Document NeZ5Kb3V1mdrjno1MZJ19Vqyg
E. 210 100X1 4, FDUnt l.J. 07452
MUIUTB OF THE KEETinB
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ASBESTOt STUDT CCMHLITBE " i 1
Frldij, Jim 1* 1973, it 9s V XK,
sc ths Institute Office, E. 210 touts 4, Paranus, H.J.
MTtHFPS PtESBfl
Z. n. Weaver, Chal H. Wagner E. B. Palarabcnd
Raybestoe-Manhattan, .Inc. Carllsls Corporation 4bsac Corporation -
OTHERS HUSSSff
5. B. McGinnis (for J. C. Burning)
M. Jscko (for R. Spurgson)
D. E. Stans
6. C. Wyatt
W. B. Gustafson
'
E. V. Ortolans
World Boston Conpany
Mar--ont Corporation
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Friction Materials -Standardi'Tnstitute,
MEMBERS WOT PRESENT
J. C. Banning T. Bell W. Spurgson
World Bsatos Cospany B. I. Portsr Co. Bandit Corporation
Ths --sting vas eallad to ordsr by Mr. Weaver, Chair--n, at 9:30 A.M.
MIKHTES OF PBEVIOPS MEETING
Tbs Sacratary raad a
Ihsso
had
obtained^
of ths Minutes of ths Masting hold Fabnacj 16* 1973. rnloassd and a notion for thsir accsptancs bad been
Upon
duly nods, sscoodsd and msnlaously passed. It vas
RESOLVED* To aceopt ths nlnurss of ths Fab-ary 16, 1973 is distributed.
FMSI-0148
UUUK
PFMSI- 0C07
At ths February 16, 1973 --stingy ths Sac--tary vas directed to distribute Infornatlon an typical CAZTTIOB labsls now la uss. Ths purpoos of this dietribu te-- vas so teat tha Co--ittee Bodwn could tsviav what is ovallabla and would bo in a position to propose label specifications to --at tbs OSHA requlsunsacs.
0ns --absr suggested that ths siss of ths labeling used should be of sufficient
size to be noticeable on a lares carton and should be co-- oaurably s--Her but
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Minutes of tbs Asbestos Study Committee Meeting
2
June l, 1973
till noticeable os a sealler package. One nesber was using an insert with
CAUTION label stuffed into the package. The use of lnpdnced CAUTION labels
on tbs carton le deslnble because .it is essentially a one-tine tooling cost
Ow use of separate labels :1s a continuing added direct expense.' . Most
now using separate g-------*
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carton when ordered.
In whet nuet be a response or e reaction by others t~easy ctastonexs are noe -- asking Meafcers About bow much percentage of asbestos -e in the brake -linings This could be a react!on on the customer's -pert as to whether they would hew to put control practices in their factories because of the ashestoe that is contained in brake lining. To nest the true spirit of tbs OSSA regulations,' > uaanfacturate doing stfcsaquent drilling, grledlng sc catting, of ash earns metelm-- ing brake UaAngs should use the cere-that OSgA euggsare
One atdxr felt that where he wee shipping drilled ground lining sets that be
would not have to iaprtnt these snail cartons with the OSSA GAUTXOB label. Other ^ nepers ere slaply putting ~tbe OSSA CAUTIOV labeling on everything. When It wee
suggested that the Coealttae should taka a position on this labeling requiresent, -
the anAen of the Coaedttae were referred bad to the Seeolutloa that vea aade *: on February 16, 1973. Hale Basolutioo said, .In effect, that OSSA labeling
practices should be adhered to where asbeetee containing naterlaln do not have -> asbestos fiber coapletely locked la or where subsequent operations nar be per*- " fozned. The question concerning the drilled end grotmd set le: While It la .
unlikely that athaequent operetlons will be perfoxaed, le It possible that they
nay be performed?
.
After e lengthy dUcusalon it was decided that no resolution concerning Tacosended CADTIOU labels would be proposed. Bather, the Secretary le directed to send to the Kaafeerahlp copies of typical labels war in use.
It wee called to the Secretary's attention that his yellow Bulletin of March 30,
1973 was In error, la that notion It stated, "Avoid breethine duet". The word**
lag should haws boon, "Avoid ersatiaa dust". Thla error will bn called to the
attention of the Membership.
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The Chairman brought up another point as regards labels. There le e alga that can be posted In the factory where there are restrictions concerning asbestos duet In the etaoephere. This le e standard sign for placing in the factory which aaya: "CAUTION - Asbestos duet hazard; avoid breathing dust; must assigned protective equipment; do not rantin in area unless your work requires It; breathing asbestos dust any be hazardous to your health". Information on
the availability of these signs will be sent to the Menberehip.
EPA EMISSIONS STAHBABDS FOR ASBESTOS
While Che nee EPA eneslons standards appear to be reasonable, there la sons difficulty la interpretation. For example, the standards are not slqply "No
visible ensslous", but (1) if the control equipment does not neat the_ air clean
ing requirements in the regulations, no visible emissions ere permissible, or
(2) one could even have visible emissions if they were using a collector with
the specifications' recommended by the EPA. In other words, if you have the EFA'a rei laswmlmil collector you could possibly have visible emissions sad still be cosplyiag with the.EPA requlrenssts. It goes without saying, that interpre tation of the requirements by individuals la the different EPA regions nay vary quite a bit.
*"< of. the
Asbestos Study Cumi4 ct-- Hf ring
-3
Jibw 1, 1973
m tha dry-bag collector. 3f an EPA Enforcement Officer aaaa a vapor from tba staek where a wet collector la used, the-source best be abla to prove tfaara la no aabestoa being dlacfaargad. In other word*, it can ba Inferred that If a source bas vet collectors they eay norm likely be dted for visible aalaalcna.
Vhile It la apparent ttit the SFl'i ealsslona standards promote tha dry collac-- -
tlon of aabestoa la bagBf nany-problem* have bean*Indicated vltfa these collectors.
One of tba problaaa vaa repeated fires in the collection aystarn, r Anothar meaber _
statad that he too had
problee mtll dgazstte smoking wee banned In the* **'
factory.. Slnca iHaeMtimiini sacking la the factory, he dales they hava not *'
had norm than ona or two flraa la .the last 25 years.-. Another anbtr add that
eay ba, but they have had a Mo Sacking tnle for easy yaars and they sdll hava
flrsa. This party blaeaa tha flraa on tha laceadve prograe where tba workers
receive a bonus for exceeding certain work standards. This promotes tha taking
of header cuts with grinding wheals and creates sparks which apparently proeota
tha fires In the aystan. Tha operation that has not had any fires for tba past
25 years does not have an incendve systan and does not permit smoking in tha
work place. Vhere tha wet collectors ere now la use, apparently -the EPA la
permitting their uae as complying with the requirements. .
At this paint, the disposal of tha aatsrlals picked op by tha collectors wae ' brought up. One maAer sent tha duet to a pelletising machine. In this process
they add 5Z-10Z cement to tha pelletiser. A volume reduction In tha order of 3 to 1 was developed. The pellets are taken by truck and dunped aa lend fill. Hhlle the pellet* could ba broken down Into a powder. If they receive reasonable handling they can ba readily moved from the pelletizing eochlno to the land fill operation. It la this neaber's Intention to install e vacuum aystea from tho collecting areas to go to e central pallatizing'machine. One meaber described
his handling of dust from (1) a central collector, to (2) e screw conveyor, to
(3) a truck, and to (4) the land fill. The workers In thin case use respirators.
The pelletizing operation not only reduces the transportation cost by three tines but eliminates the need for a watering truck sod aa individual to wet down tho land fill. However, the coats of this pelletizing equipment era substantial. A manufacturer of pallatizing equipment la Ferro Tech Zac., 1231 Banker!lie load, Pittsburgh, Fa. 15216.
Several aezbers mentioned that la dealing with the EPA Baglaoal Offices they were having difficulties deciding what was a "new source" and what was aa "esdstlng source". Also, whore one manufsecurer adds one nachina to aa existing collection system bo aty not bo In co^Uance without getting a Valvar of CoopUance. Appar ently the EFA will not give a Valvar of Compliance that trill take acre than 12 month* to cooplate, An applicant' must give the steps to be taken and tha schedule to bo net. Vhen each data arrives, the applicant nust advise EPA concerning coapladcn of that stag* of die schedule.
One i >ar felt that we should review the EPA source report form to get a bbeatttteerr
understannddilnngg ooff wwhhaatt tthheeyy warn
_ for. Page oneof die report would b* uaa_d
for factory. As there would most likely ba aaveral points of amission, pegs
2 would b* conpleted for each stack, or collector that eaits asbastos.
If a nannfacturar wished to asks an addition or modification In his plant with equLpmac that might put asbastos into the atmosphere, he must file with the EPA. On page 1 of tha report ha would cross off tha words "Sourca Bsport" and type la either "Application to Construct a Haw Source", or "Application to Modify Exist ing Sourca". In reviewing page 2 of tha report under "Process Description", sows questions cams up aa to how to eenplato thin section. One masher who had worked on this report with the EPA said you should aatar hem die type of
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Uj nttfmm of the '' Asbestos Study Comelctee Heating
Jons 1, 1973
aachinsry used without quantifying. Another asubsr indicttad that tha EPA
Insisted that ha liat tha typa of aqulpaaat and tha oubtn of aach piaea of
equipment. If tha CPA specifically aald to liat tha nunbara and types of aqulp-
aant in thla auction it vaa auggaatad that thay would have aald ao on paga 2 of
tha report. Tha question of putting down tha ntabaza and typas of aquipaant could
bacons wexy nnjiaiaoaa where a aanufacturar wiabad to nova a grinding --hi-- ;
from a locadon with tons collector-to another location where it would ha booked -
into soother collector. W Tha asaber idjo filed widrtia ZPA washed on reports -in
2 different Jurisdictions: - Maw York and Tennessee.% Be indicated that at neither '
location did ha enter the nuuber of pieces of equipment on this - fora. ; (Sinas thd
asetlng he called to advise that the application filed in Tennessee without '
quantities was accepted by .the CPA. Bis application in New Yoxfc State had not
been either accepted or rejected as of June 4, 1973.) It would appear that
Beglanal Offices are not in agrseasnt as regards quantification of tha aquipaant
under tha "Process Description."
.
The question cans up concerning interpretation of question 3, the "Annret of Pollutant." In aeny factories a eat of dry ale brake blacks could nit Into e collection syetea at the wiser,.at the briquette prase, at the cut-off
wheels, at grinding, at drilling,, and at inspection end booing. The problem is that this Is the eaas original asbestos which entered the process and sight
be cowted 6-8 Claes. So, in effect, a factory talcing la ono wlllloo pounds of
tha wording of tha fore. It would appear that thla la exactly what tha SPA wants. However, another nsober wee told that "this in not what the SPA wants. Be suggests that if a factory takes la out aUlioo pounds of ssbsstos into the process that it should not report la total wore than one all11 on pounds of asbestos. If he hod
10 different amission points, hs would diyids tbs ana alllioo ponds of ssbsstos
by 10 to give the "anoret of pollutant." Again, their apparently has been a difference in interpretation froa different Regional Offices of the SPA.
On page 3 of the report, under "Waiver of Compliance," it was stated that Sect! 2a and 2b did not hove to be completed unless EPA specifically requests this lnforastlon.
INSTITUTE SPgHAE ON SAFETY AMD HEALTH
At the February 16, 1973 nesting, suggestions were nods that the Institute consider the sponsoring of a seminar for nepers associated with plant- operations
Tbs Institute indicated it would be willing to sponsor such a seminar if suffl- .
dent interest developed.
*
A question was raised as to whether this seminar would apply only to asbestos. Tha Secretary indicated that such e seminar would apply to any field of interest but it should be related to prcbleas that can be tied into State and Federal regulations. Among tha topics suggestsd for a seminar were tha following:
Air aaapling and asbestos concentration detennlnatloa. Tha pulmonary fraction tost and X-Ray. Possible extension to include nolee and heat stress. Cooperation between nenegenent end woxkere in nesting the
regulations. Asbestos beg opening aachlaaxy.
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.Minute* of the ' Asbestos Study
-J- Jim i, 1973
Ih Socretary was directed to mk* tv o Hot of subjects which night Istoroat
tho ifa^ership and to canvass tha aa^>ors as regards their Interest, la addition to the agenda ltaao to suggest to the Membership, It was suggested that the
canvassing latter aak If aa -individual froe that aeaber-company would attend,
where the wasring should be held,: sad vhea the useting should be beld.sIt wss
Indicated that e nearing la tha, late fall would be desirable and .such'ilocatloos as
Chicago, Detroit,'CRittabtxr|h. and Para i were suggested.' s.
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Vhea tha Secretary has prepared a quastloaaaire It will be submitted to Mr."' ;.
Felarabead for hla revlaw prior to distribution to the Membership..: The actual. .
agenda will be drafted after the- aasbezs have Indicated their preference. t^Tha '
question was raiaad as to whetbar outside speakers would be Involved and it was
suggested that we ware not Interested In a eounerdal pitch at the meting.
Johns-Manvllle bad indicated aa Internet la approaching each e seminar with "die'
idee of promtlng their HEAP (High Energy Air Filter) pollution control equlp-
mnt. It was suggested that perhaps it eight be worthwhile to have outsiders .
mke presantatioas concerning asbestos beg opening equipueat,' pelletising, .
eollectian, etc. - This will have to be worked out at n future Committee .meeting.
Brake end Clutch Emissions Ganaratad Dnriff fuhida Operation
This particular study was run by Beadlz Research Laboratories mder sponsorship of tha EFA. A psper was praoeatad to tha S.A.E. by Dr. H. Jacks and Mr. E. DuChsrm of Beadlz, and Mr. J. Somxs of tha ERA. The actual report to the ERA Is e massive document ezplainlng every test procedure and every method of collection used in the study. A technical paper wee presented by theee 3 gentlemen at tha SAE Meeting In Detroit In Hay, 1973. Tha study assentally canters oe how much ashes toe is being put into the atmosphere from brake linings and clutch facings. As Dr. Jacko wee In charge of this investigation he discussed the paper at our meting. Be advised that a condensed version appears in the magazine AUTOMOTIVE ENGINEERING. Among the points that Dr. Jacko made was that there ware problem where a brake on one side wee enclosed and tha other brake was open to tha regular atmosphere. Modifications had to be made involving cooling of tho outside of tha shroud so that there would not .be too great a teaperatura difference from die left slda to die right side. This was more of a problem with the disc brakes on the fronts. Actually with the necessary cooling, thers was hardly any difference between the dun brake rears side to side.
Among the item discussed la the paper were hew much asbestos is used In fricd.au materials. It le indicated that there are about 193 ad.lll.oa pounds of asbestos In the friction materials which are used In the United States each year. There apparently are aom differences of opinion as regards how much asbestos Is involved but it generally falls in die 90*120 adlllon pound rsags. Actually, the anoint Subject to wear is about 66-2/3Z of the actual lining that gets oo to the brake (after grinding). Nhen asbestos la being used in brake linings it is discarded in one of three waye: It gets deposited on the surfaces of the brake, such as on the caliper, and around the wheel cylinders. (This is surface debris). Additional material is collected on the lining surfaces, in the rivet holes, and on the brake dxua. (This is called suep debris) Additional notarial becomes sizborns and is collected oo mdirene filters. (This is called airborne debris). It la this letter airborne debris chat the research* era ere sacking to quantify.
Based on the ampins that wars collected, tha conclusions warn that more than 99.7X of ths asbestos In die brake lining is caavmrtad.ro other products. By txtrspolatlag ths data that they vara able to develop on s passenger car the researchers indicate diet a total of 5060 pounds of asbestos is put into ths
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HLsstas of the Asbeatoe Study Committee Mmdug
4-
June 1, 1973
buipban* Oiia airborne ubutot emission Is 3.22 of tbs total ubutaa oiettd from all automotive brake Unions and dutch facings la tha U.S.
A quMtloa arose as to uhat happens to the asbestos debris that drops out. Does
It eventually get late the ataospheref , It was indicated diet based on die study
of other eaterlals that apparently, there heve.beea bulld-upe such as -lead along 7
the sldas.of turnpikes. tads -notarial apparentlyfgoes date -die earth'a surfaces;
and whether.ltds picked tp-agdali dependent! on . other :factois .such .as -the
proximity-to stzeeas, etc. . .
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A gentleman fion Ford Motor Cespaay was also to present a paper to the SAE neeting concerning asbestos pardeulate enisalaos into the atmosphere. Bo paper was - . available at this tine. There were sons questions concerning procedures and a source of data on the Ford paper, but in any event the p^er indicated a lower total asbestos ealeslon than the Bendlx paper. - These two papers should serve as source lnforaadou when others are etteaptlng to quantity die asbestos enitted into the atnoephere from brake linings and dutch fadags.
. CTSEE ITEMS
The topic of OSBA inspections and enforcement van brmpit tp briefly and the neobers Indicated that no new actions had been taken by QSHA as -regards enforce* sent concerning the asbestos standards.
The Asbestos Information Association (AIA) is to put out a Compliance Manual concerning control practice* This is still preliminary and there is no advance copy available at this time.
There being no further business brought to the attention of the Committee, upon notion duly made and qnaalnoualy peased, it was
BZSOLVED: to adjourn.
Adjourned: at 2:30 F.M.
E. W. Drialene Secretary