Document XROE6aro9MM6EygVMDxx8yekg

`rzzcz:: llond7, April 26, 1973, at 9:3? 1 Institute Office, E-210 Route 4, Paranus, H.J. MEMBERS PRESEirr X. H. leaver, Chalraan a. L'agnar A. StJoha (For D. E. Stone) J. Duadardala" E. 2. Feierebend . Raybestos-!!anhactan, Inc. Carlisle Corporation Sendix Corporation Royal Industries Abex Corporation FOR THE INSTITUTE E. W. Drislana :s2ers rax present ' Friction Material* Standards Inaxlcute E. P. Stefl li. Jacko R. K. Porter.Co. Bendlx Corporation The neetin; vas called Co order by Hr leaver, Chalraan, at 9:30 A.H. :HSPTES OF PREVIOUS HSSH3C The Secretary read suasaary of the Minutes of Che 'leetinf held June 16, 1976. These cinucas had been released and a notion for choir acceptance had baan obtained. . Upon notion duly aade, seconded end unaalsously passed, it was RESOLVED: To accapt Che ninutes of Che June 16, 1?74 netting as discrlbuced. FMSI-0192 SUGGESTED WORK PRACTICES TOR OSaA STANDARD . In laca 1974 cha Asbestos Information Association submitted some recoemended work practices for manufacturers and fabricators using asbestos friction caterials. These were to be sent to OSHA for their consideration. OSHA has been considering a net; or revised standard in which work practices eigne be emphasized. Mr. Drislane reviewed the AlA suggested work practices, before they were sussicted and aade some suggestions for change. A draft cn the suggested work practices was circulated to the membership of this corcaitcee. Raybescos-Manhatcan had done work on the subject entitled, "Asbestos Dust Control in 3rake Service 'Centers." It was suggested that chase procedures sight be applicable for fabricators. There were several suggestions on how T ir Minutes - 4" ..,.-11 23, 19 75 to handle the suggested Fnyaescos procedures. One suggested thee these be forvarded to the Asbestos Information Association to be Included in their recommended vork practices for 9SEA. Another suggestion was for this to be distributed to our meters for their distribution to their customers. It is considered likely that when the revised OSHA standards come out that the suggested vork practices will not be included. There does not appeer to be any action chat this Cocaiccee can taka at this Cine as regards work practices except for tha suggested practices in the Brake service centers. The OSSA Regulations and the Membrane Filter Method for MeasuresTM r Originally this subject was to be two items on this agenda: (1) Tha Menbrana Filter Method for measuring airborne ajbestos concentrations, (2) The OSSA standards with emphasis on tha July 1, 1976 two fibers/ce limit. In discuss ing these subjects it was found difficult to separata the membrane filter technique frds the OSSA standards. They are being combined for purposes * of these slauees. - It was suggested' chat with the current economic climate that pexhaps there jirht be sosn de-^emphasls in OSHA regulations. There has been de-trphasis / on seat belts, and bumpers, emissions control and it*wale suggested thst . perhaps OSSA sight eass off on their regulations. Ons Cmesittee mssfcer said chsc it was nose un-likely that there would be say backtracking os tbs * OSZA regulations. * If anything they night be stiffened. One member stated "* that there were five different types of asbestos and* that seas were mere harmful than others. It was .suggested that while this-night he so, all s asbestos is apparently linked with lung cancer and asbestosis. It would be difficult to win: an argument that there are some- types of asbestos than are- cot harmful to the respiratory trace. At this point the eethod for counting fibers was discussed. It was stated by one cesser chat originally a fiber would not be counted if It was not totally within she field. This was from a Johns-Hanville course on the use of the nenbraae filter technique. It was stated now chat anything that Is in the cop or the left hand borders of the sample, even if only pertly in the field, are to be counted. Another member indicated that when he took the ;nOS2! course at Cincinacti char this was the way that he was cold to count: any fiber on the left hand or top border, even If not fully within the field being counted, would be counted'in that field.- * ` It was stated that the crystallization of the solvent used on the slide could sometimes cake it appear to be an asbestos fiber. There is a method of preparing the slides so chat the formation of crystals will not appear similar to a'sbescos fibers for counting purposes. This method is apparently used by most companies doing their own counting of the fibers. It was pointed out also that slides should cot be re-used. Re-used slides may accelerate crystallization of the solvent. It was stated there is as much variation in readings of fiber count as their are people nakin? readings* Out member sus8sc^ chat he used the MIOSE manual as a Bible. It was stated that this manual was subject to vide inter pretation. A nsrber indicated that he exchanged samples with MIOSE in Cincinnati and has had decent correlation with their counts. It was stated chat os the lower counts that three different readings would come out plus or ninus IDS on the count. However, when higher counts were read, the . AjOeS1=3 Minutes -3- . .1 23, 1375 three different readings would come out with plus or sinus 50Z in the count. Over how long a period were chest samples collected? One member seated that OSBA cakes 8-hour samples. Another stated chat they cook samples for a minimum 3-hour period vith a 30-minuce cycling. Another had three one-hour periods for collecting samples using one filter. As regards differences, it was seated by two members chat che OSIiA inspectors have actually picked up lower counts than some of the members. It was stated that there were differences in results depending upon whether the counts were done la house, by outslds organizations, or by government people. Vith these differences in fiber count, a question waa raised as to how can one solve a problem when they don't know how severs the problem Is. In response to a question as' to what this Committee could recommend 1c was suggested th*c members should at least cast each operation every six months. In attempting to get counts down to the 5 fiber Halt and eventually down to two fibers a meaber stated thee good housekeeping Is required. Several members mentioned ehe Nilfisk vacuum cleaner. This particular vacuum cleaner can be used for geetlng into placas Chat a central unit cannot reach. It has a plastic bag liner end runs on e 13 amp circuit. Of the movable type vacuum cleaners che members seem to prefer this Nilfisk. This is Swedish make vacuum c3s.T~.er. Mor* tnforraclon will be gathered on this vacuum cleaner for distribution to the members. In addition It was suggested that ose . . oust have a good central collection system. One that was mentioned was the Jli modified central vacuum system, which utilizes the main duct system . as a central vacuum system. Seversl members stated thee good housekeeping was one of the main things chat must be taken care of In order to bring the fiber counts down. It was suggested that there are three points for good housekeeping: (I) Good shrouding and good dust collection; (2) Therm should be a central cleaning system for che work area; (3) The NllLsk vacuum cleaner should be used for general housekeeping In che work area. In addition It was stated that there should be no dry sweeping In the work area. It was suggested that the friction materials business is different from regular asbestos manufacturing. In addition to asbestos, we have other materials in the product such as resins, carbon blacks, friction dust and various minerals. It Is possible that some of these may be picked up during the staple gathering before che count. In some cases these will be counted by operators as being asbestos fibers. In essence it 1$ more difficult to count asbestos in a friction material environment than it is la e textile environment. It Is felt that there may be greater difficulty in getting consistent readings on fiber counts in the friction materials business. For chat reason friction material manufacturers would prefer a work practices oriented standard. It waa stated chat the membrane filter method should not be abandoned as it is che only cool for measurement. .However, reliance on this tool for enforcecent may be almost unbearable in friction materials factories. It was suggested that OSHA be advised of our industry's concern with the wide variation in fiber counts. Based on che fact chat materials ocher than asbestos might be involved, it is necessary that the counts be interpreted realistically. In ocher words, v/hile Che membrane filter method nay be the only method that is available currently for measuring airborne asbestos, and it is r.oc felt that there is another method chat can cake its place, it is a tool that should be used by manufacturers only in trying to cl--an up their areas. It is not felt that this Cool is accurate enough to be. used for enforcement purposes. It is suggested that OSHA inspectors must realize this before factories are closed corra aud fines ere levied when there is ' doubt as to bow accurate the measurement is- Because of the vide variation in results there is concern anon; members as to the millions of dollars now being puc into control oetbods. Even with these expenditures, there is no way of knowing positively whether industries are getting their counts down to the required levels. Various words were used to describe the reliability of the centrant filter method for enforcement: One indicated thet it was "unreliable," and another indicated that it was "inadequate." The emphasis was that it is the only tool now aveilable but it is not the proper cool for enforcement. ' Ironically it bad been suggested by some government people in the pest then the friction material industry would be the first to comply with the OSSA standards. HIOSH felt that the friction materials business could most readily neat'these standards. At this meeting, industry members are indicating that it may be more difficult for the friction materials business to meet the levels because of the difficulty in counting the fiber samples. It was suggested chat if we're having difficulty meeting the 5 fibers/ce limit currently, it would be near Impossible to meet the 2 fibers/ce limit due July 1, 1976: It was suggested that the Industry should oppose this change. It was stated that realistically it is unlikely Chet OSHA will not .go to the 2 fibers/cc limit on July 1, 1976. The only question is will they go* lover than the 2 fiber limit? Dr. Selikoff has spoken of a 1 fiber/ce limit and has even said no fibers. It was stated thet the Asbestos Information Association had circulated information concerning the HIOSH suggestion that the friction materials business would corns under the standard now. Such literature was never received by the Institute. Host members on the Committee were unfamiliar with this NIOSH suggestion. As had been suggested earlier, it is necessary to make the counts as accurate as possible. For this reason suggestions on counting procedures, possible crystallization of solvents, and a prohibition on the re-use of slides are important. Hr. Weaver pointed out that in a recent publication he noted that a plastic shroud is placed about the entrance to the pump being worn at the work place, in order to keep large particles of asbestos from getting pulled in to the filter. This shroud would-prevent material from being taken fron a worker's clothes as well as from some large pieces that would ordinarily fall to the floor without being inhaled. He stated thet Turner Brothers has been using such e shroud. The unit is completely open on the front and it is felt that this technique gets rid of some sporadic high counts. Weaver will get a copy of this and distribute it to the members. This could be another possible improvement In the sampling technique which sight make the membrane filter method more palatable. It was suggested chat this be considered and perhaps a proposal be made to OSHA for its use. The problem is twofold: (1) Improving the reliability of the membrane filter technique, and (2) The use of the membrane filter as a tool for enforcement with its lack of reliability. This subject had been fairly well covered. There was some agreement about the problems ir. using this technique as a cool for enforcement of the OSHA regulations. The question was what should be done about it? One member stated that the Committee would be remiss if it did not advise the -embers of these cifficulties. It was suggested chat the Board of Directors be advised that there is a problem and chat there is going to be more of a problem when the 2 fiber limit is put into effect. To repeat the problec: Minute* while we need the membrane filter method as a cool for measurement, this tool is not suitable for enforcement purposes. It Is. suggested that when the 2 fibers/cc Unit cakes effect that tills will become a most serious problem. ?.ecoT=*adatlonj should be put Into effect on Instructions to employees, the use of vacuus cleaners, the use of dust collecting systems, disposal, etc. %an these fork practices are put into effect the area will be cleaner. It vas suggested chat the Institute contact the Asbestos Information Association concerning the use of the membrane filter technique for enforcement. (See later section of these minutes concerning Asbestos Information Association.) The Industry must concentrate on collecting, cleaning and housekeeping, using the membrane filter as a Cool to sea how the levels are being reduced. One camber brought along a work sheet with target dates for. completion of various leans that will help in meeting the OSEA standards. This is essentially e schedule with daces projected for each step which will move chair factory nearar to compliance. The ala is to have the factory at the 2 fiber Unit by July I, 1976. Various critical areas ere covered with detailed steps projected to clean up each arte. It was suggested Chet this vas aloaost necessary for control and would certainly help in proving intent to comply with the regulitiers. 9 In another area, e question arose as to whet were the' Canadian standards.' cha present time, there is no national standard in Canada. Howsvar it Is likely, with the recent furor over asbestos in Toronto, that Canada will be moving to e 2 fiber/cc limit. Upon motion duly made, seconded end . unanimously passed, it was ' At RESOLVED: That the Committee requests guidance from Che Board of Directors concerning the problem of the 2 fiber/cc limit and the lack of reliability of the membrane filter method for measureaent of fiber counts. . ASBESTOS FI3ERS SHORTER THAN 5 MICRONS Those prosocing standards for the work place and the environment are now expressing concern about the asbestos fiber which is shorter than 5 microns. Their feeling is that fibers shorter than 5 microns are medically significant. There may be a problem with lower efficiency systems filtering out sub-micron material. It nay be simpler for sub-five micron particles to by-pass filters and any natural filtration in the human respiratory system and more readily gsc into the lungs. I: has been stated chat in the ERA "Ho Visible Emissions standard" chat there art probably many fibers less than 5 microns chat are not visible. In order to measure these fibers one would have to go to electron microscopy. It vas stated chat a measuring device called the Hucleopore can make measurements down to 0.1 micron. A problem is that industry is having so much difficulty with the standard for particles greater than 5 microns, so vhec can they possibly do about those shorter than 5 microns? There is no reliable means of gathering sub 5 micron particles in wide usage today. It vas suggested that if work practices and control procedures now being put into effect are effective in reducing the 5 micron and larger particle counts doum to acceptable levels, that at the same time industry would .-LS-ej ccs - : - -7 ------ ---- - Minutes ,K .1 23 1375 be reducing the sub 5 micron particle level. EFFLUENT GUIDELINES - ASBESTOS INDUSTRY One of the requirements of the EPA effluent guidelines is that manufacturers must use the best technology available in effluent control. This essentially means chat they cust use the dry bag house. Some members did not want to abandon wet dust collectors. Regardless, most have now moved to the dry bag house. Thera are problems with the dry beg house. In particular one is when a bag is broken. Another is the continual problem with fires. It was suggested that thara should ha pra~separator before the bag house. Soma metiers use a Cyclone. ' ' As at an earlier meeting, one metier pointed out that when they enforced a smoking baa la the work place, they stopped the fires la the bag house. Another cumber indicated that he had tried this but that it did not work. It was stated that one could use fire proof bats but they era expansive. It was also suggested that while this problem can be solved, the solution is expensive. However, aa regards the effluent guidelines, the way to compliance is by the *is2 o.f dry bag house. . . NATIONAL EMISSIONS STANDARDS FOR ASBESTOS . It was pointed out that the Friction Materials Standards Institute did comment to the cPA concerning the proposed amendments to the national Emissions Standards for Asbestos. This comment was made on Deces&er 3, 1974a The FMSI pointed out that there were two problems: (1) The inclusion at fabricators of friction produces In the requirements, and (2} The requirement for warning signs on inactive waste disposal sitas. The first problem is that the fabricators were not aware that they were cooing under the National Emissions Standards and there was not sufficient time for them to comment to EPA. One member took the proposed amendments and the letter to EPA and cireulacad thesa to his customers so that they would be aware of the problem and possibly comment to EPA. The ocher problem affected industry directly is chat private contractors ware hauling the material to public land fills. Tha problem is the wending signs on inactive waste disposal sites and the fact that this could effectively remove the land area from fucura development, hr. Weaver advised that the Asbestos Textile Institute had commented concerning the difficulties with the various EPA solid waste requirements. Is particular they commenced concerning sludge removal that might have to he transported to a land fill, and the requirements for covering a land fill. ATI indicated that some of the regulations were moving at cross purposes. For example, OSHA prefers wet methods to control dust whereas EPA wants dry methods to prevent water pollution. This land fill problem is going to be a major problem if implemented as indicated in the proposed amendments co the National Emissions Standards. AS3EST0S INFORMATION ASSOCIATION (AIA/MA) One member stated chat he was disappointed that the Institute did not take steps co have closer liaison with the Asbestos Information Association. !ir. Drislant advised chat this was a subject on the Board of Directors T v Minutes - 4 ~ ril 23, 13 75 agenda at cht June Meeting. The Institute has always triad to maintain an independent coursa and has net affiliated with othar organitationa. Ua hava, however, triad to cooperate with the Asbestos Information Association. Iha general feeling is that the Asbestos Information Association is doing a good job for the Asbestos Industry, including friction material manufacturers. We have caintained our contacts and links with the Asbestos Information Association. 2a Secretary advised that at a March meeting of the Board of Directors a * resolution was passed that ve would contact the Asbestos Information ` Association offering financial support. Whether this support would be a direct contribution by the Institute or a recommendation of support by individual mashers has not been decided. The Secretary contacted Mr. Mereaess of the Asbestos Information Association concerning this possible support. . At this point, it was stated chat we had considerable discussion earlier la the meeting about the difficulty friction materials manufacturers srs having in matting the existing 5 fibers/cc standard and will have in meeting the 2 fibers/cc limit. The question is: Are other manufacturing groups having this same difficulty? It was suggested that the Secretary contact the Asbestos Information Association to find out: whether ocher unarm . of asbestos are having this difficulty. While the mes^rane filter method .' is the only method available, the members are questioning its inherent * inaccuracy and the difficulty in training people. Have other Industry accepted the 2 fiber/ec limit? Perhaps the friction material industry is having more' problems with the msabraae filter technique then other Industry groups* This question will be asked of the AIA. To sunoarlzs: Have ocher industry groups -questioned the existing 5 fiber/cc llaic and the 2 fibers/cc limit that goes into effect July 1, 1976. Upon motion duly made, seconded and unanimously passed* it was RESOLVED: The Asbestos Study Commietee wishes to go . on record in favor of support of the Asbestos Information Association. Is a comment, the words "financial support" wars not used, as the Committee suggests chat the Institute either give direct financial support, or as an alternative recommend direct support of the Asbestos Information Association to cht members of the Institute. . P0SSI3LE WORK SHOP--ASBESTOS PROBLEMS It was stated that perhaps the Committee members were not the best qualified to handle the asbestos problem. Perhaps some members are environmental people. Others may be factory people. Others might not he directly involved with the problems of asbestos. Perhaps it would be well to call on others vho eight be able to give specific expertise. It was pointed out that Sendix had two members on the Committee with different expertise. It would be completely reasonable for the members of this Committee to bring along to future meetings people skilled in different areas in the asbestos problem. Such attendees would be welcome at any meeting. At this point it was suggested chat the proposed seminar chat had been.suggested two years ago night be worthwhile. A more formal program dealing with asbestos probiens only could be scheduled. For example, nose people who attended the T Minutes IT 22, 2375 Johns-Manville seminar vera quit* pleased with it. Perhaps they have up-dated some of their work. Thie is half day session that was put on in various parts of the country and to vhlch several members of the Institute were invited'. Perhaps Johns-Manville would be willing to put on such a seminar again and it was suggested that Mr. Bill Reitze of Johns-Manville be contacted. Methods on air sampling could be discussed at a J-M seminar. Mr. U*aver suggested chat he would contact Johns-Manville concerning this subject. Zc was suggested chat if the Institute were interested in sponsoring e work shop, the Johns-Manville program would be ideal for the first half-day period. To strengthen our ties with the Asbestos Information Association le would be veil to have someone from the AIA address those attending. In this way va could Indicate soma of the problems ehe friction materials Industry has that the AIA might not be aware of. Also it might be possible for the Asbestos Information Association to solicit support of the Institute end Institute members at such a session. Upon motion duly made, seconded and unanimously passed, it vas - RESOLVED: That the Committee recommends that the Institute sponsor a one day vork shop on the asbestos problem in the early Pall of 1973. OTHER BUSINESS It was suggested chat the Asbestos Study Committee might enlarge their activities beyond the field of asbestos. There vas a recant article in one of the newspapers concerning the health hazards of nickel. Nickel i a substance found in asbestos and it apparently is found In cigarettes ax well. Klekel does not gee Into the cigarettes from the plane, but apparently Is picked up during processing. It vss suggested that perhaps this vas causa of the lung cancers that have been associated with asbestos. It vas also stated that this might be "grasping at straws.*' A real problem In Che workplace may be encountered by those using lead or lead oxides in the workplace. OSHA is talking of lead concentrations in the .20/. 13 mg/cubic meter. It may be worthwhile to bring lead into this consittee's activities. It vas suggested that the committee be re-named the "Hazardous Materials Study Committee." No action vas taken in this area. It vas also stated that because of the heavier lung cancer risk for chose who smoke as against those who do not smoke that anti-smoking campaigns should be promoted. Even Dr. Sellkoff has indicated that a non-smoker working in an asbestos vork place may be no more likely to be effected by lung cancer than a person in the general population. However cigarette smoking coupled with exposure to asbestos In the vork place multiplies the problem. ***** There being no other business brought to the attention of the Comictee, upon notion duly made, seconded and unanimously passed It was RESOLVED: To adjourn. Adjourned at: 2:00 P.M. E. V. Drlslane Executive Director T