Document NEO0BnBvOz8nMD2V88aOoG9mg

PLAINTIFF'S EXHIBIT ' ' '' ?-Z?C?.T ON Fi-SI ASBESTOS STUDY COMMITTEE ACTIVITIES| ab-ui The Asbestos Study Committee was forced July 1971 with the assigned consent or. rules and regulations promulgated by state and federal governments concerning asbestos ar.d its app-iacations. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. P. Stef! of P.aybe sees-Manhattan, with members from Wbrldbestos, Abex, Benriix, and Carlisle Corporation and J-M present. The following items were reviewed and/or discussed: (1) Relationship with Asbestos Information Association/North America- (2) Proposed Ulino Regulations. (3) Vehicle friction material emission test program to be conducted by 3er.di>: under ERAcontract. (4) tfanitoring for airborne asbestos fibre. (5) Districution and circulation cf literature on Asbestos/Health subjects. The purpose of the Asbestos Study Committee was restated as follows: "to gather and cessirate to its members information about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environment (particulate emissio: and to draft comments relative to proposed regulations in defense of reasonableness." The following is a lisu of the actions taken by the FKSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: September 'JO - Issued minutes uf first Commltteo meeting with letter coummtinc cn proposed Federal EPA and Illinois emission standards. October 23 - 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 Regulations on Occupational Expo sure. On January 26, 1972 arrangements were announced for Bill Reitze of J--H to conduct an instruction session on asbestos fibre monitoring at FMSI headquarters February 10. On . February IT this session was presented to nine attendees representing six member ccnmanies. The second Asbestos Study Committee meeting also was held cn February 10 with I. H. Weave: r.aytes" s-Manhattan, acting as chairman ar.d members representing V/orldbestos, J-H, Benaix ar.d Tarlisle attending. The following items were covered: P.eviev: c fAIA/HA comne 2. Review cf proposed OSHA asbestos standard and comparison with British standards ar.d re relations. ish Friction Material Council comments cn Illinois standards. ec forward to BFI-TC copies cf minutes cf future rKSl Asbestos O A etinss. l. Recommendation made that the FMSI Asbestos Study Committee maintain - n - c--- - - jT L ;. Reviewed background and expected thrust of OSHA .r.d m?A regulations. fi -4- z. F.e viewed .monitoring equipment and methods. 7. Recentended future course for Asbestos Study Committee. The following is a summary of- actions taken by the Executive Secretary during the first half of 1??2 in regard to Asbestos Study Committee natters: February IS - Circulated Bulletin 127 regarding various standards for asbestos cust 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 128 reporting on February 10 demonstration by Mr. Reit of rerbrane 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 tentatlv schedule for third Committee meeting to be held late July or August. - Tune 12 - I trued announcement of 05HA. nermanert standards on asbestos dust ^exposure as published in June 7 Federal Register. . The latter item has been rather intensively studied by your Chairman, by AIA/NA, and no doubt also by concerned individuals in practically all companies represented in FKSI. 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 matters. 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 prate reive clothing required above 1C fpcc ceiling limit. Change rooms, dual looker facilities, and speciallaundering and clothing handling, procedures required. __ .___ 7. Monitoring required at least every six months at operations exceeding allowable 1. Physical exam and doctor's approval required before assigning employees to jobs requiring use cf respirators. 5. ILinir.atior. cf references to ''cancer" and Kdanger" on signs and labels. Labeling eliminated for products containing locked-in fibre. 6. .s on ''dry sweeping1' and use of co: ssec for cleaning including pulmonary function tests,required annually for to dust. Ittlcyes access to medical and monitoring records required. Employees exposed to levels above 71V must be notified in vritinr. c ly locked'-in fibre need not be sealed nor labeled. -3 - '.vr.ile -~~y serious difficulties are expected in achieving compliance with the new regulatio by miners, texciie manufacturers, and insulation fabricators and installers, it appears to me zhaz nosz friction material manufacturing operations not relying on textile technolog should have relatively little trouble, although some dry meld type friction operations may also pose problem*. - ----- -- ------ Perhaps of a mere serious nature is the potential threat of banning of asbestos in friction materials, particularly in:automotive vehicles, to eliminate emissions from wear defarisf _ 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 uniij. late this year. Ibst of 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 of August, and they could bo-delayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatins. 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 vet cust collectors. This should be helpful to industry in permitting somewhai more flexibility in dust collector selection and application. 3efcre closing, I should like to recommend a few of my thoughts and suggestions that I have received fren ethers concerning items that should be considered and reviewed by the Asbestos Study Ccmzoittee during the following year. 1. Uniform, interpretation of CSHA standards, liaison withlAXA/faf will be . ~ 2. Istsminatior. cf technological feasibility of achieving both 2 and 5 fibres, throughout the industry. - 3. lemerminaticn cf the overall effect on the friction material industry of 5. levslopneuc cf guidelines, aids, and educational programs to help customers comply with ohe.regulations. i. Investigate a suitable standard method for analysis for asbestos in brake lining v.-sar debris. s and recommendations for safe disposal or recycling of friction waste.I. I. Follow as closely as possible medical and occupational health research concerning assess:* and asbescos-reiated diseases ana determine whether FI-31 or its member ccr.psr.iss should help sponsor or otherwise suppofcb work of .this nature. . 4- All of these subjects probably will be reviewed at the third Asbestos Study Ccmittee reeting to be scheduled within the next ronth 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 reeting. Respectfully submitted, --- I. H. Weavery Chairman V