Document K3ppd8643GoYa2JbzGoZrx20

Inter Office Mr. E. 8. Termaat Manufacturing Staff May `9, 1980 Subject: Carcinogens Task Force Report to E&R and M&S We have reviewed the subject draft report that was circulated by Messrs. J. V. Durstine and G. 0. Keutgen on May 1, 1980, and have the following comments: Past Company Actions Ve believe that since this section is not all inclusive it-eiwujd be prefaced with some words which indicate the following ar^representative of past Company actions, eto. /" Also there should be some words about the fact that since 1973 new suppliers of nonproduction materials have been required, under Manufactur ing Engineering Procedure II d 1, to furnish complete composition data to Industrial Hygiene and Toxioology and selected compositional information to Facility Environmental Engineering for clearance to use these materials in the plants. Second paragraph - Should be worded as follows: "Sprayed on structural f steel fireproofing ...," Carcinogenic Substances First paragraph, second sentence of the second tick item should read: "Medical evidence links certain hexavalent chromium compounds ...." Last sentence of the third tick item suggest wording: ".... limit of 1 ppm in air as a time weighted average in 8 hours." Second paragraph - Add a sentence that states the Manufacturing Engineering Procedure II d 1 provides for the review of nonproduction materials and inputs into MATS, eto. str"t?frY an(* Workplan Bulk Mate*rfflft and Parts - Nonproduction tabulation: The figures for y benzene should read: A g C Total 35 - 8 Third paragraph, second sentence should read: ".... vehicle activities iTiftraifAftfairlng activities, and the Manufacturing and Supply Staffs." 8004 0237 SCF-FORD-1900 Mr. K. B. Termaat -2- May 9. 198O Recommendations 2. Suggest rewording as follows 1 "Assign carcinogen central program management responsibility ...," 4. Suggest Inserting the words "where feasible" between benzehe and for Job #1, 1985. 5. Suggest Including the DPO Product Engineering Offices In addition v/ to the NAA0 Offices. Figure 1. Insert the word "asbestos" following the word "permissible" in the footnote. Page 2. Monproduction Materials - Change "was" to "were" in second to last sentence, i.e., ".... procedures at Central Laboratories were ...." Page 8f. Figure 16, third tick, under Carcinogen Identification - Recommend explaining the acronym "NAEPIS". ' Page 8. Carcinogens Search, first sentence - Suggest deletion of the words "was tedious and inexact." Page 9f. Carcinogens Search Results, figure 18 under Nonoroduction Materials/ Parts - The benzene figures should read ABC Total Page 10. Carcinogen Strategies - The entire write-up relates only to product materials and applications* The strategies should be reworked to also include nonproduction material strategies. Page Ilf. Figure 20 - Recommend numbering of the actions to more clearly tie-in with the applicable write-up on page 11. General - The last reference to a figure in the text is figure 17 on page 8. Thereafter there are 6 figures (18 - 23) which have no reference in the text. Consideration should be given to include suitable text reference to figures 18 - 20. Attached you will find a marked-up copy of the draft report that indicates the suggested changes. If you need further clarifipd^tjlon please contact Zaven Dolik or James V. Shaw. Attachment cc J. V. Durstine G. 0. Keutgen 8004 0238 Inter Office Mr. K. B. Termaat tv s>>-} Manufacturing Staff May'9, 1980 Subject: Carcinogens Task Force Report to E&R and MSS We have reviewed the subject draft report that was circulated by Messrs. J. W. Durstine and G. 0. Keutgen on May 1, 1980, and have the following comments: Summary Past Company Actions We believe that since this section is not all inclusive it should be prefaced with some words which indicate the following are representative of past Company actions, etc. Also there should be some words about the fact that since 1973 new suppliers of nonproduction materials have been required, under Manufactur ing Engineering Procedure II d 1, to furnish complete composition data to Industrial Hygiene and Toxicology and selected compositional information to Facility Environmental Engineering for clearance to use these materials in the plants. Second paragraph - Should be worded as follows: "Sprayed on structural steel fireproofing ...." Carcinogenic Substances First paragraph, second sentence of the second tick item should read: "Medical evidenoe links certain hexavalent chromium compounds ...." Last sentence of the third tick item suggest wording: ".... limit of 1 ppm in air as a time weighted average in 8 hours." / Second paragraph - Add a sentence that states the Manufacturing Engineering Procedure II d 1 provides for the review of nonproduction materials and inputs into MATS, etc. Stratacry and Workplan Bulk Mat^irt'flg ftnd Parts - Nonproduction tabulation: The figures for benzene should read: A g C Total / 31 - 8 Third paragraph, second sentence should read: vehicle activities, mwTMifaoturing activities. and the Manufacturing and Supply Staffs." 8004 025? Mr. K. B. Tennaat -2- May 9. 198O 2. Suggest rewording as follows* "Assign carcinogen central program * management responsibility ...." 4. Suggest inserting the words "where feasible" between benzene and /for Job #1, 1985 5. Suggest including the DPO Product Engineering Offices in addition to the NAAO Offices. Figure 1. Insert the word "asbestos" following the word "permissible" in the footnote. Page 2. Nonoroduction Materials - Change "was" to "were" in second to last sentence, i.e., ".... procedures at Central Laboratories were ...." Page 8f. Figure 16, third tick, under Carcinogen Identification - Recommend explaining the acronym "NAEPIS". Page 8. Carcinogens Search, first sentence - Suggest deletion of the words "was tediouB and inexact." Page 9f. Carcinogens Search Results, figure 18 under Nonproduction Materials/ Parts - The benzene figures should read A . C Total /Page 10. Carcinogen Strategies - The entire write-up relates only to product materials and applications. The strategies should be reworked to also include nonproduction material strategies. Page Ilf. Figure 20 - Recommend numbering of the actions to more clearly tie-in J with the applicable write-up on page 11. General - The last reference to a figure in the text is figure 17 on page 8. Thereafter there are 6 figures (18 - 23) which have no reference in the text. Consideration should be given to include suitable text reference to figures 18 - 20. Attached you will find a marked-up copy of the draft report that indicates the suggested changes. If you need further clarifip^t)Lon please contact Zaven Dolik or James V. Shaw. Attachment co J. V. Durstine G. 0. Eeutgen 8004 0240 EXECUTIVE SUMMARY CARC1N0C.CNS IN THE WORKPLACE Introduction Th Task Force on Carcinogens In the Workplace Mas established by the Engineering and Research and Manufacturing nnd Supply Subcommittees to identify enreinogens nnd quan tities in use, set targets for elimination aheud of regulation, take steps to find substitutes, develop a directive ond workplan and organize to identify substances systematically. The Task Force assignment responded to evidence that cancer may be a serious occupational concern and to the Company's and public concern with regord to protection of the environ ment and public health. Additionally, the Company has been subjected to a growing number of laws which regulate material use. transport, handling und disposal. In summary, internal and external pressures regarding hazardous substance control ond complionco have increased substantially since March, 1977, when Directive B-101 assigned responsibilities within the Company. Past Company Actions * .` Since 1977, the Company has removed lead chromates'and molybdates from paint (except special order), "Trls" flame retardent from fabrics and instituted controls on asbestos, including a Vehicle Engineering directive that newly designed components should not contain asbestos (documentaryexc^tjpns must be encapsulated or resin coated). Sprayed-on^ireproofing has been asbestos-free since 1969 for new and reworked construc tion. Several manufacturing standards prohibit asbestos os a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazards from paint-related chromium compounds. Carcinogenic Substance* . The Task Force has identified sixty-seven (67) carcinogens in use in the automotive industry. Twenty-six (26) of those are currently regulated byOSHA; the balance have boen proposed for new regulation. More restrictive standards have been proposed for some of those sub stances currently regulated. Thirty-one (31) substances are reported to the Michigan- Dcpartmcnt of Natural Resources for computation of water surveillance fees. Michigan plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur rently required to be reported in the other states. The list of carcinogens was prioritized by the Task Force according to impact on the Company to identify the top eight (8). The top three of the eight priority substances, asbestos, chromium compounds, and benzene, were examined in detail. ' Asbestos is used by the Company primarily In vehicle brakes, clutches, gaskets and for nonproduction roofing, millboard and corc/mold-msking materials. Medical evidence links inhalation of asbestos dust to lung cancer, mesothelioma and other diseases. The present OSHA limit is 2 fibers per ce of air (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/cc as early as this year. * Chromium compounds are used primarilwJnoaints and inks for production and nooproduction use. Medical evidence linksjiexafefent chromium compounds to lung cancer, b'yer and kidney damage and other diseases. The present OSHA limit is 52 mg per or of air which Is proposed to be reduced to 1 mg/m . - Benzene occurs primarily in coke oven operations as a by-product. It is a residual constituent of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has proposed a limit of 1 ppm in airtime weighted average in 8 hours. ^<x. Specific lists of bulk materials and parts for production and nonproduction use have been developed. A new computer data base is being developed. Materials and Toxicology System (MATS), which links health, engineering, and manufacturing dato bases to facilitate rapid Identification of carcinogen applications (2nd quarter 1981). The engineering release system has been audited and is being updated to extend materials identification to all parts. Product Engineering Procedure PEP 3-189 hos been rewritten to require systematic review of suspect carcinogens and input to the data base; ' 8004'0241 (Continued) Strategy and Workplan Ttie search for asbestos, chromium compounds nnd benzene defined the number of pnrts ond matcrinls containing these .substances ns listed in the table below. Where possible, the applications were divided into three groups: A Known substitute material without major redesign. B - Known substitute mntcrial with major redesign nnd C No known substitute or advoncc'd engineering required. The dutu is directional only. There remain many suspect applications which require tiinc-consuming analyses for identification. _____________ Bulk Matcrinls nnd Pnrts Production X B <5 TotoT Nonproduction ABC Total Asbestos Chromium Compounds Benzene 34 49 22 - - 23 - - . 15 10S 25 IS 8 -- 8 98 81 34 213 3 --&) 8 Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three carcinogens by Job HI, 1985, in light of competitive and regulatory pressures, and Company experience. Where elimination cannot be contained, institute controls on design, process and exposure, it is Judged that the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing ports and materials. For those applieotions requiring major redesign (Group B, e.g., drum brake linings) the elimination timetable would have to be adjusted to refjeet Company cycle plnns^lthough C.Mi has stated an intent te eliminate ' asbeetcc by 1 Bifr. Finally, where no known substitute exists (Group C), advanced engineering will have to be completed before a elimination timetable can be established. A generalized workplan has been prepared on the basis of the evaluation of the carcinogens already referred to. The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle ncti- vitieauand the Manufacturing and Supply Staffs. It is judged that approximately a year is 'Squired to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is judged that one additional year would be required to implement the most feasible product actions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro grams. Recommendations Achievement of the recommended strategy requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force recommends: 1* Establish a Hazardous Substance Control Committee chaired by Environmental and ,, Safety Engineering Staff. The Task Forc^ would be discontinued. t* Assign Carclnogerfjprogram managedresponsibility to Environmental and Safety Engineering Staff. . 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for Uto 6? known carcinogens for-review and approval by the subcommittees. (The Task Force has requested General Managers and Chief Engineers to recommend directional timetables.) . 4* Direct all affected organizations to proceed with the elimination of Group A asbestos, ehromium compounds wd^nzene/oi^ . 5. Request that NAAO/mwuct Engineering Offices and Manufacturing Staff present to the subcommittee Specific action plans and timing for the Group A applications Identified. .. 6, Provide advance program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). t. Adopt as the Company carcinogen listing the 87 current OSIlA-regulated and proposed Category 1 substances. Establish the top eight priorities proposed by the Tusk Force as Company priorities. 8004 0242 Engineering Staff - EARS Manufacturing Staff May 2,1980 DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2,1980 8004 0243 OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production * Nonproduction . . Task Force Charter Carcinogenic Substances Prioritized by consensus Asbestos, chromium, benzene . Asbestos Summary . Chromium Summary - . Benzene Summary Carcinogen Search - List specs, and parts - Identify items havingno substitutes - Identify substitutable items .. Eliminate when redesigned or reordered ' - Develop substitutes for others (advance engrg. funding) . MATS . Carcinogen Search Results Carcinogen strategies . Generalized Workplan . . Proposed Chemical Substances Control . Proposed Priority Actions .. Exhibits . . List of "67" Carcinogens . MATS . * Appendices ' ' Asbestos-containing parts and materials . Chromium-containing parts and materials Benzene-containing parts and materials . --------- ---------- . _ &Q0 0244 DRAFT FEDERAL AMD MICHIGAN ACTS nrCOLATINO TOXIC/IIA7.ARDOUS MATERIALS HAVING IMPACT ON THE COMPANY PlOURE 1 Regulatory AU Occupational Safety and Health Ael - 1970 D.O.L. (OSHA)* Kasardous Materials Transportation Act -1975 D.O.T. (HTMA) Toxic Substances Control Act - 1971 E.PA. (TSCA) Kesogree Conservation and Raeovary Aet -1971 E.P.A. (RCRA) Clean Air Act and Clean Water Aet Amendments - (CAA) 1577/71 E.P.A. Michigan Act SOS. P.A. - lltl Michigan D.NJU (MDNR) Packaging A Sleeking federal Hazardous Substances Act - 1970 . Poison Prevention Packaging Act-1970 . Consumer Product Safety Ael - 197* Haste Management . Hazardous Waste Management Act 1979 Mich., P.A. t a . Solid Waste Management Aet -1971 Mlclu, P.A. 641 Expected to bo revised during 1910. to lower permieslblemxposure Unit from present 9.9 flbers/ee toOJor 0.1 flbtft/cc o/ lire ' . TtOVKl 1 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (OtRECTIVE B-101) Staff ESES Responsible Activity SSECO PRO IHAT * Mpa STAFF BAPETY Plant Eagrg. Office Mfg. Engrg. A Systems Plants EARS Prog. AnaL A Mails. Engrg. Research Staff . SUPPLY Trans. A Traffic OSHA TSCA CompUancs Reporting REOOLATORY ACT rCAa A State SoUd/ Hex. Wastes CompUancs Reporting HMTA Compliance Reporting Identification of Controls Material Inclusion In EPA Inventory Monitoring Enforce Controls Facility Controls Non-Prod. A Prod. Development Mails. Revie* Process Controls Mon-Prod. Metis. Development Review Process Controls Non-Prod. Metis. lapismentation Review PadHty Control Implementation Develop new metis., mfg. processes. A caesurament devices. Production Metis. Review Chemistry in DOT Lebel Dote Bass In Dele Base Disposal Math. A Pac. Dev. Waste Charac terixaUoo Pedtaging Storage Material Characteri sation ,P CompUancs Reporting CLEAN AIR A WATER Compliance Reporting Monitoring MICH DNR Compliance Reporting Chemistry In Data Base PaotUtM Rouge Consol Development idation Process Contr, Development Permit Reporting Osage Reporting 1 May 2, 1980 . 8004 0245 I DRAFT 8004 0246 CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established during the 4th quarter, 1979 by joint action of the E&R and M&S Subcommittees. The Task Force Charter was to coordinate plans and efforts among Company activities, to identify carcinogens in use, and eliminate or control them in future products and manufacturing operations. Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendices. Background Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.S. might be associated with occupational factors. Accordingly, Personnel and Organization Staff, Employe Health Services, has exerted a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. . Public concerns relating to the control of toxic/hazardous materials, are shared by Ford, due to the Company's regard for public health and the protection of the environment and potential impact of legislation on our products and manufacturing operations. Also, the right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. __ Resolution of workplace exposure concerns relating to the management of toxic/hazardous substances, materials, and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques as well as by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines up to $25,000 per day, and a citation normally consists of multiple related violations. Litigation is also a growing concern. At present the Office of General Counsel has three suits pending, involving deaths allegedly due to the inhalation of carcinogenic substances. Some Workman's Compensation expense has also been incurred. The greatest potential for major expense, however, lies in the possibility of punitive action by the court. Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. a Federal Register 45(15): 5031, January 22, 1980. . -1- May 2,1980 DRAFT FIGURE 3 PAST COMPANY ACTIONS Production . Removal of lead and chromium from paints. * . Removal of "Tris" flame retardant Controls instituted for asbestos in new designs. Nonproduction . Removal of asbestos from, . Structural fireproofing - Thermal insulation - Molding compounds . Substitution of vacuum for air blowing in brake and clutch maintenance . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations .l 8004 0247 - 2f - May 2,1980 DRA PT PAST COMPANY ACTIONS Production Materials In response to OSHA regulations in 1970, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977, in response to an inquiry by NHTSA. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. Car Engineering released a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. Nonproduction Materials . In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with the lead naphthenate free M-2C142 materials, and deleted the use of asbestos bearing molding compound at Sheldon Road. In 1978, an adhesive used at San Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories^ was^revised to eliminate benzene, the volume of lead-chromate employedTin vinyl plant operations was reduced and ventilation/protective measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used In painting. (The substitution of non-hazardous paints is targeted for Romeo for late 1980.) * 8004 0248 -- 2- May 2,1980 DRAFT FIGURE < TASK POnCR CHARTER The Task Force whs chartered by F.&K and M&S Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts to: 1. Identify substances in use (OSIIA Categories I and II). ' 3. Determine quantities used (for muterials regulated by Michigan Department of Natural Resources). 3. Set targets for elimination of as many Category I substances as possible. 4. Take aggressive steps to find substitutes for as many Category I substances os possible in ntielpotion of government regulations, 3. Develop a policy and action plan for eliminating potential carcinogens where possible. C. Organize to identify substances systematically. , FIOURE S USAGE OF MICIlir.AN CRITICAL MATF.R1AI.S AS REPORTED TO MA'tS (ADJUSTED V Tlll-l 1`I.AVIS IN Tlll'.llt MDNR REPORTS) Material Acrylic Acid Lbs. of Usage iii.ibf * WV- Faint Principal Users ^ Acrylonitrile 641,133 PPV- Paint : Aniline 90 MCC, Dbn. Glass. T&C Sterling Antimony Arsenic ' 30,571 11,157 PPV - Vinyl TftC Vandyke. PPV - Vinyl Asbestos (not reported as a material - present i articles only) Benzene 365,035 AAD - Dearborn Assy., Gen. Service Cadmium 3,311 PPV-Vinyl . Chromium Cloroprene 81,377 34,676 PPV - Paint, EED - Ypsi. AAD - Utica ' Cobalt 310 PPV - Saline . Copper 331,704 AAD - Dearborn, PPV - Saline, MSD - Monroe Cyanides Dichlorobenzenes 933,069 3,643 MSD - Monroe FTO Highland Park Formaldehyde 488,965 MCC. PPV - Paint * Hydrazene Hydroqujnone Hypochlorite Lead Uthlum Nickel * Phenol Selenium. Silver 130 1 15,841,758 636,037 133 136,634 5,839 137 33 PPV . PPV - Vinyl MSD - Monroe AAD - Wayne/Dearborn, PPV - Paint ED - Northville, TftC Sterling MSD - Monroe, T&C Sterling Mich. Cast. Cntr. T&C Sterling ' TftC Sterling Silicon-Dioxide Coaled Lead Chromate Styrene- Tetracloroethylcne 3,317 1,413,986 1,095 PPV PPV - Milan, PPV - Vinyl AADOO, Mich. Prov.` Gmd. ` Thiourea Triaryl Phosphate Esters Trichloroethylene Vinyl Chloride Zinc - 18 160,033 91,649 116 1,085,724 PPV - Vinyl . . Steel, TftC Sterling , EED - Rawsonvllte PPV - Vinyl PPV - Paint, AAD, PPSD, FTO . * Michigan locations not reported to MATS: Detroit Industrial Engine Research ft F.nginccring Center . Research Glendale Troy * Tractor , Vulcan Forge Dearborn Class Dearborn Specialty Foundry Wlxon Assembly * ` -3f- May 3,1980 rr*1 ! I 8004 0249 DRAFT TASK FORCE CHARTER To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. The complete Task Force Charter is shown in Figure 4. In 1977, OSHA issued a draft policy listing numerous chemicals that could be classified as "Category I" and "Category n" carcinogens. According to OSHA's draft policy, Category I substances are known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category n substances are so classified where data is suggestive or carcinogenicity in test animals and humans, or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. A listing of 67 Category I substances in use in the automotive indus try has been prepared. (Exhibit I). - For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used asbestos only as articles, 81,377 pounds of chromium compounds, and 385,028 pounds of benzene. . Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category 1 substances were examined in detail. 8004 0250 -3- May 2,1980 DRAFT FIGURE 5 TASK ORCE PRIORITIZED CATEGORY 1 SUBSTANCES Substance 1. Asbestos 2. Chromium Compounds 3. Benzene 4. Cadmium/Cadmium Oxide 5. Coal Tar Volatiles . Bertzo (a) Pyrene . Benzo (a) Anthracene 6. Ethylene Chloropolymer 7. Beryllium 8. Trichloroethylene Occurence within Company Friction materials, gaskets, sealers Chrome plating, paint pigments Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions Vinyl Aluminum foundry operations Degreaser Current Exposure Limits 2 fibers/cc 0.1 mg/m15 62 73 84 10 ppm 0.1 mg/m5 0.2 mg/m5 3 0.2 mg/m 3 0.2 mg/m None established 2 ug/m5 100 ppm 8004 0251 - 4f - t May 2,1980 DRAFT CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that are contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6. The current exposure limit for these substances is also provided. It is important to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed are presented in order of priority as established by Task Force consensus. The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3, respectively) as test cases because they are considered by Operations and Staffs to have the greatest impact on the Company. NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to eliminate/control these materials, in a practicable manner in anticipation of Government regulations, were formulated. A plan to extend the strategy formulated for asbestos, chromium and benzene, to as many Category I substances in Company materials as possible, was established. -4 May 2,1980 8004 0252 draft CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer . Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Fibers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Fibers/cc) 0.1 0.5 5 8004 0253 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core & Mold Making Materials Safety Apparel 5f May 2,1980 DRAFT CARCINOGENIC SUBSTANCES ASBESTOS' During the past several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHA, is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group, and OSHA have recommended that limits be tightened to as low as 0.1 in 1980. Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban on all non-critical uses may occur as early as 1985. 8004 0254 * -5 May 2,1980 V it CARCINOGENIC SUBSTANCES 8004 0255 CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds X X X X X Other Chromium Compounds X X X x - FIGURE 11 Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) Exposure Limits - 52 yg/m8 a/ 1 yg/m8 1/2 of above 25 yg/m810 Hr workday - 50 yg/m8/15 Minutes 1/2 of above a) Measured as chromium. No differentiation is made regarding valence or type of disease due to exposure. FIGURE 12 Classes of Materials Containing Carcinogenic Chromium Compounds Production Topcoat Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers . Marking Inks - 6f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (e.g., ' sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of their handling of materials, primarily in paint making and application. Protective measures are employed to assure regulated limits are not exceeded. . The current statutory limit is 52 mg/m although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. -6 May 2,1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE FIGURE 13 . ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENE Contact Dermatitis Eye Irritation Narcotic and Central Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dysorasias (disorders) _ Time-Weighted Avg. Ceiling FIGURE 14 EXPOSURE LIMITS Regulation 5 ppm/15 min. Proposed * 1 ppm/8 hr. 1 ppm/ 2hr. Sample collected at 1 liter/minute . FIGURE IS CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealers Rust Preventive* Thlnners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases and Oils Lubricating, Hydraulic Ac Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids /C 7n onno -7f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES BBNZENB Benzene is a leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, and employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline ex* other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no possible way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. (See Exhibit QI) . i- -7 May 2,1980 DRAFT CARCINOGEN SEARCH FIGURE 16 . Carcinogen Identification . - Reviewed all likely material specifications and manufacturing standards. - Reviewed the IH&T CATALOG of Hazardous Materials. | - Reviewed NAEPIS to identify Industry Standard Materials - Reviewed the Michigan Critical Materials data . Surveyed previous assessment of production materials. - Communicated with material suppliers. Analyzed the production material list (PEO). . Carcinogen Usage ' Reviewed the NAEPIS cross-reference for production material/part usage. . Reviewed processes/uses involving the substances in nonproduction materials. - Confirmed the NAEPIS usage list for completeness/verification. MATERIALS AND TOXICOLOGY SYSTEM FIGURE 17 r^c\ fcrtftO - 8f - May 2,1980 I DRAFT CARCINOGEN SEARCH Three Category I carcinogens were examined to determine material specifications, parts and nonproduction uses* was tedieus -and ineitaeU Existing data bases containing Engineering, Manufacturing and Purchasing information were found to be incomplete and not readily accessible. In the absence of one reliable system, the detailed steps in Figure 16 were under taken. . For production materials, each PEO reviewed the material/usage, list for completeness and established a list of parts and bulk materials of their design responsibility suspected of con taining the subject substances. These lists were returned to Engineering Staff. E&RS con solidated the lists (See Appendices) and provided them, along with the approved source and material identifications to Purchasing and Supply Staff for supplier contact to determine substance usage and to find out if there is a known substitute. Nonproduction materials were identified by similar methods, except for the PEO review. MATERIALS AND TOXICOLOGY SYSTEM (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (P&O Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental & Process Engineering Review System (Mfg. Staff). These Systems can be linked together with some manual effort to search for uses of suspect carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing suspect chemical compounds can be identified in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 2. For Production- materials, parts lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list. Purchasing can determine quantity used and Manufacturing En gineering can determine processing methods. , - Other functions of MATS include Approved Source Lists for production and nonproduction, materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide nonconfidential list of hazardous material usage and precautions for each plant. *-8- May 2,1980 Asbestos-^ Cr Compounds3- / Benzene DRAFT CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts AB 34 49 - - - C Total 22 105 25 25 15 15 Asbestos * 4/ Cr Compounds - Benzene Nonproduction Materials/Parts -1/ ABC 8 98 3 Total 8. 21*3 8 Note: A = Known substitute material available without major redesign. B b Known substitute material available with major redesign. C No known substitute. Advanced Engineering Project required. NA* Not available 1/ Data are directional estimates only and refer to materials known ~ to contain the particular carcinogen. ^ 2/ Primary source - Car Engineering. 3/ Only certain hexavalent chromium compounds considered. . 4/ ' AU chromium and chromium compounds considered. - 9f - May 2,1980 DRAFT CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium, benzene, a partial list of production and nonproduction material applications has been assembled. These were classified ast Known substitute material available for application without major redesign; Known substitute material available for application with major redesign; No known substitute. Advanced Engineering Project required; Even in group A, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. .* 9- May 2,1980 draft FIGURE 19 CARCINOGEN STRATEGIES - Continue OSHA Category I carcinogen control by design, process and exposure limits. Eliminate carcinogens where substitutes are known when required by regulation or business pressure, a/ - Proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985. Where elimination cannot be contained, control the design, process and exposure, b/ - Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. a/CurrentCar Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos. In documented case* precluding- alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. ' b/Advanced funding would have to be provided where elimination cannot be ~ contained in the 1985 timeframe. lOf- May 2,1980 DRAFT CARCINOGEN STRATEGIES Three major strategic alternatives were considered for the elimination and control of carcinogenic substances. Twenty-six (26) OSHA Category I substances and Forty-one (41) substances that affect the auto industry and are proposed for regulation (MVMA analysis) provide the basis for these alternatives. NIOSH advised substance controls were deemed to be of lower priority. It was agreed by the Task Force and PEO chief engineers that the Company should proceed now to eliminate asbestos, selected chromium compounds and benzene by Job #1, 1985. Where elimination cannot be contained, design, process and exposure controls would continue for specific applications. Implementation of the recommended alternative can only proceed by specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) can be initiated now but cannot with confidence be expected to be fully implemented in the 1985 time frame. Implementation decisions will have to be made for each application in the context of the vehicle cycle plan, component redesign, plans facility renovation/replace ment and the practicality of the substitute. -10- May 2,1980 DR APT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) Action - Manage Program Propose list of known and suspect-a/ specifications Verify proposed list a/ Identify known and suspect part " numbers _ t G` Request supplier verification of suspect specifications and parts Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) Implement Group A actions 00- Implement Group B actions * Implement Group C Actions <$> Audit effectiveness Responsibility . Production Nonproduction SSECO SSECO SSECO * SSECO PEO's PEO's Mfg. Staff Mfg. Staff b/ NAAO/DPO Purchasing NAAO/DPO Purchasing PEO's (NAAO Pch.) Supply Staff Supply Staff Mfg. Staff (Supply Staff) Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO's SSECO Mfg. Staff Mfg. Staff Tech. Ping. Research Staff BMD SSECO. .i Block Timing Prod. (Nonproc Ongoing 1 Month (A) 1 (A). 1 (A) 2 3. 6 12 33 (TBD) 45 c/ Ongoing * Ongoing a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. . c/ Complete for asbestos, chromium compounds and benzene. - Ilf - May 2,1980 DRAFT GENERALIZED WORKPLAN The foregoing strategies, even though having been tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination* The first three actions of the workpla ____ . ited for asbestos, chromium compounds, and benzene. The fourth and fifth actions have been initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. Completing the actions by these dates requires Corporate direction that the elimination/control of these substances is a mandatory priority effort. Without such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogens. Overall program management is essential to this effort. 11- May 2,1980 DRAFT FIGURE 2] MEMBERSHIP HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control Office Environmental and Safety Engineering Staff . Purchasing and Supply Staff . Personnel and Organization Staff . Scientific Research Staff . Manufacturing Staff . Car Engineering Body and Assembly Operations . Ford Parts and Service Division . Ford Tractor Operations . Powertrain and Chassis Operations . Basic Products Operations * . Electrical and Electronics Division . Climate Control Division . Truck Operations . European Automotive Operations . Office of the General Counsel FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER ' cc -12f May 2,1980 DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the requirements for chemical substances control. . It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issued. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an E&SES location was recommended. In view of budget constraints, it has been agreed that the existing Commpliance and Liaison Department would perform the Program Manager function. The Manager should be responsible for implementing carcinogen control strategies coordinating Company response to potential and promul gated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to B-101, establishing a financial measurement of the compliance effort, and assuming development direction and control for the computer information system and implementing the workplan as directed. The ongoing responsibilities of the Chemical Substances Control Manager will be to coordinate the product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forecasting/regulatory'impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee shouldbecqmposed of responsible executives from the areas shown tofr-the I* is further recommended that the Committee be chaired by the E&SES repre sentative. Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. , . i 12 May 2, 1280 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 1. Hazardous Substances Control Committee 2. Program Manager 3. Direct elimination of Asbestos, Chromium Compounds, Benzene 4. Request Operations Workplans 5. Adopt the priority carcinogen listing 6. Request the establishment of overall elimination timetables. - 13f - May 2,1980 DRAFT PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force on Carcinogens in the Workplace recommends that: 1. Establish a Hazardous Substances Control Committee chaired by the Director Environmental Control Office. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering Staff. S. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. 4.* Request that NAAO/DPO Product Engineering Offices and Manufacturing Staff present to the Subcommittee specific action plans and timing for the Group A applications identified. 5. Adopt as the Company carcinogen listing, current OSHA regulated Category I sub stances (26) and proposed for regulation substances (41). Establish the top eight prior ities proposed by the Task Force as Company priorities. 6. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene by Job #1, 1965, as outlined in the workplan. 13- May 2,1980 DRAFT EXHIBIT I OSHA CATEGORY I CARCINOGENS Regulated Acrylonitrile Amosite Anthophylite Arsenic Asbestos Benz (e) acephen&nthrylene Benz (a) anthracene Benz (a) anthracene, 7,12-Dimethyl- Benz (a) anthracene, 7-Methyl- Benz (a) anthracene, 7, 8,12-Trimethyl- Benzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dlbenz (a, h) acridine Dibenz (a, j) acridine Dibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso- 1-Naphthylamine 2-Naphthylamine Serpentine Vinyl Chloride . . Proposed for Regulation Acetamide Acetic acid, Lead (2+) Salt Benzidine Sulfate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium . Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3+) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt . Chromic Acid, Lead (2+) salt (1:1) Chromite Chromium Chromium (m) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Dlethylamine, N-Nitroso- p-Dioxane Ethane, 1, 2-Dibromo- Ethane, 1,1, l-Trlohloro-2, 2-bis (p-ehlorophenyl) Ethylene, chloro-, monomer Ethylene, Triehloro- Hematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (Q) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid ' Tannin ` o-Toluidine Urea, Thio- May 2,1980 CAS Number i "DRAFT . CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II FIGURE 2 N* * May 2,1980 I ] DRAFT CARCINOGEN SEARCH Materials and Toxicology System (MATS) EXHIBIT II To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALOG of Hazardous Materials (PdcO Staff) containing materials, their toxicological evaluation for worker/consumer protection and the chemical composition, the Engineering Material Approved Source List (EicRS) containing the material specification title and the materials approved to that specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction material standard and the approved materials; and the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. ,, Carcinogen Search Strategy Developing the links between the above systems will, in the future, provide a method for locat ing suspect carcinogens in nonproduction materials and production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the following search steps: 1. The Chemical Abstracts Service numbers of the suspect carcinogens and its compounds are identified by IH&T. The system will then generate a list of materials which contain that chemical. 2. Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other suspect materials and specifications. - 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a cross reference list of all parts which use that material. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. Functions The primary function of MATS is to maintain and produce the Approved Source List for non production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract. The system is also available to the plants and the Poison Control Center at the Rouge to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g., chromium. Affected Activities ` All Corporate Staffs concerned with materials/toxieological/environment controls are currently Involved in using/developing the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with the exception of Chassis which currently does not participate in material control as required by PEP 3-189. : PRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification Material Basie Part No. Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Gasket Gasket Deadener Sealers -- 7086 4035 350038 350038 9900000 Trans. Ext. Gasket Carrier Gasket . Eeon. PDV Box Assy. , Econ. PDV Box Assy. Courier Box Assy. Body ESB-M2G58-C Adhesive ESB-M2G171-AB Adhesive ESB-M2G188-A Adhesive ESB-M3G95 Tape ESB-M4G1-B Sealer ESB-M4G31-A Sealer ESB-M4G32-A Sealer ESB-M4G40-A Sealer ESB-M4G58-B Sealer ESB-M4G101-A Sealer ESB-M4G108-A Sealer ESB-M4G109-A Sealer ESB-M4G110-A Sealer ESB-M4G126-A Sealer ESB-M4G137-A/B Sealer ESB-M4G13&-B Sealer ESB-M4G141-A Sealer ESB-M4G145-A/C Sealer ESB-M4G147-B Sealer ESB-M4G161-A/C Sealer ESB-M4G162-A Sealer ESB-M4G172-A . ' Sealer ESB-M4G174-A Sealer ESB-M4G175-A Sealer ESB-M4G177-A/B Sealer -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- '-- -- . -- Primer for Adhesive -- .-- -- -- -- -- -- -- -- -- -- -- '-- . i -- -- ' .-- M ____________ 8094 0274 APPENDIX I DR A PT 5/2/80 Specification ESB-M4G188-A ESB-M4G197-A ESB-M4G198-C ESB-M5G8-A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A Trans ESB-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A Material Sealer Sealer Sealer Deadener Deadener Deadener Rust Prevent Gasket Gasket Seal Gasket -- Sealer Sealer Sealer Coating Phenolic ESF-M3D113-A BSA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A -- CCD ESF-M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket Gasket Gasket Gasket Gasket Gasket Sealer 2- Basic Part No. -- -- -- -- -- -- -- nrrart ina DRAFT 5/2/80 Part -- -- -- -- ,-- Sprayable Wax Type Rust Preventative 7D026 7A136 4035 7052 7A247 15520 9004650 * Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer 19560 19560 19554 19515 Caulking Cord Rope Sealer Perfect Seal Undercoating 18B374 8K621 17B616 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 . A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator I/C Lamp Socket Water Temp. Sender Gasket EEC Seal . Air. Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket 19D970 2A792 i A/C Comp. Gasket . P/B Cable Opening Cover 5004 0275 .. -3- APPENDIX I draft 5/2/80 NONPRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts -15 lb. Asphalt Saturated Asbestos Roofing Felts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper .* 8004 0274 -4- utl UIA 4 draft 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group B -- Known Substitute Material Available With Major Redesign Specification Material Basie Part No. Part Light Truck ESE-M8G106-B ESE-M8G140-A Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor Vendor , Vendor Vendor Vendor Vendor Gasket Gasket Phenolic Phenolic -- -- -- -- -- -- -- -- -- -- -- SB266 5B266 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket * Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy, Trans. Clutch Plate Assy. Chassis ESB-M8G106-A ESA-M8G14Q-A -- Gasket G'ssket -- 5B266 5B268 2022 2021 Resonator Gasket Assy. Tesonator Gasket Assy. Front Disc Brakes . i' 8004 027? -5PRODUCTION MATERIALS CONTAINING ASBESTOS DR APT 5/2/896" Group C -- No Known Substitute; Advanced Engineering Project Required. Specification . Material Light Truck ES-C8AA-2B282-A ES-D20A-2B072-BB ES-C8AA-2B282-A ES-D20A-2B072-BB -- Vendor Print -- Vendor Print -- ES-EOTA-2B120-AA ES-D6TA-2B118-AA ES-C8TA-2B282-A -- --' ES-C8TA-2210-D - . ES-C8TA-2010-C -- ES-D8TA-7550-A -- ---- ---- 1 -- Trans Vendor -- Vendor -- Vendor -- Heavy Truck -- * -- -- ** A* -- -- -- -- -- "T, - . mm*e --i' -- -- -- '-- -- ---- Basie Part No. Part 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 Lining Front Wheel Brake Outer Lining Front Wheel Brake Inner ' Shoe and Lining Inner * Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake Inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch Clutch Plate Clutch Plate Parking Brake Lining ^ 4797 4A435 7550 Rear Axle Diff. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A598 7550 . 7E434 Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Brakd Compressor Fan Clutch Assy. Clutch and Bracket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Brake Assy. 8004 0278 Chassis ESE-M8G149-A Gasket 5F263 2284 2285 wconuiA i DR APT S/2/80 Exhaust Manifold Gasket Rear Brake Shoes 8004 027? Inter Office Mr. K. B. Termaat Manufacturing Staff May 15, I960 00 A. 0. Folger 0. 0* Keutgen V. N. Moore Subject: Draft of Executive Summary - Carcinogens in the Workplace In accordance with your note to Mr. Q. 0. Keutgen of 5AV80, we have reviewed the subjeot draft. The comments listed below are supplementary to those appearing on the attached marked copy. Introduction See marked oopy. Representative Past Company Actions A Ve recommend that the title be ohanged to "PAst Company Actions/ and / that this paragraph be onmpHtoly rewritten/to highlight the dlretivoo?~T^~l prOoedures^. actionsgmtT, that have been taken to aeoipi mespnnnM'H+ries a-**.u. nwrt flflfliat- dag that workers are protected and that the composition of&naterialB are identified with regard *to health and safety environmental fconsiderations. Examples: Directive B-101 Procedure II d 1 PEP 3-189 - Vehicle Engineering Directive on Asbestos / V Idd^icpdlly, tha-'ftotiana taken by EmjjIe^eT&talth Serviot>a~IiKthe rspjtwT' Cn g^t^A^S^x^Wkplacc^ea^osuPCjL-jettfT should oe-iricluded. " Potentially Carcinogenic Substances Ve recommend making this section more brief with less emphasis on detail Suggest highlighting the activities that have occurred with regard to concentrating upon the top three of the eight substances selected by the Task Force far priority consideration. ' Our other comments are as marked upon the copy. Strategy aid Workplan . See marked copy. 8004 0280 Mr. X. B. Tennant - 2- May 15, 1980 Reeonmendations Suggest revising the order of the recommendation^ and certain responsi bilities (see marked oopy). Additionally, ye Relieve Items 8 and 9 should be deleted since they are details andLeould be handled by program management (see marked oopy). Item 10 should be revised to read, "Endorse allocation of appropriate funding and prioritization of efforts to address the development of designs, materials and protective measures as required to implement the recommended strategy (responsibility: E&R and M&S Subcommittees)." Attachment P. P. Guy 8004 0281: EXECUTIVE SUMMARY CARC1NOOENS IN TUP. WORKPLACE Introduction Al the October 1979 joint meeting of the Engineering end Research end Manufacturing and Supply Subcommittees, a report on the Occupational Safoty and Health Administration (OSHA) Policy for Regulating Workplace Carcinogens was presented by Personnel and Organization Staff. This report noted that final regulations for carcinogens in the workplace wore anticipated by the end of 1979. Thcro was discussion on the probloms Involved in dealing with a great variety of substances and suppliers if wo ore not in a position to bo speclflo in asking about possible substitute materials. It was agreed that efforts to elim inate the use of potential carcinogens where possible should be preceded by analysis of the affected materials and processes. In this regard, a Task Force was established by the Subcommittees to identify careinogens and quantities in use, set targets for elimination ahead of regulation, take stepe to find substitutes, devolop a directive and workplan and organize to identlfy<gnd further control potentially carcinogenic substanccg Since October, OSHA has released its Policy which further defines Category I potential carcinogens as substances known to be carcinogonic In humans or which have been demon strated to be careinogenle In two separate laboratory animal studies. Category II substances are those where data is suggestive of carcinogenicity in humans and test animals. Tho Policy also establishes the mechanism for standards setting. Normally, once tho need for a standard Is determined by OSHA, a ruling may be Issued In 11 - 20 months. If an "Emergency Standard" la set, the ruling is issued and immediate compliance is required. Comments and hearings are subsequently sollolted. Tlic Policy hus boon challenged and is awuiting disposition by e U.S. District Court and two Circuit Courts of Appeal. A draft list of candidate substances governed by the Policy was issued two years ago. A revised list is ' expected to be released in July, 1980 followed by a prioritized extract in September. U it expected that the list will be updated periodically. The Task Force has concentrated on developing the capability for managing the elimina tion/control of Category I potential carcinogens in the workplaco.and net on^other luxic^ hazardous-eubatances. A start has been made In identifying specific applications for sub sequent elimination or control. Representative Past Company Actions , Since 1977, the Company has removed lead chromates and molybdates from paint (except lor school bus yellow and special orders), "Tris" flame retardant from fabrics and Instituted further controls on asbestos. In this respect, a Vehicle Engineering directive has been issued that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). As of 1969, sprayed-on structural steel fireproofing has been osbestos-froe for new and reworked construction. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposuro has been reduced to permissible levels or eliminated since 1978. Ventila tion was increased at Romeo to minimize potential exposure to paint-related chromlu compounds. TOkJteSlft Kbm<i nn an MVMA rtappoorttTfflihhob Task Force has to date identified thirty-six (36) potentially [ carcinogenic substances or groups of substances in use in the automotive industry or genhy ifwtnctrini [v^oKpa., Eleven (11) of those arc currently regulated by OSHA os potential carcinogens; the balance have potential for new regulation. More restrictive standards have been proposed for some of those substances currently regulated. Thirty-one (31) substances are reported to the Michigan Department of Natural Resources (MDNR) for computation of water surveillance fees. Michigan plants i<sed 1.3 million pounds of tho eleven (11) potential carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data Is not currently required to be reported In the other states. The list of carcinogens wos prioritized by the Task Force, according to impact on the Company and potential for further regulation, to identify the top eight (8). The top three of the eight priority substances, asbestos, hexavalent chromium compounds and benzene, were examined. Speclflo lists of those bulk materials end ports for production and nonproduction use have been developed. The osbestos list has been forwurdod to purchasing for supplier verification of content and availability of substitutes. The benzene and chromium compound lists are being analyzed by the product offices and manufacturing to define specific parts usoge. 8004 0282 2- Asbestoa is used by the CompanvAlmarlly In vehicle brakes, clutches, gaskets end (or nonprcrfuctloiTISfiSjfi^nlBbard and core/mold sealers. Medical evidence links inhalation of asbestos dust to lung cancer, mesothelioma end other diseases. The present OSHA limit is 2 fibers per cc of air (2 million fibers per cubic meter) which may be proposed for reduction to 0.1 f/cc possibly this year. - Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links certain hexovalent chromium compounds to lung cancer and others to liver and kidney damogo and other diseases. Tho present OSHA limit Is S2 microgram per cubic meter of air for which National Institute for Occupational Safoty and Health (NIOSIlj has recommended u reduction to 1 microgram per cubic meter. Benzene occurs p. rimaril_y in coke oven o.perati.on..s. as a b.y-.p_ro_d__uct and in petroloum f`uola. It 'Is a rcslduul constituent in solvents, pel mors, adhesives, lubricating oils, fuols and hydraulic fluids. Medioal evldenee links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has issued a standard of 1 ppm in air as a time weightedjrirerege for an 8 hour workday. The standard Is nowtafore.the f A new computer data base is being de\mlgpgk(2nd quarter 1981), Materials and Toxicology System (MATS), which links health, aftfitneoring, and manufacturing data bases to facilitate rapid identification of potential carcinogen and other toxic substance applications. The Mm between these jystemS will provide a method for generating a list of production and nonproduction material specifications which contain Category I potentkA^arcinogcns. NAAO -supplier codear-cpoolflaatlon-numbers-aad-product- names, MATS will Identify nddllienal seuumiatlcwi. --The specification num*bers are t-hen cross-ref-erenced to part numbers which use that materi'a)'. Finally, the production part and bulk materials list is matched In the purchasing system to determine suppliers to be queried for ellmination/eontrol of potential carcinogens. To date, of the five major MATS subsystems, two have been completed and the others aro being manually *bMayted for potential carcinogen searching. The engineering release system has bcerVauditj&eiW is being updated to extend materials Identification to all ports. Product Enginocflngrrocodure PEP 3-189 is being rewritten by NAAO to require systematic review of potential carcinogens and input to 2F*r.'. If" Strategy and Wo The search for asbestos, chromium compounds and benzene defined the number of parts end materials containing these substances as listed In the table below. Where possible, the applications were divided into throe groups: A - Known substitute material without major redesign, B - Known substitute material with major redesign and C * No known substitute and advanced engineering required. Tho data Is There remain many applications which require time-consuming analyses lor IdentlHCfitlom------- ^ Bulk Materials and Peru ***j Production k B c Total K'onproducttbn T~ B C Total Asbestos 38 21 28 103 8-- 8 Chromium Compounds / - - 22 22 Benzene J'. - 14 14 88 81 34 213 3 &- 8 Strategies have hden formulated to eliminate or control those substances. The recom mended strategv/u to proceed to ellmln.ito Croup A applications of these thrcesubstances by Job II, 1985<r Where elimination is not feasible. InstltulC-Canfrals on deslgn^pfocess and ^.exposure. For thafiS-appllcationsreouIrlng major redesign lOrouyBao.g., drum brake llnlngsT the elimination timetable must reflect Company cycle planvwawaMptrwrtian er renevatien (Q.M. has Stated an intent to eliminate asbestos bv 198S). FlnalivjBSttMTe no known feasible substitute exists (Oroup C"j,'' a dvanced engineering w^ill have to be ceompleted before ap / elimination timetable can be established, individual timetables remain to be established (or the balance of tlm prioritized subotanecsr- 8004 0285 I A generalized workplan has boon prepared on the basis of the evaluation of the substances referred to above. The workplan requires central program management, with action Imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle activities. Manufacturing activities, and the Manufacturing and Supply Staffs. It is Judged that approximately a year is required to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is Judged that one to two additional years would bo required to implement the most feasible actions not requiring major redesign. Substitution requiring major product, plant, equipment or process redesign would tako 33 months for vuhiclo or 43 months for mujor powertruin programs. A specific workplan b required for each application in Oroups D and C. Although a strategy and workplan b proposed In this paper and efforts hove been started in theso areas, there are considerable timing and feasibility risks In each of the identified applications. For the moat part there are no substitution programs except as mandated by regulation. Without funding or direetod prioritization over other engineering effort the work on the Identified asbestos, chromium compound or benzene applications cannot proceed* < jfndcr present economic conditions, Jilavarthrlesa, a measured Company reaction IsSej necessary to initiate orderly substitution programs with sufficient flexibility to adapt to / engineering and oconomle limitations. 7 /s Recommendations 8004 0284 Achievement of the recommended approach requires a Corporate commitment by the Policy and Strategy Committee to foster an integrated, suslatnod effort throughout the Company *| over a number of years. To accomplish the strategy, the Task Force recommends: Establish a Hazardous Substance Control Committee chaired by Environmental and + Safety Engineering Staff. The Task Force would be discontinued. (Responsibility: EAM and MAS Subcommittees) Assign hazardous substance program management responsibility to Environmental and Safety Engineering Staff. (Responsibility: BAfipand MAS Subcommittees) o 3. 6)7- Revise Directive B-101 to reflect adjusted responsibilities. No *w Pftli*y It frquIrH, O the matter b broadly covered under Policy C@o(Re8ponsiblllty^tvogram Manager)) Continue the development of MATS. A bu< et and headcount transfer from Engineering Staff has been agreed to. (Responsibility: ragram Manager)}-- >//;Adopt as the Company potential carcinogen listing the 36 cui nt OSHWragula&d ana proposed Category I substances. Establish the top eight prioriti js proposed by the Task Force as Company priorities. Dlreot that the listing be ipdated semiannually. (Responsibility: EAR8, MAS Subcommittees, PAO Staff) 6. Establish elimination timetables for the oight prioritized potential carcinogens for review and approval by the subcommittees. (Responslbillty^Tfogram Manager) /'. ^-Direct all chromium affected organizations to proceed with the compounds and benzene for Job II. 1983 elimination of Croup A asbestos, where feasible. (Responsibility: PECs, BMD<s) - 8. Provide advanced program funding to develop designs and/or materials for new production and nonproduction parts to identify feasibility, reliability, cost and weight implications of alternative materials/designs (Croup C). (Responsibility: EARS Subcommittee) ) f Engineering Staff Manufacturing Staff May 14,1980