Document MMp3dz5OXmDR0RbKDDGoQzKjV

FILE NAME Packings and Gaskets PAG DATE 2020 Feb 5 DOC PAG066 DOCUMENT DESCRIPTION Report of William E. Ewing CIH Samuel Ingram REPORT OF WILLIAM M. EWING CIH RE MR SAMUEL INGRAM February 5 2020 At the request of Mr. Shane Hampton of Simmons Hanly Conroy I have prepared this report concerning Mr. Sam Ingram's exposure to containing materials ACM I am the Technical Director of Compass Environmental Inc. located at 1751 McCollum Parkway Kennesaw GA 30144. I am certified in the comprehensive practice of industrial hygiene by the American Board of Industrial Hygiene Certificate No. CP 2627 Industrial hygiene is the field of identification evaluation and control of occupational and environmental health hazards I have practiced industrial hygiene for 42 years with the emphasis on asbestos exposures in facilities I have conducted asbestos investigations in over 2000 industrial commercial institutional and governmental buildings I have measured asbestos exposures to workers in the building trades and have researched the published literature and unpublished reports and studies to understand the historical exposures workers experienced I am also familiar with the standards guidelines and regulations applicable to workers exposure to asbestos I have conducted sampling for asbestos and analyzed such samples over the course of my career I was formerly the director of the Environmental Protection Agency EPA sponsored Asbestos Information Center at the Georgia Tech Research Institute I was a technical advisor to the EPA during the Brake Mechanics Education Program and was Chair of the EPAsponsored Asbestos Brake Conference in 1987. I have published approximately 25 articles on the subject of asbestos exposure My curriculum vitae is attached providing specific details of my qualifications experience and publications Compass Environmental Inc. invoices 325 per hour for my time plus any necessary expenses The following case specific materials were provided and which I have relied upon in developing my opinions 1. Deposition of Mr. Sam Ingram dated May 31 June 1 and June 23 2016 3 volumes 2. Affidavit of Mr. John Specklemeyer worker of Mr. Ingram at Deyer 1 3. Military records for Mr. Sam Ingram 27 pages 4. Plaintiffs Answers to Interrogatories and 5. Social Security Earnings Record for Mr. Sam Ingram Outlined below is a summary of my understanding of Mr. Ingram's work and personal history from which I have formed opinions Should this understanding be incorrect or be augmented my opinions may also change Mr. Sam Ingram was born on November 21 1937 in Indianapolis IN He grew up in Indianapolis and lived his life in Indianapolis or Clermont IN He attended Arsenal Technical High School in Indianapolis but left after a few months in 1951. His father worked as a mechanical engineer for Ready Mix Concrete Corporation His mother never worked outside the home He was the youngest of nine children His first job was during 1951-1953 about 2.5 years working at Turner's Pure Oil service station It had two service bays with one lift He began by washing cars and pumping gasoline and after 2-3 months doing mechanical work including brake and clutch work He also did engine tune and other work requiring replacement of gaskets He did tire work and batteries as well He estimated he did about 10-12 brake jobs per month during his 2.5 years working at the service station The work was mainly on drum brakes on American brands of vehicles He recalled American Brake Blok Bendix and Delco Remy brands of replacement brake linings and shoes He removed old friction from shoes and installed new linings on shoes with rivets He beveled the edges with a grinder Used compressed air to blow off the dust created by the beveling After working at Turner's about 6 months he began doing clutch replacements He estimated he did about 2-3 clutch jobs per month during his 2.5 years at the service station He stated he used an electric jitterbug sanding device sandpaper and a wire wheel on the two sides of the clutch plates He stated he removed some BorgWarner clutches and installed BorgWarner and Delco clutches He used compressed air to clean out the bell housing and described it as filthy and dusty He recalled using gaskets manufactured by Dana Victor and Delco All replacement parts came from Kersey's auto parts store Mr. Sam Ingram left home and served in the U.S. Marine Corps beginning in November 1955. He completed his 16 weeks of basic training in San Diego From here he served in Okinawa Japan and Camp Fuji Japan In Japan he worked as a radio operator and field wireman He next returned to Camp Lejeune NC and then spent 6 months aboard a ship in the Mediterranean He did training and some cleaning aboard the ship but no mechanical work He was honorably discharged from the service in December 1958 After his military service he returned to Indianapolis and went to work at the Bryant manufacturing plant He worked as a laborer deburring metal parts degreasing metal parts and also bending copper tubes These were the only jobs he did at this plant during 1959-1961 His next job for about a year in 1962 was as a track wireman for the New York Central Railroad He replaced corroded copper wire and wood crossties alongside tracks with new material The wire was not insulated He held additional jobs as a milkman for Roberts Dairy and truck driver He operated an International tractor and would haul flatbed trailers with building materials His work included picking up loads of mostly roofing from Manville Corporation's Waukegan plant He was only at the shipping and receiving warehouse Sometimes about 25 he assisted in loading the flatbed trailers using a forklift He unloaded the flatbed trailer himself about half the time He visited the plant to pick loads 2-3 times per week over about two years He delivered these materials to construction sites and retail stores His next job was at Volkswagen Speedway as a mechanic This facility had 12 service bays with lifts He worked exclusively on Volkswagen VW vehicles He worked here during 1965-1966 according to his Social Security records He recalled working on brakes and clutches He stated he did brake jobs every day sometimes two or three They were all drum brakes He used compressed air to blow out the brake dust He beveled the edges of the new brake shoes on a pedestal grinder every time He did about two clutch jobs per week He would remove the engine to access the clutch disk behind the flywheel He recalled the replacement brake shoes and clutches were shipped from VW in 1 He stated he sometimes picked up other products like asbestos cement siding and pipe He stated sometimes he unloaded materials by hand Germany Some were riveted and some were bonded brake linings He abraded the clutch friction surfaces of the new VW clutches with sandpaper and a wire wheel He cleaned up his work area using a broom to sweep it clean the blow the dust out of the shop with compressed air He did not do any major engine work Most of his work was on VW Beetles some VW buses and some Karmann Ghias He next worked at Dreyers Cycles as a mechanic during 1966-1971.2 He worked on British Small Arms BSA motorcycles and other brands He replaced brakes and clutches rebuilt engines and other work He stated they used drum type brakes He recalled BSA Bendix Delco and American Brake Blok brands He described riveting new linings onto the shoes He stated he beveled the edges all four edges of each brake shoe on a grinder This activity took 2-4 minutes per shoe He estimated he did 2-3 brake jobs per week sometimes more.He estimated he worked on clutches about 2-3 times per week as well.4 The BSA motorcycles clutch was a pack of 6 lined plates and 6 stainless steel plates These were wet clutches He recalled using BSA Barnett and Delco clutch parts He used sandpaper on the friction surface of the new clutches He recalled using Dana gaskets at this location especially on motorcycle overhauls There were about 25 gaskets in the engine that were replaced during each overhaul He removed old gaskets with a putty knife sometimes a pocketknife and sometimes a rotating wire wheel He estimated he did at least 100 overhauls or about 1-2 per month All the gaskets were precut and came as a kit He worked about 70 on BSA motorcycles 20 Triumph motorcycles and % other motorcycles such as Honda and Yamaha.5 In 1971 he left Dreyers Cycles and started his own shop Sam Ingram Cycles He continued to work on BSA motorcycles but also all other brands including % Yamaha some Hondas Suzukis Kawasakis and about 15 Harley Davidson motorcycles He worked on brakes of BSA motorcycles a couple of times each week He also replaced drum brakes on Harley Davidson motorcycles about 10 times with new Harley Davidson 2 Per Social Security records 3 He also estimated he did about 5 brake jobs per month 4 He also estimated he did about 4-5 clutch jobs per month 5 He did not work on BMW motorcycles but was around another mechanic that did He also stated he only worked on BSA motorcycles at Dreyers and other mechanics worked on the other brands 4 brakes He replaced about 1-2 Honda and Yamaha brakes each month He used compressed air to clean out brake wear dust often followed by wiping with a solvent soaked rag He continued to bevel all four edges of each brake friction on a bench grinder He recalled ECB brakes He used original equipment brakes on Yamahas Suzukis and Kawasakis He replaced clutches as well Wet clutches were not dusty He continued to replace gaskets associated with engine work on the motorcycles Installed precut gaskets He closed the shop following a shoulder injury in about 1986 In 1986 he and his son Daniel went into professional flat track motorcycle racing Mr. Sam Ingram sole job was pit crew During 1989-1993 they had Hondas Yamaha and one Harley Davidson He did all the maintenance work on these including tires cables brakes clutches and engine overhauls He recalled Barnett and Delco brakes He installed only precut gaskets Outside of work he maintained his personal vehicles He changed the brakes on his own vehicles about once every year or two starting at age 16 through about 2014. He recalled American Brake Blok and Bendix brands used He used compressed air to clean out brake wear dust He hand sanded the new friction He also did gasket work on personal vehicles using Dana Victor and Delco gaskets Mr. Ingram was diagnosed with malignant mesothelioma in early 2016. He died on November 4 2016.7 Malignant mesothelioma is almost always associated with previous exposure to asbestos with a latency period of at least 10 years Exposures to asbestos are expressed as a concentration of asbestos either as fibers or structures in air The units are either fibers per cubic centimeter of air cc or structures per cubic centimeter of air cc An industrial hygienist refers to a significant concentration of asbestos in the air or a significant exposure as one that is statistically significant above background or baseline 6 Bendix brake dust is 100 7 Indianapolis Star Obituary for Sam Ingram published March 19 2017 5 There are several statistical tests used to make this determination and such a determination is required for air sampling following an asbestos response action in a school building to comply with the Asbestos Hazard Emergency Response Act AHERA regulations To be able to state there is a significant exposure to asbestos and not due to chance alone the exposure usually needs to be about 5-10 times the background level.8 The background level usually referred to as the ambient level is what is found from sampling the outdoor air Many different numbers have been reported depending on how the measurements were done fibers included in the analyses and location of the samples Analyses by National Institute for Occupational Safety and Health NIOSH method 7400 uses the light microscope contrast with results expressed in cc Analyses by transmission electron microscopy TEM have results normally expressed as cc but may also be expressed as cc A structure can be a fiber bundle of fibers cluster of fibers or a matrix with fiber protruding Mr. Sam Ingram was repeatedly exposed to asbestos from friction products starting in about 1951 through 1953 and again during 1965 through about 1986. These exposures resulted from his mechanical work with brakes clutches and gaskets Mr. Ingram used compressed air associated with much of his brake and clutch work He used a grinder to bevel the edges of brake friction He relined some brake shoes He sanded clutch friction faces and some brake friction Published studies in the scientific literature repeatedly demonstrate that significant airborne asbestos exposures occur when performing brake work where compressed air is used to clean out the brake assembly Figure 1. Selikoff and Lee reported a range of exposures of 0.4 - 29.4 fibers per cubic centimeter cc when blowing dust out of brake drums Additional data demonstrate that even though the concentration in the brake wear dust may be only one percent or less peak concentrations of 87 cc can occur during 8 Keyes D.L. and J. Chesson A Guide to Monitoring Airborne Asbestos in Buildings Environmental Sciences Inc. Tucson AZ 1989 p 63 fi Selikoff I.J. and D.H.K. Lee Asbestos and Disease Academic Press New York p 115 1978 6 blowing the dust out of brake assemblies with compressed 10,11,12 Some brake wear dust collects in the brake drum and on the brake components as the brake lining wears down When this dust is subject to the force of compressed air the dust disperses into the air and is inhaled by the mechanic and others in the area This entrainment of the dust is recognized as a source of asbestos exposure among vehicle mechanics and even sweeping of the dust has been shown to cause exposures in the range of less than 0.1 to 1.7 14,15 These exposures have been shown to pose a health risk to workers Table 1 lists the specific ranges of exposure measured by some researchers investigating exposure during the specific activities of brake work The data presented below include measurements taken on the person doing the actual work and measurements taken in the area while another person is doing the work 10 Lorimer W.V. et al Asbestos Exposure of Brake Repair Workers in the United States The Mt. Sinai J. ofMed Vol 43 No. 3 pp 207-218 June 1976 Rohl A.N. Asbestos Exposure During Brake Lining Maintenance and Repair Environ Res Vol 12 pp 110-128 1976 12 Plato N. et al An Index of Past Asbestos Exposure as Applied to Car and Bus Mechanics Ann Occup Hyg Vol 39 No. 4 pp 441-454 1995 13 Rodelsperger K. et al Asbestos Dust Exposure During Brake Repair Amer J. Ind Med Vol 10 pp 63-72 1986 14 Occupational Safety and Health Administration OSHA Automotive Brake and Clutch Repair Work Safety and Health Information Bulletin Washington DC July 26 2006 Available at www.osha.gov/dts/shib/shib072606.html 15 Kauppinen T. and K. Korhonen Exposure to Asbestos during Brake Maintenance of Automotive Vehicle by Different Methods Amer Ind Hyg Assoc J. Vol 48 pp 499-504 1987 16 Lemen R.A. Asbestos in Brakes Exposure and Risk of Disease Amer J. Ind Med Vol 45 pp 229237 2004 17 Lloyd J.W. Current Intelligence Bulletin 5 Asbestos Exposure During Servicing of Motor Vehicle Brake and Clutch Assemblies NIOSH Publication Number 78-127 August 8 1975 available at http://www.cdc.gov/niosh/docs/1970/78127_5.html accessed November 4 2014 7 Table 1. Asbestos Measurements Reported During Brake Maintenance and Repair Mt. Sinai data18 Blowing dust auto brake drums Area n Blowing dust auto brake drums Personal = Grinding used truck brake linings Area n Grinding used truck brake linings Personal 10 Beveling new brake Area 4 Beveling new brake Personal n Riveting new brake linings Sweeping floor around grinder n 0.4 4.8 cc 6.629.8 6.629.8 6.629.8 cc 0.2 - 1.7 cc 1.7-7.0 1.7-7.0 cc 0.3 - 0.6 cc 26.3 - 72.0 cc 1.9 - 2.0 cc 3.6 cc Trucks & Buses Kauppinen data Opening of brakes 25 Cleaning brake by brushing 8 Cleaning brake with damp cloth = Cleaning brakes by washing = Punching rivets into linings 12 Grinding brake linings n on machine - no exhaust Grinding brake linings 30 On machine - with exhaust Beveling edges of brake with file n Assembling of brakes n Sweeping floor of garage 4 0.11.9 cc 0.1-4.5 cc 1.1 3.3 cc 0.1 - 0.2 cc 0.1 1.6 cc 0.3 - 125 cc 0.1 5.9 cc 0.1 0.9 cc 0.1 0.4 cc 0.1 1.7 cc mean = 0.4 cc = mean 1.3 cc mean = 1.9 cc mean = 0.1 cc mean = 0.7 cc mean = 56 cc mean = 1.5 cc mean = 0.4 cc mean = 0.2 cc mean == 0.6 cc Passenger cars - Kauppinen data Opening and brushing drum brakes n Compressed air cleaning drum brakes n Comp air cleaning with exhaust = Changing disc brakes no clean 10 Change clutch linings n 0.3 - 0.6 cc 0.1 - 8.2 cc 0.1 0.2 cc 0.1 - 0.1 cc 0.10.1 cc mean = 0.4 cc mean = 1.5 cc mean = 0.1 cc mean == 0.1 cc mean = 0.1 cc 18 Rohl Rohl A.N. Asbestos Exposure During Brake Lining Maintenance and Repair Environ Res Vol 12 pp 110-128 tables 3 & 4 1976 Rodelsperger Data 76 German Shops Blowing out 5,8 Dry Brushing 6,1 Riveting 0,7 Grinding by hand 5,0 Machine grinding 10,4 Turning truck drum linings Combinations 14,5 Passenger Cars Trucks Average Fiber Dose fibers micrometers per minute 4.7 4.0 www 3.9 3.9 - 3.8 5.3 9.3 9.0 - 9.9 8.6 4.4 Figure 1. Blowing brake dust from a drum brake using compressed air and electron micrographs of the same brake dust 19 In this study the exposures were normalized by converting exposure measurements in cc to dose measurements in cc per minute For example a measurement of 10 cc for a minute sample during blow out would be converted to 3.3 minute To compare the dose number to an hour PEL of 0.1 cc the PEL is recalculated as 0.1 cc times 480 minutes or 48 min 9 The National Institute for Occupational Safety and Health NIOSH undertook a study to evaluate mechanics exposures to asbestos during brake work at 11 service centers in the Cincinnati area Their report provides a brief history of the development and use of friction materials for vehicle braking applications Six of the 11 facilities service automobiles and performed 2-45 brake jobs per week at about 65 minutes per vehicle Four facilities did 5-45 brakes jobs per week on automobiles and trucks One facility only did truck brake servicing They conducted personal and area air sampling following Physical and Chemical Analysis Method CAM 239 except for some short samples where they used a flowrate of about 10 liters per minute A subset of samples was analyzed by transmission electron microscopy TEM The methods for cleaning the brake wear dust varied from compressed air blow compressed solvent mist wash off dry brushing wet brushing squirt bottle and HEPA21 filtered vacuum method There was no brake arcing beveling grinding or sanding conducted The NIOSH report found that two of the four peak samples collected during compressed air blow of the brakes were over the Occupational Safety and Health Administration OSHA Short Term Excursion Level STEL in place at the time 10 cc for 15 minutes The hour weighted average TWA exposures were all below the then current OSHA hour TWA Permissible Exposure Limit PEL of 2 cc When the 8hour TWA values were compared to the then NIOSH Recommended Permissible Exposure Limit RPEL of 0.1 cc there were 8 of 13 exposures over this level All of the peak exposures exceeded the NIOSH STEL RPEL of 0.5 cc in place at the time They also found that the exposures were consistent among the mechanics in the shop even among those not working on the brake replacements The TEM analyses found that 80-90 of the fibers detected by TEM were less than 5 micrometers in length and therefore not counted by the optical method They found that the geometric mean length for chrysotile fibers was 1.70 micrometers and a geometric mean width of 0.15 micrometers 20 Roberts D.R. and R.D. Zumwalde Assessment of Asbestos Exposure to Mechanics performing Brake Service Operations NIOSH Cincinnati OH April 27 1981 21 HEPA _ high efficiency particulate air 10 On December 1-2 1976 Bell Laboratories conducted sampling at three garages in the Miami area.22 Each of these garages performed preventive maintenance inspections of the brakes on or ton service vans When necessary new brake shoes were installed Personal air sampling following CAM 239 was in a range of 0.16 - 0.24 fibers greater than 5 micrometers per cubic centimeter cc with an additional three samples too heavy to count due to overloading Four area samples and one outside ambient air sample were submitted for electron microscopy analyses looking only at fibers greater than 5 micrometers in length One inside sample was 0.24 cc and the remaining were below the limit of detection Paik & Lee evaluated exposures at two automobile maintenance shops during the 1980s.23 Table 2 summarizes their findings Table 2. Airborne Fiber Concentrations During Brake Servicing Process No. Samples Geometric Mean cc Range cc Grinding Brake Lining 16 0.28 0.04 -2.51 Assembling Brake Lining 7 0.40 0.03 -3.04 -3.04 Changing Brake Lining 8 0.02 0.01 -0.13 Brushing Brake Lining 12 0.26 0.08 -0.62 -0.62 Cleaning with Compressed Air 5 4.26 0.117.28 0.117.28 0.117.28 Brake Lining Test 3 0.06 0.04 -0.09 -0.09 The brake shoes that Mr. Ingram worked with were likely containing throughout his career and when working on personal vehicles until at least the late 1980s At this point the brake shoes began shifting over to asbestos alternatives metallic brake pads for disk brakes were widely used during the 1970s and later The asbestos- 22 Kenny G.D. Bell Telephone Laboratories Asbestos Exposures During Brake Changes March 30 1977 23 Paik N.W. and Y.H. Lee Characterization of Worker Exposure to Airborne Asbestos in Asbestos Industry Korean Ind Hyg Assoc J. Vol 1 No. 2 November 1991 pp 144-153 11 containing brakes used by Mr. Ingram likely contained approximately 40-50 percent chrysotile asbestos Mr. Ingram was exposed to significant concentrations of asbestos when he performed brake beveling chamfering of new brake friction material Exposures of up to 125 cc have been reported during grinding of friction on truck brakes with no local exhaust Published sources indicate that beveling of brake materials results in a range of exposure of 26.3 - 72.0 cc In a study using Carlisle brake blocks the beveling produced exposures in a range of 69 - 241 cc Similar conclusions were reached in the study by Falgout.27 In eight tests of brake grinding he found an average of 465.1 cc per gram of brake material ground He also found that only 3 of 113 asbestos structures would be seen by the phase contrast microscope The hand sanding of the friction surfaces brakes and clutches would also produce elevated exposures but not in the range of grinding or beveling One study measured personal exposures during the hand sanding activity in a range of 2.4 - 7.2 cc n with PCME of 2.1 -2.4 -2.4 f.cc Mr. Ingram was also exposed as a bystander to the work performed by others at times Researchers from Mt. Sinai School of Medicine in New York evaluated exposures during automotive and truck brake repair at a repair shop during the 1970s.29 They looked at the exposures to fibers during blow of brake drums at various distances from the work and after time had elapsed from the work Tables 3 and 4 summarize these results 24 Environmental Protection Agency Asbestos A Review of Selected Literature through 1973 Relating to Environmental Exposures and Health Effects Publication No. 2-76-001 EPA Office of Toxic Substances Washington DC January 1976 p 28 25 Brake Linings Goodbye Asbestos Hello Semi Glass and Plastics Brake and Front End May 1985 pp 29-37 26 Millette J.R. Beveling Carlisle Truck Brakes Report of a study to Simmons Cooper August 25 2009 27 Falgout D.A. Environmental Release of Asbestos from Commercial Product Shaping EPA Publication No. S2-85 August 1985 28 Materials Analytical Services Inc. Opening of Brake Box and Hand Sanding of Brake Shoes Report dated February 16 2004 29 Rohl A.N. et al 1976 12 Table 3. Exposures at Distance during drum brake blowout Operation Distance ft N Fiber Concentration cc Mean Range Blowout of 3-5 432 brake drums with 5-10 432 compressed air 10-20 10-20 10-20 432 16.0 3.3 2.6 6.6 - 29.8 2.0 - 4.2 0.4 -4.8 -4.8 Table 4. Exposures at distances during and following brake drum blowout Distance ft Time lapse min Fiber Concentration cc Background samples 10 0 0.3 taken at varying 80 0 0 distance and lapsed 12 5 0.2 times after brake 50 5 0.1 drum blowing 65 7 0.1 75 14 0.1 Researchers from Ford published data they collected in the late 1960s.30 The point of the research was to evaluate a novel control device against the usual method of blowing out brake dust They also measured the concentration of fibers in an adjacent repair bay to simulate the exposures of mechanics working nearby They found 0.84 - 5.35 cc n for the mechanics doing the blowouts and 0.16 - 0.52 cc = in the adjacent repair bay These measurements were collected over a hour period The same researchers from Ford repeated this work to evaluate truck brake servicing during the late 1960s.,,During a hour period a mechanic serviced truck brakes that included the use of compressed air His measured exposure was reported as 7.09 cc during this work The measured concentration during the same hour period in the adjacent service bay was 0.28 cc and in two bays away it was 0.17 cc Mr. Ingram was exposed to asbestos when handling the old brake shoes and unpacking the new shoes In a study sponsored by Ford GM and Chrysler researchers measured 30 Knight K.L. and D.E. Hickish Investigations into Alternative Forms of Control for Dust Generated During the Cleaning of Brake Assemblies and Drums Annals of Occup Hyg Vol 13 1970 pp.37-39 31 Knight K.L. and D.E. Hickish Exposure to Asbestos During Brake Maintenance Annals of Occup Hyg Vol 13 1970 pp 17-21 13 exposures when packing and unpacking containing brake shoes and pads to estimate the exposures parts suppliers would have encountered when handling brake shoes They reported the average airborne minute asbestos concentration of 0.086 0.368 cc when unpacking and repacking brake pads and 0.021 0.126 cc when unpacking and repacking brake shoes.32 Mr. Ingram performed clutch replacements on vehicles including motorcycles An article by Cohen and Van Orden summarized a study sponsored by the Borg Warner Corporation to estimate vehicle mechanics exposure to asbestos from clutch removal The authors reported a range of exposures of 0.015 0.13 cc during this work In this study the clean out the bell housing was not done This activity would result in additional exposures It would be expected that Mr. Ingram's past exposures when performing clutch replacements would be consistent with the Cohen and Van Orden data with additional peak exposures during clean out of the clutch wear dust from the bell housings It would not be expected to have any significant increase in asbestos exposure when removing a wet clutch from a motorcycle clutch basket Mr. Ingram also handled many clutches A study was performed to estimate exposures from handling clutch boxes They reported 15 minute and minute exposures in a range of 0.006 - 0.37 cc 0.004 0.70 cc for handling clutch boxes This is consistent with the findings of sampling conducted by Ford during unpacking of pressure plates and opening clutch plate boxes.35 They reported a range of 0.05 0.30 cc Mr. Ingram was exposed to asbestos at times when he replaced containing gaskets on vehicles Some gaskets were cork or rubber and resulted in no excess exposure Other gaskets may have been completely covered with a layer of soft metal 32 Madl A.K. et al Exposure to Chrysotile Asbestos Associated with Unpacking and Repacking Boxes of Automotive Brake Pads and Shoes Ann Occup Hyg Vol 52 No. 6 2008 pp 463 479 33 Cohen H.J. and D. R. Van Order Asbestos Exposures of Mechanics Performing Clutch Service on Motor Vehicles J. Occup And Environ Hyg Vol 5 No. 3 2008 pp 148-156 34 Jiang G.C.T. et al A Study of Airborne Chrysotile Concentrations Associated with Handling Unpacking and Repacking Boxes of Automotive Clutch Discs Reg Tox and Pharm 51 2008 pp 87- 97 35 Francis Mark R. Letter Report to C.J. Augey Industrial Hygiene Asbestos Study - Clutch Assembly Area May 14 1979 14 e.g. copper effectively encasing the asbestos fibers within containing gaskets that were removed would have likely resulted in some exposure containing gaskets were used for cylinder head applications intake manifolds and exhaust manifolds among other locations in the engine New compressed sheet gaskets for hot surfaces began changing over to asbestos in the late 1980s However place gaskets that were installed into engines on hot surfaces and exhaust systems prior to that time were usually containing Exposures to containing vehicle gaskets would be highly variable depending among other factors how easily the gasket released from the surface and how vigorous the flange cleaning procedure It would also depend on the technique used to remove the place containing gaskets Industrial hygiene sampling has been conducted over the years to measure exposures to asbestos when working with compressed sheet gaskets containing asbestos A sheet gasket forms a seal between two moving surfaces to prevent the leakage of a liquid or a gas In place and undisturbed the asbestos in the gasket is not released from the materials However when the gaskets are removed cut drilled sawed sanded or in other ways abraded asbestos fibers are released The historical data is largely focused on asbestos gasket manufacturing operations and exposures from work with asbestos gaskets used on pipes valves pumps and similar equipment In one study conducted by the U.S. Navy where 14 samples were collected in the breathing zone of workers during the removal of gaskets using a hand scraper they found a range of exposures from less than 0.06 fibers greater and 5 micrometers in length per cubic centimeter cc to 0.39 cc with an average of 0.13 cc.37 A published article by industrial hygienists from Chevron Corporation found an exposure range of 0.11 -0.33 -0.33 cc when removing sheet gaskets using dry scraping and brushing.38 Millette et al also 36 Zeitz J.E. What Will Replace Asbestos Gaskets Diesel & Gas Turbine Progress July 1980 37 Ibid p 41 38 Cheng R.T. and H.J. McDermott Exposure to Asbestos from Asbestos Gaskets Appl Occup Environ Hyg 6 1991 pp 588-591 15 found a significant increase in exposures to asbestos when performing maintenance operations on asbestos gaskets McKinnery and Moore published their findings from work with asbestos gaskets Based on 23 personal samples they found a range of 0.05 -0.44 -0.44 cc for gasket removal and installation using light microscopy for analysis The numbers increase dramatically to 0.86 - 18.45 asbestos structures per cubic centimeter cc when the analysis is performed by transmission electron microscopy TEM The electron microscope is capable of seeing the shorter and thinner asbestos fibers not detected by the light microscope In 1976 Briggs & Stratton conducted industrial hygiene sampling to measure the exposure of workers handling containing head gaskets for small engines.41 The results were in a range from less than 0.073 to 2.6 cc More recently measurements have been conducted on mechanics doing work with engine and exhaust system gaskets Boelter et al collected minute measurements during Gasket work that included anything from handling metal parts wiping down parts to scraping compressed sheet gaskets The results were reported in a range of 0.044 -0.413 -0.413 cc by contrast microscopy PCM using NIOSH method 7400 and 0.044 - 0.413 cc by transmission electron microscopy TEM using NIOSH method 7402.42 The authors stated Removed and replaced gasket materials positive for asbestos ranged from % to 85 chrysotile Unfortunately the article did not disclose to what extent containing gaskets were involved in the work for which the air samples described above were collected However the study authors did disclose this information in a paper presented at the 2005 39 Millette J.R. et al Releasability of Asbestos Fibers From Containing Gaskets EIA Technical J. Fall 1995 pp 10-15 40 McKinnery W.N. and R.W. Moore Evaluation of Airborne Asbestos Fiber Levels During Removal and Installation of Valve Gaskets and Packing Amer Ind Hyg Assoc J. 53 1992 pp 531-532 41 Letter report from Jack E. Peterson Ph.D. to A.T. Dirksmeyer of Briggs & Stratton dated May 3 1976 42 Boelter F. W. et al Heavy Equipment Maintenance Exposure Assessment Using a Activity Model to Estimate Surrogate Values for Replacement of Missing Data J Occup Environ Hyg July 2007 pp 525-537 Table IV 16 American Industrial Hygiene Conference Twenty 22 of the 62 gaskets contained asbestos or 35 percent A study by Liukonen L.R. and F.W. Weir measured exposures to fibers during work with gaskets associated with disassembly of a medium duty diesel engine They reported 14 personal sampling results analyzed by NIOSH 7400 in a range of 0.017 0.120 cc Unfortunately the only personal sample collected during the buffing of head gasket surface was not analyzed since the sample overloaded with particulate The bulk sample analyses of the gaskets found that 28 of the 33 gaskets handled in this study contained 5 - 70 chrysotile asbestos A study by Paustenbach et al measured exposures during work involving exhaust systems on 15 General Motors Chrysler and Ford automobiles built during 1953-1970 and one automobile built in 1946.45 Compressed sheet gaskets were associated with exhaust systems of these vehicles Some of the gaskets were containing and some were not Of the containing gaskets bulk sample analyses by ray diffraction were reported to be in a range of 9.5 -80.1 -80.1 chrysotile All of the 16 vehicles had exhaust manifold gaskets During the removal of 12 of these exhaust systems the researchers chose not to remove these exhaust manifold gaskets For the other four vehicles that the exhaust manifold gaskets were removed only two contained asbestos No wire brushing was used to remove the residual gasket material from these two flanges The researchers collected a total of 35 personal samples excluded 5 personal samples that were overloaded with particulate excluded 7 samples collected when working on exhaust systems known to have no asbestos components leaving 23 samples that were analyzed The article reported 0.006 - 0.066 cc 0.022 cc for these samples by PCM and 0.0005 -0.105 -0.105 cc am - 0.013 cc for these samples by TEM 43 Boelter F.W. et al Airborne Asbestos Fiber Exposure Assessment of Heavy Equipment Mechanics American Industrial Hygiene Conference presentation Anaheim CA 2005 44 Liukonen L.R. and F. W. Weir Asbestos Exposure from Gaskets during Disassembly of a Medium " Duty Diesel Engine Reg Tox Pharm Vol 41 2005 pp 113-121 45 Paustenbach D.J. et al Chrysotile Asbestos Exposure Associated with Removal of Automobile Exhaust Systems ca. 1945-1975 by Mechanics Results of a Simulation Study J. Exposure Sci Environ Epi Vol 16 2006 pp 156-171 17 A study by Blake et al examined exposures during the partial disassembly of engines and the removal of gaskets remnants from engine receiving surfaces and loose parts It also examined engine reassembly and installation of new containing gaskets The work was done on three automobiles 1974 Chevrolet Malibu 1978 Chevrolet pickup truck and a Ford Thunderbird In describing the work practices followed it was stated To aid in the gasket and other residue removal process the mechanic sprayed the parts with a chlorine containing solvent dispersed from an aerosol spray can Aerosol Systems Inc. N TM 3506. It was further stated Loose parts such as engine heads and manifolds were next immersed into a water bath cleaner a product of Safety Kleen and washed using an Arm and Hammer brand Aqua Works Cold Cleaning Solution before being burnished using a rotary in knot type wire end brush NAPA service tools Part Number N 2312. A total of 6 personal samples were collected on the mechanic during the three engine disassemblies one on the left shoulder and one on the right shoulder during each engine disassembly work The range for these 6 samples was 0.007 - 0.027 cc as analyzed by PCM NIOSH 7400. The TEM by NIOSH 7402 results were not provided in the article with only the asbestos fiber ratio reported A total of 6 of the 9 compressed sheet gaskets involved in this study were found to be containing in the range of 14 - 75 chrysotile Three of the 9 33 were not asbestos containing Measurements during the installation of new gaskets did not detect asbestos fibers in the four personal samples by NIOSH method 7402. The article concluded this was due to the gasket being precut and sprayed with an adhesive sealant It is my opinion that Mr. Ingram's exposure to asbestos resulting from his gasket work was in the range of 0.01 - 1.0 cc with a likely geometric mean average of about 0.1 cc for a minute period Mr. Ingram likely had some exposure to asbestos associated with his loading and unloading of his flat bed delivery truck with certain products from the Johns Manville warehouse in Waukegan IL Mr. Ingram was exposed to asbestos dust from 46 Blake C.L. et al Assessment of Airborne Asbestos Exposure during the Servicing and Handling of Automobile containing Gaskets Reg Tox Pharm Vol 45 2006 pp 214-222 18 asbestos cement pipe In 1977 the Asbestos Cement Pipe Producers Association conducted a study to measure exposures during various activities with asbestos cement pipe They reported when loading and unloading asbestos cement pipe n the exposures were less than the detection limit 0.01 cc to 0.03 cc I hold the opinions expressed herein to a reasonable degree of scientific certainty Poeeceenefi 47 Noble W.M. et al of Equitable Environmental Health Inc. Asbestos Exposures During the Cutting and Machining of Asbestos Cement Pipe Report to The Asbestos Cement Pipe Producers Association Arlington VA March 16 1977 48 Equitable Environmental Health Inc. Dust Exposures During the Cutting and Machining of Asbestos Cement Pipe Additional Studies Report to The Asbestos Cement Pipe Producers Association Arlington VA December 15 1977 19