Document K3aG5KooNN8kBy7v08by51Kr

October 5, 1976 Mr. Marc Collinn Alrflex Plant : Baton Corporation 9919 Clinton Road Cleveland, Ohio 44111 Subject: Airborne Asbestos . >* Dear Marc, ' ^ ^ Clb'1 .*%>,. I have your letter of October 1, 1976 and willcomment' On=lt and the other topic of our conversation, possible asbhdtbs dust exposure by people who change or grind brake linings. / 1 1 i' Taking the last item first, I can offer, the relieving facts and opinions. The August 14th, 1975 issue of * the kali Street Journal carried an article that is the cause of a lot of. consterriation from people who are exposed to the problems associated with the,use of asbestos. A copy of the article la attached for:iybur review.1 In the article, a NIOSH^spokesman makes a statement that I do not agree with and Is the basis'|for a lot of unnecessary fears regarding the use of asbestos-containing products. In the second paragraph of the article, HEW reputedly. aaid)that, "garage personnel who change or grind brake Uningg bre being exposed to potentially hazardous levels of airborne aebegto*:." If the statement had been made that, "garage, personnel who change and grind brake linings --" rather than, H~ who ' change or grind brake.linings--", I would not object. As written, it, implies thit the sere.Set of changing brake linings exposes personnel to high levels of: airborne asbestos. This, in my opinion, is not the case asjfl4wlll shoe 'later. However, I cannot disagree that the act of grinding- aslbeatoe-contalning products may cauaa some liberation of . asbestos, which may become airborne and could lead to people in the immediate area to become exposed to potentially hazardous levels of alrbornP asbestos. More about this later on. In.the next to the last paragraph of the article, the information la. given (and I do not disagree with it in general) that asbeatoa dust Ohh bs generated where truck and bus linings are ground to fit brake .... or are resurfaced after use. However, I do disagree with the Marc Collins -Z- October 5, 1976 statement that, "the changing of asbestos brake linings for automobiles was also dangerous because mechanics usually use an air hose to blow out the loose dust after removing the old lining." The implication here is that the brake lining debris that is trapped in the drum contains significant amounts of asbestos that can become airborne after being blown out of the drum by the air hose. This too will be touched upon shortly. . Exhibit 1. copy attached, is an abstract along with the reference* . . regarding brake lining decomposition products. Mr. Lynch, the.^u&for, C V' was a member of the U.3. Public Health Services when he presented, his finding in May, 1968 that the high temperatures involved i'n broking ' converts asbestos to other minerals and that the very small amounts! of. free fiber appear to be an inconsequential health hazard,5:, j ` % Exhibit 2 Is an abstract of a submission made by Caterpillar Tractor Company to the Illinois Pollution Control Board on* October 19,; 1971 as its documented argument against the banning of ashestds^ontaining friction materials. Beginning on Page 13, a section titled~""B. Brake Wear Products" is pertinent to our present discussion.* Here, Caterpillar draws information from Mr. Jeremiah Lynch who publiahed' an article in the Air Pollution Control Association Journal entitled "Brake Lining Decomposition Products". (This may have: been part|;5f the study referred to in Exhibit 1, but the findings are,Reported..in greater detail.) The gist of the article Is that little or. no frba;asbestos is present in the dust taken from drums and only insignificant.amounts of asbestos may become airborne during braking opefltlqpl. (Incidentally, we do not know if there even was a page,14:in thilfJphesentation. The contljr^jity of the thou^it content suggests' that- there never was a page 14 -- that an error occurred in numbering the pages.) - \f ' ,v, .*sfv ^ rw . Exhibit 3 Is an EPA Supported, long term project that was presented in May, 1973. The most Infofinative figure from this comprehensive article is that less thanjO.,3% of aajoestos fiber originally present may be emitted to the atmosphere,during brake life, the remainder will have been con- . verted to other, mineral produc ts. The ibfomatloriipresented in the three exhibits leads me to the inescapable' conclusion that if there were significant amounts of free asbestos generated during braking that both OSHA and EPA would Ijave made allEoncerned-aware of this. On the contrary, all experimental data points' to the fact that insignificant amounts of free asbestos is generated ^p4'eiJth|T*.emitted to the atmosphere or trapped within a brake drum and "i'the amount is not large enough to raise the fears of even the most militant'of the anti-asbestos forces. * . . . -:'As far as J. W. Penney & Sons Company is concerned, my thoughts are thit very little, if any, asbestos is released to the air during clutch Engagement, While there may be some dust or smoke- observed during severe FAW 11856 Marc Collins -3- October 5, 1976 clutch (or brake) engagement, the bulk of this is carbonized material from the binder or non-asbestos mineral material from the fillers. While the friction material may contain about 50% by weight asbestos, the high temperatures involved in braking or clutching will cause the asbestos to be transformed into a non-asbestos mineral. It is my opinion that if OSHA had any information suggesting that the amount of airborne asbestos liberated during brake or clutch opera tions being at potentially dangerous levels, they would have monitSrgd this in the Great Northern Paper Company plant rather than asking them ; the question of how much is released to the air during clutch ^operation'.' ' * v; I In summary, my opinion after reviewing all facts available to' me < is that for all practical purposes, there is no measurable: amount of airborne asbestos liberated during a clutch or brake engagement and this should not be a cause for concern among people using your brakes and clutches. ' :\! In Mr. Rosenow's mono to you dated September 7, 1976*?he states that some countries in Europe are striving tq; outlaw;thp use of asbestos I have not heard of this before. Would itr be,:posaible for Mr. Rosenow to get me some information concerning this.5: I, I trust that the information is-adequate for your intended purpose. If I can be of further aaslstance^plaase |et'iBe know. Best regards. E. J. Sydor General Manager EJS:Jm Enel. '' cc: E. Flgert' ;,4 * _ A ' Cf \ :? % Eaton Corporation Z- t Inter-Office Correspondence FlT Date October 18, 1976 To Sod Balts Division & Plant R. L. Balts Co./Boaton From R. W. Roseaow Division & Plant EDD/Airflex Copy to R. L. Burks, T. Luglnbuhl subject J. W. Penney & Sons Co. & Croat Northern Paper Co. 5o VI % ;* > j The recent request from the subject Companies for information regarding the asbestos content in Attflbsc.friction material, was forwarded to national Frietlon Froducta^^^ . Hr. Ed Sydor, the General Manager, hasresponded to this request, and I will pass the informstiori on to'y$d for transmittal to your customer. \ :/ .$ ,;i v, Ktv Hie friction material may containabout 501 asbestos by weight. During clutching and braking actions, the surface temperature is generally quite high, apd this tends to convert asbestos into other minerals. The subsequent very small amounts of asbestos free filler are then considered to be an inconsequen tial health hasard. Mr.Sydor's report states that less than 0.3% of asbestos fiberforiginally present may be emitted to atmosphere ddring dlatdh or brake life, and this la considered Keep ih'C&nd.that a certain amount of dusting or smoking may be observed during a severe clutch or brake engagement, but the balkofchis Is carbonised materiel from the binder or ^sxiBiabeStol mineral material from the fillers. In sUanmry, Mr. Sydor states "that for all practical purposes, there Is no measurable amount of airborne asbestos liberated ..during a clutch or brake engagement, and this should not be a cause for concern among people using your brakes and clutches". Continued For inter-office and inter-plant correspondence only Form 30-23-5 (Rev. 4-711 FAW 17100 P.age two Red Balts October 18. 1976 It would seem that if OSHA was really concerned, they would take air samples and monitor the area. ,ik * < For additional information, please review the attachments P v marked Exhibit 1. 2. 3! ^ *0 , - &. W. Roaenow RWR/pl Attachmentsr :v*vCr #; cr .jyi; ,.M, :Cr tJOJS.'I-' Cr Vi' r 4 t, V4' \.o: r'. 4 -4* <4 ^ , K.J ccf,C4*,4...c.<....o.4...:vC.:..cv. \, 4 \ Cr #. <,4 y V 444 FAW 17101 Eaton Corporation Industrial Drives Division Airflex Plant 9919 Clinton Road Cleveland, Ohio 44111 Telephone (216) 281-2211 T. LUGINBUHL (21) October 22, 1976 Mr. 8. J. Sydor Soaeral Manager Hational Friction Produces Cory* U41 Holland St. F. 0. Box 327 toganapors, Indiana 46947 Dear Mr. Sydor; F:TN la your letter of October 5, 1976 toHarc Collins, you furnish ed me useful iafiwadfoa regarding asbestos 6s8 1st friction material. Too indicated that toe frietlnasBtorial nay eoateia about All asbestos by weigh** hoes type friction mate rial contain approximately toe same aaeunt of asbestos? la reference to your exhibits, a statement appears in several places tost extrema or ;hiib'converts asbestos into soma other mineral toicht appattolyv is harmless, go Page 13 of toa Caterpillar tractor teport (Exhibit 2), a 900? tempera ture is mentioned g: fad" tost Manta areas of tatmum heat is toe real cause of iiaiugwsar, Certainly, toe braking demands on eardnmnrinmr hoaw trutos. sad certain automotive stepping retol^eaoats^.toa be quite severe, hot for toe aost part, an Airflex clutch or brake will not be mowad to these high temperatures;, can you tell us at tost temperature the actual thermal breakdown of asbestos occurs? If ys:^tos||ae%to^ toe friction antertal temperatures never reach tola thermal bseafcdosn point, abrasion must be the cause ofu&ar. `!"lf asbestos decomposition does not occur during the "wear process, are wa, in fact, emitting a higher concentration of asbestos fiber to toe atmospheret 1 realise toat even If tota ls true, toe amount of asbestos fiber released during an ifJteur exposure period would still most likely be intigalflesnt bet, at tola point, me simply don't know tots to to e fact. Continued .. FAW 17108 %f Pegs An Ur. B. J. Sydor October 22| 1976 hossrrfs associated with caposure to asbestos fibers, and are scddag answers to some questions regarding friction oiecMAi-.' that, findtlfi wo axe unable be furnish. Tour assistance,1aY1' this matter mill be appreciated. . ' .*>> - <7ery truly yours* *KV <*; ''x \J :;i , C \?-L FAW 17109