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FILE NAME Brakes BRK DATE 1986 June 20 DOC BRK147 DOCUMENT DESCRIPTION Federal Register - OSHA Standard 22662 Federal Register / Vol 51 No. 119 / Friday June 20 1986 / Rules and Regulations TABLE WORKER Exposure Data for AUTOMOTIVE BRAKE AND CLUTCH REMANUFACTURING Job classification Mean 8hour TWA exposure exposure Number of Standard deviation | observao-bserva- obtsieornsva- Source of data percent of the exposures are greater than 2.0 cc and 28 percent are between 0.5 cc and 2.0 cc One of the respondents QR to the RTI survey reported exposures rarging from less than 0.02 cc to 0.5 cc for the wet Dry mechanical .scsce oo sess ssseee see srserasee sssenenaternereeneernaeneaeennnesentesrae : Dry mechanical ve Other cere tree 0.05 .12 .08 0.00 1112 | RTI survey removal of pipe wrap wallboard and .11 23 | OSHA MIS gasket materials The respondent stated .10 56 Do. that PEL of 0.2 cc can be attained This is the number of workers represented by the 1 Data on the number of samples were not provided vv figure * Plants designated as tt uu vv xx zz GH and KL 1984. One outlier was omitted 1.6 cc since years the 1979 through available for * Data on 24 observations were the other observations were 05 05 cc or below Two outhers were omitted 1.1 cc and 1.0 cc since all of the * Data on 58 observations were available Source obscrvations were 0.4 cc or below derived from RT survey US Department of Labor OSHA Office of Regulatory Analysis as data all of other during these small or minor rip- out operations by using wet removal practices OSHA has thus determined that the 0.2 cc PEL is feasible for certain minor outs in nuclear vessels but that respirators will be 2 additional exposures can be kept below needed during major outs in non- Service Industries the PEL of 0.2 cc through the use of nuclear vessels ERM ~t\ - Automotive Brake and Clutch Repair ventilation and wet methods which Construction Workers who repair brakes and clutches have been used successfully in other made with asbestos may be exposed New Construction Although concerns because brakes and clutches deteriorate industries however anticipates problems about the potential health hazards of with wear thereby resulting in friable OSHA during major asbestos exposure have curtailed its use asbestos Asbestos dust present on in controlling exposures out operations These operations from substantially in recent years a number of asbestos materials are still used in these automotive parts is easily disturbed and becomes airborne during involve the removal of asbestos such machinery rooms or new construction These products the repair and removal of the linings large areas as engine rooms The particular constraints include C pipe and sheet vinyl asbestos floor tile and asphalt roofing Exposures above 0.2 cc are of the shipbuilding work traditional particularly prevalent when compressed environment limit the use of felts and coatings air is used to clean the linings These controls Safety rules A Pipe In a study Exhibit 84-279 exposures can be significantly reduced engineering the number of hoses pipes and performed in 1977 for the A Pipe however by using solvent mists on the restrict that can pass through Producers Association Equitable linings and then wiping them off or by other equipment bulkhead openings below deck Environmental Health Inc. EEH using vacuums to remove the dust certain confined in ships impede the collected short personal samples to OSHA determined that it is feasible The spaces ventilation evaluate exposure during various for this industry to meet the 0.2 cc use of even portable certain areas In addition operations that might be perforined in This determination is based primarily on MIS equipment in wetting agents are not permitted for rip- nuclear reactor the field on A pipe using different types of equipment For example while data obtained from the OSHA data base and from a out activity in of the fear of unloading pipe at the site and laying compliance 22 1982 study by the compartments because in the trench the highest TWA November Occupational National Institute for contamination at the pipe concentrations reported were 0.03 cc a No. For example in testimony Thorton of and 0.02 cc respectively These data Safety and Health NIOSH Report The OSHA data contained 47 formal hearings Mr. James R. suggest that there is little potential for 32.4 observations from the period 1979 the Newport News Shipbuilding data exposure in these operations and that no through 1984 with a mean hour TWA Drydock Co. presented exposure major outs of specific controls are necessary to keep et of 0.03 cc and standard collected during where the use of exposures below the 0.2 cc PEL Lan exposure deviation of 0.14 cc In addition the reactor compartments water and saturating agents was When installing A pipe however it NIOSH study demonstrated that average restricted These data show that 41 may be necessary to cut machine or tap were below 0.1 cc when re exposures of the exposures were greater the pipe at the work site which may using either the solvent mist or the high- percent than 2.0 cc and another 32 percent expose workers to airborne asbestos efficiency particulate air HEPA between 0.5 cc and 2.0 cc fibers Although the current trend is for vacuum systems Thus OSHA were Transcript of June 25 1984 p more of these activities to be performed determined that the 0.2 cc is feasible Hearing The Federal Employees Metal by the manufacturer rather than in the in this sector . 79 Trades Council Exhibit 158-6 field Exhibit 333 Sections Q Shipbuilding and Repair Current submitted to the record other monitoring cutting and machining are associated shipbuilding activities should not results of major asbestos outs in the with potentially high exposures Joe generate any worker exposure to reactor compartment of nuclear Jackson of the Association of A Pipe asbestos because the use of asbestos These data showed similar Producers AACPP noted however the has been phased out of this type of submarines levels with 40 percent of the feasibility of installing A pipe with re construction The greatest potential for exposure than 2.0 cc and 10 exposures below the PEL of 0.2 cc In removal asbestos exposure is during the exposures greater between 0.5 cc and 2.0 cc hearing written testimony he stated or out of old asbestos material tearing percent Thus OSHA concludes that the 0.2 cc not feasible during asbestos rip- as follows following AACPP's recommended Rip often requires sawing and scraping to remove existing PEL is without the Workers could almost always ensure cutting outs of nuclear components work practices asbestos materials and these activities use of respirators that they would avoid peak exposures in frequently occur in confined spaces According to Mr. Thorton the excess of 0.75 cc over 15 minutes while Additional sources of asbestos exposure results for major asbestos rip- eight weighted average exposure for a small number of shipyard workers exposure of nuclear components where would remain at 0.1 cc or below Exhibit occur during operations such as gasket that these outs wetting agents can be used show that 5 91-16 Section 0 p 12. cutting OSHA believes Federal Register / Vol 51 No. 119 Friday June 20 1986 / Rules and Regulations 22753 Appendix E to Interpretation and Classification of Chest Roentgenograms a Chest roentgenograms shall be interpreted and classifieidn accordance with a professionally accepted classification system and recorded on a Roentgenographic Interpretation Form Form NIOSH M 2.8 te b Roentgenograms shall be interpreted and classified only by a reader a board certified radiologist or an experienced physician with known expertise in pneumoconioses c All interpreters whenever interpreting chest roentgenograms made under this section shall have immediately available for reference a complete set of the ILO International Classification of Radiographs for Pneumoconioses 1980 Appendix F to 1910.1001 Practices and Engineering Controls for Automotive Brake Repair Mandatory This appendix is intended as guidance for employers in the automotive brake and clutch repair industry who wish to reduce their employees asbestos exposures during repair operations to levels below the new standard's action level 0.1 cc OSHA believes that employers in this industry sector are likely be able to reduce their employees exposures to asbestos by employing the engineering and work practice controls described in Sections A and B of this appendix Those employers who choose to use these controls and who achieve exposures below the action level will thus be able to avoid any burden that might be : imposed by complying with such requirements as medical surveillance recordkeeping training respiratory protection and regulated areas which are triggered when employee exposures exceed the action level or PEL Asbestos exposure in the automotive brake and clutch repair industry occurs primarily during the replacement of clutch plates and brake pads shoes and linings Asbestos fibers may become airborne when an - automotive mechanic removes the asbestos- containing residue that has been deposited as brakes and clutches wear Employee exposures to asbestos occur during the cleaning of the brake drum or clutch housing Based on evidence in the rulemaking record Exs 84-74 84-263 90 14O8SHA believes that employers engaged in brake repair operations who implement any of the work practices and engineering controls described in Sections A and B of this - appendix may be able to reduce their employees exposures to levels below the action level 0.1 fiber These control methods and the relevant record evidence on these and other methods are described in the following sections A. Enclosed Cylinder Vacuum System Method . The enclosed cylinder system used in one of the facilities visited by representatives of the National Institute for . Occupational Safety and Health NIOSH during a health hazard evaluation of brake repair facilities Ex 84 26c3onsists of three . components ' 1 A shaped cylinder designed to cover and enclose the wheel assembly 2 A compressed hose and nozzle that fits into a port in the cylinder and A filtered vacuum used to evacuate airborne dust generated within the cylinder by the compressed air To operate the system the brake assembly is enclosed in a cylinder that has viewing ports to provide visibility and cotton sleeves through which the mechanic can handle the brake assembly parts The cylinder effectively isolates asbestos dust the drum from the mechanic's breathing zone The brake assembly isolation cylinder is available from the Nilfisk Company ' and comes in two sizes to fit brake drums in the 7- inch size range common to automobiles and light trucks and the inch size range common to large commercial vehicles The cylinder is equipped with built compressed guns and a connection for a vacuum cleaner equipped with a High Efficiency Particulate Air HEPA filter This type of filter is capable of removing all particles greater than 0.3 microns from the air When the vacuum cleaner's filter is full it must be replaced according to the manufacturer's instruction and appropriate filtered dual cartridge respirators should be worn during the process filter of the vacuum cleaner is assumed to be contaminated with asbestos fibers and should be handled carefully wetted with a fine mist of water placed immediately in a labelled plastic bag and disposed of properly When the cylinder is in place around the brake assembly and the HEPA vacuum is connected compressed air is blown into the cylinder to loosen the residue from the brake assembly parts The vacuum then evacuates the loosened material from within the cylinder capturing the airborne material on the HEPA filter The HEPA vacuum system can be ; disconnected from the brake assembly isolation cylinder when the cylinder is not being used The HEPA vacuum can then be used for clutch facing work grinding or other routine cleaningfacing B. Compressed Solvent System Method A compressed hose fitted at the end with a bottle of solvent can be used to loosen the containing residue and to capture the resulting airborne particles in the solvent mist The mechanic should begin spraying the contaminated parts with the solvent at a sufficient distance to ensure that the asbestos particles are not dislodged by the velocity of the solvent spray After the asbestos particles are thoroughly wetted the spray may be brought closer to the parts and the parts may be sprayed as necessary to remove grease and sprayed other material The automotive parts with the mist then wiped with a rag which must then be disposed of appropriately Rags should be placed in labelled plastic bag or other container while they are still wet ensures that the asbestos fibers will become airborne - Mention of tradenames or commercial products does not constitute of endorsement recommendation use . after the brake and clutch parts have been cleaned If cleanup rags are laundered rather than disposed of they must be washed using methods appropriate for the laundering of contaminated materials OSHA believes that a variant of this compressed mist process offers advantages over the compressed mist technique discussed above both in terms of costs and employee protection The variant involves the use of spray cans filled with any of several solvent cleaners commercially available from auto supply stores Spray cans of solvent are inexpensive readily available and easy to use These cans will also save time because no solvent delivery system has to be asembled i.e. no compressed mister ensemble OSHA believes that a spray can will deliver solvent to the parts to be cleaned with considerably less force than the alternative compressed delivery system described above and will thus generate fewer airborne asbestos fibers than the compressed method The Agency therefore believes that the exposure levels of automotive repair mechanics using the spray solvent mist process will be even lower than the exposures reported by NIOSH Ex 84-263 for the compressed mist system 0.08 cc C. Information on the Effectiveness of Various Control Measures The amount of airborne asbestos generated during brake and clutch repair operations depends on the work practices and engineering controls used during the repair or removal activity Data in the rulemaking record document the hour weighted average TWAs asbestos exposure levels associated with various methods of brake and clutch repair and removal NIOSH submitted a report to the record entitled Health Hazard Evaluation for Automotive Brake Repair Ex 84-263 In addition Exhibits 84-74 and 90-148 provided exposure data for comparing the airborne concentrations of asbestos generated by the use of various work practices during brake repair operations These reports present exposure data for brake repair operations involving a variety of controls and work practices including Use of compressed air to blow out the brake drums Use of a brush without a wetting agent to remove the containing residue Use of brush dipped in water or solvent to remove the containing residue Use of an enclosed vacuum cleaning system to capture the containing ~ residue and * Use of a solvent mixture applied with compressed air to remove the residue Prohibited Methods The use of compressed air to blow the containing residue off the surface of the brake drum removes the residue effectively but simultaneously produces an of airborne cloud asbestos fibers According Ex to NIOSH 84-283 the peak exposures of mechanics using this technique were as high as 15 fibers and hour TWA exposures ranged from 003 0.19 cc 22754 Federal Register / Vol 51No. 119 / Friday June 20 1986 Rules and Regulations Dr. William J. Nicholson of the Mount Sinai School of Medicine Ex 84-74 cited data from Knight and Hickish 1970 that indicated that the concentration of asbestos ranged from 0.84 to 5.35 cc over a minute sampling period when compressed air was being used blow out the asbestoscontaining residue from the brake drum In the same study a peak concentration of 87 / cc was measured for a few seconds during brake cleaning performed with compressed air Rohl et al 1976 Ex 90-148 measured area concentrations of unspecified duration within 3-5 feet of operations involving the cleaning of brakes with compressed air and obtained readings ranging from 6.6 to 29.8 / cc Because of the high exposure levels that result from cleaning brake and clutch parts using compressed air OSHA has prohibited this practice in the revised standard cc with peaks of 0.25 to 0.68 cc This technique and a variant of it that OSHA believes is both less costly and more effective in reducing employee exposures is described in greater detail above in Sections A and B. D. Summary In conclusion OSHA believes that it is likely that employers in the brake and clutch repair industry will be able to avail themselves of the action level trigger built into the revised standard if they conscientiously employ one of the three control methods described above the enclosed cylinder vacuum system the compressed solvent method or the spray solvent mist system Appendix G to 1910.1001 Technical Information for Asbestos to cause lung cancer mesothelioma and cancer of the stomach and colon Mesothelioma is a rare cancer of the thin membrane lining of the chest and abdomen - Symptoms of mesothelioma include shortness of breath pain in the walls of the chest and or abdominal pain . . III Respirators and Protective Clothing A. Respirators You are required to wear respirator when performing tasks that result in asbestos tremolite anthophyllite and actinolite exposure that exceeds the permissible exposure limit PEL of 0.2 cc These conditions can occur while your employer is in the process of installing engineering controls to reduce asbestos tremolite anthophyllite and actinolite exposure or where engineering controls are not feasible to reduce asbestos tremolite anthophyllite and actinolite exposure Air- Ineffective Methods . Mandatory - - purifying respirators equipped with a high- When dry brushing was used to remove the containing residue from the brake drums and wheel assemblies peak exposures - measured by NIOSH ranged from 0.61 to 0.81 cc while hour TWA levels were at the new standard's permissible exposure limit PEL of 0.2 cc Ex 84-263 Rohl and his colleagues Ex collected area samples 1-3 feet from a brake cleaning operation being performed with a dry brush and measured concentrations ranging from 1.3 to 3.6 cc however sampling times and TWA concentrations were not presented in the Rohl et al study a When brush wetted with water gasoline ~ I. Substance Identification - A. Substance Asbestos is the name of a class of magnesium minerals that occur in fibrous form Minerals that are included in this group are chrysotile crocidolite amosite tremolite asbestos anthophyllite asbestos and actinolite asbestos - . B. Asbestos tremolite anthophyllite and actinolite are used in the manufacture of resistant clothing automative brake and clutch linings and a variety of building materials including floor tiles roofing felts ceiling tiles asbestos pipe and sheet * and resistant drywall Asbestos is also efficiency particulate air HEPA filter can be used where airborne asbestos tremolite anthophyllite and actinolite fiber concentrations do not exceed 2 cc otherwise supplied pressure full facepiece respirators must be used Disposable respirators or dust masks are not permitted to be used for asbestos tremolite anthophyllite and actinolite work For ' : effective protection respirators must fit your face and head snugly employer __ required to conduct fit tests when you are ' first assigned a respirator and every 6 months thereafter Respirators should not be loosened or removed in work situations or Stoddart solvent was used to clean the - containing residue from the affected present in pipe and boiler insulation materials and in sprayed materials parts exposure levels hour TWAs located on beams in crawlspaces and measured by NIOSH also exceeded the new between walls 0.2 cc PEL and peak exposures ranged as C. The potential for a product containing high as 2.62 cc Ex 84-263 asbestos tremolite anthophyllite and Preferred Methods Use of an engineering control system actinolite to release breatheable fibers - depends on its degree of friability Friable means that the material can be crumbled where their use is required B. Protective Clothing You are required to _wear protective clothing in work areas where . asbestos tremolite anthophyllite and actinolite fiber concentrations exceed the permissible exposure limit PEL of 0.2 cc to prevent contamination of the skin Where protective clothing is required your employer must provide you with clean garments me involving a cylinder that completely encloses with hand pressure and is therefore likely to Unless you are working on a large asbestos the brake shoe assembly and a High emit fibers The fibrous or fluffy sprayed tremolite anthophyllite and actinolite Efficiency Particulate Air HEPA filter- materials used for fireproofing insulation or removal or demolition project your employer equipped vacuum produced hour TWA sound proofing are considered to be friable must also provide a change room and employee exposures of 0.01 cc and peak and they readily release airborne fibers if separate lockers for your street clothes and exposures ranging from nondetectable 0.07 disturbed Materials such as asbestos contaminated work clothes If you are ee me cc Ex 84-263 Because this system floor tile or roofing felts are considered working on a large asbestos tremolite pe achieved exposure levels below the nonfriable and generally do not emit airborne anthophyllite and actinolite removal or Lit standard's action level it is described in fibers unless subjected to sanding or sawing demolition project and where it is feasible to detail below Data collected by the Mount operations Asbestos pipe or sheet do so your employer must provide a clean Sinai Medical Center Ex 90-148 for Nilfisk can emit airborne fibers if the materials are room shower and decontamination room I of America Inc. the manufacturer of the cut or sawed or if they are broken during contiguous to the work area When leaving ee brake assembly enclosure system showed that for two of three operations sampled the demolition operations D. Permissible exposure Exposure to the work area you must remove contaminated clothing before proceeding to exposure of mechanics to airborne asbestos airborne asbestos tremolite anthophyllite the shower If the shower is not adjacent to fibers was nondetectable For the third and actinolite fibers may not exceed 0.2 the work area you must vacuum your 402 operator sampled by Mt. Sinai researchers fibers per cubic centimeter of air 0.2 cc the exposure was 0.5 cc which the authors averaged over the hour workday attributed to asbestos that had contaminated . II Health Hazard Data the operator's clothing in the course of previous brake repair operations performed A. Asbestos tremolite anthophyllite and clothing before proceeding to the change room and shower To prevent inhaling fibers in contaminated change rooms and showers leave your respirator on until you leave the shower and enter the clean change room without the enclosed cylinder actinolite can cause disabling respiratory IV Disposal Procedures and Cleanup disease and various types of cancers if the system facilities a fibers are inhaled Inhaling or ingesting fibers A. Wastes that are generated by processes I Some automotive repair use skin _ also where asbestos tremolite anthophyllite and compressed hose to apply a solvent mist . from contaminated clothing or can to remove the containing residue result in these diseases The symptoms of actinolite is present include from the brake drums before repair The these diseases generally do not appear for 20 1. Empty asbestos tremolite anthophyllite NIOSH data Ex 84-263 indicated that . more years after initial exposure . and actinolite shipping containers mechanics employing this method : B. Exposure to asbestos tremolite 2. Process wastes such as cuttings experienced exposures hour TWAs of 0.8 anthophyllite and actinolite has been shown trimmings or reject material