Document VG8V1k91ZK7303XLLwaj2zekw

U 133 E.STIEGEL STREET, MANHEIM, PENN. 17545 Raybestos v Manhattan f. H. WEAVER CQ**a**tt a^tcro* June 16, 1972 Mr. E. W. Drislane Executive Secretary Friction Materials Standards Institute, Inc. Bergen Hall Office Center E.210 Route #4 . Faramus, N.J. 07652 '' Dear Ed: '. Attached is ay repo-t cn the past year's activities of the Asbestos Study* Committee which I hope will be satisfactory for your presentation the week after next. I regret I won't be on hand at the meeting and certainly appreciate your pinch-hitting for me. ' If you have any questions or recommendations concerning revisions or additions or deletions to the attached report, please call me. I expect to be in the office Monday, Tuesday, Wednesday aid Friday next week and Monday, the 26th. After that I will be away until July 17* Also attached is a copy of a tabulation prepared by AIA/NA comparing each, major item in the final OSHA standard against the industry position and the recommendations of NIOSH and the Advisory Committee on Asbestos Dust, I think this might be worthwhile copying and forwarding to the other members of the Fi-ISI Asbestos Study Committee. I am not returning the form you sent me regarding the schedule for the next meeting as all of the dates listed on this schedule still are open as far as I am concerned. Unless you advise otherwise I will wait until I get back from vacation to return this schedule to you, as by that time I expect to know a little more regarding my plans for the last week in July and -the month of August. . Best regards. H. vv aver we SCF-ALLF-04050 r ' REPORT ON Fi-51 ASBESTOS STUDY COMMITTEE ACTIVITIES The Asbestos Study Committee was foraed July 1971 with the assigned purpose to review and comment on rules and regulations promulgated by state ana federal governments concerning asbestos ar.d its applications. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. ?. Stefl of Eaybestcs-Mar.hattan, with members fron V.brldbestos, Abex, Bencix, and Carlisle Corporation and C-V. present. The following items were reviewed and/or discussed: (1) P.slaticnship with Asbestos Information Association/tiortn America. (2) Proposed Illinois Regulations. (j) Vehicle friction material emission test program to be conducted by Bencix under EFA contract. (4) Monitoring for airborne asbestos fibre. (5) Distribution and circulation cf literature on Asbestos/Health subjects. The purpose of the Asbestos Study Committee was restated as follows: "to gather and dessimate to its members information about pending regulations concerning asbestos in the work place (occupational exposure) and in the general environment (particulate emissions, and to draft comments relative to proposed regulations in defense of reasonableness." The following is a list of the actions taken by the FKSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: September 'j,0 - Issued minutes uf first Committee meeting \.*ith letter commenting cr. proposed Federal EPA and Illinois emission standards.- " October 2S - Issued bulletin and further information on Illinois hearings. November 10 - Issued information on membrane filter monitoring method. Eovenber 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 Irepartment of Labor Regulations on Occupational Exposure. On January 26, 1972 arrangements were announced for Bill Reitze of J-M to conduct an instruction session on asbestos fibre monitoring at Fl-iSI headquarters February 10. On Ferreary 1C this session was presented to nine attendees representing six member r.c Asbestos Study Committee meeting also was held on February 10 with I. H. "Weaver, s-Manhattan, acting as chairman and members representing VJorldbestos, J-M, Benaix, isle attending. The following items were covered: r.eviev cSAIa/HA cements regarding OSHA meeting in Washington on January 2i 2. Review cf propcsed OSHA asbestos standard and comparison with British standards and regulations. > -- . > C itish Friction Material Council comments cr. Illinois standards, tc forward to 3FKC copies cf minutes of future F1-5I Asbestos nestings. PLAINTIFFS EXinBrr or. made that the 7Y11 Asbestos Studv Committee maintain --. A-'n--t-rw / : AB429 r.eview! kzround ar.c exoecced thrust of OSHA _r.d n?A regulations / i\ -2- .. Reviewed monitoring equipment and methods. 7. r.eco--ended future course for Asbestos Study Committee. lloving is a ary of-actions taken by the executive Secretary during the first f 1972 in regard to Asbestos Study Committee natters: February IS - Circulated Bulletin 427 regarding various standards for asbestos cusc exposure and control'. This included copies of the January 12 Federal Register announcement cf proposed permanent CSHA standard for asbestos control in the work place. February 18 - Issued Bulletin 428 reporting on February 10 demonstration by Mr. Reitze of membrane 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 tentative schedule for third Committee meeting to be held late July or August. .< June 22 - Irsued anno-'rcement of 03HA permanent standards on asbestos dusrt exposure,, as published in June 7 Federal Register. . The latter item has been rather intensively studied by your Chairman, by AXA/faA, and. no doubt also by concerned individuals in practically all companies represented in FK5I. 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 protective clothing required above 10 fpcc ceiling limit. Change rooms, dual Iccker facilities, and special laundering and clothing .handling procedures r ecuired. - . 3 squired at least every six months at operations exceeding allowable :xam and doctor's approval required before assigning employees to jobs use cf respirators. . atior. cf references to !cancer,: and .anger" cn signs and labels. Labeling e .ated for procucas containing locked' ' *31*2 . e_mnmr.ate: ''dry sweeping" and use of compress' for cleaning Tedical examinations, including pulmonary function rests,required annually for all employees exposed mo dust. Inoloyes aocess dr medical and orr.itoring reccrds required. Ipplcyees exposed uo iu. A- .4 L _ *:no aiding only locked-ir fibre need nbb be s5eaa"1led r-.ror labe.lleedd.. V.'-.ile ---j serious difficulties are expected in achieving compliance with.the new regulation by niters, textile manufacturers, and insulation fabricators and installers, it appears to me that most friction material manufacturing operations not relying on textile technology should have relatively little trouble, although some dry mold type friction operations may also pose problems. - 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 debris. It is doubtful that any further action in this direction will be taken until results of the comprehensive study by 3endix Corporation for E?A have been announced. I have been advised that this study, originally to have been completed this month, now is not expected to be finished ur.tlj. late this year. Jbst of the difficulties that arose in this study to date have occurred in connection with the gas collection chase 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 E?A 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 E?A Hazardous Pollutants Branch that the earliest date these standards are expected to be issued is the beginning oi' August, ana they could be delayed * until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operators. 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 dust collectors. This should be helpful to industry in permitting somewhat sore flexibility in dust collector selection and application. ' Before closing, I should like to recommend a few of my thoughts and suggestions that I have received fren others concerning items that should be considered and reviewed by the Asbestos Study Committee during the following year. 1. Unifcm interpretation of CSHA standards. Liaison with AIA/NA will be . r.sluful in this-. * 2. let emanation of technological feasibility of achieving both. Z and 5 fibres . throughout the industry. - 3. determination cf the overall effect on the friction material industry of ;. leveloumer.t cf guidelines, aids, and educational programs to help customers conulv with the, rerulatior.s. -..ear ueo suitable standard method for analysis fc: asbestos in brake lining 7. develop methods ar.d recommendations for safe disposal or recycling of friction closely as possible medical and occupational health research concerning a. fees cos-related diseases and determine whether 71-31 or its member uld help sponsor or otherwise suppofct* work of this nature. 5 All of these subjects probably will be reviewed at the third Asbestos Study Ccrcittee meeting to be scheduled 'within the next month or so. Please advise us of any additional iters you or others in your organization ray wish to add to our agenda for this up coming meeting. r Respectfully submitted, I. H. Weaver, Chairxan