Document KG6romVEQEpvYYLx7vVQrarOx

^ . `a ' HZPORT ON FI-51 ASBESTOS STUDY COMMITTEE ACTIVITIES The Asbestos Study Committee was formed July 1971 with the assigned purpose to review and co--sr.; on rules and regulations promulgated by state ana federal governments concerning asbestos and its applications. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. ?. Stefl of Rayiestos-Manhattan, with members from Worldbestos, Abex, Bendix, and Carlisle Corporation and Z-Y. present. The following items were reviewed and/or discussed: (1) Relaticr.ship with Asbestos Information Association/North America. (2) Proposed Illinois Regulations. (3) Vehicle friction material emission test program to be conducted by Bendix under EPA contract. (4) Monitoring for airborne asbestos fibre. (5) Districution and circulation of literature on Asbestos/Kealth subjects. The purpose of the Asbestos Study Committee was restated as follows; "to gather and cessimate to its members information about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environment (particulate emissions, ana to draft comments relative to proposed regulations in defense of reasonableness." The following is a list of the actions taken by the FKSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: ' September 30 - Issued icinutes uf first Committee meeting with letter commenting cn proposed Federal EPA and Illinois emission standards. October 2S - Issued bulletin and further information on Illinois hearings. November 10 - Issued information on membrane filter monitoring method. November 14 - Issued bulletin on revisions to Illinois and Federal EPA proposals. December S - Issued information concerning final draft of proposed Illinois regulation, proposed EPA. emission standards, and Federal Department of Labor F.eg_iations on Occupational Exposure. On January 26, 1972 arrangements were announced for Bill Reitze of J-M to conduct an instruction session on asbestos fibre monitoring at FI--SI headquarters February 10. On February 1C this session was presented to nine attendees representing six member ccnraries. se . -c-j -i r.c Asbestos Study Committee meeting also was held on February 10 with I. H. "Weaver, s-Manhattan, acting as chairman and members representing V;orlabestos, J-M, Bendix, isle attending. The following items were covered: F.sview cfAlA/NA comments regarding CSKA meeting in Washington on January 26. 2. Review cf proposed OS HA asbestos standard and comparison with 3ritish standards and remulations. , Study Comm ' British Friction Material Counci ed to forward to 3FKC copies cf ee meetings. comments cn Illinois standards, utes of future FKSI Asbestos PLAINTIFF'S EXHIBIT L. .-.e commendation made that the FM5I Asbestos Stud}' Committee maintain c_ose _iais:r. wmtr. Au-A/l.A. ab-jm nevoe-.-eo oacxtrour.a anc exoeccec t.nrust of OS HA _.nd a PA regulations." G t I /i 2- - . Reviewed monitoring equipment and methods. 7. P.eco--ended future course for Asbestos Study Committee. The following is a summary of-actions taken by the Executive Secretary during the first half of 1972 in regard to Asbestos Study Committee matters: February IS - Circulated Bulletin 427 regarding various standards for asbestos gust exposure and control. This included copies of the January 12 Federal Register announcement of proposed permanent CSHA standard for asbestos control in the work place. February 18 - Issued Bulletin 428 reporting on February 10 demonstration by Mr. Reitze of membrane filter monitoring method. June 1 - Circulated announcement of Microscopy Seminar scheduled by McCrone Research Institute in Chicago week of June 26. June 6 - Circulated supplementary information received from Illinois Institute of Technology Research Institute regarding friction material emissions and issued tentative schedule for third Committee meeting to be held late July or August. ? June 12 - I* rued anno'ir cement of OSHA permanent standards on asbestos dust expo sure as published in June 7 Federal Register. , The latter item has been rather intensively studied by your Chairman, by AIA/faA, and no doubt also by concerned individuals in practically all companies represented in FK5I. The consensus appears to be that the new regulation is stricter than need be in respect to the future TLV of 2 fibres per cc, but is more lenient than was expected in regard to many other important natters. Major changes between the new regulation and the earlier emergency standard and earlier proposed permanent regulations are as follows: 1. Automatic reduction cf TLV to 2 fibres in four years. 2. use of protective clothing required above 1G fpcc ceiling limit. Change rooms, dual lccker facilities, and special laundering and clothing .handling, procedures required. _ - ea at least every six months at operations exceeding allowable al exam and doctor's a?; v. reqa in? use cf resmirators. before assigning employees to jobs elimination cf references to :cancer" and -danger" cn signs and labels. Labeling eliminated for orocucos containing locked-ir. fibre. 6. & a on "dry sweeping" and use of compressed air for cleaning ec. examinaoions, includin ovees exocsed to dust. onary ncoic.n oesos,required annually for o medical and monitoring records required. Employees exposed mo muso be notified in vrioirr. c locke e meed moo be sealed nor labeled. . 'i -5 V'r.ile ~--.y serious difficulties are expected in achieving compliance with the new regulation by miners, textile manufacturers, and insulation fabricators and installers, it appears to me that most, friction material manufacturing operations not relying on textile technology should have relatively little trouble, although some dry mold type friction operations may also pose problems. - perhaps of a acre serious nature is the potential threat of banning of asbestos in friction materials, particularly in automotive vehicles, to eliminate emissions from wear debris. It is doubtful that any further action in this direction will be taken until results of the comprehensive study by Bendix Corporation for EPA have been announced. I have been advised that this study, originally to have been completed this month, now is not expected to be finished ur.tij. late this year. Host cf the difficulties that arose in this study to date have occurred in connection with the gas collection phase of the program. Since the study involves collection and analysis of g aseous emissions as well as particulates, precision rotary seals and gas collection systems had to be developed and evaluated, and this has necessitated extensive and time consuming engineering design efforts. Another vital EPA program also is running behind schedule. That is promulgation of the permanent regulations and standards for asbestos emissions to the ambient atmosphere. T have been advised by the EPA Hazardous Pollutants Branch that the earliest date these standards are expected to be issued is the beginning oi August, ana they could bo delayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatir.s. Significant changes are expected in the sections applying to mining and spraying operations. Probably the only significant change between the proposed regulation and the expected final regulation as far as manufacturing operations are concerned is the broadening of specifications on fabric filters and wet dust collectors. This should be helpful to industry in permitting somewhat more flexibility in dust collector selection and application. Before closing, I should like to recommend a few of my thoughts and suggestions that I have received frcm ethers concerning items that should be considered and reviewed by the Asoesucs Study Committee during the following year. 1. Unifcrm interpretation of CSHA standards. Liaison with AIA/^IA will be heirful in ohisu 2. leterminatior. cf technological feasibility of achieving both 2 and 5 fibres throughout, the industry. - 3. 1st emanation cf the overall effect on the friction material industry of f guidelines, aids, and educational programs to help customers emulations. x suitable standard method for analysis for asbestos in brake lining is and recommendations for safe disposal or recycling of friction waste. . "cllcw as closely as possible medical and occupational health research con c emir, r see;-.:; and asbestos-related diseases and determine 'whether ?M5I or its member o.-.paoies should help sponsor or otherwise suppofeb work of this nature. . -4- All of these subjects probably will be reviewed at the third Asbestos Study Committee meeting to be scheduled within the next Tenth or so. Please advise us of any additional iters you or others in your organization nay wish to add to our agenda for this upconing meeting. Respectfully submitted, I. H. Weaver, Chairman