Dear Mr. Drislane: I have attached a copy of the minutes of the meeting between Environmental Protection Agency (EPA) personnel and representatives of FMSI that was held on January 3, 1980. Please let me know if you have any corrections, deletions or additions to the minutes. Sincerely, rut.tJLOL Albert Col! i Enclosure FMSI 03646 UNITED STATES ENVlRONfi!ENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 OFFICE OF TOXIC SUBSTANCES Meeting with the Friction Materials Standards Institute January 3, 1980 At the request of the Friction Materials Standards Institute {FMSI), EPA staff met with FMSI representatives at EPA, ~'lashing ton, D.C. A. list of attendants is attached as enclosure { 1) The purpose of the meeting was to discuss a list of questions on friction products provided to the FMSI by EPA on November 16, 1979. FMS~ was to determine whether their members would answer the questions and what mechanisms should be used to solicit the responses. The list of questions are attached to these notes as enclosure (2). Ralph P. Moalli, representing FMSI, stated that the chances of obtaining responses from the members of Ft1SI would be increased if the questions could focus on disc brakes and exclude drum brakes at this time. He suggested that a second questionaire could be submitted, specifically addressing drum brakes, after the responses to the questions on disc brakes had been secured. Changes to the original questions were made by mutual agreement during the meeting which resulted in a revised list which has been included as enclosure {3). At the conclusion of the meeting, E.W. Drislane, representing FMSI, stated that the questions as phrased would probably be submitted to 15 of their 19 members. He indicated that responses to the questions would be obtained in about 3 months. FMSI 03647 Name Al Colli Hope Pillsbury Jim Armstrong E.W. Drislane Eugene L. Rogers Ronald P. Moalli Alan Carp.ien Richard J. Guimond Jim Silverman David Mayer Jim Hughes Bob Liss Jane Nowak ENCLOSURE I Company/Code OPTS/CAD OPTS/CAD Bendix FMSI Bendix FMSI/Raybestos EPA/OGC OPTS-CAD OPTS/CAD OPTS/PID OPTS/ORA OPTS/CAD OPTS/CAD Telephone Number 755-8023 755-8023 313-352-6350 201-845-0440 518-273-6550 202-371-0101 755-0794 755-8023 755-6660 755-5854 755-6660 755-8023 755-8023 FMSI 03648 ENCLOSURE II Informational Needs for Friction Products Containing Asbestos 1. What are the basic ingredients used in nonasbestos linings for disc brakes? Specific formulations are not necessary. 2. What are the basic ingredients under consider~tion for use in nonasbestos linings for drum brakes? Specific formulations are not necessary. 3. What data or evaluations are available regarding the health effects of nonasbestos brake linings or materials used in them? 4. What are the performance characteristics and the problems associated with the use of substitute products for brake linings containing asbestos? 5. Are nonasbestos brake pads used in conjunction with asbestos pads?. For example, is the outer part of the pad nonasbestos and does the inner pad contain asbestos? 6. Are nonasbestos brake pads interchangeable with asbestos brake pads? If the vehicle has a nonasbestos pad as original equipment, must the replacement pad be nonasbestos? 7. Are the composition and manufacture of nonasbestos brake linings developed by your company protected by patent or are they trade secret? ,. 8. Are there mechanisms for the transfer of this technology to other companies who manufacture brakes for vehicles? For example, would your company consider licensing of the technology to manufacture nonasbestos brake pads? 9. Can nonasbestos brake products be manufactured in existing production facilities or will new facilities be required? What will be the capital and operating costs associated ~ith change over? 10. What is the projected price differential between brake linings containing asbestos and nonasbestos substitutes? 11. Do brake systems which utilize nonasbestos friction products require a different design from brake systems with linings containing asbestos? If component parts for use with nonasbestos linings are different, what is the product price diffe-rential? FMSI 03649 '_.,...... DitAFl ENCLOSURE III Informational Needs for Friction Products Containing Asbestos 1. rfuat are the basic ingredients used in nonasbestos linings for disc brakes? {Specific formulations are not necessary). The materials used to substitute for asbestos are of particular interest. 2. What data or evaluations are available regarding the health effects of nonasbestos disc brake linings or materials used in them? If the substitute is a fiber what are its physical characteristics and size distribution? 3. What are the performance characteristics and the problems associated with the use of substitute products for disc brake linings containing asbestos? How do the substitute pads compare with asbestos pads? (For example: expected wear, noise levels from use, etc.) 4. For orignal equipment applications describe the asbestosnonasbestos braking system. Include part number, vehicle application, and model years for each system decribed. 5. Describe the asbestos-nonasbestos braking system used for original equipment applications. Specify the vehicle applications and the model years for each system described. 6. Describe the historical development of nonasbestos disc brakes in your company. For example, provide date of initial research, dates of initial testing, dates of commercial available product.- Estimates research and development costs for developing commercial product. Provide either total cost or cost for each phase. 7. Are nonasbestos pads interchangeable with asbestos brake pads? If the vehicle has a nonasbestos pad as original equipment, what problems or advantages do you foresee with replacement pads that contain asbestos? 8. Are the composition and manufacture of nonasbestos disc brakes linings developed by your company protected by patent? What are the patent numbers? 9. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brakes for vehicles? For example, would your company consider licensing of the technolo~y to manufacture nonasbestos brake pads? FMSI 03650 10. Can nonasbestos disc brake products be manufactured in existing production facilities or will new facilities be required? IVhat will be the capital ano operating costs associated with change over? (For example: machinery, tooling, and time considerations.) 11. ~fuat is the projected unit cost differential between disc brake linings containing asbestos and nonasbestos substitutes for the part numbers specified above. 12. How much of the asbestos used by your firm in 1979 would have been eliminated had all disc brakes been nonasbestos in that year? FMSI 03651 FRICTION NATEP.IALS STAi'lDARDS Ii:lSTITUTE, INC., E-210 ROUTE 4, PARM1US, N.J. 07652 February 8, 1980 TO: Delegates and Alternates SUBJECT: EPA Office of Toxic Substances Questions Concerning Asbestos and Non-Asbestos Disc Brake Linings Based on Board of Directors recommendations, an Institute Task Force met with EPA in Hashington to clarify and modify the Eleven Questions that EPA had drafted to ask manufacturers of friction materials. As you may be a'lo7are, the EPA is permitted under the Toxic Substances Control Act to subpoena information relative to initiatives in this area. The Institute feels it to be prudent to work t-7ith EPA on a voluntary basis in providing information and background so that any actions they take will be based on facts rather than assumptions. v1e are askinglJ therefore, that member companies who manufacture asbestos or non-asbestos disc brake linings for passenger cars and/or light trucks (under 10,000# GVU) respond to this questionnaire. At some later date, the EPA will probably ask similar questions concerning drum brake linings, brake blocks, etc. Control of Individual Company Response It is suggested that individual member companies have one individual control and coordinate the response. In this fashion, he will insure that contradictory responses are not sent to the regulators by individual contacts or questions from others in Washington. Along this line, it has been suggested that responses to EPA and others be only sent where the request for information is in writing. This is to avoid conflicting responses to telephone inquiries and the like. Institute-Coordinated Response Versus Individual Direct Response The Institute is attempting to coordinate the response to EPA. Replies will not be attributed to companies, but it must be remembered that EPA does have subpoena power and could determine the source of the ans,.rers. If individual companies wish to comment on other aspects of this subject-beyond those suggested in the questions--they should add comments. He will code the answers for our response to EPA. Legal Counsel Revi~f of Responses to Questionnaire Institute's Legal Counsel had asked to revie,T the questionnaire. He has failed to respond to several requests to review and approve this questionnaire for circulation. It has been decided to release this questionnaire as l<7ritten, but the Hembers are urged to have their own Legal Counsel revi~7 the individual replies. FMSI 03652 Delegates and Alternates February 8, 19 80 Replying Directly to EPA If a member company feels it lTould be in its best interest to reply directly, ~he response should be sent to: Hrs. Joni T. Repasch (Record Clerk) Office of Toxic Substances (TS-793) U. S. Environmental Protection Agency 401 11 Street, Sl1 Hashington, DC 20460 (Nark Prominently: Docket Humber OTS-61005) If you do reply directly, your response is part of the public record. If you provide any confidential or proprietary information, you should provide it only if the EPA can assure you that the confidentiality of the information can be safeguarded. * * * * * There is no question but that the EPA is considering a ban on asbestos in friction materials. Their first step is with automotive disc brake linings. He believe that accurate objective information can influence decisions to be made in this area, and recommend that all member companies help "1ith this response. As indicated earlier, if they do not get this information on a voluntary basis, they can compel it. We are trying to gather this information so that we can forward it to EPA no later than Harch 31, 1980. EliD/erc cc-Health &Environmental Affairs Committee E. H. Drislane Executive Director FMSI 03653 1. What are the basic ingredients used in non-asbestos disc brake linings, which were not used in earlier asbestos type formulations? Of particular interest are the materials used to substitute for asbestos--those that reflect a net change. 2. As regards the substitute materials, if the substitute is fibrous, what are the physical characteristics of the fiber--structure, fiber size, size distribution? 3. What are the performance characteristics and the problems associated with the use of substitute products for disc brake linings containing asbestos? How do the substitute non-asbestos pads compare ~r~i_th asbestos pads for lining wear, rotor wear, noise, wet recovery, etc.? 4. Where you are the original equipment supplier of non-asbestos type disc brake linings would you describe the packaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: 4.1 Full non-asbestos linings 4.2 Non-asbestos friction material with asbestos backing 4.3 Use of non-asbestos lining at one position (inner or outer) with asbestos type lining at other posititon 5. Describe the historical development of non-asbestos disc brake linings with date and/or time from (1) initial research, (2) successful laboratory prototype, to (3) availability:of conunercial product. Also, estimate research and development cost for development of commercial non-asbestos disc brake linings (either in total or for each phase of the development). 6. If a vehicle has a non-asbestos pad as original equipment, what problems or advantages do you see in use of asbestos type pads for replacement? 7. Are the composition and manufacture of non-asbestos disc brake linings developed by your company protected by patent? If so, what are the patent numbers? 8. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brake linings? For example, would your company consider licensing of the technology to manufacture non-asbestos brake pads? 9. Can non-asbestos disc brake linings be manufactured in existing production facilities or will new facilities be required? Please estimate the capital and operating costs, and the availability and lead times associatedwith acquisition of the machinery and tooling? 10. What is the projected unit cost differential between these three popular domestic disc brake lining sizes containing asbestos and non-asbestos substitutes? (FMSI 728A, 7013A, 7017A) FMSI 03654 11. Based on your 1979 production, how much asbestos would be eliminated in a total conversion to non-asbestos disc brake pads? The foregoing questions relate to passenger car and light truck (under 10,000 lbs. GVW) disc brake linings. The Office of Toxic Substances has indieated that they will be asking questions along a similar line,- at some later date, for drum brake linings used on passenger cars and light trucks. And at still a later date, they will ask about brake blocks and probably clutch facings. FMSI 03655  FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, NEW JERSEY 07652 January 8, 1980 TO: BOARD OF DIRECTORS ENVIRONMENTAL AFFAIRS COMMITTEE SUBJECT: MEETING WITH EPA OFFICE OF TOXIC SUBSTANCES PERSONNEL CONCERNING THEIR REQUEST FOR INFORMATION ON FRICTION MATERIALS At the December 4, 1979 meeting of the Board of Directors, among the many items discussed were the eleven questions asked by the EPA's Office of Toxic Substances Control concerning asbestos and non-asbestos friction materials. At the Board meeting it was decided that a Task Force would be formed to meet with the Office of Toxic Substances to clarify and re-define these questions. This Task Force consisted of: Mr. R. R. Moalli, President of the Institute; Mr. J. W. Armstrong, Chairman of the Health and Environmental Affairs Committee and Mr. E. W. Drislane, Secretary. Mr. Armstrong invited Mr. E. L. Rogers of the Bendix Friction Materials Division to help with the questions. Messrs. Moalli, Armstrong, Rogers and Drislane met with the personnel from the Office of Toxic Substances on January 3, 1980 at 10:00 A.M. at the EPA Offices, Waterside Mall, Washington, D.C. Those in attendance from the EPA are listed belaw: Name EPA Office TeleEhone (Area Code 202) Al Colli Hope Pillsbury Alan Carpien Richard J. Guimond Jim Silverman David Mayer Jim Hughes Bob Liss Jan Nowak CAD/OPTS CAD/OPTS EPA/OGC EPA/OCC CAD/OPTS PID/OPTS ORA/OPTS CAD/OPTS CAD/OPTS 755-8023 755-8023 755-0794 755-8023 755-6660 755-5851 755-6660 755-8023 755-8023 The elven questions that had been submitted earlier were covered in detail at this meeting. Without going into the detail, every question was discussed and the proposed new draft of the eleven questions is attached. Essentially, the questions are limited at this point to automotive disc brake linings. Questions or inferences as regards drum brake linings or others have been removed. However, the EPA indicated that at some later date they will be seeking similar information on drum brake linings. The questionnaire at this time will refer to asbestos and non-asbestos disc brake linings only. FMSI 03656 BOARD OF DIRECTORS ENVIRONMENTAL AFFAIRS COMMITTEE -2- January 8, 1980 Further, these are for passenger cars and light trucks which will be defined as vehicles under 10,000# GVW. For example, question #2 on drum brake linings was eliminated. Other questions were almost completely restructured. Question #11 of the original eleven questions was also eliminated because it involved a knowledge of the brake system itself rather than brake linings. Further, a new question #11 was added concerning how much asbestos would actually be eliminated by conversion to non-asbestos brake pads. In response to a question from EPA, the Secretary indicated that he felt that it would be three months before this information would be available. He suggested that this material must go to both our Legal Counsel and our Board of Directors before we can even solicit replies. Among other matters it was stated that where a respondent prefers to go direct to the EPA rather than through the Institute that replies should be addressed to the docket established with the Federal Register notice of October 17, 1979. That would be Docket OTS-61005. It was pointed out that replies would be concentrated on domestic passenger car linings which would mean that the imports are not being addressed directly. Also, the questions would be directed to United States Active Members and not to Regional Members. This would mean, of course, that some information relating to imported cars and replacement linings therefor will not be included. Before this questionnaire is sent to the Membership, it must be approved by Legal Counsel and the Board of Directors. The foregoing is sent along as a matter of information. EWD/lmc E. w. Drislane Executive Director FMSI 03657