Document RjExOLZvp6maKpvM6Re8MErO8

ASSESSMENT OF ASBESTOS tTSE AND IMPENDING HEGDLATIONS ( C 105531 Vehicle fetal*! ft 1 fl Development artrl Planning August, 1979 002942 PRODUCED BY FORD ASBESTOS-IMPACT Purpose "o reviev and update the engineering asbestos plan. Background The 1975 OSEA proposed standard remains dormant. If promulgated it vill lower the permissible occupational exposure limit for asbestos from the current 2 fibers per cubic centimeter to 0.5 fiber/co. Formal hearings that normally precede issuance of a final standard hare been delayed for. several reasons; . A standard for the construction industry has ndt been prepared. . An economic impact study has not been released, although it has been in draft form for six months. . Continued attack on the proposed atandard by asbestos and mining interests as being too restrictive. Contrary to this apparent inactivity, HIOSH has recommended documentation of the "life cycle" of asbestos from mining to disposal and elimination of all non-essential uses. A working group in EPA's Office of Toxic Substance is currently performing a "life cycle" analysis of asbestos. First priorities for regulation are paper products (gaskets) and friction materials (brakes). Assessment ' study of the current regulatory situation indicates a high probability that tighter jnvironmantal restrictions on asbestoa will be promulgated within the next two years. The fact no firm evidence arista that the current standard is inadequate only means there will be no emergency standard of a disruptive nature. Evaluation of the current atandard could take 30 or 40 years still not surface concrete evidence supporting either the government or industry position. The burden is clearly on industry to "prove" the current standard is adequate. Since this is not possible wnrf the government agencies were created to regulate the use of materials, we must proceed an the assumption there will be further regulation of asbestos* The previous scenario for a staged tightening remains a possibility. This would mean a reduction of the current standard to 1 fiber/cc by mid-1990 and 0*5 fiber/cc by early 1983However, this tiling is unlikely because most industry currently meetB 1 fiber/cc end ohe proposed standard cas been "cn-the-booka" for nearly four years with no action. If, as expected, during the next two years the proposed OSHA standard is promulgated, and/or regulation by EPA of asbestos emissions from brake wear occurs, then the following results can be expected: A. A drastic reduction in the use of asbestos containing friction materials over the next 3 to 5 years. Comments: , Court challenges will delay implementation of standards for at least 1 year. . Transmission and Axle programs will be accelerated for non-asbestos sub stitution. (Attachment I) . Costly "crash programs" for braks drum substitutions. , Attachment II shows the company usage of asbestos containing friction materials. franeral list being conmiled by 1TMD&E- additional innut reauired 002943 PRODUCED BY FORD it L' 002944 ) a. B. The uae of asbestos containing gasket, insulating and sealer materials will remain cost-effective for moat applications. Comments: . Eav asbestos comes from Canada. . Process areaa meet 0.5 fiber/cc by encapsulation. , No eoiaaion problem because of encapsulation (with the possibls exception of disposal). *. Attachment III shows the company usage of asbestos containing gasket insulating and sealer materials. It is leas likely that we will see a standard of 0.1 fiber/cc. Streets in major cities have been measured at levels higher than 0,1 fiber/cc and citing this level as dangerous could result in "public panic". Competition Several years ago', GM reportedly considered a policy to get asbestos out of the brake linings because of the toxic concerns. They decided that the effort to find a substitute for asbestos would be better spent to improve the performance and durability of the lining material and opted for a development program with semi-mats by '8l-'B2 and all linings (disc end drum) by '85. The asbestos issue has helped keep the semi-met programs going over the years. There is no "official" GM company policy tc remove asbestos from other component areas. However, because of toxic concerns and company awareness of asbestos, gaskets and heat insulators are slowly being replaced with asbestos free materials. Asbestos insulation reportedly has been removed from manufacturing plants and the facilities that manufacture brake linings meet the present standard of 2 fiber/cc. It appears obvious, regardless of company policy, that CM -`ntends to eliminate the use of asbestos. Their approach of "no formal policy" is a result f f uncertainties associated with cost and timing for substitutions, and a general awareness that issues must be dealt vikh before they become problems. Chrysler also has no formal program for asbestos removal. However, in the ease of sealers and gaskets, they attempt to use non-asbestos materials wherever possible and in most cases, are now introducing the substitute materials. In the area of brakes, front wheel discs are being converted to semi-mets as new programs permit, but no plan exists for rear brake drum substitution. 1 It is unlikely that crash programs on some friction materials can be avoided when tighter standards are promulgated for the following reasons: . Reportedly there are no asbestos free substitute materials for drum brake linings available for evaluation at this time. . Despite the lead body solder fiasco, the engineering attitude (with the exception cf Transmission and Axle) remains "wait until the standard is promulgated". (Questions have been raised by various PEO's regarding a policy or position for the use of asbestos. In the absence of other direction, VMD&F micas recommendations later in this paper for a specific asbestos policy.) . The automotive industry has not shown sufficient interest in non-asbestos materials to warrant accelerated RAD efforts by suppliers. General list being compiled by VMD4P - additional input required from PEO's for completion (He ABOVE COMPETITIVE INFORMATION IS mm qh gENERALLI I A7VAIHABI_INDUSTHT SATA- TM.iT5P 'Hern'T?! ra PRODUCED BY FORD 3 Summary (continued.) , "sbestos containing gasket, insulating and sealer materials vill remain cost-effective this V. rfine around. However, the ultimate goal of NIGSH is to ban the use of asbestos, which means regulator? pressures will continue for many years to come. If we do not begin a Berious effort to develop non-asbestos substitutes, additional "crash programs" en be ejected. Recommendations Tbs above assessments raise questions about company response to impending government regula tions for environmental exposure to asbestos. In order to minimize the economic nd timing impacts of jthesa regulations, the Company must increase response in the following areas: 1. Initiate Advanced Engineering projects in the FEO'a to develop alternate materials for friction, gasket, insulating and sealer components that contain asbestos, the October 7, 1978 Transmission and Axle Engineering Nonasbeetoe Material Program (Attachment I) is an excellent example. The suppliers must be made aware that we are seriously interested in alternate materials so that they will expend the necessary BSD efforts. Additional manpower will be necessary to assist the already over burdened PEO's. Responsibility: PEO'a (Advanced Engineering) 2. It will be necessary to increase the capability of the Friction Materials Study Group within Research Staff to provide parallel support for engineering projects. Responsibility: E&HS 3. A firm company policy must be adopted for asbestos usage. Attached is a Car Engineering Practice Latter signed by the Vice President, Car Engineering (Attachment IV). Responsibility: VMD&P 4. Baceuse af the lack of a formal mechanism to follow progress in this area, periodic reports must be made to management via the Engineering and Re search Subcommittee. Responsibility: PEO's (Advanced Engineering) Vehicle Materials Development and Planning August, 1979 C 002945 PRODUCED BY FORD I Dmr:-33.*;o* -a develop can-asbestos cotericl cecpor.eots to replace tr.ose ite=3 currently released which eoctacc asbestos. `tnufacturi.-.g controls necessitated by anticipated 03K. ooor.dcris to ccr.trcl ctroir.egecic csientls '.oil "=tu: elittmace asoesaos usage = one autocative Locuscrp. For automatic tracscissiocs, the initial cevelc=srt effort to evaluate acc-csoestos fnotion citensls is being ccccuoted vita tee Co tracscissicn; initial rroi-ttt:-. oroirpcrncicr is scheduled for foe I, 19:1. ;3 find cateri-L selections are cate fcr tndiTii-il fr tion elsnsnts, tee ocr.or autonsaic transuission grstps ** r4 n^ a CH +*3 Cc T1T' "as asbestos reiafcreed cr.enolio reactors ill 00=00.00 passing out in 19c3 ana be 00=151317 passed cut cy :.*.= c-1 cut in 002946 o a ( "7 PRODUCED BY FORD 002947 PQ PRODUCED BY FORD