Document Vj9B30EMmb3vknoJ5OnQqJxK8

August 8, 1975 NATIONAL. INSTITUTE I Oil OCCUPATIONAL SAFETY AND HEALTH 5600 FISHERS LANE ROCKVILLE. MARYLAND 20852 PLAINTIFF'S EXHIBIT USX-1095 Dear Colleague: This communication is intended to alert you to recently gathered informa tion indicating a potential health hazard for persons exposed to asbestos during the servicing of motor vehicle brake and clutch assemblies. On July 21, 1975, the National Institite for Occupational Safety and Health convened a meeting of government and university scientists, industry representatives, and labor union officials to discuss the present state of knowledge with respect to this problem. Data was presented by investigators from the Mount Slani School of Medicine in New York City indicating that workers engaged in the maintenance and repair of automobile and truck brake linings are exposed to potentially hazardous levels of airborne asbestos dust. Specific brake servicing operations studied included blow-out of automobile drum brake assemblies, grinding of used truck brake linings, and bevelling of new truck brake linings. Average peak asbestos air concentra tions for these three activities based on personal samples taken within ten feet of the operator were, respectively, 10.5, 3.75, and 37.3 fibers (>5 microns in length) per ml. An analysis of samples of brake drum dust revealed that almost all of the asbestos fibers found were shorter than 0.4 microns in length. Previous studies of the extent of asbestos emissions from automobile brake lining wear showed that only a very small fraction of the original asbestos content of the brake lining is found in brake drum dust (Ref. 1-3). It was presumed that this is due to thermal degradation of the fibers during braking. The present findings indicate that enough asbestos is preserved to produce significant exposures during certain brake servicing procedures. r '* The full extent of asbestos-related disease in brake servicing personnel is not known at present because this particular occupational group has not been studied systematically up to now. However, a review of the scientific literature on the association between asbestos exposure and mesothelial tumors of the pleura and peritoneum has revealed at least four cases of these rare tumors in persons who were employed in jobs involving automobile brake servicing (Ref. 4-6). Page 2 For your information and guidance, we are enclosing pertinent references, estimates of the population at risk, a NIOSH interim recommendation for brake and clutch servicing \procedures, and a copy of the Department of Labor standard covering exposure to asbestos in the work place. The environmental studies of brake lining servicing operations outlined above together with observations of mesothelial tumors in persons so employed affirms the necessity for instituting and maintaining recommended control measures in this Industry so that the health hazards of asbestos are minimized. Enclosures J. William Lloyd, s.D. Director Office of Occupational Health Surveillance and Biometrics J m .cnsgr. REFERENCES 1. Lynch, J.R.: Brake Lining Decomposition Products. J Air Pollution Control Assoc, 18:824-26, 1968 2. Hickish, D.E. and Knight, K.L.: Exposure to Asbestos During Brake Maintenance. Ann Occup Hyg, 13:17-21, 1970 3. Jacko, M.G. and DuCharme, R.T.: Brake Emissions: Emission Measure ments from Brake and Clutch Linings from Selected Sources. EPA Report 68-04-0020, 1973 4. Newhouse, M.L. and Thompson, H.: Mesothelioma of Pleura and Peritoneum Following Exposure to Asbestos in the London Area. Brit J Ind Med, 22:261-69, 1965 5. McDonald, A.D. et al.: Epidemiology of Primary'Malignant Mesothelial Tumors in Canada. Cancer, 26:914-19, 1970 6. Greenberg, M. and Lloyd Davies, T.A.: Mesothelioma Register 19671968. Brit J Ind Med, 31:91-104, 1974 ESTIMATES OF THE WORKFORCE POTENTIALLY EXPOSED TO ASBESTOS IN THE MANUFACTURING AND SERVICING OF BRAKE LININGS AND CLUTCHES Auto Mechanics Garage Workers Manufacture (original and rebuilding) TOTAL 833,535 67,679 6.657 907,871 SOURCE: Adapted from 1972 Census of Manufacturers, 1972 County Business Patterns, and Census of Population: 1970 Occupation by Industry (all are Department of Commerce, Census Bureau publications) RECOMMENDED (INTERIM) PROCEDURES FOR ASBESTOS BRAKE AND CLUTCH SERVICING The National Institute for Occupational Safety and Health (NIOSH) has research underway concerning dust exposures during brake and clutch servicing. Due to preliminary data demonstrating significant asbestos exposures during presently used brake and clutch servicing techniques, NIOSH has reviewed t alternate techniques whereby asbestos exposures are reduced. The following are interim procedures recommended by NIOSH to minimize dust exposures. 1. If possible, an area shall be designated for all brake and clutch repairs. Entrances into this area shall be posted with an asbestos exposure warning sign as follows: Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Area Unless Your Work Requires It Breathing Asbestos Dust May Cause Asbestosis and Cancer 2. During brake servicing, an air purifying respirator, either single use or with replaceable particulate filter(s), as approved by the Mining Enforcement and Safety Administration (formerly Bureau of Mines) or NIOSH, shall be worn during all procedures starting with the removal of the wheels and including reassembly. During manual clutch servicing, such a respirator shall be worn during- removal and cleaning of the clutch, pressure plate and housing assembly and during instal lation of the new clutch assembly. 3. Dust shall first be cleaned from brake drums, brake backing plates, brake assemblies and clutch assemblies using an industrial type vacuum -cleaner equipped with a high efficiency filter system (>99% efficiency for 0.3 pm diameter aerosols). After vacuum cleaning, any remaining dust shall be removed using a rag soaked in water and wrung until nearly dry. Under no circumstances shall compressed air or dry brushing be used for cleaning. 4. During arcing and riveting operations,' an approved respirator, as described in (2) above, shall be worn. Grinding (arcing) .machines shall be provided with local exhaust ventilation such that worker exposures are maintained at least below the 1976 OSHA asbestos standard (29 CFR 1910.1001).* At a minimum, the dust bag of the arcing machine shall be removed and replaced with the hose of the high efficiency industrial vacuum described in (3) above. j .V -2- 5. Industrial vacuum cleaner bags containing asbestos dust and cloths used for wiping brake and clutch assemblies shall be sealed in plastic bags and labeled with the following warning label printed in letters of. sufficient size and contrast to be readily visible and legible: Caution. Contains Asbestos Fibers Avoid Breathing Dust Breathing Asbestos Dust May Cause Asbestosis and Cancer. , / All asbestos waste shall be disposed of in accordance with the OSHA asbestos regulation, 29 CFR 1910.1001(h). During removal of vacuum bags, an approved respirator, as described in (2) above, shall be worn1. 6. All floor cleaning in areas where brakes and clutches are repaired shall be done with the high efficiency industrial vacuum cleaner as described in (3) above. Grinding (arcing) machines shall also be cleaned with such a vacuum cleaner and any remaining dust wiped with a damp cloth. An approved respirator, as described in (2) above, shall be used during this cleaning. 7. Although adherence to the above procedures should minimize any contamination of work clothing, it is required that the appropriate portions of the OSHA regulations on asbestos (29 CFR 1910.1001(d) (3 and 4)) concerning special clothing, change rooms, etc. be followed. NOTE: Strict adherence to the above procedures should minimize exposures to mechanics during brake and clutch servicing. These are interim recom mendations and are subject to revision pending results of ongoing NI0SH research. * Section 1910.1001 of the Code of Federal Regulations was formerly Section 1910.93a. This change was noted in the Federal Register, May 28, 1975. _ .k Prepared By Division of Field Studies and Clinical Investigations National Institute for Occupational Safety and Health Cincinnati, Ohio fiULES AND: REGULATIONS 91910.93. Asbestos. (a) Definitions. For the purpose of this section. (1) "Asbestos" includto chryootOe. amosite, cxoddollte, tremofile, anthophylllte, sad acttnollte. . (2) "Asbestos fibers" means asbestos fibers longer than 6 micrometers. (b) Permissible exposure to airborne concentration* of asbettoe fibers--Cl) Standard effective July 7, 1972. The 8-hour time-weighted average airborne concentrations of asbestos fibers -to Which any employee may be exposed shall not exceed fire fibers, longer than 5 micrometers, per cubic centimeter at air, as determined by the method pre scribed in paragraph (e) of this section. (21 Standard effective July 1, IS7B. The 8-hour time-weighted average air borne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers, longer than 5 micrometers', per cubic centimeter af sir, as determined by the method pre scribed In paragraph (e) of this section. (3) Cctliny concentration. No em ployee shall be exposed at any time to airborne concentrations of. asbestos fibers In excess of 10 fibers, longer than 5 micrometers, per cubic centimeter of air, a* determined by the method pre scribed in paragraph (e) of this section. (c) Methods of compliance--(1) jfnytneertny methods. (1) Engineering con trol*. Engineering controls, such ss, but not limited to. Isolation, enclosure, ex haust ventilation, and dust collection, shall be used to meet the exposure limits prescribed in paragraph (b) of this section. (II) Coca! exhaust ventilation, (a) Local exhaust ventilation and dost col lection systems sball be designed, con structed, Installed, and maintained In accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, ANSI 2SU.2--tir/l. which is In corporated by reference herein. lb) Bee i 1910.0 concerning the avail ability of ANSI Z9.2-1971. and the maintenance of a historic file In connec tion therewith. The address of the Amer ican National Standards Institute Is given In 11910.100. (III) Particular tools. All hand-op erated and power-operated tools which may produce or release asbestos fibers In excess of the exposure limits pre scribed In paragraph <b) of this section, such an, but not limited to, saws, scorers, abrasive wheels, and drills, shall be pro vided with local exhaust ventilation sys tems tn accordance with subdivision 'll) at this subparagraph. (2) Work practices--(I) Wet methods. Insofar ss practicable, asbestos shall be handled, mixed, applied, removed, cut. scored, or otherwise worked in a wet state sufficient to prevent the emission of airborne fibers In excess of the ex posure limits prescribed In paragraph (b) of this section, unless the usefulness of the product would be diminished thereby. (11) Particular products' and opera tion*. No asbestos cement, mortar, coat ing, grout, plaster, or similar material containing asbestos shall be removed from bags, cartons, or other containers In which, they on shipped, without bring either wetted, or enclosed, or ventilated so as to prevent effectively the release of airborne asbestos fibers In excess of the limits prescribed In paragraph (b) of this oration. (M> Spraying, demolition, or removal. Employees engaged in the spraying of asbestos, the removal, or demolition of pipes, structnroe. or equipment covered or fnoolated with asbestos, and In the removal or demolition of asbestos In sulation or coverings ahull be provided with respiratory equipment In accord ance with paragraph (d) (2) (.111) of this section and with special clothing In ac cordance with paragraph (d) (3) of this section. (d) Peroaitat protective equipment-- (1) Compliance with the exposure limits proscribed by paragraph (b> <j this sec tion may not be achieved by the use of respirators or shift rotation of em ployees, tmeesrt: (1) During the time period necessary to inetafi the engineering controls and to Institute tiro work practices required by paragraph (c> cl this section; .e'tei. FEDERAL REGISTER, VOl. 39, NO.. 125--THURSDAY, JUNE 27, lr<l 235 l-l RULE5 AND REGULATIONS (II) In work situations In which the (c) No employee shall be assigned to (2) Personal monitoring--(l) Sam methods prescribed In paragraph (e> of tasks requiring the use of respirators if, ples shall be collected from within the this section ere either technically not based upon his most recent examination, breathing zone of the employees, on feasible 'Or feasible to an extent Insuffi an examining physician determines that membrane filters or o.s micrometer po cient to reduce the airborne concentra the employee will be unable to function rosity mounted In an open-face filter tions of asbestos fibers below the limits normally wearing a respirator, or that holder. Samples shall be taken for the prescribed by paragraph (b) of this the safety or health of tho employee or determination of the 8-hour time- section; or other employees will be Impaired by his- weighted average airborne concentra (III) in emergencies. use of a respirator. Such employee shall tions and of the celling concentrations of (lr) Where both respirators and per be rotated to another Job or given the asbestos fibers. sonnel rotation are allowed by subdivi opportunity to transfer to a different po (U) Sampling frequency and patterns. sions (1), (11), or (111) of this subpara sition whose duties he Is able to perform After the Initial determinations required" graph. and both are practicable, person with the same employer. In the some geo by subparagraph (1) of this paragraph, nel rotation shall be preferred and used. graphical area and with the same senior samples shall be of such frequency end (2) Where a respirator Is permitted by ity, status, and rate of pay he had just .pattern as to represent with reasonable subparagraph (1) of this paragraph. It prior to such transfer. If such a different accuracy the levels of exposure of em shall be selected from among those ap proved by the Bureau of Mines, Depart-, position is available. (3) Special clothing:' The employer ployees'. In no case shall the sampling be done at intervals greater than 6 months ment of the Interior, or Ore-National In-' shall provide, and require the use of, spe for employees whose exposure to asbestos _stltute for Occupational Safety and cial clothing, such as coveralls or similar may reasonably be foreseen to exceed Health, Department of Health. Educa tion. and Welfare, under the provisions of 30 CFR Part 11 (37 FJR. 8244, Mar. 25, 1972), and shall be used in accordance with subdivisions (1), (11), (111), and (lv) of this subparagraph. whole body clothing, head coverings, gloves, and foot coverings for any em ployee exposed to airborne concentra tions of asbestos fibers, which exceed the celling level prescribed in paragraph (b) of this section. the limits prescribed by paragraph (b) of this section. (3) Environmental monitoring--(1) samples shall be collected from areas of a work environment which are represent ative of the airborne concentrations of (I) Air purifying respirators. A reusa ble or single use air purifying respirator, or a respirator described In subdivision (11) or (ill) of this subparagraph, shall be used to reduce the concentrations of airborne asbestos fibers In the respirator below the exposure limits prescribed in paragraph (b) of this section, when the celling or the 8-hour time-weighted-aver age airborne concentrations of asbestos fibers are reasonably expected to exceed no more -than 10 times those limits. (II). Powered air purifying respirators. A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator described in subdivision (ill) of this subparagraph, shall be used to reduce the concentra tions of airborne asbestos fibers In the respirator below the exposure limits pre scribed In paragraph (b) of this section, when the celling or the 8-hour timeweighted average concentrations of asbestos fibers are reasonably expected to exceed 10 times, but not 100 times, those limits. (III) Type "C" supplied-air respirators, continuous flow or pressure-demand class. A type "C" continuous flow or pres sure-demand, supplied-alr respirator shall be used to reduce the concentra tions of airborne asbestos fibers In the respirator below the exposure limits pre scribed in paragraph (b) of this section, when the celling or the 8-hour timeweighted average airborne concentra tions of asbestos fibers are reasonably expected to exceed 100 times those limits. (4) Change rooms: (1) At any fixed place of employment exposed to airborne concentrations of asbestos fibers in ex cess of the exposure limits prescribed In paragraph (b) of this section, the em ployer shall provide change rooms for employees working regularly at the place. (11) Clothes lockers: The employer h*)i provide two separate lockers or con tainers for each employee, so separated or isolated os to prevent contamination of the employee's street clothes from his work clothes. (ill) Laundering: (a) Laundering of 'asbestos contaminated clothing shall be done so as to prevent- the release of air borne asbestos fibers In excess of the ex posure limits prescribed In paragraph (b). of this section. (b> Any employer who gives asbestoscontaminated clothing to another person for laundering shall Inform such person of the requirement In (a) of this subdi vision to effectively prevent tho release of airborne asbestos fibers in excess of the exposqre limits prescribed In para graph (b) of this section. (c) Contaminated clothing shall be transported in sealed Impermeable bags, or other closed, Impermeable containers, and labeled in accordance with para graph (g) of this section. (e) Method of measurement. All de terminations of airborne concentrations of asbestos fibers shall be made by tho membrane filter method at 400-480 . (magnification) (4 millimeter objective) with phase contrast Illumination. asbestos fibers which, may reach the breathing zone of employees. Samples shall be collected on a membrane filter of 0.8 micrometer porosity mounted In an open-face filter holder. Samples shall be token for the determination of the 8- hour timo-welghted average airborne concentrations and of the ceiling con centrations of asbestos fibers. - (ID Sampling frequency and patterns. After the Initial determinations required by subparagraph (1) of this paragraph, samples shall be of such frequency and pattern as to represent with reasonable accuracy the levels of exposure of the employees. In no case shall sampling be at intervals greater than 8 months for employees whose exposures to asbestos may reasonably be foreseen to exceed the exposure limits prescribed In para graph (b) of this section. (4) Employee observation of monitor ing. Affected employees, or their rep resentatives, shall be given a reasonable opportunity to observe any monitoring required by this paragraph and shall have access to the records thereof. (g) Caution signs and label*. (1) Cau tion signa. (1) Potting. Caution signs shall be provided and displayed at each location where airborne concentrations of asbestos fibers may be in excess of the exposure limits prescribed In paragraph (b) of thin section. Signs shall be posted at shch a distance from such a location so that on employee may read the signs and take necessary protective steps befqre entering the area marked by tho signs. Signs shall bo posted at all ap (lv) Establishment of a respirator pro (D Monitoring--(!) Initial determi proaches to areas containing excessive gram. la) The employer shall establish nations. Within 0 months of the publi concentrations of airborne asbestos a respirator program in accordance with the requirements of the American Na tional Standards Practices for Respira tory Protection. ANSI Z88.2-1969, which cation of this section, every employor shall cause every place of employment where asbestos fibers arc released to bo monitored In such n way os to determine fibers. (ID Sign specifications. The warning signs required by subdivision (1) of this subparagraph shall conform to the re Is Incorporated by reference herein. whether every employee's exposure to quirements of 20" x 14" vortical format (b) See 11910.6 concerning the avail asbestos fibers Is below the limits'pro signs specified In 11910.146(d) (4), and ability of ANSI Z88.2--1869 and the main scribed in paragraph (b) of tills sec to this subdivision. The signs shall dis tenance of an historic file in connection tion. If the limits arc exceeded, the em play the following legend In the lower therewith. Hie address of the American ployer shall Immediately undertake a panel, with letter sizes and styles of a National Standards Institute Is given In compliance program In accordance with visibility at least equal to that specified 1810.100. paragraph (c) of this section. in this subdivision. - rSCGRAl R'-cisn-q, vot. :n. no. trv--TRunsnAr, iuiif. V/. ttw RULES AND REGULATIONS 23545 Legend \ Duat Buvd. ' Avoid Breathing Dust-- WMr Aaaignyl Protective XcpitpQtmt* Do KM Bamain In Ann Vnlme Tour Work Bo- qumalt. Breathing Aaboatas Dust lb; B* Bsaaxdoua To Tour Health. mention 1" San* Sarlf, Gothio or Block. K" flans Serif. Qothio or Block. U" Gothic. Gorilla. %"Oothlc. 14 point Gothic. paragraph, which indicates the' em- -to the Assistant Secretary of Labor for ployee'a own exposure to asbestos fibers.: Occupational-Safety and Health, the <3? Employes notification. Any em- Director of NIOSH, to authorised physl- ployoe found to hare been exposed at any dans and medical consultants of either time to airborne concentrations of asbes- of them, and, tflxxi the request of an m- tos fibers In exfceas of the limits pro- ployee or former employee, to his phyri- scribed In paragraph (b) of this section clan. Any .physician who conducts a shall bo notified In writing of the expo- medical examination. required by this sure ae soon aa practicable but not tetofr Paragraph shall furnish to the employer thn 5 days of the finding. Tho employee of the examined employes pH the infor- ahaJl also be timely notified of the cor- station specifically required by this rective action being taken. paragraph, and any other medk*l In ti) Medical examinations--(1) Gen- formation related to occupational ex- end. The employer shall provide or make Posuro to asbestos fibers. ____ Spacing between lines shall be at least equal to the height of the upper of an? two lines. (2) Caution labels--(1) Labeling. Cau- available at hla cost, medical examina tions relative to exposure'io asbestos re quired by this paragraph. (2) Preplacement. The employer shall -tlon labels ahall be affixed to all raw. materials; mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label Is required where asbestos libers have been modified .by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, provide or malce available to each at his employees, within 30 calendar days fol lowing hbi first employment in anoccupation exposed to airborne con centrations of asbestos fibers, a compre hensive medical examination, which shall Include, as a minimum, a chest roent- cuuogmn (posterior-anterior 14 x 17 inches), n history to elicit, symptom handling, storage, disposal, processing, or atology of respiratory disease, and transportation, no airborne concentra pulmonary function tests to Include tions at asbestos fibers in erases of the forced vital capacity (FVC) and forced exposure limits prescribed In paragraph expiratory volume at 1 second 0RBVU). (b) of this section will be released. (3) Annual examinations. On or be (11) Label specifications. The caution fore January 31, 1973, and at least an labels required by subdivision (1) of this subparagraph shall be printed in letters of sufficient alee and contrast as to be readily visible and legible. The label shall state: CiUTlOH nually thereafter, every employer shall provide, or make available, comprehen sive medical examinations to each of his employees engaged In occupations ex posed to airborne concentrations of as bestos fibers. Such annual examination Contains asbestos Fibers Avoid Creating Dust shall Include, as a minimum, a chest roentgenogram (posterior-anterior 14 x 17 inches), a hlgtory to elicit symptom Breathing Asbestos Duat May Cause Serious Bodily Berm atology oK respiratory disease, sad pulmonary function tests to Include <h) Housekeeping--(1) Cleaning. All external surfaces in any place of employ forced vital capacity (FTC) and forced expiratory volume at 1 second CPEVU), ment shall be maintained free of accu .(4) Termination of employment. Tim mulations of asbestos fibers If, with their employer shall provide, or make avail dispersion, there would be an excessive' able; within 30 calendar days before or concentration. after the termination of employment of (2) Waste disposal. Asbestos waste, any employee engaged In an occupation scrap, debris, bags, containers, equip exposed to airborne concentrations of ment, and asbestos-contaminated cloth asbestos fibers, a comprehensive medical ing, consigned for disposal, which may .examination which shall Include, as a produce In any reasonably foreseeable minimum, a chest roentgenogram (pos use, handling, storage, processing, dis posal, or transportation airborne concen trations of asbestos fibers In excess of the exposure limits prescribed in paragraph terior-anterior 14 x 17 Inches), a history to elicit symptomatology of respiratory disease, and pulmonary function tests' to Include forced vital capacity (FVC) (b) of this section shall be collected and forced expiratory volume at-1 second disposed of in sealed Impermeable bagSi (FEV). or other closed, impermeable containers. (S) Recent examinations. No medical (1) Recordkeeping--(l) Exposure rec examination Is required of any em ords. Every employer shall maintain rec ployee, If adequate records show that ords of any personal or environmental the employes has been examined In ac monitoring required by this section. Rec cordance with this paragraph within the ords shall be maintained for a period of past 1-year period. at least 3 years and shall be made avail (8) Medical records--(1) Mainte able upon request to the Assistant Secre nance. Employers of employees examined tary of Labor for Occupational Safety pursuant to this paragraph shall cause > and Health, the Director of the National to be maintained complete and accurate Institute for Occupational Safety wrf records of all such medical examina Health, and to authorized representa tions. Records shall be retained by tives of either. employers for at least 20 years. (2) Employee access. Every employee (11) Access. The contents of the rec and farmer employee shall have reason-' ords of the medical examinations able access to any record required to be required by this paragraph shrill bo made "- - maintained by subparagraph (1) of this aviable? for- inspection and cogging,, _ . ^ ^ ..