Document V3y2EoGdx3ZyqBoZrNV5KJ3Zw

nUCTIOT MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMOS, K.J. 0 765 ASBESTOS STUDY COMMITTEE Friday, October 24, 1975, at 9:30 AM Institute Office, E-210 Route 4, Paranus, N.J. MEMBERS PRESENT H. IJagner, Chairman E. B. Feierabend D. E. Scone I. H. Heaver J. Dunderdale Carlisle Corporation Abex Corporation Bendlx Corporation Raybestoa-Hanhattaa, Inc. Royal Industries OTHERS PRESENT M. R. Cole Z. VI. Drislane Clapp & Eiaenberg Friction Materials Standard* TnaLitaei MEMBERS NOT PRESENT K. Jacko E. P. Stefl Bendix Corporation H. R. Porter Co. The meeting was called to order by Mr. Wagner, Chairman, at 9:30 A.M. MINUTES OF PREVIOUS MEETING The Minutes of the Meeting held April 28, 1975 had been distributed. These minutes were reviewed and a motion for their acceptance was made. Upon motion duly made, seconded and unanimously passed, it was RESOLVED: To accept the minutes of the April 28, 1975 meeting as written.M " p-FMsi* ocoa ASBESTOS INFORMATION ASmarmartut The Asbestos Information Association (AXA) held their annual GovernmentIndustry Conference in Washington on September 10-11, 1975. Non-members of AIA were invited to attend this conference. Several individuals representing friction materials attended. One of the items of interest was the proposed OSHA regulation which was due near the end of September. It had been indicated that the OSHA standards would be oriented more twards work practices than to a numerical standard. Mr. Heaver indicated that the OSHA individual who indicated this did so believing that the new standard would not hove a new numerical limit. Apparently there was alot of movement within OSHA by other jn*--nossiblv labor unions and HIOSH--end that the proposed lower Minute* of the Meeting Asbesto# ggudy Comaltree Occooer prepared for publication. The standard, which will be discussed later, proposed s numerical standard of 0.5 fibers/cc (TWA). tendsas stated that this conference was most worthwhile, it gave a gdM overview on asbestos. The only criticism oade was that the speakers did not have sufficient tine to be questioned after their presenta tions. lbs Institute trill continue to nonitor this conference and expresses its support of the work of the AIA. PLANS FOR INSTITUTE SPtTHAH OK ASBESTOS !1. Wegner and Ur. Drlslans had taken the initial steps to organize this sanlnar. At the April 28, 1975 seating of the Aabestoe Study Conlttee a resolution was passed recommending that ths Institute sponsor s workshop on the asbestos problem in the fall of 1975. This resolution was reviewed with the President of the Institute, Hr. Simon, and it was decided to proceed with such a seninar. Hr. Wagner contacted Hr. Noel Hendry of Johns-'LanviUe relative to his putting on a session siailar to that which J-M presented two years ago. (For reference: Hr. Noel Hendry, Denver, Colorado, telephone 303-770-1000, Extension 2142). It was suggested that the Johns-Maxrvllle presentation would have to be - the corner-stone of any seminar and that this would have to be arranged first before arranging other presentations. Mr. B. K. Kwon of 0SHA had been invited by Mr. Wagner to * address this seminar. Ur. Kwon had Indicated that he should be able to attend. It was suggested that the seminar would he a good time for a synopsis of the major points of the sew OSHA standard. Also it would be well for Hr. Kwon to talk with people from our industry. A comment was made to the effect that OSHA had misled those attending the conference in Washington indicating that the proposed standard would be work practices oriented. (The standard came out with a lower numerical limit.) It was stated that 1-Ir. Kwon was knowledgeable in the industrial hygiene area but he was not a policy maker. He was not responsible for the addition of numerical standard in the proposed amendments to the OSHA regulations. Mr. Drislane indicated that he had talked with Mr. Bob Mereneas of the Asbestos Information Association, and Mr. Mereness indicated that he would be pleased to attend. Also'Hr. Drislane contacted Hr. R. Magdelain of Hilfisk of America Inc. Mr. Magdelain would be most pleased to put on a presentation relative to that type of vacuum cleaner for the work place. Hr. Wegner also talked with Mr. W. Engelelghtener of Ferro-Tech relative to their pelletizing equipment, fir. Engelelghtener will also make a presentation. At the meeting Hr. Wagner called Ur. Noel Hgpdry to firm up the J-M participation. In summary, it was indicated that Mr. Bill Reitze would discuss the medical aspects of the regulations. Mr. Ed Fenner would review OSHA and EPA regulations. Mr. Noel Hendry would discuss fiber handling. The J-M presentation will require-a 35 mm projector, a 60 x 60 screen, along with a podium and a PA system. Mr. Drislane Indicated that arrangements for these would be made. Asbestos Study Cocolttee October iy/j The seminar trill be scheduled for Wednesday, Dccenter 3, and Thursday, Decenter 4. The opening session vill be a presentation by Johns-Jianville for the full afternoon on Deceafeer 3. Other topics will be scheduled on Thursday morning, with lir. bareness (or sooeone else froa A1A) talking at the luncheon on Thursday. There would be a registration fee of $10 for the seninar. Ur. Drlslane will try to sake arrangements at either the Marriott at Saddle Brook, the Ramada Inn in Rochelle Park, or the Sheraton heights In Easbrouck Heights. Mr. Drlslane will write Mr. Magdelaln and Mr. bareness to officially Invite them. Mr. Wegner will write to Mr. Kwon, Mr. Eegeleightener, and Mr. Hendry to fire up the arrangements. The committee recocmends that Messrs. Wegner and Drlslane plan and schedule the seminar. ' It vas suggested that the type of person to be invited should be someone involved with plant problems, but It should also be tl.e foreman or ocher Individual who could get across the message to not use an air hose or e broom. The possibility of s movie being shown was discussed. It was suggested that the concroverslal interview of Dr. Selikoff and Dr. '.awinaohn of Turner Brothers would not bs the right presentation. Farhtos a movie that emphasized controls in the work place might be worthwhile. 13o iecision vas made as regards a movie. Another suggestion was to have a presentation by those who have used foam to envelope the work station so that no dust is raised during mixing. ' Mr. Weaver felt that this was an interesting technique. Mr. Stone had discussed this at an earlier meeting but had made no further progress on this since chat time. 1c vas decided that this would not be added to the agenda. ' . As regards the Hilfisk equipment, it vas noted that this is good equipment for local pick-up of dust and debris in the work place. However, this subject should be expanded to include a central system such as a Hoffman unit. It vas felt that this session should be called `'housekeeping in the vork place" rather than ^'Nilfisk". However, the Nilfisk representative would discuss his unique equipment. The idea vas to sell the concept of cleaning che vork area (not to sell the vacuum cleaner). Hr. Drlslane vill indicate this particular point to I!r. Magdelaln in his invitation. AIA BOCISLET "ASBESTOS AMD BRAKE LININGS** Mr. Mereness requested Mr. Drlslane to have this booklet reviewed for update and corrections. The first question raised vas "Who is this booklet aimed ac7". Also, "What- is the purpose of this booklet?" It was stated that this write-up vas not a complete presentation of any particular aspect of the asbestos problem, and while interesting Insofar as it vent, vas not particularly convincing. It is not the type of message that would ordinarily be given to customers of friction material manufacturers. The message for re-builders and the garage people is to not create dust in the vork place. There should be more emphasis, if this vas the direction of the booklet, on such things as labelling, possible use of Instruction sheets, the handling of lining, and the proper use of exhaust systems. One of the problems in the field is that these customers will often groove, chamfer or provide extra drilling. It is during these subsequent operations that asbestos concentrations may be raised to levels above that allowable. It was pointed out the Asbestos Study Committee could not re-write a draft unless it knew what the booklet vas aiming at. It vas stated that the title is wrong. Perhaps there should Minutes of the tleetlag Asbestos Study Cosmictee -5- October 24, 1975 Written comments concerning Che propose! oust be submitted in quadruplicate: Docket Officer, Docket H-033 DS Department of Labor, Room H3620 200 Constitution Avenue N.W. Washington, D.C. 20210 . The question was asked as to what would be the most effective means of cocnxunieating with Washington to Indicate the problems with this new numerical standard. Should the Institute comment? Should the individual members comment? It is not enough for the manufacturer to feel his views will be represented to the regulators by the Asbestos Information Association or FliSI. It was suggested that it would be best if both the Institute and individual members respond with points that are particular to t.eir factories. It is felt that participation by the small manufacturer will be most meaningful. The Asbestos Study Committee will review the proposed standard and note some of the points that members may wish to cotmatac on. It should be pointed out that even if members comment to the effect that they support the ALA comments or they support the FMSI comments, at least they will be on record espousing their viewpoints. A comment was made to the effect that everyone has been gearing to get their concentrations down to the 2 flber/cc limit by July 1, 1976. The technology necessary to take the count down to 0.5 fiber/cc is not known. ' Bov can consents be made on the cost impact, effects on competition, effects on employment, effects on energy supply, when the technology for getting to the 0.5 fiber/cc is not even known at this time? The least that can be done is to request an extension of time for comments past December 8, 1975. Upon motion duly made, seconded, unanimously passed it was RESOLVED: That the Institute will request the Department of Labor to delay the cut-off date for comment on thee** proposed amendments to April 1, 1976. The friction materials Industry does not know whether the 0.5 fiber/cc limit can be reached. Perhaps it vill be necessary to go to materials with a material cost ten times that of asbestos in order to get the work place down to the proposed level. Industry is confronted with requirements for Standard 121 and Standard 105-75 from the National Highway Traffic Safety Administration with stringent friction materials requirements at the same time that they must evaluate whether they still use asbestos in their products. There are several points in the OSHA standard besides the 0.5 flber/cc limit. However, the main problem is the 0.5 fiber/cc limit. Some of the comments to follow concerned new problems that may arise as a result of this proposed standard. These problems will be pointed out to the members so that they can look at these from their viewpoints with the aim of advising Washington on their individual problems with this standard. The reduction of the limit to the 0.5 level is going to effect processors such as the re-builder and the garages who were not really included in this standard before. Any outfit that handles friction materials may very well find airborne concentrations of asbestos fibers that exceed the 0.5 fiber/cc level. For example, a junk yard which might have a Minutes of the Meeting Asbestos Study Coanlctee -7- October 24, 1975 work place for the uncomfortable clothing. To require air-conditioning in the work place while also maintaining the extensive exhaust systems would be prohibitively expensive--if it can be done at all--because one la at cross purposes with the other. Costs also will be increased because of the new monitoring requirements. ( As regards the effect on competition "It -was pointed out "that this nay very well be the trigger which would close down some marginal operations with a resulting transfer of jobs outside of the D.S. Even in Great Britain where much medical information has been gathered they have not gone to the 0.5 flbers/cc limit. It does not appear that Great Britain has sufficient medical evidence to support such a limit. Countries on the continent do not have this 0.5 fiber/cc limit. The Latin American countries have no limits. As regards the effect on employment and competition, the huge capital expenditures required for the U.S. plants may very veil export additional jobs. While seas of the procedures recommended for handling asbestos and removing^ the worker from contact with the produce may shoe labor saving results c the actual level of exposure to the remaining workmen from these en&gee still | will be quite high. There would be considerable costs for meabers In the friction materials' industry to requalify brake blocks and heavy duty segments for the requirecents of the HETSA Standard 121 which went into effect during 1975. There has been a considerable expenditure of funds for Standard 105-75 (hydraulic brake systems standard) by many members. Any changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard would add additional costs for manufacturers Is requalifying their mattrials. The friction materials industry in particular is caught between the forces of improved performance of braking materials along with restric tions on how to manufacture and distribute their materials. There may be considerable testing to requalify materials if there should be a change in processing or compounding. . As regard* the.costa to consumers and society in general the Industry does not know whet can be done if It is necessary to remove asbestos from brake lining. The industry could be subject to 5 - 10 years of serious dislocations In addition to the problems with the OSHA standard that appear evident, costs can not be quantified at this time. Industry needs more time to respond to these far reaching regulations. One of the requirements for record keeping stated that the records must be maintained for forty years, or for an employment Interval plus 20 years, which ever is longer. This is a considerable record keeping requirement. However it was stated chat perhaps this is necessary in order for subsequent study of the epidemilogy of asbestos. It was suggested that perhaps this is one of the new proposals that can be lived with. In prior meetings and at prior workshops the problem of correlation of fiber count has been discussed. 1c general there seems to be some agreement that different experienced counters may total up results shoving as much as a 30Z variation in counts from the same sample. This is already a problem. However these counts where the 30Z variation is evidenced are in the 2 fibers per cc to 5 flbers/cc area. A 30Z difference with a 5 fiber/cc count is 1.5 fiber/cc. Here, OSHA is asking for a concentration limit of 0.5 flbers/cc when with current observations there can be variations of as much as 1.5 flbers/cc. ........... .........* * ^Kers/ce not onlv does technology get Minutes of the lieetlng Asbestos Study Comalttee -8- Octobcr 24, 1975 Industry conditions Is 1975 (under the current 5 fibers/cc liolt) are much improved over industry conditions which were In effect through aosc of the 1960's. Each additional step approaching zero flbers/cc is a lot oore difficult than the steps that were taken to get Industry dwn to the 5 flbers/cc Holt. While It'will be burdensome to aove the concentrations to the .. 2 flbers/cc Halt, the steps necessary to get down to 0.5-fibers/cc are not known. - There are requirements is the proposed standard for worker re-assignment. If many employees are moved to lesser and lesser duties maintaining the same premium pay that they had received for working with the asbestos products, there will be a negative productivity result. It has been industry practice In the past for night shifts and more difficult tasks Co command higher pay prelums. This rotation to another job with no loss in pay will be another penalty to productivity. The recommendations that will be made by the FMSI or the All are not known at this time. It Is believed that the AIA stand will include background on medical information. However, It- Is most Important that the individual companies make a response. They should not expect that someone else will write It for them. The Secretary will prepara a bulletin to be sent to the membership suggesting that they caaent to OSHA on these requirements. It' '/ill be pointed out that the eomaents must be those of the individual member and they should not echo the suggested outline of problems which the Institute trill prepare. It was also pointed out that there are a lot of new items in the proposed regulations Including Items on loading, unloading and storing of asbestos cargo. Toe carrier--be it a railcar, ship or other--must make a visual inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed. Who does this? Does the carrier do this? Are the carriers aware of this problem? A close reading of the proposed OSHA standards revealed many problems of this nature which will have to be pointed out to others who may not feel that they are affected by the asbestos regulations. THE EPA NATIONAL EMISSIONS STANDARDS FOR ASBESTOS The Environmental Protection Agency published the amended standards for the National Emissions Standards for Asbestos. This appeared in the Federal Register October 14, 1975. Ordinarily the EPA amendments would be an item of prime concern to the manufacturers. However the proposed OSHA standards are so extensive and so far reaching they mist take priority over these new EPA Standards. It was pointed out that the EPA notice is the adoption of the amendments to the standards. These are not proposed amendments. In particular the waste disposal requirements are of Interest to friction materials manufacturers. The friction materials manufacturer is responsible to see that land-fill operators and trucks carrying waste comply with the requirements of EPA on disposal of asbestos bearing materials. The manufacturer is responsible for supervision to see that these requirements are carried out. Members reviewed the section 61.25 on waste disposal. There was some difficulty with interpretation. Mr. Weaver pointed out that the requirements for covering the asbestos containing material were applicable only if there were visible emissions to the outside air from the waste disposal site. In -............. c ---------------------------------------------------- --j - - j --, - " ------------------ _ f . \ --i /,.%/>> Minutes of the fleecing Asbestos Study Canmittee -9- October 24, 1975 of 61.25 do not cone into play. However these requirements for cover do take effect if there are any visible emissions. The most difficult areas of the new EPA standard are in the waste disposal area. There was no other business called to the attention of the comaittee. Upon motion duly made, seconded and unanimously passed it was RESOLVED: To adjourn. Adjourned: 2:15 PM E. W. Drislane Secretary