Document Xzxro3eLpOKZdLo5RMK6q8pOg

......""'. -. FMSI 02798 :~IC'fiON MATERIALS STANDARDS IUSTITUTE,Ii-IC., E. 210 ROUTE 4, PARAMUS,N.J. 07652 BULLZTIN N 0. 462 December 6, 1972 TO: ACTIVE HEHBERS SUBJECT: SURVEY - OSHA LABELING REQUIP..E!1EHTS On cloverober 6, 1972 we sent out a request for information and interpretation of the OSHA regulations concerning labeling requirements for asbestos type brake linin~ and clutch facing shipments, where subsequent machining (cutting, grinding, drilling, chamfering, grooving) "ras likely to be done on these products. Twenty-five questionnaires were sent out. Eleven replies were received. Replies were received from a reasonable cross-section of the membership. As the replies were confidential, the forms submitted by the members have been destroyed. The survey will be a tool used at the next Asbestos Study Committee Meeting. It is suggested that members of the Committee attending the next meeting be versed in their own Company's position on labeling. EWD:llz cc: Asbestos Study Committee E. l>l. Dris lane Executive Director FMSI 02800 ~, . iRICTION MATERIALS STANDARDS INSTITUTE, INC., :C.210 ROUTE 4, PARM1US,N.J. 07652 ASBESTOS STUDY COMHITTEE - LABELING SURVEY (25 Requests 11/6/72, 11 replies 12/6/72) Question Yes No Undecided 1.1 Now label replacement shipments 1 10 1.2 Now label O.E.M. shipments 19 2.1 Plan to label replacement shipments? 53 3 2.2 Plan to label O.E.H. shipments? 52 3 3.1 Interpret OSHA to require labeling ,.,here subsequent machining is expected? 9 2 Not Applicable 1 1 Comment A,B c A. l1ernber replying YES, states: "If such practice is required and/or adopted by FHSI." B. !fember replying l~O, states: "Our material has been treated with a binder- therefore no raw asbestos is present." C. Hember replying YES, states: "~.Je '.rill label if it is determined that our bonding or binding material does not meet the standard." FMSI 02801 November 28, 1972 Mr. J. H. Kelly Bendix Corporation 1217 S. Walnut Street South Bend, Indiana 46621 Dear Jack: This concerns our discussion concerning labeling requirements where brake linings are being shipped to customers. In attempting to determine what practice one must use, OSHA has stated that if one is meeting the spirit of ita regulations it will not be cited for violations. As a result of tbis, it becomes necessary to interpret some of the OSHA regulations. I am enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association (AIA/N4). You will note on these reports that Mr. Armstrong, from Bendix corporate headquarters, attended these meetings. There is absolutely no question concerning the requirements for labeling where loose asbestos is being shipped. The big problem develops where members are shipping what the AIA and OSHA refer to as locked in asbestos products - brake linings, brake blocks, clutch facings, etc. When customers of yours drill linings, chamfer linings, cut linings, or grind linings, they may very well raise the asbestos concentrations in the atmosphere to above the OSHA standard. Some members have indicated that the drilling and grinding operations are problem areas in brake lining factories with existing exhaust systems. Therefore, if a customer of yours started drilling or grinding without having proper dust collectors, he would problbly be in va~lation of the OSHA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to warn the customer of this possibility. The form which the warning takes is still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for a violation. Therefore, ~ Z you ceddt: . put in every one of your skids, or cartons, or pallets, a warning notice to the effect: "Power tools without dust collectors should not be used for n~chinjng, cutting, or sanding this product." If a notice such as this were enclosed with every carton, or stenciled on the outside of the carton. it is likely that you would be meeting the spirit of the regulations. if you were to write your customer aad tell him about this with every shipment made, you would probably be also meeting tl1e spirit of the regulations. If you send a one time letter to your customer saying this, it is hard to say whether you would be meeting the spirit of the regulations. FMSl 02802 Mr. J. H. Kelly Bendix Corporation -2- November 28, 1972 I am enclosing a copy of the warning label suggested in the OSHA regulations where loose asbestos fibers are being shipped, and the "Instruction Sheet" suggested where a customer is to do further machining on clutch facings, brake lining, etc. I hope this is enough information for you. Dave Stone attended our most recent Asbestos Study Committee Meeting where the subject of labeling was brou8ht up. Your Mr. Armstrong is aware of some of the controversy concerning labeling. The current survey indicates that no members are now labeling shipments. A slight majority of those responding to date indicate that they interpret the OSHA regulations to require some kind of a warning where subsequent work is to be done on brake linings. This is controversial item for the Institute in that some members feel that one or two companies are trying to railroad them into labeling. Another group of companies feel that we should comply with the spirit of the law now and it is not fair if they do the proper labeling and their competition does not. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE EWDtllz Enc. E. W. Drislane Executive Director FMSI 02803 October 30, 1972 Mr. 1. H. Weaver Raybesto~nhattan, fne. 12.3 E. Stlegal Street Manheim, Pa. 17545 Dear Ike Enclosed are two ooples of a survey on OSHA labeling for our members. Please look this over. I will not distribute till you give me the go-ahead. EID/lmc Encs. Sincerely, E. W. Drislane Executive Director FMSI 02804 rRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE /}4, PARAMUS, N1J. 07652 October 30, 1972 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey ofmembers on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust.- A key paragraph in the standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall 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 fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is the shipment of asbestos containing brake 1inings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/co TWA, or 10 fibers/cc ce i 1i ng). The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do you Qlan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? J. Do you interQret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grinding, etc.) are likely to be performed? ~!ould you please complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to me at the Institute Office. E. W. Dr i slana Executive Director FMSI 02805 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N.J. 0?652 OSHA LABELING REQUIREMENTS 1l Current LabelinP PracticA 1. 1 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. 2. Planned Labeline Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA cau1ion label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. Interpretation of OSHA LabelinP Repulations 3. 1 We interpret the OSHA labeling regulations to require caution labels on friction material. shipments that will have subs~ quent working (drilling, grinding, etc.). Yes (==) (==) (-) (==) (==) fu -( - ) (==) (==) (==) () BY__________________------------------COMPANY_ _ _ _ _ _ _ _ _ _ _ _ _ __ DATi~-------------------------------------- FMSl 02806 ' FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 Route 1;14, Paramus, N.J. 07652 BULLETIN N O. 4 5 7 October 20, 1972 TO: ACTIVE MEMBERS ASBESTOS STUDY COMMITTEE LICENSEES SUBJECT: Occupational Safety and Health Standards (OSHA) In the October 1S, 1972 issue of the Federal Register, the Department of Labor issued a complete set of Rules and Regulations for the OSHA Standards. As regards asbestos, the section (1910.93a) pertaining thereto is unchanged from that sent to the membership with our Bulletin 442 of June 20, 1972. The Department published these to bring in all amendments to the standards through September 22, 1972. The purpose was (1) to publish the OSHA Standards fully and reflect changes made during the year, (2) to correct typographical and clerical errors in the original standards, and (3) to publish an index with the standards. As these full standards are a bulky 250 page issue, it is suggested that members interested in acquiring up-dated standards request them from: Superintendent of Documents U. S. Government Printing Office Washington, D. C. 20402 If interested, order the Federal Register of October 18, 1972, with payment of 20 cents payable to Superintendent of Documents. E. W. Drislane Executive Director FMSI 02807 .FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N.J. 07652 November 6, 19?2 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey ofmembers on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust. A key paragraph in the standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall 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 fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem, in this case, is the shipment of asbestos ceetaining brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/co TWA, or 10 fibers/co ceiling). The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1,1 For replacement market shipments? 1,2 For original equipment shipments? 2. Do you plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2,1 For original equipment shipments? 3. Do you interpret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grinding, etc.) are likely to be performed? Would you please complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to me at the Institute Office. E. W. Dr i slane Executive Director FMSI 02808 FRICHON MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE //4, PARAMUS, N.J. 07652 OSHA LABELING REQUIREMENTS 1. Current Labeling PracticA 11 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. 2. Planned Labeling Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA cau't ion label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. lnterQretation of OSHA Labeling Regulations 3. 1 \"ie interpret the OSHA labeling regulations to require caution labels on friction material shipments that will have subse~ quent working (drilling, grinding, etc.). Yes (-) (==) (==) (==) (==) fu (==) (==) (==) (==) () BY_______________________________________ COMPANY_ _ _ _ _ _ _ _ _ _ _ __ DATE'--------------------- FMSI 02809 FRICTION HATERIALS STAl:IDARDS INSTITUTE, INC., E.210 ROUTE 4, PARA..'MUS, H.J .07652 October 10, 1972 TO: 1:1EHBERS OF Tllli ASBESTOS STUDY cm~UTTEE SUBJECT: ASBESTOS PUBLICITY - DR. SELIKDFF Attached is an article from the Neli York Times of October 5, 1972. vf particular interest is that paragraph concerned with "wearing away of asbestos brake linings in automobiles and trucks." The reporter says this is a"significant source of airborne asbestos." This paragraph is not directly related to the headline and lead article concerning the incidence of cancer of the stomach, colon and rectum (as well as lung cancer) in workers exposed to asbestos. Ordinarily, there will be an article of this type in the Times about every month with Dr. Selikoff generally the source. EWD:llz Enc. E. w. Drislane Executive Director FMSl 02810 FMSI 02811 FRICTION MATERIALS STANDARDS INSTITUTE, INC. E-210 ROUTE 4, PARM\US, N.J. 1/07652 August .30, 1972 To: Asbestos Study Committee Subject: "Health Hazards of Asbestos", by J. C. Gilson Enclosed is an article "Health Hazards of Asbestos~ by J. C. Gilson. Mr. 1. H. Weaver, Chairman of the Committee, felt this was a good overview of the entire asbestos health situation as it now stands, and suggested that it be distributed to members of the Committee. E\ID/erc Enclosure E. W. Dr islana Executive Director CC: British Council AIA/NA (Swetonic) Committee Members - - __, _ __________________________FM_S_I 0_281_2__ , MEMO (rom Ike desk of I.H. W~~AVER I think the attached article gives a good overview of the entire asbestos/ health situation at it now stands. I suggest you distribute copies to the other members of the Asbestos Study Committee. Ike FMSI 02813 J. C. GILSON* Inhaled fibres of asb~?.stos can cause fibrosi~ of the lungs and two kinds of cancer. Protection of asbestos worl,ers calls for monitoring and controlling their workin(] environment and linking these records with records of their health HISTORICAL. A~best<>s was the first inorgamc fibre to be used in Ct'mpositcs. More than -iOOO year:; :~gu clay pot' in Finland we:r strengthened by adding anthophy llitc fib1cs 1. In classical bcc;lmt stit f;;r than normal so that the compliance is reduced. The thickemng in the alveolar walis. when the disease is ex:emivc. also reJuces th~ gas transfer for oxygen, so thai the blood leaving the lung is no longer fully saturated with this gas. The transfer of c~rbon dioxide from times asbestos cloth w:1s U>Cd to preserve the ashes of the the bbud to the air in the lungs is not, however, ;;ppre.. eminent. The oldest known piece of asbestos cluth frum ciably affected. The reduced oxygen transfer is psrtiy thl '"ew World, dati.1g from about 1740. i> a small rursc ;.:uHlpco~aictl ier by aP increase ill t;"Le frequency of breat!1- .l m~:dt- of tremolitc m the Sir Hans Sloan':: colltction of ing so tbt the subject notices breathlessness on slight ! mincrah in the British Museum (Natural Hrstmy ). exertion. These: alterations of lung function are used to The modem asbestos industry is about 1OU yc . rs cl!d, assist in diagnosis of asbestosis and measure the severity sl,lfting neady simultaneously in Canada and the USS}{, but it W3S Ill'! ~1:1til 30 years later that the fir;t mcd<cal repo1 ts appeared in France and Engl<md, indi,;:~ting that there might b~ a specific type of damage to the lungs fc1:\owing inhalatiun of the dust. By the late I 'J20s i: was of the danngc. Asbestosis takes a number of years 10 develop, even under very dusty conditions, but uncc established it is a progressive disease not materially affected by avoiding fluth~L dust exposure. The less the dust exposure, the clea; fwm surveys made in this country and in USA u that a h;;;h p1oportiun of older workers in the asbestos textile Iunger intervai bcl'ore the onset of disease, the less its scvetity; and the less chance of being affected. ThisJos'~ imlu,.tr irs were becoming severely disabled by a sre-:ific I) pc of chest di,casc due 1>1 the dust. This w~;, n:.mcd rcspon:;e rclatio;J';hp is used to fix the acceptable dust k,ds - threshold limit values - for those workmg with a~bc:;tosis. asbes!os. 1 he 3rtick by Holmes in this issue describes how tl1csc standards are applied in pr:Kt1cc. Prevention by avoidir;g expo;,IJICS to a dangerous quantity of dust IS an DISEASES CAI./SED BY ASBESTOS DUST essential step towJrds the safe usc of asbesli)S. Research carried out in the 1<J30s, supported by the ~~really expanded investigations during the last 15 years in\IJ the typ,~s nf disease c<nlscd hy asbestos, now provid~s a much clearn pictlrc uf the specific hazards and how damage to health can be :t'T.idcd in the future. Tahir I lists the diseases. Asbestos cancers Some years after the recognition of asbestosis as an impor- tant problem in the asbestos textile i!1dust1y, articles began to appear in the medical journals4 suggest iii~ an association between asb.:stusi~ and lung cancer. A survey in 19~5 f!rn!ly ?stah~i:;bcd that t!1us..: \1vl1u !tad \,,od..eti tn the Table 1 DI3'3St'S O::'IU'>f:-d by asLestos dust asbestos textile industry bef,,rc the impruwn1ents in dust c<mtro!. introduced in the ILJ30:;, had a tO-fold excess risk Asb(sto~ts Cancer F mrosis. of rungs 8runchial Hungl Mrsothclicma of dcveluping lung cancer 5 The survey, however. also indicated that the Improvement in dust control introduced at a particular factory after 1933 lnd very m terially - - - - - -Asbc~1o~ Corns - - - - - - - - - S - ktn -- - - - - - ,'~ r~e~odnufcnemde the d thi-; risk. 6 Later survevs at this factmv have ., Til~ lung caiccrs seen 111 asl':c.tus wm kcrs are similar to those ,auscd by cigarette smoking. Re,;ent ;rscarch indi- Asbestosis l11 :J;h,stu,is the: Ju;;t cJlhcs scarrlllg and thid:clllllg o! the cates that the1e 1s likely to be a syrwrg,ist;c effect of cig;~rette smuking and exposure to ash~stos dust 7 The tJ>)liC; of tile hill!'.. I h.' twu pailS palticubrlv :.ft.c!c'd Jr:' th-: fil;r..;~t dil p;J~)~!~e-; (rc-.ruall.ny hroncht'-'!r:-;) ''ht.tc thl'Y :'Lifn.:h 1n~u the l'fP1H1,Jl aH ~acs (tit~ Jh~dLJ. ,u.d ~~~,:> :.tlfl::rt ui tilc hu::,(pkul.l) 'lliC thd-.enin!(o:'tii'.~ ti;.dc-. ndu. ( d by t!,, .:\hc<...ll:. du...,! ~dfcct:-. 111~.- functi(JI tlt the ) Ill/ 1!: tl:r v \~;:\-". I'h: \',)iutn:...~ when \u!ly 1nri.:~~.J ~1r tl_. ~J;) 1,; .1 ttJII ~~i : . ~ '" J' 11.~-, 1h.1n fltlll'tl ~~ J !ll' 1t,l~r..-.. l>t.~l 1. \jH( 1'~]\.Ull . ,lrlt\1'- t'ntt. lllndi,:J!':~ 1il''l' .11 !',;: l l,i \ I! I ' { , Ill )' -~ I'L ( ~\ j \ \ 11 ~- J*'Cl'C quant1ta1ive inter-relationship h'.'tWL'Cil asbcsto::. ei~Jic'ttn. ;;nd other factors is not fnlly ~SLihiishcd, hut p ..'it'll! ev,J-:n<c indll:atc;. that tho>~ whu 'mokc cigJn~tt<.s ~' ,,! <>fC : .\po,,J to "'hc,;tus dust have a m.k uf dl'velllpirrg !10::,~ :ll1c"l'f ~~t k;hl filt~ time; l(lCatcr than 1wn-smo;<e1s \'.li '~:c 111)1 ('\!~U'-:od :1) aSh'..''\11)'- d1JSI.. l11 the i."t :, )c'.!IS thr.re h.::; been nrw:h nc.v infcrnnLIC;l rih\ltli !\ll' l>.lk tK:.wct?ll cxpn~tll...' h) a::.\y....:,tO'-' ~Ut\..\ 'ihlll\.:1 i'fl'\'1\!U'-IY VCf) l:Ji~c typ;.. ~d Ci.llh:.:r afl(lting lhC FMSI 02814 ----------------------- surf;,ce of Llt lt'nb and the gut h. Reports of the,c mcso::.c1i.>rna~ ac they ar~ c:~lled ktve increased steeply over C1e la~.t I 0 year~. 1 here is general af'rccment 1;1 mn:.t industri.dizcd coul,tlll'S that the1c h:!s been a rc:1i !llcrca;;c of t..is ,u.-nt of cancer''. ln about XO';o of cases tl1cre is a history of exposure to a::bc:;tos dust at surne t 1111e in the past. A feature c>f thcse turn our~; is the long in tcrval betwt>cn first exposure:, to asbc~:tos dust and the detection of tlw cancer. It i:; LJicly less titan ~0 years and 1nay l.~t' up to 50 or more ye;1rs. In snrne 1mtancc<; the exposure 1Ll the dus' has been si1ort, only a few lllllllths. but the highest incidence of turnnms has occu11 ed lll those most heavily exposed 10 :tsbest<h dust. C1garctte smcJk1ng seems to play no part in rhesc tumours. but >ome research workers think there rn<:y ht other en-factors present as wdl as asbestos 1"- The unly nthcr spcctfic injury caused IS the f,,rnlal ic111 of asbcsh)s corns on the fingers when the fibr cs lod!'c in tl:c skin. The removal of the fibre usu;llly cures the corn and no cancers of the skin relatable to asbestm have been reported. PRACTICAL IMPL/CA T/ONS OF THE BIOLOGICAL EFFECTS OF ASBESTOS Inhalation of the fibre For all practical purposes the risk from asbestos is limited to inhalation of the fibres. Thus control of the ;,i, hurne dust le1cb and their monitoring by inst1unrcnts. whi,h will measure that part oi" ;he dust which can gain access tel the deeper parh of the hrng, is an essential step in the safe usc of all types (If asbestos. Although asbestos f1bres can be ingested in minute :m,ounts in beverages wltrl'll haYe h~Ul filtered thn,ug!I asbe,tus, lH water supplies 11 . thert' rs IlL' firm evidc:tce th:tt such tiny traces have any lli-<~1kLtS. Feeding m;c;sivr closes of asbestos h) animals has so far failed tn produce any mesotheliomas or othe1 cancers. Size and shape of fibres Recent research has hrlped t0 clarify the probable influ- ence of fibre length and diameter in producing asbestusrs anrl the br,Hlchial oncers. The fibrc1sis is thought to b~ cau~d principall:; by the fibres bdween ab,.Jut 5 and 100 1H11 ,;, ieng.h. Fihrl's much br~cr thdn thi' ir the er"ittt:!1Jc'JI! ,c::t;, uu( qurc1-.iy and arc nut inh;rlcd. Furtl!t'r silt: :-<.';1:1r~11t.)ll lk'l'ttrs in the air pass~tgcs. the nnpnnJnt si-:c pdr,;n, tc'l l'cin~ fihrc di;Inwtcr ,irrl'c it 1s tills duncn- s;un rothcr th:lll fibre' krHttlt th.t! ~ovcrrb the fallins S!h'cd of the frhre;. Thus fibtcJ. ~lc':ltl'r in lbanwtcr th:lll abnut 2 J.111l (these aJs,, tcntl to be the longest) !lltlstly fall or impact rn the upper respir;ttny tra.:t and arc' carried away with the 'Pillum. In !he narrow airways any long fibres rcrnatntH~ ill<' depusttcd by intnceptinn and fibre' Iunger than ;d1uut 100 J.lrll seldom teach the t'incst bwHchioJ,, Tim rnc;!Ih tlrJt for the Ctlntru! of asbclltnsis. and prtoh:Jllly hfllllcili:IJ C":!IICCIS. ~he dose ot' t'ibrCs bctWl't'll abuut ~ f.Jili and I(iiJ 11111 111 length and up to :tbllut ~ f.Jrn rn dram~tcr '' the lr:lc"t!"ll ut' the du,t whtc'il h.1s to he rnt'asurcd. For I( lllCS<~Ihclllllll:l' i!tc c'VIIknce dbc>Ut lire hru l<n~i,::dl\ llllp<nt:t;tt .r:c '' Jlllt.:h Jt-,, cl'lllpkle I ,,n, iill~~rllLI\'.'1 1 lit'i11 JIJJil)' suur(:l".'\. -..t~o..:!l J\ tht al'f11dvn,JiiliC b,Jr,\1.'111 -d l11tc t'tlr.. tJ,,. "1.c and '""Jl'' ,,1-ldlle, \\ll;dt \,f,\[(' lt'l.li!lC1! lfl , l~t h111;'.\ ;t!lllllJh ,!Tid 11,,!11 h 1 l!ll'.\ dl~ c.,p:l\lllc 1t1 tlrf(,rt'lli t'il<'' "' ,1\J,c,t.'>. illl.l tl,, cp1 dcminlogtcal studi(s of the in.:idcnce of th:se 1lllll.'iir; i11 rnan for differer>t t~-pes of fibt~, ;1 seems probable tli;J! iltt important ftbrrs arc hkely to be thusc which arc str~;!'.!Jt, small Iil diame;cr (up to :1hnut ! f.l!ll) Jncl perlrops 10 11m in kngth. It is not vet ~nown whether the ultra-fin~ fibre~ onlv vi;ibie under the electron microscdpt arc i>iologicail~ ;mp>rt.lnt. Su,~h fibres arc present in latgr numbers in the lun)!S of those who have been exposed to asbestos, but theic combined mass is extremely sm31L !tis too rarly yet to usc tills information to cstab!is:1 with confidence a s~paratc dust standarJ to prevent the development of these mesothelioma~. This is a field of intensive research at t!,e present. Stlt11C of the new evidence suggests d'at the size and \ltapt' of the f1brc are more in~pcltLr:li. than 1ts chcmic;:l composition, provid~d it is rcbti;ely ;nsnlublc. lt nuy be that ext rcrnl'!y fine fibres of many different materiah c~n l'cnetr;lle cells witlwut immediately killing them. hut once inside can damage the mcchani'>ms of cell divisions. An implication cf this view is that care shoidd be take11 to avoid C'XJHisurc to dusts of all types of fibre less than 05 11111 dial!etrr :1'vJ s~ve:at rni,:r\..)n1etr~s in kJ1g~lL Types of asbestos and occupations within the industry The last J0 years have shown the import:mce to health of the type of asbestos inhaled and the occupation of the WtiiJ..:nswitlun the industry. Earlier medical reports did nut dJffcrrntr:Jtc between one type of <bhcstos and another. 2nd nwst of the surveys were concerned with a;.be'f''" textile Wtllkers. A full asses;ment of tht risks would ide3lly be based on >ludic; of "urker;. only cxpo,ed io e:ch type of lrbr~ and in ali the opcraticm witlun the industry 111 which 'iris frhrc "'"'used. !n practic~ ti1e inform~tion is ;nuch k" complete !han this. Exposures to c>ne type of fibre luvc usually occurreJ only in the minini!. aPd fibre separatrng. This work usually takes place in countrit's .vhere the medical records are scanty and the labour turnOI'er is rapid. A notable exception is in the chrysotile mines in Quebec where a very comprehensive survey has just been compkted11~14. In the manufacturing countries several types nf fibre are often mixed together o~ have been processed concurrently so that employees ha\e been expo~ed to scvcr:d types of fibre in unknown quantities. ]';,,t recmds nf {~n:<i!L'' ' :.:r.~ .ar-~:y ,.\:lihh;.; ~-\_:! Iciating lu t~Jt: J!l.. iJ.cnn: of the drscascs. Tlrus ;lw current ;,ssess;IH''rH of -,be ;~LHIV< risks in thr p;!J,t fr,>rn dtffercn\ type\ Gf f't~re a11d clCCilpatl'.lll> rs ba;ed on rnftlltnati,lll which is far fro;n complete. l.'se can be mJde ,_,f e~,pcrimrnb in animals. especially rats. because most of the d~Sea,es seen in man can he p10duccd in these anrmals. New information is rapidly accumulating which I~ray gi1r a clearer indi.-,ll;un of the way in which Jifi'er,nt tnns Gl :~sbcstos produc~ their b;ologi~d e:fec!s. There is ger1Nal agreement that asbestOsiS ar'd brnnchial c;m.:ns can be caused by all types of commercially u<>ed :tsbestos(;unositc. anthophyllite, chrysotile, and croc!dolite) if the du,t is inhaled in suf!Jcic11t qu~ntitics. b;,;t it now 'c't:IIIS likely that the risk frorn chrysotilc may be less than \\'lit !~Jc uthc1 types of fibre. Thc:c is ;:l>u cviJcrKc that thL I i -~ IS l\l\\ ,;t ill lllllling and IIICtCJSCS along the ftbrc -.L'p~P.t1Jllf' J!Jd in:IrHJLvltlllng proct''~es Thi:-. i~ th(HlfhL to nrh-. ..LIJ.' !n tlk lJJ~~;IL'I P'UihHflllll (ilibor!ll' dust Ct'C~lSiing ~~~ rl''J"'if,d'!~.. fihtc.., :{hk tu pL!H.:t:~tfc 1n1u th\.' d~crc'\l pari .t ti.t ilr\~. Jri rt.lclic'l' thl) llll'JII\ th,tt liiC ,Jc:!llCT ibC lthrt' .1:1J th.' t!llfc c':lipktely it i-; scp;nJtl'd intu tndil'i:lual FMSI 02815 . ~i!~.,,:s and small hcuhllcs, the grn\('r the risk. Titer~ i; ;:\sn 'Uil'rncnts of fxposnre; tllc mcdi(Jl recwds 1>f those ~10< 1 evidence ,f ;; dose rcspons~ rei at ionsltrp lor ;r,hcs!usis O'P'''ed. Computers POW mak~ it easy to store this infor- and brom:hiJI oncer; and titus, if the dust leveb arc' kept matiun, hut we still need the for,sig,ht and administr.11ion withrP the new stJ<ld.nds. lite risks of asbestns!S and hr<lll- to sec that it is a.:hicved. If it is not dt.rre we m;;y still i;l chial cancers in tl:c future sllOuhl b~ very small. The rrsk of rlcvcltlprng mc,;othc!iomJ' !as a drfkrcnt 20 YL'ats or so be in no better position tu amwrr unportant qucsti<l'lS which ~rc ;;t prc~.ent unamwe, ~blc lKca;Jsc of ti1e relatwn to ribrc typ.:. It rs probably hi~hest with crncidJiitc paucity of past r~c:ords. ~nd lt,west with chrysotile. No :a;cs cle:uly related to Jntllllphyllite :.t!o~rr~ have hccn rep"rtcd. dcsprte carcful ><'arch The risk with amosrk pwb;rbly Ires hct\Hcn CONCLUSION crocrdolilc and clnysotilc. The cvrucncc for a d<bl' resp<'nse relationship is Jess clear in the CJ'iC or !llc,uthcJiolllaS and hence tire thrrslruld lrmit value IS murc diffrcult tel a:;srss. In tht Ashestm Regulations 1')(1',! 15 the stand:11J fpr ctocid<'lite is set at one-tenth of th;1t for other types uf asbestos. The re.:~nt increase in the number of cases of a::brstosis and other diSl'i<SC> related- tu past expllSure to asbestos ts the result of relatively heavy exposures to the dust, particularly in parts of the ~sbc:-tos industry not covered by the 1931 Asbc:;t11.; Rcgui.Jtion;,. Much new infonnation about the biL1logical effects of asbcstus has been acquired recently. The new Asbestos COMPARISON OF OCCUPATIONAL RISKS Regulations I969 based on this information, if correctly appli~d. should greatly reduce the risks in the fui'Jre. \\1ut is the magnitude of the risk of devciup:ng il!-ltealth frvn-, iJ;;b~..- ,~v~: Nt-, ~in~k inLl~>.. pro.JVJJe~ a S<illSl-~<:tury mca,urc of injury to ltP;rlr'L Thus the excess risk of death before a 'pccifieJ J~c may be a useful index for those diseases crusin~ sud(kll or rapid dedth, but it is ;111 in3ppropriate index for disease:; cath;llg a long period of drsahrlity but little slwrtcning of iifc. 1 he cancers associated wirh asbestos exposure fall intu the fnst group and asbestosis the second gruup. In different llc"t.'ll- pa!ional gruups comp:rrisuns of mort:rlity are easier tu maKe than those of illness. llut even for mortality the cumparrsons are not straightforward. For example, the mt~rc the The ::election of which types of asbestos to usc in new pruce:;s: . ;iroulJ t,tke ittlv accour;t therr biological effects if the risk of dust exposure is likely to nccur during manufacture or in the use of tht products. When workmg with extremely fine fibre~ of <ny material which may become airborne, caution is needed. An examin:rt ''"' of the possible biulogrcal effects is required if the pmduct is to be widely used and ri;,ks of damage to he,dth arc to be avoided in the future. Pronf of the efficacy uf present preventive mrasures dLpcnds on much better record keepmg than has been the case in the past. selection is limited to a definable group with ;r hrgh p:st cxposur,~. the worse the risk will appear. AllowJncc' ha5 also to be nrauc for tile effects of a:;e, length of exposure, REFERENCES and how long the occupational group has be<'n followed. When ~.uch a!iLJWJnces are made the excess mor t;t!ity from 'all causes' in gruups of workers heavily cxpo..rd ru the more d~rn;rging types of asbestn; dusts in tlh' past is closely cum parable tu that of coalminers who have dc,elupcd the severn form of cnalworkers' pneumuconiu:>1s or that of dcep-<.ea fishC1111en who have the highest rJtes ol accidental Je.tths of any occupatiun. However, the excess mortalrty from 'a!i cames' in these occupational groups rs Jess than that of male smokers of t\vcrt ty cigat t't tcs and I!HllC' ;t da~. con:p.1 r~ .i \Vith 1\(Jfl-\PJn!.r::" Tins rs the po:;IHlll for Jca~J:, fr,Jill ail Clll\es'. hut d('~ilhs finrn '.pc~..:dJc ~.:au .. c'. ~uch ~J~. nh\~Jtl~l~IJonLh . t~h('~ to\ls. ur lllrti;! ,;~nccr> rc'\Jtrvc tu t!t:t: ui the genet,,! puhl1c. a:e qf c"<Hirsc pi<),lufl;,,n,ltclv much more 11rcreas~J. Tl11s IS bec,rusc mc,otlteii,m." ;1nJ ;r,bc,rusJ:, arc C\tll'lllt'ly r.rrc in tho"-' \\l:o h:rVL' not wnrh.ed wrtlt a,!Jcstuo;. C.11l1Lhictn ~Oillctrnrcs ucLurs IL'twccn the P"'portiun uf indJVIlh.rh rxr,hed \.Ito dnriop ;1 dis<'ase and the excess r"k "' .1 particular di\e.csc 111 c.\poscd individuals compared wirlt the general public. The rrrst may be rdativcly small and tit'' second cxtremdy lu\'.\1. J-..:llTO Leo. American Industrial Hygiene Association Journal, Vol !<J. p 195 (I <loR) Mtre\\cthcr F. K. A. and l'rkc C. W., 'Rrpor! on thr effects of asbestos dust on the lungs and dust suppression in the Asbestos Industry'. London, HMSO (t930) Dreessen W. C., lldlavalk J. M., l.dwards T. 1.. ~,filler J. W., Sayers R. R., 'A >tudy of asbestosis in the a>lll'stos text1ie industry'. lJS Trtasury Dcparllll<'!l\, Public llc.llth Sen icc. Public Hcaltltllullctin No 241 {Avgust 193~1 4 ~lercwcthcr F. 1\. A. Annual Report. lnspccl>r of Factc,ries. [ 0110o11, liM SO (I').-:' I Dl'll Rll'hnrd_ l~rinsiJ /(111t ,,..! of .11.':/:l.::t;i:.Jj .."kdi{Ult', Vui J.J, i' Slil'1.i5) (J );no\ J. I .. hulrnc' ~-Doll R., arhl lliJ: l. Il., /lntisi1 Jc::rr.a{ of!'lduHJia/ .\L~Ju:n~'. ,.(1[_""~5. p :9..~ (IW~t'~} S~.:l!b\1 f J. J .. ./<J!lllll;f oj tiJc /1 fltr't"fra.n .\lcJica{ l1.HrJCiillUm. J"oi.'!JI.r IO.J rl'lr.l') S \\',uwr J. C.. (;il'<l!l J. C.. Berry c; .. an.! Tirnhrdl V., Hririrh ~J,dc,alllcliletill l'o/.'7.1' 71 (1~7/j 9 C:I..,:Jn J. (:., ,\,h~,.q~J'i he.tlth !t:lJJr,h'. in Slu:liro. H. h. (1.'d~totl, 'P:~t'llill0(lll'l!~'~i<, Plun'\.'dlllf'.' nf o~- ln1 1:;nailr;~11 ( nnkiL'Ih't'. JohanrH? .. burg. 74 r\pril---2 M<l) liJ6{J, p 173. l.qh' Town elc., U.\rt.nd Universit~ Pr~. ...s (1970} !0 \\\.b,t~..r 1.. 'Al'.bc-..tor.. e\.posure in South Afnca'. ibid. p ~ 2J II Curu<rn!']lam fl. M. and Pontcfract R., Nature. l'o/2.1:!. p 33:! (/V7/) t 2 lkd.takt Margaret R.. Fournrer-Ma<Sey (;isdc, \.lc-Donald L C.. Sicmiatycki J., and Rossiter C. F., flulll'tir dr Physio- THE FUTURE ,rAs rn 111.,;\\ "'~III'JtronJI drsc.r'c' proof L'j the cltr,.:,y llC'W Jll,'\'~' 1 1 1 1\l' lllr.r-...ttll'" 111l'IU-illl~' !lie va!idtt) tl! t!t' Cllllt'!l! tl.ll'\h1dd lund V,!:u~'- ~...an oniy ...:uith' !.!Uill lt:tklltt: J:lllllll~ltl(!ll ul thll'C type-:. lhl' PL!l~Ul,lL'IIlflll~' }1ftlC:L'\. :rrhl tit, type' ,r t"ihrc' :rnJ Pthcr rn;JI,'rr,r\, tiSt'd the llll'.l l'"tlwloKi<' Rr'-'fllratoire. Vol t1, p t.37 ( IY70) 1.1 \t, llonald J. CUJl>l'! I, \k!Jon.rld AI""" [) ., Grbbs Graham W., ~IL'llltJ.I) ll-:1 Jack, and Ro-.~ltcr ( h:ulco;;. F., Archirt'S of I tJr,I/II11IW!IIealth. Vo/.:.;.rn77(!971) ll Jodom t;dl:..<:. t t~hh. C \\'., \1Jd,klll P T .. ~kDon;Jd J. C., B, kL!~-'- \~.H;' 111! H ln;(rr, 1Jt! l\t'l H H' of' 1\~'\Plf~J(Of).' f;l U."H' io{ /0/.f! ~ :_) { /'1 7/j l" ~1.Jiut,q~ !n~trU!'I:I'h )qflq \u (ll)ll, lJ ..:torir), lllC />.~hl'~lo.., I~' 'HL.IHn; ... Jllt~9 I dlhlun, 11:\lSO li\JI1'JJ FMSI 02816 Asbestos Information Association/North America ~2 East 40th Street New York, N. Y. 10016 (212}.~~ (c.'i,c\ ~~1 '( July 5, 1972 TO: AIA/NA MEI-1BER COMPANIES AIA/NA ENVIRONMENTAL CONTROL SUB-COMMITTEE AIA/NA LEGAL COUNSEL James Armstrong - Bendix Corporation E. C. Bratt - H. K. Porter Company, Inc. G. G. Gabrielson, Jr. Nicolet Industries, Inc. Bernard Gross - American Bilt Rite Rubber Company J. Hall - GAF Corporation H. M. Jackson - Johns-Manville Corporation W. N. Johnson - Unibn Carbide Corporation A. R. Hooker - The Flintkote Company C. A. Neumann - Kentile Floors Incorporated G. W. Nickel - Armstrong Cork Company Clifford Seymour - The Carborundum Company J. R. Stetson - Congoleum Industries, Inc. Philip Weinstein G. w. Wright, M.D. - Evertex Incorporated - St. Luke's Hospital Gentlemen: A meeting was held in Washington last Thursday bet\veen the AIA/NA and representatives of the OSHA standards development and compliance sections. Attending on behalf of the AIA were John Marsh, Raybestos-Manhattan; Paul Weiner, GAF; Hugh Jackson, Johns-Manville; Frank Zimmerman, National Gypsum; Bradley Walls, AIA/NA Legal Counsel, and M. M. Swetonic, AIA/NA Executive Secretary. OSHA was represented by John O'Neill and Harry Gilbe~t of Standards Development; and Ray McClure of Compliance. The purpose of the meeting, as was discussed at the Association meeting on June 22, v1as to clarify a number of points with regard to the interpretation and enforcement of the asbestos standards. Because the standards are to go into effect this week, we considered it imperative to provide you with the basic points of interpretation a~d compliance established at the meeting. A more complete report on the meeting will be forthcoming in the near future. Spom10red by Atlas Asbestos Co .. Cement Asbestos Products Co .. Certain-teed Products Corp., Flintkotc Co.. GAF Corp . Johns-Manville Corp., National Gypsum Co., Panacon Corp. and Raybestos-Manhatlun, Inc. FMSI 02817 .' . -2- The following are the main areas discussed and the decisions reached: 1. LABELING: The AIA/NA is applying for a temporary industry-wide variance on the exact wording of the labeling requirements of the standards, in order that existing supplies of boxes, cartons, bags, etc. containing a label with wording somewhat different than that called for in the standa~ds will be permitted until they are used up. As long as the label currently being used contains basically the same information as the required one, it will be acceptable to OSHA until stocks are used up. Products to be labeled should follow the listing submitted by Dr. Fred Pundsack of Johns-Manville to OSHA following the March hearings. A copy of Dr. Pundsack's list, with minor alterations~ is attached for your information. No product which requires labeling will be. permitted to be used without any label until existing stocks of non-labeled bags, etc. are used up. A stick-on label of some type would be satisfactory. The size, color, placement, etc. of the label is left to the discretion of the employer, as long as the label is "readily visible and legible." A good rule to follow would be: if you are trying to hide the label, OSHA will probably not accept it. 2. CLOTHES LOCKERS: Separate clothes lockers are required only for employees working at levels in excess of the five fiber TWA. 3. It was the intention of OSHA to require Type "C" supplied-air respirators and protective clothing only for insulation and fireproofing spray applications. AIA/NA will apply for a modification of the law to exclude other types of asbestos-spray applications from these requirements. -More- FMSI 02818 . -3- 4. RESPIRATORS: There is a mistake in the standards in paragraph (d) (2) (ii) "Powered Air Purifying Respirators." The first sentence of that paragraph now reads: "A full facepiece powered air purifying respirator, or a powered air purifying respirator, or a respirator etc." The sentence should'read! "A full facepiece powered air purifying respirator, or a respirator etc." The phrase "or a powered air purifying respirator" should be deleted. 5. MONITORING AND PHYSICAL EXAMINATIONS: Company monitoring and physical examinations should be conducted on all employees who regularly work with asbestos and are exposed to airborne fiber, as well as on maintenance men, company industrial hygienists and other employees that the co~pany feels require monitoring and physical examination because of the nature of their work or because of their close proximity to dusty asbestos operations. This would exclude office personnel, most people working in non-asbestos using sections of an asbestos manufacturing operation, etc. 6. CITATIONS: A company's own monitoring or other records will not be used as evidence to issure citations~or will they be used to give a plant a clean bill of health. 7. OSHA INSPECTIONS: OSHA industrial hygienists will take dust samples, if at all possible, for a full eight hours, perhaps divided into two four hour samples. In addition, samples will be taken on more than one day, so that a more accurate count can be produced. Ceiling sampling periods will be at the discretion of the OSHA hygienist. Ceiling samples as short as five minutes may be taken if deemed appropriate. Under some circumstances -More- FMSI 02819 -4- (an obviously very heavy dust concentration) , only ceiling samples may be taken, but this would not be normal practice. Employers will be given specific dust counts only if they are in excess of the standard. Counts taken by NIOSH hygienists will be reported to OSHA, but will not be used by OSHA for purposes of issuing citations. 8. EMPLOYEE NOTIFICATION: On the question of notifying employees if they are found to be working in dust concentrations above the limit, neither O'Neill or McClure would make a decision whether the notification clause in the standard would be satisfied by the posting on a plant bulletin board of stations above TWA, or whether a more individualized approach, such as sending the employee a registered letter, would be required. To answer this question, we were asked to write to the solicitors office in OSHA for a ruling. Unfortunately, a prior informal conversation between Paul Weiner of GAF and a member of the legal staff of OSHA indicated that the answer to such a question would be in favor of the registered letter approach. As a result, we have decided not to submit this question for a ruling, but will leave it up to each company in the industry to decide in what manner it wishes to abide by this requirement, and wait to see if bulletin board notification will be challenged by OSHA regional inspectors. In general, the concensus of the AIA group that attended the Washington meeting was that the industry could expect reasonable treatment from OSHA as long as the industry did not try to circumvent the intent of the regulations. For example, the various requirements in the standard for protective clothing, change rooms, separate lockers, etc. have as their purpose the preventing of excessive amounts of asbestos dust being carried home on an employee's clothes from work. As long as this purpose is achieved, the industry will be given wide latitude as to the types of protective clothing, footwear and headgear required; the location and size of change rooms; -More- FMSl 02820 -5- the distance between separate lockers, etc. In short, the industry is free to interpret many sections of the regulations as it sees fit, as long as the spirit and intent of the law is observed. Sincerely, Matthew M. Swetonic Executive Secretary NOTE: The following is the new address and telephone number of the A:.n../NA effective imrnediat,ely. Asbestos Information Association/North America 22 East 40th Street Suite 1611 New York, New York 10016 212- 689-3378 FMSI 02821 ..bv-.\ rv , , Asbestos Information Association/North America 22 East 40th Street New York, N. Y. 10016 (212) 001-~ Co~"\ '1~l'i' July 12, 1972 TO: AIA/NA l'1El1BER COMPANIES AIA/NA ENVIRONMENTAL CONTROL SUB-COMMITTEE .l\IA/NA LEGAL COUNSEL James Armstrong Bendix Corporation E. C. Bratt - H. K; Porter Company, Inc. G. G. Gabrielson, Jr. - Nicolet Industries, Inc. Bernard Gross - American Bilt Rite Rubber Company J. Hall - GAF Corporation H. M. Jackson - Johns-Manville Corporation W. N. Johnson - Union Carbide Corporation A. R. Hooker - The Flintkote Company C. A. Neumann - Kentile Floors Incorporated G. W. Nickel - Armstrong Cork Company Clifford Seymour - The Carborundum Company J. R. Stetson - Congoleum Industries, Inc. Philip Weinstein Evertex Incorporated G. W. Wright, M.D. St. Luke's Hospital Gentlemen: Inadvertently, the list of non-locked-in asbestos containing products which was to have been attached to our July 5 mailing was not included. Attached, therefore, is the list as originally promised. It has come to our attention that a number of companies still have questions concerning whether certain asbestoscontaining products which they manufacture should or should not be labeled. The standard is rather indefinite in that it calls for warning lables on products which "during any reasonably foreseeable use" may create airborne concentrations of asbestos in excess of prescribed limits. The Occupational Safety and Health Act itself states that "any standard promulgated ... shall prescribe the use of labels or other appropriate forms of warning as are necessary to insure that employees are apprised of all hazards to which they are exposed, relevant symptoms and appropriate emergency treatments, and proper conditions and precautions of safe use or exposure." Quite obviously, the rather simple FMSI 02822 Sponsored by Atlas Asbestos Co., Cement Asbcsto!:. Products Co .. Certain-teed Products Corp., fllntkotc Co., GAF Corp., Jol.nsMimvtlle Corp., Nuuonal Gypsum Co .. P,:~nacon Curp. ond AayUc~tos-r..,anhattcm, Inc. -2- warning label prescribed in the regulations does not meet all of the criteria described in the law, which only adds to the problem. Each company will have to decide for itself whether a particular product requires a label or not. Obviously, there should be uniformity on th~s subject, because if one company decides to label a certain product, and another company decides not to label the same product, the latter company whould be placed in a most untenable position with OSHA. It is our understanding that OSHA is planning to use the list of non-locked-in products submitted by Dr. Fred Pundsack of J-M at the March hearing as its labeling criteria. If this list is followed, difficulties with OSHA should be few. Nevertheless, there are always products which do not fit any list, or which may produce levels in excess of the standard at one step in the application or handling process. For example, the field cutting or trimming of asbestos-cement pipe might produce levels in excess of the standard, but only for the man doing the actual cutting and only very intermittently or rarely. Thus, to place a warning label on asbestos-cement pipe would be quite misleading in that it would alarm all those handling the product, when only one man has a potential excess exposure. Our recommendations to you on labeling would thus be as follows: l. If the product is included on the list of nonlocked-in products, it should be labeled. 2. If a oroduct is not included on the lict of non-locked-in products but you consider it to be a border line case, or if the product has an occasional handling or fabrication problem, the following options are open: a. Label it and be on the safe side. b. Do not label it and hope OSHA doesn't question your decision. c. Conduct tests to determine if the use of the product does indeed produce levels in excess of the standard. Chances are that -More- FMSI 02823 -3- most product uses of this type will meet the eight hour TWA standard of five fibers, and that most problems will be in meeting the ten fiber ceiling standard. If tests determine that neither standard is exceeded, the product obviously need not be labeled. The test results should be kept in readiness in case an OSHA 'inspector questions your decision. I1 d. If the eight hoc:..r time weighted average is above five fibe~s per cc, then the product should be labeled. e. If the ceiling value is above ten fibers per cc, which is the more likely of the two possibilities, then the use of the product should be examined to determine (1) how far above ten fibers per cc is the ceiling value, (2) does this particular work practice or use of the product occur frequently, intermittently, or only rarely, (3) can the product be applied, cut, triwmed, etc. in another fashion such that the ceiling level does not exceed ten fibers per cc. After these questions have been answered, it will be up to the individual company involved to weigh each answer carefully and to arrive at a decision based on the simple proposition: Does this product or its use place the health of workmen in jeopardy? Obviously, if the answer is "yes," the product should be labeled. If, on the other hand, you honestly believe that the answer is "No!" then you should not feel constrained to label the product, nevertheless you must be prepared to defend your position with OSHA should they question it. There are a number of ways that you can place your company in a better defensive position should OSHA challenge your decision not to label a particular product. The basic idea would be for you to alert the purchasers of this particular product that one or more operations in the handling, application, cutting, etc. of the product might produce levels in excess of the standard and that -More- FMSI 02824 -4- precautions should be taken. This could be done through personal contact between industry salesmen and customers, or in the form of an instruction sheet delivered with the order that might specify certain work practices or types of machinery that should be used to keep dust levels. low. The instruction sheet, for example, might say nothing more than "Powered bench sa~,o;s without collectors should not be used in cutting this product. If this is impractable, operate~ should be provided with a u.s. Bureau of Mines approved respirator." An approach of this type, or one somewhat similar, would indicate to OSHA, should the question arise, good faith on your part. With regard to the coordination of industry labeling practices, if your company has decided to label a product not included on the attached non-locked-in list, I would appreciate being notified of this decision and the rationale behind it as soon as possible, so that a uniform position can be established with other companies in the industry manufacturing the same product. If you have any questions or problems with regard to labeling, please feel free to contact us at any time. I would not advise your asking OSHA for a decision on whether or not to label a certain product. Almost assuredly they will tell you to label any border line product, and that decision will become binding for the rest of the industry as well. Very truly yours, Matthew M. Swetonic Executive Secretary Enclosure FMSI 02825 , ' NON-LOCKED-IN ASBESTOS-CONTAINING PRODUCTS REQUIP.I~JG A WARNING LABEL ACOUSTICAL PRODUCTS Dry spray type Foamed asbestos CALCIUM-SILICATE SHEETS Low density sheets (less than 50#/~t3} CEMENTS Dry Gypsum joint cements Insulating cements INSULATIONS Low density calcium silicate binders Corrugated paper Low density magnesia binders High temperature blocks & bricks PAPERS & FELTS Conunercial grades (unsaturated) Roofing felts (unsaturated) Gaskets (unsaturated or not encapsulated) Millboards (unsaturated or uncoated} STUCCO & PLASTER Dry mix cement stucco Dry mix decorative plaster TEXTILES (unsaturated or uncoated) Braided products Cloth Listing Wicks Yarn ASBESTOS FIBER BAGS FMSI 02826 FRIC110N MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE /)4, PARAMUS, N. J. 07652 BUL L ET I N NO. 4 4 6 July 11, 1972 TO: ALL MEMBERS ~~~ASUREMENTSSUBJECT: EQUIPMENT/TRAINING F9R "I / ' At the recent Annual Membership Meeting it was brought to my attention that many members had not received information on equipment for measuring airborne asbestos in the work place. Most of the following information is a re-hash of earlier information- particularly Bulletin j428 of February 18, 1972. OSHA STANDARDS, OTHER PAPERS REL AT IV E TO ASBESTOS IN THE WORK PLACE 1. Occupational Safety & Health Administration (OSHA) Standards per ~Vi 11 iams - Steiger OSHA Act of 1970. Federal Register, May 29, 1971 2. OSHA Standards for Exposure to Asbestos Dust, Federal Register, June 7, 1972 3. "Measurement of Airborne Asbestos Fiber by the Membrane Filter Met hod11 Asbestos Textile Institute P.O. Box 239 Pompton Lakes, New Jersey 07442 (Price $1.00/copy) The Institute distributed copies of these to the members during the past year. The most pertinent are Item 2 (OSHA Standards for Asbestos) and Item 3 (Measurement of Airborne Asbestos "). GENERAL METHOD (MEMBRANE FILTER MEJHOD) A pick-up is worn by a worker in the area to be measured. A battery operated vacuum pump draws in air over a specified period--say 60 minutes, 90 minutes or four houre. Asbestos fiber is trapped by the filter and then sealed and sent to the laboratory. The sample is examined using an optical microscope where asbestos fibers are counted. Details on the optical count are given in the book 11 Measurement of Airborne Asbestos Fiber by the Membrane Filter Method11 FMSI 02827 Bulletin t446 -2- July 11, 1972 EQUIPMENT & SUPPLIES Depending on the size of operation, at least two pumos costing about ~150 each are required: (a) Mine Safety Appliance Co., Pittsburgh, Pa. 15208 (b) Willson Products Div., Reading, Pa. 19603 (c) Unico Environmental Instruments, Fall River, Mass. 02720 A battery charger (one for each 2 pumps) is suggested. The charger would cost about $50. Pad and filter inserted run about 70 a piece, and are available from the Millipore Corporation, Bedford, Mass., 01730. A binocular microscope with phase contrast illumination set for 400/430X magnification is required. While a Bausch & Lomb microscope costing ~p1,200/1,500 is basic, binocular microcopes with additional fixtures should be worth the additional cost. (Seek professional advice on this.) Most of the above information is verbatim from the book "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method." OUTSIDE SERVICES AND TRAINING It may be feasible to have outsiders do the full job- from sampling through examination and reporting. Others will do the analysis work only where the samples are mailed to the laboratories. Tracerlabs in California will do analysis work for about $50.-60. per analysis. Johns-Manville will do the full job for a fee (Contact Mr. W. Reitze, Manager Industrial Hygiene Engineering Service, Johns-Manville Corporation, P.0. Box i;15108, Denver, Colorado ;~0217) George Clayton Labs, Southfield, Michigan will do the full job for a fee. There are other labs that may do the entire package or the analysis work only. Johns-Manville indicated it would be willing to train personnel in the technique in a two day period. They would take one trainee or at most two trainees, to one instructor for $200. a day. These sessions would be at Phindern (Somerville) New Jersey or Waukhegan, Illinois. Again, the contact would be with Mr. Reitze in Denver. It is most important that those concerned with the OSHA Standards enforcement receive this basic information. Should additional information be required, please advise. E. VI. Dri slane Executive Director FMSI 02828 REPORT ON FMSI ASBESTOS STUDY CO~ITTTEE ACTIVITIES The Asbestos Study Committee was formed July 1971 with the assigned purpose to review and comment on rules and regulations promulgated by state and federal governments concerning asbestos and its applications. The first Committee meeting was held September 15, 1971 and was chaired by Dr. E. P. Stefl of Raybestos-Manhattan, with members from Worldbestos, Abex, Bendix, aRd Carlisle Corporation and J-M present. The following items were reviewed and/or discussed: (l) Helationship with Asbestos Information Association/North America. (2) Proposed Illinois Regulations. (3) Vehicle friction material emission test program to be conducted by Bendix under EPA contract. (4) Monitoring for airborne asbestos fibre. (5) Districution and circulation of literature on Asbestos/Health subjects. The purpose of the Asbestos Study Committee was restated as follows: 11to 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. 11 The following is a list of the actions taken by the FMSI Executive Secretary on behalf of the Asbestos Study Committee during the remainder of 1971: September 30 - Issued minutes of first Committee meeting with letter commenting on proposed Federal EPA and Illinois emission standards. October 28 - Issued bulletin and further information on Illinois hearings. November 10 - Issued information on membrane filter monitoring method. November 14 -Issued bulletin on revisions to Illinois and Federal EPA proposals. December 8 - Issued information concerning final draft of proposed Illinois regulation, proposed EPA emission standards, and Federal Department 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 FMSI headquarters February 10. On February 10 this session was presented to nine attendees representing six member companies. The second Asbestos Study Committee meeting also was held on February 10 with I. H. Weaver, Raybestos-Manhattan, acting as chairman and members representing Worldbestos, J-M, Bendix, and Carlisle attending. The following items were covered: l. Review ofAIA/NA comments regarding OSHA meeting in Washington on January 26. 2. Review of proposed OSHA asbestos standard and comparison with British standards and regulations. 3. Review of British Friction Material Council comments on Illinois standards. It was resolved to forward to BFMC copies of minutes of future FMSI Asbestos Study Committee meetings. 4. Recommendation made that the FMSI Asbestos Study Committee maintain close liaison with AIA/NA. 5. Heviewed background and expected thrust of OSHA and EPA regulations. FMSI 02829 - 2- 6. Reviewed monitoring equipment and methods. 7. Recommended future course for Asbestos Study Committee. The following is a summary of actions taken by the Executive Secretary during the first half of 1972 in regard to Asbestos Study Committee matters: February 18 - Circulated Bulletin 427 regarding various standards for asbestos dust exposure and control. This included copies of the January 12 Federal Register announcement of proposed permanent OSHA 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 l - 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 12 - Issued announcement of OSHA permanent standards on asbestos dust exposure as published in June 7 Federal Register. The latter item has been rather intensively studied by your Chairman, by AIA/NA, and no doubt also by concerned individuals in practically all companies represented in FMSI. 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 of TLV to 2 fibres in four years. 2. Use of protective clothing required above 10 fpcc ceiling limit. Change rooms, dual locker facilities, and speciallaundering and clothing handling procedures required. J. Monitoring required at least every six months at operations exceeding allowable TWA concentration. 4. Physical exam and doctor's approval required before assigning employees to jobs requirj.ng use of respirators. 5. Elimination of references to 'cancer" and ndanger 11 on signs and labels. Labeling eliminated for products containing locked-in fibre. 6. Specific restrictions on 11 dry sweeping" and use of compressed air for cleaning eliminated. 7. Medical examinations, including pulmonary function t~sts,required annually for all employees exposed to dust. 8. Employee access to medical and monitoring records required. E~ployees exposed to levels above TLV must be notified in writing. 9. Waste containing only locked-in fibre need not be sealed nor labeled. FMSI 02830 - 3- 'dhile many serious difficulties are expected in achieving compliance with the new regulation by miners, textile manufacturers, and insulation fabricators and installers, it appears to me that most friction material manufacturjng 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 more 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 Bendix Corporation for EPA have been announced. I have been advised that this study, originally to have been completed this month, now is not expected to be finished unti~ late this year. Most of the difficulties that arose in this study to date have occurred in connection with the gas collection phase 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 EPA program also is running behind schedule. That is promulgation of the permanent regulations and standards for asbestos emissions to the ambient atmosphere. I have been advised by the EPA Hazardous Pollutants Branch that the earliest date these standards are expected to be issued is the beginning of August, and they could be delayed until early September. However, no major changes are expected in the portions of the proposed regulation affecting manufacturing operatins. 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 wet dust collectors. This should be helpful to industry in permitting somewhat more 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 from others concerning items that should be considered and reviewed by the Asbestos Study Committee during the following year. l. Uniform interpretation of OSHA standards. Liaison with AIA/NA will be helpful in this. 2. Determination of technological feasibility of achieving both 2 and 5 fibres throughout the industry. J, Determination of the overall effect on the friction material industry of the OSHA standards. 5. Development of guidelines, aids, and educational programs to help customers comply with the regulations. 6. Investigate a suitable standard method for analysis for asbestos in brake lining wear debris. 7. Develop methods and recommendations for safe disposal or recycling of friction material grinding waste. 8. Follow as closely as possible medical and occupational health research concerning asbestos and asbestos-related diseases and determine Y.rhether FMSI or its member companies should help sponsor or otherwise suppoet work of this nature. FMSI 02831 - 4- All of these subjects probably will be reviewed at the third Asbestos Study Committee meeting to be scheduled within the next month or so. Please advise us of any additional items you or others in your organization may wish to add to our agenda for this upcoming meeting. Respectfully submitted, c~~~ I. H. Weaver, Chairman FMSI 02832 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, PARAMUS, N.J. 07652 June 20, 1972 TO: MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: OSHA STANDARD- POSITION OF INDUSTRY, NIOSH AND ADVISORY COMMITTEE Mr. I. H. Weaver, Chairman of the Committee, felt the attached tabulation proposed by AIA/NA comparing items in the OSHA Standard against the lnudstry position and the recommendations of NIOSH and the Advisory Committee on Asbestos Dust would be of interest to all members of this Committee. Copies of this tabulation are attached for your information. EWD: 11 z E. W. Drislane Executive Secretary FMSI 02833 ~~:..~--...~~....~,....;~~~tijf ..-..--.~..~..,............~~~~~-" ..... -.....:il ~~~~-.--~---------------- Subicct 1. NQ~erical Stcnd~rd O:.>H.,\ ;~.;GI.i1..r.2IUL t) o:! .~:)~~. ~;.;~.:o.; Industry Po~ition l!IOS!lj;\,~v:i,]or_L Cc>nrd.t~cc Re con;.l_cncl:_tt ion Five fibers vrith ~ auto11.:1tic reduction to t1;1o fibers. ?ivc fibers Hi th ct.'1 nutomo.tic reduction to bvo fibers in bra ye<:..rs. Fin<'.). OSii;\ ::Jt:-nrld Five fibers \:i th c~'1 auto::;. reduction to tvro fibers ir: ~years. 2. Lo.belins llo l~bel on loch:cd-in nshe.stos cont<:tinins }Jroducts. 1'hc ,rords 11 cancer11 or i.ldr..n~ern should not be used on labels. All asbestos-containing products should be labeled. L~J.bel should c:c:..rry twrds 11 co.ncer11 n...'1d 'cla..'!.Ger a !Jo label on locked-in ask: containin.::; products. '.lord:: 11 cc.ncer11 and 11 d.o,nger 11 Nil:i. not be used. 3. Honitorin.:; Frequcnc;,' !1onito ring should be conducted lTIO.SI!: 1\n~n.1nl r.10ni torin;:; .o,t at a frequency necessary to stations bclou T'.l.f,. -luarterly assure coupli<'.ECe Hith the monitori11[j at stn.tions above environr.1ent~:Q .stn.llclards. 'J:1.!A. iUWIJU~I.Y COl :I iiT'l':~: Tuice- lbn:..::;en:nlt should decide yenrl:r r.1o:1itorin~; o.t stntions freq t~.ei~c:r. belmr .T'.i.4.. l ;ontr~y ooni~orinr; at sto..tions above T.u~. Honitoring cv:;r,y .sL: n0;1t: at station.s o.bovG' T'.ih.. 1-ionitorinij ct other s~::ti.::. at a frequency to c,ssure compli::mce Hitil c;wiron:.:e;: stnnclarcl.s. !:.:_:!1.:..ger:le~1t to decide fr~c;ucncy. 4. Protective Clothins lio protective clothi:r.g required below 5-10 times 'J:'.li~. triOSII: Protective clothinc l'equii~ec1. in o.ll D.reas above liLLi..t. /J1VI. ~CU:: COI J :IT7,:r.~: no pr,1tectivc clothin[; belmr 10 ti;~eG ~.il\. Protective clothing requi:: only \/here peo.~: exposures above J_ioit (10 fibers) occur. "T1 -3: 5. ~1~.stc Disposo..l CJ) 0 cwNo ~ Only unstcn thnt gcnorate cluGt in c::ce;;;:; o::' linits G~lonl:l be! b::::::od. All \Htste sl1onlcl be ba;,zed. Only Hastes tl:."1.t t>~:1cr.:::.te dust in excess of liii:its nust be br,::;~-;ecl. ------;qj;qJii &liiall 1CWi W"'i ...-.~~~jfibf"~;Wl,SO~--~:::'i, ;_..:~JIJ -.?.- If~".,.,~.. Y M '\a:!' :p'f1Hr' r;~*"ibiJRi'~~&...!fiifiM.~~~'::>:t>f;.-4.i!ii'~~~~,. ..-,...-. Subject Indw.:.;trv Position ;:rcs:!{~r~~}-,;orv Cor1r1ittce HPco;-t!nr:;-:c1n tioYl:. ~,?; 1~:'JJ_ 0.:..): :_1 .S C:n:~.~~rd 6.?requency of llcdicn.l Zxnminc-,tions j~x~utr:; ev<-:ry tHo yonro for \-JOrl:crs ui th lcos tho.n 10 yeo.rG c:ClJO.S1U"'e. I:xr""~.r1~3 every yeu.r for \lOr~:crs 1.1ith ;Jorc than 10 years exposure, or Hith symptoPJs of dicease. i :r0:3II : St:.uc <G in<iustry position. i><lvisory Committee: Sar.1e c:,s incluatry :ooc;ition. /li1.11U<cl C:X:<l.U:J required of ~<11 e;.1ployees exposed to o.sbcstos dust, rcs~rulcss of length of er,lployment. 7. Eedical Surveill.:mce En1)loycr should "provide or r12.ke availuble" medical exans us required. IUOSH: No specific rcco!:Jnencb.tion. Adv.ism7 Com.ra:i..tt.ea:. Sc::J~IC us industry position. Er:1})lo;yce should select physician to perforr.1 exam. Employer t.o pay cost of exam. 8. Hedical Records :Snploycr shall maintain records uncl have uccess to them as required to comply Hith reculutions. l!IOSH: IJo specific 1'ecommendo.tion. Anvisory Committee: J.:-:mploycr shcll not r:1aintain records nor h.:'.vc access~ to them. So.r.Je us indHstry position. ., -3en: -. 0 N ()C) (1.) (J1 9. Hearing of Respirators. No specific recommende.tions. HIOSJ!: lJo Sl)ecific. recor:1f,Jendn.tion. Advisory Committee: No er.1ployee shall be required to v1en.r a respirt~tcir if he ho.s any of a lone list of symptol1113 of diseo.se. Physician selected by enployer to conduct medical surveill~nce proGr<u,J shall decide if er1ployee can or cannot Hc.:.:.r respirator. June 16, 1972 Hr. E. N". Drislane Executive Secretary Friction Materials Stru1dards Institute, Inc. Bergen Mall Uffice Center E.210 Houte 1/4 Paramus, N.J. 07652 I. H. WEAVER. NCO~PORATE OIRE.CTOR LNVIRONMEI'ITAL CONTROL w f'l Ul --t fTl Gl fTl r Ul. ;--ot fTl _.f.T..l. :z>s:: I fTl :s:: "U zfTl z Dear Ed: Attached is my report on the past year' 1 s activities of the Asbestos Study Committee which I hope will be satisfactory for your presentation the week after next. I regret I won 1t be on hand at the meeting and certa.inly appreciate your pir1ch-hitting for me. If you have any questions or recolill!lendations concerning revisions or additions or deletions to the attached report, please call me. I expect to be in the o ff:i.ce Nonday, Tuesday, Wednesday ard Friday next week ru1d Monday, the 26th. Arter 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 reconunendations of NIOSH and the Advisory Conunittee on Asbestos Dust. I think this might be worthwhile copying and forwarding to the other members of the F11SI Asbestos Study Committee. I am not returning the form you sent me regarding the schedule for the next rneetirlg as all of the dates listed on this schedule still are open as far as I am concerned. Unless you advise otherwise I will vrait 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 reek in July and the m:mth of August. Best regards, /k~ I. E. Vi aver e FMSl 02836 FRICTION f'iL~TERIALS STANDARDS INSTITUTE, lf\IC., E-210 ROUTE r/4, PARNc~US, r~. J. 07652 BUL L ET I N ~~ 0. 4 3 9 June 12, 1972 SUBJECT: Occupat ionsl Safety S_ Health Administration Standard for Exposure to Asbestos Dust. On June 7, 1972, OSHA published their standard on exposure to asbestos dust in the work-place. Exoosure Limitations The standard remains at 5 fibers (a fiber being longer than 5 micrometers) per cc of air as measured by the membrane filter method--for an 8 hour time weighted average. This is effective July 7, 1972. As of July 1, 1976 the 8 hour time weighted average will be reduced to 2 fibers per cc of air. There is a ceiling concentration of 10 fibers per cc at any time. This new standard has details onthc use of respirators, ventilation, wetting down of asbestos, clothing, lockers, laundering, caution signs, medical exams, etc. are covered in this standard. The Institute would be happy to send a copy of this Standard to members on request. E. W. Dr i slane Executive Secretary Distribution: Active Members FMSI 02837 FRICTION MATERIALS STANDARDS INSTITUTE, INC., 6-210 ROUTE #4, PARAMUS, N. J. 07652 June 6, 1972 TO: Members of Asbestos Study Committee SUBJECT: Asbestos Fibers Emissions- Friction Materials A seminar was held at the Illinois Institute of Technology Research Institute back in April of this year. Dr. Colin Harwood of IITRI was one of the advisors to the Illinois Pollution Control Board who was in favor of the proposed 1971 regulations as wr i Hen--that is to include a ban on the11 use of asbestos in the brake lining of vehicles manufactured after January 1, 1975 and sold for use in lllinois. 11 The pages from the 1ITR1 paper are: pages 22, 25, 26, 27, 28, 46, 49, 65, 66, 67, 68, 69, 70, 71, 72, 73. Your Chairman, Mr. 1. H. Weaver, sent this data to me for distribution to the Committee. He commented on the paper: "The main issue I would have with Dr. Harwood's conclusion would have to do with whether or not the free fibers or fibrils released from friction material decomposition are truly hazardous in any way, and I also believe he tends to underestimate the problems in non-asbestos containing braking systems. 11 Your Chairman believes that a meeting of the Committee should be called. I'm asking for a reply on the attached form, for which~ not !g ~ ~ meetine. From this I will try to arrive at a meeting date (perhaps late July or late August). EWD/lmc E. W. Dr i slane Executive Secretary FMSI 02838 MEETING SCHEDULE - ASBESTOS STUDY COMMITTEE TO: Friction Materials Standards Institute, Inc. E-210 Route //4 Paramus, N. J. 07652 Gentlemen: Concerning a proposed meeting of the Asbestos Study Committee, PLEASE DO NOT SCHEDULE IT FOR THE FOLLOWING WEEKS: July 24-28,_ _ _ __ August 7-11_ _ __ August 14-18~--August 21-25._ _ __ August 28-31_ _ __ Additional Comments:_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ By_____________________ Company_ _ _ _ _ _ _ _ _ _ _ _ _ ___ Date~-------------------- FMSI 02839 ,..--:; (~Jl,.f"~'A ~""">.. I June 1, 1972 Mr. E. lv. Drislane, Executive Secretary Friction Materials Standards Institute, Inc Bergen Hall Office Center, E.2l0 Route #4 Paramus, N.J. 07652 I. H. WEAVER II NCORPORATE DIRECTOR ENVIRONMENfAl CONTROL w !'1 (/1 --i 1"1 0 fT1 r (/1 ;-o-i fT1 1"1 .:-' :;:: )> z I 1"1 :;:: 'll zfT1 z Dear Ed: The attached material concerning automotive emissions of asbestos fibre was received from Illinois Institute of Technology Research Institute yesterday and probably will be of interest to other members of the FMSI Asbestos Study Committee I suggest that you circulate it to them. 'fhis material was forwarded by Dr. Colin F. Harwood of IITRI as a supplement to information presented at a seminar on asbestos they conducted April 4 through 7. Very little attention was devoted to automotive emission sources during the seminar. The main issue I would have with Dr. Harwood's conclusion would have to do with whether or not the free fibres or fibrils released from friction material decomposition are truly hazardous in any way, and I also believe he tends to underestimate the problems involved in nonasbestos containing braking systems. Since it appears unnecessary and probably impossible to schedule an Asbestos Study Comrr~ttee meeting in June and I will be away the first two weeks in July, I think it might be prudent to tentatively schedule a meeting late in July, preferably during the last week. By that time I expect there will be a number of subjects worthwhile reviewing. If you agree, kindly canvass the other members and pick a date. As far as I know, I will be available aqtime during the week of July 24. I am also open the week after that in the event this suits the others better. Best regards, If.<iF I. H. \veaver w FMSI 02840 attachments such that the dust created is arrested at the source and collected in filter bags. Commercial devices are available but normally fir:ms w1th a sincere interest in pollution control, design and fabricate their own devices. Two examples of such ~ devices are shown in Figures 6 and 7. These control hoods work on the high velocity, low volume principle and can be readily adapted to industrial vacuum cleaner systems. When arrest-at-the-source systems are not possible, techniques similar to those employed by the asbestos spraying industry may be utilized. Rules wh1ch relate more specifically to fabrication of asbestos products may be found in such publications as: 1. "Recommended Practices for Fabricating, Handling and construction Industries," Health and Safety Council-Asbestos Cement Products Association" 2. "Recommended Health Safety Practices for Handling and Applying Thermal Insulation Products Conta.ining Asbestos," National Insulation Manufacturers Association (NIMA) . 3. The Asbestos Research Council - Control and Safety Guides (London, England) . 4o "Recommendations for Handling Asbestos," Engineering Equipment Users Association (EEUA), EoE.U.A. Handbook No. 33. 3.3.3 Friction Material Applications Typical friction ma.terials contain 30 to 50% asbestos and may be up to 70%, and the industry that manufactures these materials is ranked third (1969) in the consumption of asbestos fibers. Crysotile is the preferred variety because it has better frictional properties than amphibol asbestos and does not exert so much wear on the opposing surface. The major uses of asbestos-containing friction materials include brake linings, brake discs and clutch facings. These products have been applied to a wide variety of industrial and commercial products. liT RESEARCH INSTITUTE 22 FMSI 02841 Sources of Emission - Em.Lssion of asbestos from friction mdterials results from normal day-to-day usage. An idea of the scope of this source can be gained from the estimation that the - average automobile wears out 3 to 4 sets of brake linings, and 1 to 2 sets of ~lutch facings during its lifetime and that commercial public transport vehicles wear out many more sets. Data concerning motor vehicle brake linings for the whole of the United States are given in the following: Vehicle miles during 1968 Mileage life of brake linings Brake lining sets on new vehicles Pounds of asbestos per set of brake linings 1,010,000,000,000 27,500 10,718,000 3 Tests performed on brake linings have indicated that under conditions of normal usage, considerable alteration of I the asbestos occurs. It is reported that most ofthe dust collected from brake drums appears non-fibrous and is S.Lmilar l in appearance to thermally degraded asbestos. The suggestion is that h.Lgh temperatures at the brake lining/drum contact points actually reach degradation levels. I Tests on brake linings, brake discs and clutches have demonstrated that the quantity of fiber emitted is some function l of the severity of the braking conditions (see Table 3). How- ever, even at the level of 1%, the total emissions must be (, considerable when the total tonnage in use is considered. Further, the emissions are likely to occur at places of high [ density population and restricted ventilation. That is, in busy main streets of towns surrounded by large buildings. r The effect of different braking conditions and different types of friction materials on asbestos emissions is the subject of a study being sponsored by the Environmental Protection Agenc~ Other studies are being conducted in California and some work on roadsides has been done at Mt. Sinai, New York. The EPA J study will establish the extent and nature of the asbestos liT RESEARCH INSTITUTE i 25 T i fMSl 02842 Table 3 ASBESTOS EMISSIONS FROM BRAKE LININGS (Test Results by Electron Micrograph) .-- Procluct Rrnnd Test No, of Conditions Presence of % Free He> tl~ _ _S.;!~P les of Tcst-F Free Fibers Fiber* 1. Automobile A drum brakes Friction 6 300-800 Few <1 2. II B Friction 3. " c Friction 4. II c Friction 5. II D Friction French 6 250-800 None 0 5 300-700 Few <1 1 700-900 Numerous "'10 5 300-800 Few <1 6. II E Friction 7. " .F Friction German 5 300-700 5 300-800 Few Few <1 <1 I 8. II G Friction 2 100-500 Few <1 9. II G Friction 1 600-700 Numerous v-15 I 10. II H Friction 2 100-600 Few <1 l 11. Automobile clutch J Dynamometer 1 normal driving None 0 l 12. Automobile disk brake K Dynamometer 1 normal driving Few <5 ] 13. Bus drum brake L Dynamometer 1 city driving None 0 14. M Friction 2 450-550 None 0 J 15. Truck drum F brnke (light) Friction 10 300-800 Few <1 ] *Heir,ht estimated from fiber volume. J J 26 FMsr 02843 emitted from brake drums, disc brakes and clutches of vehicles operating under real conditions. Hopefully the situation will be more clearly understood at the end of those studies. Emission Control Techniques Emission at Overhaul - To avoid blowing the accumulated dust into the atmosphere at the time of overhaul devices have been suggested for extraction of the dust from brake and/or clutch housings by suction. Of the devices tried, a simple hand-held vacuum cleaner has proven to be the most flexible unit. Changes to the original design have been limited to the addition of a disposable paper bag inserted in the original cloth bag. The paper bag may be easily sealed before removal to pre~~nt emission. Substitution - Beyond the adaptation of better cleaning practices during brake and clutch maintenance, as mentioned above, additional controls seem to be limited to improve de$ign of brake and clutch assemblies and/or substitution of other materials for asbestos. The high temperature properties and exceptional tensile strength of asbestos have resulted in very compact and economical design. These same unique properties which make asbestos applicable to friction materials also make the application of substitute materials very difficult. The tensile strength and modules of rigidity of asbestos as compared to several candidate substitute materials follows: Tensile Strength lb/in. 2 Asbestos 550,000 Fiber yarns 180,000 Steel wool 50,000 Mineral wool 25,000 Modulus of Rigidity lb/in. 2 30,000,000 3,000,000 100,000 60,000 There is no doubt that substitution of other materials for asbestos is possible, but the design changes required to accommodate the stresses and temperatures involved would result in liT RESEARCH INSTITUTE 27 FMSI 02844 larger, more expensive components. Brakes - The recent adoption of disc brakes by the automotive industry makes material substitution more plausible. Disc brakes are capable of greater energy dissipation than similar sized arum brakes because the design results in considerably lower heating rates. This is due to the fact that at any one time the friction pad contacts only a section of the disc surface. The lower operating temperatures permit the use of friction materials which do not contain asbestos. Another feature of disc brake design which has reduced the need of asbestos materials is the lower strength requirement of the friction material. Clutches - The substitution of other material for asbestos in clutch facings of traditional design could only be done by changes in size and design. Two changes in clutch design which have reduced the requirement for asbestos-containing friction materials are the advent of the automatic transmi~sion and the redesign of manual clutch friction surface. The clutch surface of the automatic transmission is immersed in an oil bath which virtually 1liminates airborne pollutants. Further, the cooling affect of the oil bath reduces the requirement for high-temperature capability materials. Automatic transmission clutch facings may be made from either sintered metals or fibrous cellulose materials. Many manual clutches have redesigned friction surfaces which consist of numerous small circular pads or discs attached to the clutch face as opposed to the standard annular ring friction surface. These small pads act in the same manner as the disc brakes friction pad. Thus, lower stresses and operating temperatures associated with the new design reduce the need for asbestos-containing friction materials. liT RESEARCH INSTITUTE 28 FMSI 02845 -10. SPECIFIC PROBLEMS 10 1 Emission Levels In understanding control techniques and their efficiencies, it is important not to be confused with efficiencies quoted-on ~ a. weight basis ~nd those based on a particle count basis. Firstly, considering efficiency based on a weight basis, it is relatively easy to get a very high efficiency with particles whose size is in excess of 5~ with a variety of control devices (see Figure 10). However, the efficiency does drop off considerably with decrease of particle size, for example, see Figure 11 for 1~ particles. (It should be noted that these graphs refer to spherical particles - information on fibrous particles is not presently available.) Now consider what these apparent high efficiencies mean ( in terms of numbers of fibers. It can be assumed that 103 average fibers of asbestos weigh approximately 1 ng. [ If 1 g of asbestos material approaches a filter rated at even as high as 99.999% efficiency, then the quantity passing through will be 0.00001 g, or 10 4 ng. A- nd since 1 ng ::!:= 10 3 [ .fibers, then ~ total of -1-07- fibers will pass through the filter for every 1 g of material impinging upon it. [ This is a situation not frequently brought out, but is very significant when exposure levels are monitored in terms of I fibers per cubic centimeter. Thus the quoting of efficiency in terms of mass efficiency is a "red-herring" statement that flatters to deceive. It bears no obvious relation to the number of fibers being emitted. However, based on tests which actually measure the number of fibers being emitted, it would seem that both fabric filters and high efficiency wet scrubbers are capable of reducing the fiber counts to acceptable levels. British experience is that I 0.2 f/cc is routine and Johns Manville finds that 1 /cc is an acceptable value when the results are averaged over a time I period. liT RESEARCH INSTITUTE 46 FMSI 02846 l l The medical evidence as to the size of fiber responsible I for adverse health effects is not positive nor is the question of whether fibrils of fibers are most hazardous. Until the medical questions are fully resolved, it would seem premature to impose inflexible or overly rigid regulations. I I I This has been the view held by the Federal occupational health authorities in assessing their standards. It would seem I that thei approach in limiting exposure to that which is possible using good modern technology is sensible. The same may be l said for their monitoring techniques. ! 10.2 Water Pollution Recycling of waste water is possible and is practiced in J certain segments of the industry. The question of the damage I' done to streams, rivers, and lakes by indiscriminant dumping of asbestos containing waste waters needs careful study. Ol}.e must remember it is a natural material which will appear in water in any case. On the other hand, there is evidence that '[ asbestos particles ingested into the stomach may cause stomach cancer. t Again, until medical evidence is clear, it would seem r sensible to recycle water whenever this can be accomplished. ~ 1 liT RESEARCH INSTITUTE 49 FMSI 02847 ...... -.... /' ASBESTOS AIR POLLUTION RESULTING FROM THE WEAR OF BRAKE LININGS By Colin F. Harwood, Ph.D. ABSTRACT Asbestos containing brake linings have been cited as a source of ambient air asbestos pollution. This paper reviews the suggestion and an estimate is presented which indicates that the asbestos emission from brake linings is significant. The ways in which this emission may be reduced or eliminated are briefly reviewed. IIT RESEARCH INSTITUTE ro West 35th Street Chicago, Illinois 60616 Ill RESEARCH INSTITU.TE 65 FMS\ 02848 ASBESTOS AIR POLLUTION RESULTING FROM THE WEAR OF BRAKE LlNINGS INTRODUCTION Recent interest in asbestos and the realization of its health hazard have raised the question of the extent to which people are exposed.to asbestos on a non-occupational basis. Measurements have been made on urban background levels and it has been shown that small but definite concentrations are to be found in areas quite remote from any apparent source. Since virtually every motor vehicles carries several pounds of asbestos contained in its brake linings and since these are worn away to some degree every time the brakes are applied then it is reasonable to expect that they could present a significant emission source. This is especially acceptable when one considers r ;'. the 100 million or so vehicles on the nations roads. The paper investigates the possible extent of such emissions r and presents an estimate of the contribution to urban asbestos concentrations. Possible means of reducing such emissions by r use of an alternative or sealing the system are briefly reviewed. The Extent of the Emission r The best information available at the present time1 2 indicates that the percentage of asbestos contained in the dust ( normally emitted from brake linings is of the order of 1%. However, under conditions of severe breaking, this may rise to 15%. The average brake friction material contains of the order of so~~. asb es t os, thus an explanation is necessary to account for the discrepancy between the measured and theoretical values. The most likely explanation results from the known facts with regard to heat generated at friction surfaces. The work of Bowden I and Tabor 3 has shown that when two surfuces ure placed together the contact area is dra1natically less than the apparent area. Ill RESEARCH INSTITUTE 66 FMSI 02849 This means that very large energy transfer takes place at thes~ contact points and extremely high temperatures are reached. In the case of brake linings, some evidence of these tempc:cCJtures has been generated in unpublished. work by the GcnerDl Motors CowpCJny 4 In this study, a small hole was cut through a brake shoe and the radiation collected from the exposed shoe surface was monitored. The results suggested that under light braking temperatures of the order of 800-900C were found, while during heavy braking the temperature reached l700-l800C. The significance of this data to the present case is that it is known that asbestocj decomposes above soooc5 to give forsterite (Mg 2sio4 ), talc (Mg 3 si 4o 10 (0H) 2) and water vapor. Acceptance of the value of 1% of asbestos emitted allows an estimate to be made of the effect of this emission on the quality of the atmosphere. Estimation of Urban Concentrations of Asbestos From Brakes a. There are approximately 100 million* motor vehicles. b. Motor vehicles have an approximate average weight of 4 lbs of friction material, when nevl, of which 50% is asbestos. c. The average motor vehicle will require replacement of the brakes after three years of use at which time they will have lost 50% of their weight by abrasion. d. The dust emitted will contain 1% of asbestos fibers. e. Of the ~ear dust, 80% is emitted and 20% is lodged within the system. *The AAA claims there are 109,000,000 licenced vehicles including 90,000,000 passenger vcl1iclcs and 19,000,000 trucks. Ill RI:.SEARCH INSTITUTE 67 I ! FMSI 02850 calculution The total weight of brake linings in use is 100,000,000 2000 X 4 = 200,000 Tons. 'fhe quantity worn off these linings per year follmvs from the assumptions made in c. t 1 0 6as 200,000 x x ~0 = 200 00 Tons/yr. This wear dust contains 1% asbestos, hence emission is 2006000 x l~O = 20~0 Tons/yr. Allowing for the fact .that 20% is not emitted, the total emission is thus 2000 80 6 X 100 270 Tons/yr. Effect on the Atmosphere l There are no facts relating directly to asbestos on \;hich one may judge the effect of these emissions on urban air. l However, there has been a considerable amount of study done on the diffusion of other materials from automobiles, particularly l lead and carbon monoxide. At a recent ACS Symposium in Ninneapolis6 evidence was presented which placed the level for l lead emission at 0. 01 llg/m3 in Thule, Alaska and 2. 5 p.gjm3 in New York City. Next to busy highways a level in excess of SO pg/m3 maywell be possible. In the light of this data the value of 2 jlg/m3 for. average urban air conditions, suggested by GM 4 , seems eminently reasonable. Considering that 5 1.25 x 10 tons of lead are emitted in total from automobiles then the following factor is used. I Avg. Cone. asbestos Quantity of 2 Jl.q/m3 city air I in city air from automobiles asbestos emitted x 1.25 x 105 tons Pb from cars Applying this figure to the present case and assuming that 1 200 to11s are emitted in city areas, then we get that: I Ill RlSEARCH INSTITUTE 68 i FMS\ 02851 The avg. cone. -'L J'L.. JL --""'- or ~ ~ 200 X _ _ _5 _ ._ _ 1. 25 X 105 3.2 X 10- 3 J..Lg/m 3 3.2 X ng/m3 A similar result is obtained using the dispersion factor for carbon monoxide. However, the values for lead are preferred since it is a particulate emission rather than a gas. Th~~i9~if!.~~nce~~f_Th!~_Y'~lue The question of whether asbestos containing brake linings constitute a significant source of ambient air background, asbestos levels can now be considered. Firstly, it is pertinent to review the available evidence on asbestos levels in &~bient air. Perhaps the most up-to-date information is reported in a recent paper by Thompson and Morgan of the EPA7 Their data suggests that values 0.5-15 ng/m3 are appropriate to urban sites, while 0.1 ng/m3 is to be found in nonurban sites. They give a figure of 0.01 ng/m3 for remote sites. The California State Health Department in collaboration with the School of Public Health, Berkeley, California, have tested ambient air for asbestos. Their results suggest values of 0.06 ng/m3 in remote sites and 3 ng/m3 near a source. Nicholson and Rohl8 of the Mt. Sinai School of Medicine have also been active in the measurement of asbestos in urban ambient air. The analysis of a large number of samples has revealed that 33% of the srunples contained 0-0.9 ng/m 3 , 55% contained 1. 0-5.0 ng/m 3 and 10% contained 5-20 ng/m 3 and a few were in excess of this. All of the workers have been at pains to point out that the results are to be considered preliminary. Thus they should be regarded not as final definite figures, but rather as good, II T RESEARCH INSTITUTE 69 FMSI 02852 considered, preliminary findings. The similarity of the figures reported by the various workers does suggest that at least an order of magnitude has been established. con~ider now the estimate of 3.2 ng/m 3 calculated pre- viously as the contribution from asbestos brake linings. Firstly, it should be stated that this figure is a conservative estimate and allowance has been made for the many factors which could reduce this figure. Secondly, although there is no reason to doubt the factor for the ciffusion of lead, it should be realized that l f this figure is an average value for the whole of the city air. f Consequently, much higher concentrations are to be expected in ; certain areas of high brake usage. For example, near intersections, tollbooths, etc. .I In the light of the evidence here presented, one must i conclude that asbestos emitted from brake linings may be a major contributing factor in the overall ambient air concen- l tration. l Further work is necessary to establih more definitely Ii the major contributors to urban asbestos concentration levels. It is not possible to state with assurance how much these ~ low concentrations of asbestos constitute a threat to the health of the general public. Medical evidence and opinion is widely ~ divergent on this issue. However, asbestos has been rated as a hazardous substance by the EPA and as such it should be treated with due respect. Emissions should be reduced or curbed ;I wherever this is possible. To this end it is worth briefly ! i reviewing how this may be achieved. ~ :r~~ii_t:~0LOGY OF ELIMU~ATING EMISSIONS The emission of asbestos to the atmosphere from asbestos containing brakes could be prevented in two ways: its use could be ~ ll.onncd altogether, or, the brakes could be sealed. In the case, an alternate would have to be found. liT RESEARCH INSTITUTE 70 I -,I I I i FMSI 02853 .' -A-l-te-r-n-a-ti-ves to Asbestos For a replacement to be as suitable as asbestos, it would have to fulfill a list of desirable features as: Resist high temperatures without degradation or loss of frictional properties. G Combine excellent friction characteristics without severe abrasion. Provide great strength - asbestos fibers have a greater tensile strength than steel and yet are more flexible. Have relative economy. Of the materials which have been considered, sintered metal with ceramics and fiberglass have been the most likely candidates thus far. ~i~te~~q-~~~al - This material has been used and indeed has t.he desirable quality of being fade-free, for this reason it is still used in some racing cars. Hov,eyer, it has several diEOadvantages. It tends to be noisy and brake screetch is a problem. They suffer from what is known in the trade as "morning sickness", this means that the first stop is very severe, or, that the cold friction is high. Wear is higher than with asbestos and thus the brakes have to be replaced more frequently. Replacing the brakes is more difficult since all brakes are honed to fit the drum. Honing metal is more difficult than asbestos friction material. Ce~~iE_~~~~l_(Ce~~~ts) - A sintered metal and ceramic composition has been developed and tried. Its use at this time seems to be restricted to the clutches on heavy-duty vehicles (tractors, etc.); in these cases it is usual to use I buttons of the material rather tl1an a complete annulus. l\1 though to a lesser degree, it suffers from the same complaints as sintered metal with respect to noise, \~ear and severe first stop, and in addition, it is relatively expensive. However, I liT RESEARCH INSTITUTE I 71 FMSI 02854 its anti-fade characteristics have led'to extensive testing. For exrunple, the Ford Motor Company put inserts of ceramic metal at the position of maximum brake wear on their 1958 Thunderbird. The concept was abandoned, reportedly due to uneven braking leading to a directional pull when braking. '" KiP~~gl~~~ - Attempts to use fiberglass instead of asbestos have been attempted since 1938. So far, no design has met the exacting standards required. As with the other materials, the first stop is harsh. Apparently the design is better for disc brakes than drums. A problem is the sensitivity of the brake to moisture. Owens-Corning are undertaking development research in this area. They are very guarded with regard to the status of their work, but state that they are actively engaged in developing a product. To date, no vehicles are known to employ fiberglass in their brake friction product. I Sealed systems have been seriously considered. Normally, cars rely on air cooling and the movement of air round the brake caused by the motion of the car. However with high I performance cars, more cooling is required. This is achieved in a simple manner by fabricating a superstructure which lr scoops up air and directs it inside the brake drum. If a filter were added on the exiting side, this would cause a substantial reduction in emissions. II A more elaborate design which has been used is to liquid ~i cool the brake system. This enables the braking system to be completely sealed and thus no emisf'ion are possible. The one problem area with this design is that the oil seals must be extremely reliable. However, with a well designed system 1 Problems due to overheating could be largely eliminated. liT RESEARCH INSTITUTE 72 FMSl 02855 ... CONCLUSIONS An estimate has been made of the asbestos concentrations to be f~und in urban air resulting from the use of asbestos containing brake rna te:t;ials. The results indicate that brake 1} use may well constitute a major source of asbestos background levels. The quantity in comparison to occupational levels 1 is extremely low. A time weighted average occupational exposure level of 5 f/cc would be of the order of 100,000 times l greater than a background level of 3.0 ng/m3 The medical significance of these results is not known with any certainty. 1 At the present time, no alternative to asbestos containing friction ~roducts is developed to the stage of finesse I required by the industry. It is difficult to believe that modern technology cannot overcome the problems presented by I the use of alternates. The use of sealed brake units is a second possibility. I Again there do not seem to be any insurmountable technological problems, but no information is available as to the cost I and time factors. I I I I I I I liT RESEARCH INSTITUTE I 73 FMSI 02856 FRICTION '~ATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE t4, PARAMUS, N.J. February 29, 1972 TO~ MEMBERS (as 1 i sted) SUBJECT~ MEASUR8JlENT OF AIRBORNE ASBESTOS FIBER BY THE MEJ\,18RANE FILTER METHOD As indicated in earlier correspondence, we are distributing one copy each of "Measurement of Airborne Asbestos Fiber by the Membrane Filter Membrane Filter Method", to the members for their information. If additional copies are needed, please contact the Asbestos Textile Institute. E\JD/lmc cc~ E. Feierabend s. Comins M. w. Jacko Simon J. Graham E. Koss R. l<ick L. Carreras F. Gatke \I Rei tze T. La her J. Greenen - Abex - Auto Friction - Bendix - Rrassbestos -Carlisle - Chrysler - Delco-Moraine - Forcee - Gatke - Johns-L1anville - Lasco -Grizzly E. \'1. Drislane Executive Secretary M. Frazier I '.'Ieaver F. Barton \'J. Sleeth A. Daly A. Roentgen J. Allen \'1. Richards c. Cawley R. Brigleb L. Burgess J. Henning -- Molded Industrial Raybestos - Reddaway Royal - Scandura -- Silver Line -- Standco Thiokol - Thermoid - FJel1man -- \'/heeling Wor 1d Bestos FMSI 02857 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 RTE #4, PARAMUS, N.J. TO: MEMBERS (as listed) February 25, 1972 SUBJECT: ASBESTOS SEMINAR-- liT RESEARCH INSTITUTE- CHICAGO This memorandum is being sent to those in member companies directly associated with the asbestos regulations, and where a member has not indicated such an individual, to the Delegate. Dr. Harwood of liT is organizing a seminar in Chicago the week of April 4-7, 1972 on asbestos regulations, etc. If you, or someone in your firm is interested, I suggest you complete the application for attendance, with the fee, and send to Dr. Harwood. The Friction Materials Standards Institute has nothing directly to do with this seminar, and is passing the information along to members for their information. EWD: 11 z cc: E. Feierabend s. Comins Mw.. Jacko Simon J. Graham E. Koss R. Kick L. Carreras Fw.. Gatke Reitze T. Laher J. Greenan E. 'N. Drislane Executive Secretary - Abex -Auto Friction - Bendix - Brassbestos - Carl isle - Chrysler - Delco-Moraine - Forcee - Gatke -Johns-Manville -Lasco - Grizzly M. Frazier J. IJeaver Fw.. Barton Sleeth A. Daly A. Roentgen Jw.. c. Allen Richards Cawley R. Brigleb L. Burgess J. Henning - Molded Industrial - Raybestos - Redclaway - Royal - Scandura - Silver Line - Standco - Thiokol - Thermoid - Wellman - Wheeling - World Bestos FMSt 02858 FRICTION MATERIALS STANDARDS INSTITUTE, INC. , E21 0, ROUTE /,14, PARAMUS, NEW JERSEY BUL L ET I N N0 4 2 8 February 18, 1972 To: ALL MEMBERS SUBJECT: Demonstration- Membrane Filter Method for Airborne Asbestos Measurement By: W. Re itze, Johns-Manville Corporation. By earlier bulletins, the membership had been advised that Mr. W. Reitze of Johns-Manville Corporation would give a demonstration on the standard method for measuring airborne asbestos fibers. Mr. Reitze made this presentation on Thursday. February 10, 1972 at the Institute Office in Paramus, New Jersey. Those AHendine: J. Greenen, President of F.M.S. I. ) ) R. Hemmelgarn ) K. Barnhardt ) J. Henning J. Graham M. Jacko - W. Richards W. Reitze E. W. Drislane Maremont Corporation Grizzly Brake Division World Bestos Company, Division of The Firestone Tire & Rubber Company Carlisle Corporation Molded Materials Division Bendix Corporation Friction Materials Division Thiokol Chemical Corporatio~ Johns-Manville Corporation Friction Materials Standards Institute, Inc. fvlEASUR ING AIRBORNE ASBESTOS FIBERS Mr. Reitze discussed the earlier lmpinger Method (no longer accepted) where the air sample is passed through a glass tube bubbler and the fiber is trapped with a subsequent count of fibers. The currently accepted method calls for measurement of airborne asbestos fiber by the membrane filter method. Briefly, the pick-up is worn by a worker in the area to be measured with a small battery operated vacuum pump taking in air over a specified period- of different times, say (JJ minutes; 90 minutes, or four hours. The asbestos fiber is trapped by the membrane filter and then carefully sealed and sent to the laboratory. The sample is examined using an optical micro- scope where a count of fibers is made. The details of the test are described in: "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method" published by the Asbestos Textile Institute. Asbestos Textile Institute P. 0. Box (/239 Pompton Lakes, New Jersey rl07442 (Price $1.00 per copy) The Institute has ordered copies and will send one to each Delegate. If additional copies are desired, it is suggested that the member order the copies directly from the Asbestos Textile Institute. FMS\ 02859 Bullet in .~428 -2- February 18, 1972 Mr. Reitze's demonstration will not be detailed as the booklet mentioned covers the equipment and procedures i~ detail. COMMENTS AND SUGGESTIONS The cost of pad and filters inserted are 70 per piece, from.Millipore Corporation, Bedford; Massachusetts #01730. It is suggested that four to six pumps (costing about $150. each) be used so that a supervisor ce.n monitor more than one test at a time. A battery charger will cost about $50. One should have one charger for every two pumps. Seeding (or sabotage) when a worker throws additional asbestos to the intake may ordinarily be detected when the sample is counted under the microscope, but additional tests may be necessary in the same area with different workers. A pump could be mounted in a fixed position near the work place but the proper method is to have the pu~p attached with the intake facing down near where the worker breathes. A binocular microscope with phase contrast illumination set for 400/4~0X magnification is required. A Bausch and Lomb microscope costing about $1,200.-1,500. is the basic instrument. Binocular microscopes with additional features could well be worth the additional cost, but professional advice should be used in the selection of equipment. 8UTSIDE SERVICES AND TRAINING It may be feasible to have outsiders do the full job- from sampling through examination and reporting. Others will do the analysis work only where the samples are mailed to the laboratories. Tracerlabs in California will do analysis work for about $50.-60. per analysis. Johns-Manville will do the full job for a fee (Contact Mr. W. Reihe, Manager Industrial Hygiene Engineering Service, Johns-Manville Corporation, P. 0. Box #5108, Denver, Colorado #80217) George.Clayton Labs, Southfield, Michigan will do the full job for a fee. There are other labs that may do the entire package or the analysis work only. Johns-Manville indicated it would be willing to train personnel in the tech- nique in a two day period. They would take one traine~or at most two trainees, to one instructor for $200. a day. These sessions would be at Phindern (Somerville) New Jersey or Waukhegan, Illinois. Again, the contact would be with Mr. Reitze in Denver. It is suggested that the members familiarize themselves with OSHA's proposed standards. A copy of these standards, as issued in the Federal Register on January 12, 1972, is enclosed with Bulletin #'427: - Asbestos Study Committee Delegates & Alternates British Friction Materials Council AIA/NA and L. D. Stickles, Counsel E. W. DR ISLANE Executive Secretary FMSI 02860 Room 512 ~riclion material StandarJd .!Jndtilute, .!Jnc. 370 LEXINGTON AVENUE NEW YORK, N.Y. 10017 MUrray Hill 3-0572 January 26, 1972 To: Members of Asbestos Study Committee Subject: Meeting February 10, 1972 Gentlemen: In separate correspondence, I have indicated that Mr. W. B. Reitze of Johns-Manville will give a session on monitoring asbestos fibers 1n the air. This session, at which S-10 people have indicated that they will attend, has been scheduled at the new Institute Office in Paramus, New Jersey for 1:30 P.M. on Thursday, February 10, 19?2. As some of those planning to attend this 1:30 P.M. session are also members of the Asbestos Study Committee, it is felt that this is an opportune time to schedule a meeting of this Committee in the morning. While some items on the agenda will be historical- the Illinois Pollution Control Board hearings, Environmental Protection Agency Proposed Emission Standards, and Occupational Safety and Health Act Standards-- the main item for the Committee to consider is the direction it wishes to take. Should it get involved in commenting on proposed requlations concerning asbestos, or should it serve more as a monitor to keep the membership advised? ~ ~eting is scheduled for: 9:30 A.M., February 10, 1972 at the new Institute Office in Param~s, New Jersey. Fot help in find;ng the new office, a 7 page "publication11 is enclosed concerning our new location. Sincerely, EWD/erc Enclosure: E. W. Drislane Executive Secretary Messrs. l. H. Weaver J. C. Henning E. H. Feierabend W. B. Reitze W. Spurgeon J. B. Graham, Jr. l. D. Stickles, Counsel Raybestos-Manhattan, Inc. Firestone Tire & Rubber Company Abex Corporation Johns-Manville Corporation The Bendix C.?rporation Carlisle Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh FRICTION MATER1ALS STANDARDS INSTITUTE. INC. E 210 ROUTE #4 PARAMUS, N.J. #07652 January 14, 1972 To: Members of the Asbestos Study Committee Subject: Department of Labor -Proposed Standard for Exposure to Asbestos Dust. I am attaching a copy of the proposed rule making on Standard for the Exposure to Asbestos Dust. This notice appeared in the Federal Register of January 12, 1972 (466-468). This is forwarded to the Committee members for their information. Edward W. Drislane Executive Secretary Messrs.: I. H. Weaver J. C. Henning E. H. Feierabend W. B. Reitze W. Spurgeon J. B. Graham, Jr. J. W. Greenen, President L. D. Stickles, Counsel Raybestos-Manhattan, Inc. World Bestos Company Abex Corporation Johns-Manville Sales Corporation The Bendix Corporation Carlisle Corporation Maremont Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh FMSI 02862 American Brakeblok Division 900 WEST MAPLE ROAD. TROY, MICHIGAN 48084 JanuaryL IA!,,dan:L9s12 British Friction Materials Council 99, Aldwych London, WC2B 4JY Gentlemen: Your letter of December 8, 1971 addressed to the Society of Automotive Engineers regarding your views on the proposed Illinois State Regulations concerning asbestos products, has been fOrwarded to me. I apologize fOr the somewhat slow acknowledgment of your letter but wanted to discuss it at our SUbcommittee meeting which is held during the SAE Annual Congress in Detroit. We appreciate very much your comments and some of the attached information was new to us and of considerable interest. There are, however, two things with which you should be aware if you have not already been advised. First, the Illinois Pollution Control Board has withdrawn the proposal covering the banning of asbestos in brake lining. This was due principally to the fact that a number of brake lining manufacturers presented data along the same lines you furnished in that there is insufficient proof that products of wear from asbestos brake lining do cause any harmful levels of pollution. The second fact that you probably are not aware of, is that the Society of Automotive Bngineers do not comment in any way on any proposed legislation. The position of SAE is quite simple in that their task is to develop recommended practices and standards which are for the use of anyone including government agencies. They definitely do not take any stand or any position with regard to any proposed or actual legislation. This very firm policy is the reason why SAE would not forward your comments to the Illinois Pollution Control Board. As it turned out, because that proposal covering the use of asbestos in brake linings after 1975 was dropped, it was not necessary to forward this information. I am taking the liberty of sending a copy of your attachments to the Frietion Materials Standards Institute, Inc., as they were active and instrumental in getting this proposal removed. I am sure they will be interested ~n this data for their files. In the future when you have FMSI 02863 British Friction Materials Council - 2 - January 14, 1972 comments regarding legislation dealing with brake linings I would suggest you direct ycur comments to that organization. I am also taking the liberty to send a copy of this information to Dr. M. G. Jacko of Bendix Corporation, who is doing work along this line and is the representative from the brake lining sUbcommittee on the SAE Particulates Committee studying the amounts and the effect of asbestos in the air. Thank you again ~r your interest and comments, and if we can be of any further help please do not hesitate to get in touch with us. Sincerely, REN:nm /f::~:l/t~ ~ E. Nelson Chairman SAE Brake Subcommittee 2 cc: Messrs. L.P.Ziegler, Jr. SAE -Detroit E.W .Drislane Friction Materials Standards Institute, Inc. Bergen Mall Office Center (new address) E. 210, Route 4, ~aramus, New Jersey 07652 Dr. M. G. Jacko BendiX Corporation - ResearCh Lab. 20800 Civic Center Drive Southfield, Michigan 48075 FMSI 02864 BRITISH ,.- ---- \ \-ir,_\t. _ '. / \ : ~)1\_i.l .\ ~llATE~;~cs CouNCIL BAKER, ROOKE & CO. CHJ...RTEUI':D AccouNT"NT:s 'TLLEPHOt<E; 01242 0211 362/rn/llFI !C The Society of Automotive Engineers, Inc., 2 Pennsylvania Plaza, New York, N.Y.10001, U.S.A. WC28 4JY 8th December, 1971. Dear Sirs, \~e have been asked by our members in the British friction materials industry in the U.K. to put their vieus to you on the proposed Illinois State Hegulations concerning asbestos and asbestos products. \~e enclose herewith their comments on the frictj_on material aspect of these draft Regulation">. \-Je have no doubt that the American lining manufacturers will be malcing stron,c; representations to the Illinois authorities for ar:~endwents to the proposals and \-le shall be grateful if you could make our views known as set out in this enclosure. i< Secretaries Enc. FMSJ 02865 PHOPOSLlJ ILLINOI.:.; ~r:...,ATE BAN ON ~B.r..~/1\);j-jik):t;D di-l.ni~E LININGS The firiti6h friction materials industry views with deep concern the proposed ban on the use of asbestos in brake linings by the ~tate of Illinois. It is notaware of any medical evidence that could possibly justify such legislation. On the contrary it would have the effect of withdrawing from the nw.rket products that were used to promote road safety, without producing any sienificant improvement in the levels of urban atmospheric pollution. It would expect ru1y of the known alternatives to asbestos to produce general particulate pollution of a measurable runount. 1. Whatever materials are used for brru<e linings the current state of the art ic cuch that the action of braking will generate products of weur. The asbestos content of conventional brake linings is almost entirely converted by the action of braking into forsterite or other amorphous, inert materials which are no longer asbestos. On the other hand, if non -asbestos alternatives are used (e.g. iron powder, sintered metal, ceramics, steel wool etc.,) the resulting wear products wii..l be releru;ed unchanged. 2. Measurements have been made of the amount of free asbectos fibre left in brake lining dust. It is an insignificant proportion of what is in any case a minute runount of total dust. The amount of free asbestos fibre that has been found in brake lining dust from vehicles, is about 1% of the total products of wear. (1), Indeed estimates vary down to 10-9g/g, i.e, for each grrunme of wear products only 1Q-9 grammea of free asbestos ma;r may remain. 3. We assume that the risk of contracting mesothelioma is the principal cause of environmental concern - there is clearly no possibility whatever as a result of vehicle braking, of a community risk of asbestosis or lung cancer, which are solely occupational risks. For technical reas.ons only chrysotile asbestos is used in the manufacture of brake linings nnd disc brake pads. This is not the type of asbestos with which mesothelioma has been mainly associated. 4, Measurements of chrysotile asbestos in the runbient air in an inqustrial centre in the United Kingdom have shown that the level must be less than 10-? g/m3 because of the limitations of the method used . This means that they must be a thousand times lower than the British Government acceptable level for occupational exposure. Current investigations using a more sensitive method indicate levels of 10-9 to 10-10 g(m3, i.e. 2 or 3 ordera lower still. (2). Brake lining wear cannot therefore be a serious source of atmospheric pollution. 5. In one of the largest brill<e testing laboratories in the world, housing many dynamometers engaged 24 hours a day in wearing away friction materials, the average monthly asbestos count is 0.2 fibres /cc, a tenth of the British Government's occupational standard. Footnotes 1. Hickish D,L, and Knight K.L, (19?0) Annals of Occupational Hygiene Vol.13, No.1, page 20. Letter to Nature attached. I .I British Friction Haterials Council 26th November, 1971 FMSI 02866 T. !;J'TUHE VCl ~3<'1 NOVEM!JER 1:l 1~7i 93 / Chrysoti}c Asb.:stos i:tl Urtan Ai.t THr 1mlu~tnal 11~e of chrysotdc a~bcstos is incn:.~su~~ and th~ question of whether its concentratiOn m urban air constllutes a h.:l7ard has been raised. But rr.c.:~surcmems oi asbestos in air ncar a~bc,tos factori<'s have proved ne,~ative with prc\cnt analytJC<~l mcthmb, so umkr the 'ponsor;hip of the Asil~~t<lsis Re~.cilfdt Cutu<cil we arc (Jcvcloping <t more ~cn,itJve tc..:lmiqth.!. Th1s artie!.: 1S a prcli!llinary account uf the estir.1at1on or chryso!ile ncJr a large. asbestos textile factory at Roclld:~k. Lancashir::. There arc several uncertainties in the tcchni<:u~. so we. were, expecting to obtain only an c.rdcr of n.1agnitude estimate. Nevcrthci~,s this would l:;,vc b~en an impo;ta;lt figure to have because of the li1CJ.. of d:na on the amour.t of asbestos in a1r. As it happened, we were only able to dckrminc an upper limit for the chrysotik concentration '' hich turned out to be three orders of ma[:nitude lc1\\W than the thre>hold value for occupatirm;JI exposure sc: by asbestos regulation\. Obviously even more scnsiti\C: tc.::hniqucs are required and arc now being developed. We used an X-ray diiTraction technique based on the measur..:ment of the integrated area under the (002) peak of chryso:ilc. The equipment, which consisted of a Phillips 1010 ~;cner<ilor, a vertical goniometer with a step scanning attachment. and a proportional counter with pulse hc1ght discrimir.ation, could be rdiably calibro:.ted tfo,~n to 10 fl of chrysot!le comrrcd with lhe I to 10 mg range rcpor:cd by Cr::ble', Jr.d '.\as crosschecked by c>tim;Jtlflg thcm<\gncsium comcnt of the callbration samples by atomic absorption spectroscopy. Sampling involn:d the col!Cction of airborne solids from 1,000 m' ( 10~ l.) uf air by an electrostatic Jevicc (H. Litton Systems Inc.) in which up to 10,000 I. min - are drawn throu~h a ::!0 kV corona disch;q:" Particks in the air are elcctrostath.:ally precipitated onto a pl:lt<! and concentrated into - I00 mi. of liquid. The collection cfiicicncy depends on tho: size distribatiop of the particles and the sampling rat~,;, but the size di~tributicn pr chrysotile in the atmo,phcr.: is not known. Th~refore we estimated the collection cflicicncy indirectly by running the sampler in part of the asb-:stos factory where a low ~onccntra tion of a~be~tos j, known to occur (hg. I) and v.c found the collection cflicic:Ky to be almmt JOO~~ when the air is sampi<:d at about 2,0Q.'J 1. n~in- 1 ~ Ji.:.1pp;f6 to betw~:t:n 25 anJ 50~'~ al the rate of 10.0')0 I. 1:1i:1 , tlcp~ndinf! on the actu:.ol si1c dJstributicn prcscn:. As ~,e wcr~ aiming ::t only an orJcr of m;;.~;ni- .-- ; FMSI 02867 94, NATURE VOL. 23-1 NOVCMOER 12 1971 :z,: ~1.!0 .l! $ .ttoo -3'~; .;~. .!0 ' 20 0 ~ Hl Pumping speed (103 I./min) Fig.. 1 Obsened amounts or chrysot1!e in 5,000 I. of faclory air. sampled at d!ll"crcnt rates. turfe assessment of ~sbcslos in urb~n ::! ir, we \vcre prepared to nc.~..::pt this uncerrain!y in the colk:.:~ion eflicicncy. The map (Ftg. 2) and Table 1 show the locotion of the sampling sites and the conditions in which ll1c sJmp~r-s wer~ obtained. The factory is in a hollow, and samp!tn~ sire Na. ~ is at the same height as the roof of the filter GJikry, v:hich is the chief air o t from the f.:1o,;io:-y. SJmpli11g site No. 1 is about 30 foot hrghcr than site No. 2. Sites J and 4 were in the gardens of houses, site 3 being about S km upwind of the factory and site 4 bein about )00 111 downwind. AU the diffraction IDees (for example, Fig. 3) contained strong lines of kaolinite and quartz, probably from the local soil, which made the assessment of chrysotile dil~lcult because the broad (001) line of kaolinite (7.18 A);, dc>e to the major (002) line of chrysoti1e (7 .36 A). Fortunately chrysotile is easily decomposed by boiling in I N hydrochloric acid wherea. kaolinite is unaffected, so it should be possible to mea~ure th;! amount or chrysotilc present by suhjcctir!g: the samples to acid lcJching and measuring the cornsponding reduction of the intensity of lhc composite X-ray band. The fact that tilis process led to no reductions in banJ in.tcnsity for any of the samples ir.dica:ed that the amount of chrysotile present was below our detection limit. We ought to have been able to detect 10 pg of chrysotile by jtself, but clearly the presence of kaolinite may have reduced D.He (1970) April22 Apr;J 24 Apr;J 27 April29 Moy6 Moy 13 May 28 May 28 May 30 May 30 June 3 June 10 Jun~ 10 October 23 October 23 October 23 October 28 October 28 October 28 Sl!C WmJ W~;\lllCI I I I I I I 3 3 4 4 2 2 2 I I I I I I SW modcr;'!IC SW~Iichr NE moJcr.ate SW moJerJte S !lronc N fresh \V]Jghl Wlight Wlight WJir.ht sw light SWslight sw sl!cht 'V modcrJie W mudera!c: \V modcrJtc N lir.ht Nli!!ht N light Jlr~1f..C'n dou;1 Groufld h;11e G1nund h:ue Ground h.lte Ground haze Ground h;llc Overc.1st, dull Overcast, dull Overcast, <lull Overcttst, dull Overcast llcat h:~ze Heat hau D;okcn cloud Broken cloud Broken cloud Broken clot1d Broken cloud Broken cloud the sensitivity. But 1he addition of 100 pg of chrysotilc to our collected samples could easily be detected. so we can say that our samples colkctcd from I,000 m' of air contained less th:m 100 JtZ of chrysutile--in other words, there was less than O.l ltg of chrysofjlc perm_, of air. The threshold limit for occupatJOnal expusurc set by the 1969 Asbestos Regulations is 0.1 mg m _,. JO 20 10 "28(CuKa) Fig. 3 X~ray diffraction pattern from a typical dust sample near the Rochdale iactory. , Fig. 2 Plan or T.U.A. factory, Rochd:~I~. The S:lir.i?lir.~ :;itcs arc indic.:.lcd by lhc arrow, 1 and :!. F, Posjlion or the chi.:f filler l!~llcry cxhausu. A more sensltivc method for estimating chrysotile is required~ and we are devclopinc a technique based on electron micro scopy. Preliminary ex~minations under the cJectron microscope of samples collected by the Litton 'ampler indicate that the actual chrysotile :ev::-1 rnay t-e 2. farther t~rcc o;der.; of maeniludc below the X-ray detection limit (that is. about 0.1 ng). The samples have so far been collected in the close Vicinity of the Rochdale factory. It is now proposld to s.ample air at certain representative urban and rural locations in UK and estimate their chrysotile content. A. L. RICKARDS v.D. UADAMI Turner Brollters Asbes/os Co. Lid, PO Box 40, Rochdale, Lancashire Rc~ivcd Aprill8; revised September 22,1971. 1 : Cra S/m ibJlJeJ, ,Jd.tjVor.A.Ashm~estr.os/mDf:.H1t /Cy~o.nrArsnsloracl.11G.'I/2v1r, 293 Us. (19G6). KilJI t!u A.thtstos Rcculmima /969, 1i:clwicallJata Aot< JJ (IJM faclory lnspcc toratc, 1%?). FMSI 02868 FR.ICTION MATERIALS STANDARDS INSTITUTE. lNC., 370 LEXINGTON AVENUE NEW YORK. N. Y. December 8, 1971 TO: MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: RECENT ACTIONS BY FEDERAL AND STATE GOVERNMENTS CONCERNING ASBESTOS There has been considerable output concerning asbestos in recent weeks. We are, therefore, sending to each member of the Asbestos Study Committee the following: 1, Illinois Pollution Control Board Regulations 1.1 Memorandum of December 3, 1971 on "prosed final draft11 of regulations on asbestos. 1.1.1 Note that the section banning asbestos containinp brake lininps after 1975 bas been eliminated. 1.2 Chicago Tribune article of December 2, 1971 concerning asbestos. 1.2.1 Nothing specific about brake lining. 2. Envi.ronmental Protection Aeency Emission Standards 2.1 Federal Register of December 7, 1971 spelled out the proposed standards for Asbestos, Mercuryand Beryllium. 2.1.1 The proposed standard for asbestos only is included in our excerpts. 2.2 New York Times article of December 4, 1971 concerning the proposed emission standards. 2.2.1 This can serve as a digest of the proposed standards in the Federal Register. 2.2.2 Note that the asbestos standards were set with control practices (filters and traps) rather than by numerical emission values. 3. Departm,nt of Labor - Exposure to Asbestos Dust 3.1 Federal Register of December 7, 1971- Federal Supply Contracts. 3.1.1 To apply the new Wi 11 iams - Steiger Act standard on asbestos to Federal Supply Contracts. 3.2 Federal Register of December 7, 1971 - Construction 3.2.1 To apply Williams- Steiger Act standards to construct ion. Messrs: I. H. l'!eaver J. C. Henning Dr.W. Spurgeon W. B. Reitze J. B. Graham E. H. Feierabend E. W. Dr i slane Executive Secretary Raybestos-Manhattan, Inc. World Bestos Company Bendix Corporation Johns-Manville Corporation Carlisle Corporation Abex Corporation FMSt 02869 fRICTION MATERIALS STANDARDS INSTITUTE. INC., 370 LEXINGTON AVENUE, NEW YORK, N. Y. December 8, 1971 TO: MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT: RECENT ACTIONS BY FEDERAL AND STATE GOVERNMENTS CONCERNING ASBESTOS There has been considerable output concerning asbestos in recent weeks. We are, therefore, sending to each member of the Asbestos Study Committee the following: 1. Illinois Pollution Control Board Regulations 1.1 Memorandum of December 3, 1971 on "prosed final draft" of regulations on asbestos. 1.1.1 Note that the section bannine asbestos contain- ine brake linines after 1975 bas been eliminated. 1.2 Chicago Tribune article of December 2, 1971 concerning asbestos. , 1.2.1 Nothing specific about brake lining. 2. Envi.ronmental Protection Aency Emission Standards 2.1 Federal Register of December 7, 1971 spelled out the proposed standards for Asbestos, Mercuryand Beryllium. 2.1.1 The proposed standard for asbestos only is included in our excerpts. 2.2 New York Times article of December 4, 1971 concerning the proposed emission standards. 2.2.1 This can serve as a digest of the proposed standards in the Federal Register. 2.2.2 Note that the asbestos standards were set with control practices (filters and traps) rather than by numerical emission values. 3. Department of Labor - Exposure to Asbestos Dust 3.1 Federal Register of December 7, 1971- Federal Supply Contracts. 3.1.1 To apply the new Williams- Steiger Actstan- dard on asbestos to Federal Supply Contracts. 3.2 Federal Register of December 7, 1971 - Construction 3.2.1 To apply Williams- Steiger Act standards to construction. Messrs: I. H. l'Jeaver J. C. Henning Or. W. Spurgeon W. B. Reitze J. B. Graham E. H. Feierabend E. W. Dri slane Executive Secretary Raybestos-Manhattan, Inc. World Bestos Company Bendix Corporation Johns-Manville Corporation Carlisle Corporation Abex Corporation FMSI 02870 ' -' GHQ December 3, 1971 TO: JOiiNS-HANVILLE ENVIRONMENTAL HEALTH TASK FORCE AIA/NA ~illMBER COMPANIES AIA/NA ADIHNIS'rRATIVE SUB-COMMITTEE CC: Dr. Joseph L. Goodman Ike \-veaver~ Ed Drislan~ -t5( C. R. Wikel R. F. Winkworth H. J. Roesch Frank -Zimmerman Bradley Walls ILLINOIS POLLUTION CONTROL BOARD REGULATIONS ON ASBESTOS Attached is the "Proposed Final Draft" of the State of Illinois Pollution-Control Board regulations on asbestos. Substantial changes.of a positive nature have been made in nearly every section of the regulations as compared with" -the draft published last summer. &aong the most important changes are the following: 1. The section banning the use of~sbestos-containing brake linings after a975 has been ~liminated. While it might appear from the co"mments iri the "Explanation" section of the regrilations on page 10-11 that this question is not completely settled, it is our belief that the Board will take no further action against brake linings unless the Federal Government does first, in which case any action taken bX the state would be rather academic. 2. The plant emission standard has been raised from a level of .5 fibers per cc to a more acceptable level of 2 fibers per cc. In addition, the standard of .05 fibers per cc at the boundary line of a plant has been eliminated completely. 3. A "no visible emissions" standard has been included in various sections of the regulations where enforcement of.a stricter standard would have been a problem, if not impossible. 4. The segment of the regulations requiring "tptal enclosure" of a'structure under d'emolition before toppling of walls could begin has .been altered to a more-or-less "do the best you can" standard. FMSI 02871 -2- 5. The section requiring the use of a sealant on all "fibrous" materials u~ed inside ducts or plenums has been changed to "asbestos-containing" materials only. 6. The section prohibiting the discharge of asbestoscontaining process waste water into the rivers, streams and sewers o_f t.hc state has been changed to permit such discharge if the waste water "is given the best available treatment consistent with technological feasibility and economic reasonableness." 7. Under the Propqsed Final Draft, only manufacturing plants will be :required to obtain a permit from the state. The first draft required permits for , any operation or activity involving asbestos. The vast majority of the above and other positive changes in ~he regulations reflect specific recommendations and corroborative evidence presented to the Bqard by Dr. F. L. Pundsack of Johns-Manville and Dr. Joseph L. Goodman of Raybestos-Manhattan on behalf of the AIA/NA at the public hearing on the regulations held October 15 in Chicago, and by Dr. Geor~~ W. Wright and an industry team at a meeting held with Board staff representatives in September. -Also participating in the nven'lll cooperative industry effort were NIHA and the Friction Materials Standards Institute. Attached is a copy of the specific. changes submi~ted by the AIA/NA at Board request following the Chicago hearing. Because of the many changes in the final draft, the section and sub-section numbers on the AIA/NA recorr~endations do not correspond to those in the final draft. However, as you can see, the basic changes recommended by the AIA/NA have been adopted by the Board. It is indeed an encouraging s1gn to find that, in this era of national environmental panic, a well-documented and well-presented industry case can produce results as fair and reasonable as those obtained in the state of Illinois. Much credit must go to the responsible yet fair attitude of the Illinois Pollution Control Board, and to all those in the industry who worked long and hard on this project. ~// ~~~ \\1. P. Raines ... FMSI 02872 .. Chicago Tribune, Thursday, ,December 2,. 19il . - N Section 3A -3 AsbestQs -Pollutilin to B~N~XfTlirY~t .. The new as~estils r~~lations ~o would ~~EiQ:W.~d'.tci. use proposed by the Illinois Pollu- the best available technology tion Control Board will, :for tlte to Jimit as~stos discharge into firs( time in Illinois; aim at water;' . ~ . ,. :; ~. <. . controlling a polfutant on a In construction~ trades; 'out- prson4o-person basis. , side spraying of asbestos on . 'J!~e , proposed regula~fons, buildings would be prohibited which probably will be adopted aft~r March 31. If the materi- - ,in mid-December, provide for .~1, m w~ll ~oards for-ex~pl~, regulating the lise of asbestos IS. used .durmg construction, 1t a~ .It ~ manufactured, used in must .be handled under a cover constr\Jction and used irr demo- or in an enclosure. Visible emlition procedUres.' During hear- i~sio~ of asbesto' :wo11ld be a ings earlier this 'year, several VIolation of regulations. doctors . linked asbestos with The regUlations will require !mig diseaseS, includin~ cancer; that buildings with asbestos be . . : ,(;overs Wide Vanety wetted ped by baannddtdhueriansgb~ersntoolsitsitroinp:- The regulations will go far- -------~-- ther than Chicago's ordinance, 1 which reqUires only that asbes-1 itos &pfaying be. limited tQ en- 1 dosed areas. r .j': U~det:; _tb~ board's prowsai, manUfactUring plants and oth. will Ier facilities tbat use asbestos 1 ~ required to provide fa- cilities where , employes <;an 1 an ichange tl\eir work clothes. . ' Tiin Harker, aid to the bo.ard, Sllld. the ,provision was . adde<\ l!_eaause ~sUn!Ony indi- cated that . asbestos workers and their wives have a higher 1 incidenee of lung~ diseas~s be- 1 ' .cause they often come in con- tac~ with the substance. 1 ' Limit on Enpssions ""This is a unique proPQSal," Harker said, "because it iden- till$ the individual as a poilu- 1 ter.~ . Ul:lder the regiJ}alions, asbes- tos manufacturetli would be al- l()wed to emit no more than I.:z.two. fibers of asbestos for each cutc centimeter of air. Pfunts . I.: '~' FMSI 02873 PROPOSED RULE MAKtNG 23239 t!on also ha.s been given to the need to othar possible sources of 'berylij.um are minimize the emi$sion of ha.zardQUB being investigated, and those sources pollutants that can. accwnulaie in the which can potentlfi1Iy ca.u.se ambient coxi'- enviromnent. centra.tions to exceed 0.01 pZ!m .will be In many ca.ses, information on possible lncluded in revisions to this standard. sources 'of the hazardous pollutants is )lOt Mercury-Inforniat!on currently a vail- available in sufficient detail to determine able suggests that an ambieJ;tt concan- perthe need for emission standards. Invest!- tratton level in the 'air below one (1) ' gations are underway:to fill these gaps in microgram cub~ meter JS sufficient knowledge, and the results of these in- to protect the publlc;.health from illness vestigations may require modification of due' to inhalation o:f.mercury. However, these standards and inclusion of addi mercliry is mobile in the environment, tiona! source categories for these and once released to the ati):tosphere maY pollutants. cycle between air, land, and water for Beryllium, mer!JtirY. and asbestos are long periods of time. Natural. processes very different in the number and type of and living organisms can. change mercury sources and oontrol options available; frQm one forin to another, at times con- therefore, each standard bas been writ- verting mercury into its most hazardous ten in a different manner to optimize forms. Therefore, when sufficient infor- effectiveness and facllltate compliance. mation and understanding are available, Asbestos--The -proposed standards for It will be necessary to. consider .the asbestos are designed to minimize emis- broader environmental problems caused sions to the atmosphere. Because there Is by mercury emissions to the atmosphere. no suitable technique for sampling and The only indu.stri3 knoWll to be emit- analy7.lng asbestos in the ambient air or tl.ng mm-cury in quantities and in a fa.sh- in emission ga.sell, the standaras are ex- ion such that ~e faci11t!es, aisumtnga pressed ns requirements for the operation negligible background level, .may cause of specifle control equipment (or other the ambient concentfa:tlon level to ex.- equipment of comparable effectiveness), or in situatio:QS where no control system ceed 1 mercu p_g/m a ry from re t o~ haenfdac.tihlietimeseprrcoudr1y1Q~ng is available a.sprohlbltions on the'use of chlor-alka.ll plants. 1'hese industries a.r.e a.sbestos. When acceptable source sam- covered in this standard. other sources piing and analytical methods are avail- may emit mercury, bUt present informa.- able and it is possible to delineate :fiazard- t1on indicates that. these l;!OUrces alone ou.s levels, these standardSmay be revised will not cause the ambient cpncentra.tion to require .compliance with a measured level to exceed li/Jila. allowable emission. ' Investigations a.re tinderwa:v to identifiY' The sources covered "in the asbestos all mercury ~w,-ce;s and to qwinttl'y their standa.t'd are: Mining, milling, spraying, emissions into the air: As mote info:rma- asand marlUfacturing. Specific examples of tion becomes avafiable, thl!i subpa.rt will emission sources which would be subject be revised, necessary, to add. add1t1o:na.l tmoatnhuef.apcrtouproesresd ostfan.daasbrdesstoasp-pcloicnatabilneintog so. uTrhcee pcar.ot CpJoI;Osre1des.r ' ' egulations r; .equ!re ap.. 'products include, but are not limited to, pfieatton to' the Adm1nistrator for aP- BnnRONMENTAI. PROTECTION AGENCY . manufacturers of the following products when those products contain asbestos: Cement.' telttiles, paper 1llld board, frie- tion products, pla.stics. floor tnes, gaskets, packings~ productlr. roofing felts... and insulation a1 porfovanyfosrtactoionnsatrruyctsioounrcoer 1m10od'Wiflb.clca.htio.an standard prescribed in the regula.tions is appllca.ble. Th the applicant eo'fAad..m......~!-:i::l-lstroatrodrfwsa.i.l...l....n......o..~,t.l.vi'aVl [ 40' CFR Part 61.] NATIONAL EMISSION. STANDARDS FOR HAZA~DOUS AIR POLLUTANTS Proposed Standards f,;, Asbestos, jl~ryDium,.Mercury .BerylUum-Amaxlmum allowable ooncentraUon of berylliwn for ambient air has been .in use by the Department a! Defense and the Atomtc Energy com'mhaisssbio~n.fo'LrlSemd !aJnlsythyeedaersv.elTohpims e.gnut iodfeltihnee beryllimiJ..standards. The proposed stand- roefcesiupct.h part or aAallpfpteheliecwacitolilostnbse'owcflillt:$bb-l.generd6e0vtioe<wl8do.eYf5Xrabo3etr fee tim structure will be e as experience wreivthis. e~d fr:opmrogt1mmme t~o developed. ' Omitted from the proposed regulattons Pursuant to ~tion 112 of the Clean Air Act. as amended,: the Adm1nlstrator published in the FEDERAl. RBGLSTEa of March 31, 1971 36 CFR Part 621 ~ initial list of three hazardous air pollut.:. ants which in his judgment. may Qau.se, or contribute to, an increa.se in mortality or an fucrea.se in serious irreversible, .or incapacitating reversible; illness. Publication of the list constituted an announcement of the~Administrator's in~ tention of establisblng;under section 112; national emission Standards for certain source categories known to emit these hazardous pollutants. These standards are based Dil .information derived from :many urces. ..lncludil:ig health .eff-ects levels, meteorology, technical analysis of control eapability, and consideratiOn of aorpdtisonoofft'emr e.tah.seurollwlgnCe+Qmoprllaonpceerbaytoerit"ltlheer emission testing or .ll).easurement of am- b1ent concentration levels in the vicinity of the plant. However, tt is anticipated that most sources will eleet to comply with the given emission limitation. Buildings or other obstructions in the Vicinity -Of the source, . or location 1n .highly .urbanized areas, may make it impossible to design and .locate.. a .8Am- PIIng network that p~:ovides sumcient .assurance that areas of .maxinitiin con:. centration are mea8ure!l , .. . 'The la?.own' major s6urces of beryllium ate extraction plants, m8ehlne shops a.bd foundrt~ 1lancillng beryllium dr .beryl:... lium-containing ~dys, ceramlc p1ant8 using beryllium, rocket propellants con- taining ~ryillum, and Incinerators burn~ are provisions for delegations of author- tty to. States under sect1on-u:t<d> (1). Nevertheless; it f.s the AdmtDJstra.tor's intention to encoixrage states 'to assume the Principal responslblllty for enforce- ment of !lll-tional.emission standards for hazardous air. pollutants. Toward this end, Procedures for qelega.ting authority will be established early next year, after the States have submitted their Plans for implements.tion cif !lll-tional ambient air quality standards~ In aceorda.nce with seetion.. 117 <fl of the Act. -publication .of these proposed standards wa.s preceded by consultation with appropnate advisory CQmm!ttees, Independent expert;s, and Federal depart- ments ld agencies. Inte:J:ested persons may participate in thf.s rule, making by su:bmlt1jing written economic impact. The overriding consid,- ing beplli~-oonta.!nJJlg waste. These erations are health. effectS. Considera.:. are covered in the proposed standards. wmroenfa in trU>llcate to mental Protection Agency, tollme cEenVofiroAn4-" No.231i--7 FEDERAl IJEGI~TER, vqL. 3~, NO. 23~TUESDAY, DECEMBE~ 7, 1971;'1 .2.1 FMSI 02874 23240 PROPOSED RULE MAKING Programs, Division qt. Compliance, Re- search Triangle Park, N.C. 27711. The Adml.n!strator will welcome comments on all ~",".".".."~"..,- of ""~ "'""' p~ """"'"" ~-u~.,.,.. co;.....- ......, Sec. 61.08 Approval by Administrator. 81.09 Source ~- ' 8811..1110 BWeBqtuVeels'.t' tor wa.iver ot CODlplie.nQe. u.s<.ac>. ."Act" means the Clean 'Air Act (42 1857 et seq.; as amended by Public meansLaw 91-604, 84Stat.1676r. <b> "Administrator" . the Ad- includlng economic and teclmologicalls- 81.13 Emlsslon. tests and monitoring. ministrator of the EnVironnientJI'Ll Pro- sues and on the proposed test methods. 81.13. Availabllity of lntormatton. tection Agency or 'his authQrlzed repre- All relevant comments received not later 61.14 State authority. sentative. .. _ . . . than 90 days after the date of publication of this notice will be consldered. Receipt . Subpart 11--Natlonal !:mission Standards for <c> "Commenced" means that' an owner or operator e,nd.a contractor to, of comments will be acknowledged, but Asbestos the Office of Air Programs will not pro- 8i.20 Applicability. or amlla.te of, such owner or operator have entered into a binding agreement or vide substantive responses to Individual comments. Public hearin.,.., will ,.._ held as re- -.,w - Quired by section 112(b) (1) (B) of the 81.:!1 Deftnitlons; . 61.22 Emission standMds tor asbestos. , 81.23 Referenced equipment spec11lcatlons. 81.24 S uobfsteiqtu~vtealdeenvticeesmfJosiriltohne attainm control. e nt contractual obligation to undertake and complete, within a reasonable 'time, a. continuous program o!'construction or modification. Clean Air Act. A notice of time, date, and place for these public hearings will be Subpart C--Nalional Emission Standards for a(d} ''Construction" -means fabrica.- tion; erection. or installation of sta- PUblished in the FEDERAL REGISTER'within Beryllium tionary .source. .. 30 days of the publication date of these 81.80 AppUca'bUtty. (e) "Emission test" inelj,DS measure- standards. Not later than 180 days after publication of the emission standards set forth q...,.._,".".' t obelpowro, mthuelgAatdel n lnistrator 1.s resueh emission standards, unless he finds, on the basis 886111.388132 81.34 61.3$ Deftnittons. . Emission .standsrd.s lor beryllium. TPeeersaitomdmpicleitnJhlgtoe..d!:sk and Proce4ures.-.stack eampllng and reports.. Waiver ot periodlc. stacll:: sampung and ment and analysis of eniliisions.Qr other procedures used for the i>urPose of deter- mining compliance with a standard for hazardous air pollutants. (f) "Existing source'' means any sta- of information presented at public hear- report req~nts. , tionary source which .1s nQt a. "new ings, ~t the pollutants in question 61.36 Test methods an4 procedure&-eolr source". clearly are not hazardous. According}y, all persons having scientific Information .61.8'7 sa.mpllng. Monitoring e.nd report&-s.fr IIAI!lPU!lg. <g> "Modification" means any physical change in, or change in .the method pertinent either to the question of 81.3.8 Election. of. operation of, a station;ary source which whether.., asbestos, beryllium, and/or ~bpart ~atlonal Eminlon Standard~for increases the amount 01 any lwla.Tdoi:Ja mercury are in fact, hazardous within . BerylliUm-Rocket Moior Firing air pollutant emitted by such sOUI'Iie or the meaning of section 112 of the Clean Air Act or to the question of the level of the tute a nvsakritoouspusbulibcsthaenacletsh that consti- are urged to 81.40 Applioobutty. 61.41 Deftni'tlons. 81.42 Beryll1um enilsslon standa.tds. . . 61.4$ Test methods IUld prooedure&-:-alr which r~ts in the emission Qf any hazardous air pollutant ~t pr~viousl.y emitted, except .that .routine ~inte~ nan<:e, repair,. imd. replacement shall. not Present such information either by testifyh1g at the hearings or by submitting the data fo dition, all i rnttehreeshteedarpinegrssornescoarrde. In adsPed!- 61* eu5 aampll.ng. TessatmmpieJnthgo. Monitoring. d e.nc1 procedur~ and. reports fpr ~ sam- . pling., .. . . . . .. :.. ically asked to present information on 61.46 Stack 8alllpllng and ~ : _ the extent to which promulgation of these emission standards for asbestos, beryllium, and mercury will be of bene- Subpart IS-NatioMnealrE~rmylul:on Stondard ' for be considered physiCal changes. . . <h> "New source" Dieans any station.., ar,v source, tbli conatruction or modification ot which Is cOmmenced after the publication in the FEDERAL REGISTBil of proposed natiotlal emfssl.On standards for hazardous air pollutan1ls whidh will bEi applicable to such facility. :. . . :. I fit to j;he public heelth. In any testimony 81.60 Applicability. or written eor:mnents on the speelfic points mentioned herein or on other matters relevant to' tb1s proposed rule 8611.6612 .61.63 61.64 Deftnittons. Abtwrovta.ttons. ETemsitssmioanthsotcatnsdIaUrldd formereury. prooedures.-mer- making, all assertions and claims shoUld .oury ore processlng taclllty... be fully substantiated by factual in!or- 61.66 Perio41o emls&lon testUlg-:-meroury ora m.ation. procesa:lng tQCI.ltty. . Summaries of the pertinent data used 81.66 ~ng...,..mercury CJN J?toces8-. in developing these standards n.re avail- lng to.cd11ty. . able free of cha.rge from the Environ- et.67 Watver ot emflls!on teet ioequ.IJ'e.o per<sOon"Owwhoneorwonsr.. operator" means leases, operates, any con- trols, or. supervises a stationary source. CJ > "Start up of c)pera.tion" means the . beginning of routine oper&tion of a sta- meamstionary source. ;,. '. , <k> "Station.ar:r ~e any . building, structure, faCI.llty. or instal- latio~ which emits or DJ8.7 .emit any hazardous air pollllta.I!.t. ' . ~ , mental Protection Agency, ,Office of Air Progmms, Research Triangle Park, N.C. . 81.68 2'1711. This notice of proposed rule making Is 81.69 !.'<SUed under the authortty of sections 112 and 114 of the Clean Air Act, Public 81.80 T:m~etnths-omdesrcuarnyd ore Pl,"oceasl.llg ta- proce.iUre&.:-mer- cuey cen c:Mor-alkalt plant. _ Periodic emlsslon testing-mercury !)ell cblo~ plants. necQrdkeeptng.....merCury oetl cblor~ 61.03 Abln:evia\fo~ ; , The abbreviationS used fn l.his part have the following m!la:nings! etm~ublc feet per.minute. ft'-,-Square feet. : L~ 91-604, 84 Stat. 1713. . a.lkaK plant. ~. . f'tO-Cublc feet. . 81.8i Waiver ot emlss:lon test reqwre- F-l)egrlle l"ahn;nhett: WILLIAJI!. D. Rl1CKELSHAUS, ments-meroury cell . cblor-:&Jlmli ln.-Inch. .Admlnistrator; facility. l_;.Liter. Envlron1T'.enud P.ro,te.ction :;tgency; ..NOVEMBER 30, '.1971. . 'S u bpart A -~Genetaf: Provisi.o11s: ,. 6IoOl Applieahllity. . mg-Mitugram; l:ll;l-~M=n~tjml.eittere:r toPART 61-NA'tiONA L EMISSION The provisions of thiS part apply the vtv-v:otume pez:votume. STANDARDS FOR" HAZARDOUS .AIR owner or operaioi of any source w~ is w.g.-Water gauge. . . -.. POLLUTANTS ., s~bpcrt A--General Provisions Sec.. .' ocapteiroanteodf, or the which construction Or. modifi;.. t8 commenced after the WpgJ/Vm"-W-Me:llegrhotgprearmvsoPtue.mt csu.b-:l~ ~r;: . date o! publication IIi the FI:DEIIAL REGIS- %..,-;percent. .~ .,"~ 61.01 Applicability. : TEll f)i proposed emissic:i:ll Standar$ for 61.04. Adoire'as. ; . ,. 61.02 Definitions. 61.(13 Abbre"rl&tions. 6l.M Address.. 61.05 Prohtb!ted act.!v>ties. haZardous air po1Iuta.nts. which are ap- .$ a,pplicati~lll!; 'requesis, Stibirilsstons -, pllcable ~ slich soUrc:e. and Inquiries wider ~ part shall be . - 61.0Z <.De~i~ons: addressed to the Environmental Protec- 61.06 61.07 Determini>.'tlon' ot eonatruction . or modill.catlon. .. Appllcs.tlon tor approval for CO:nstiuc- AB. used.in this part, 8JJ terms not de- fined ill tJwse e1,1bpa.rt,s shall bave the tion Agency, Office of Air Piogra.Jns, Dlvt- " elon .of Compliance, i':seareh 'Trlallgle' ,, . tion or modiilca.tlon. ' meiming:given them in the Act: Park, N.c. 27'111. ' ' F!:D~RAL ~EGISTER, VQL. 36, NO. 234-TUESDAY~ DECEMBER 7, t9it FMSI 02875 PROPOSEQ RULE NJ,AKI"fG 61.05 Pcohihired'acthities. wb!ab.. .:t:l;l:(i1if)ugNs oot inc e or th,geuchin1fnotmenad.t~ido n ~d denlal , psoena~Wtioll a~ssurp_reotthea<t:~~ ~~tlJlAlomf1pnee;nr~t Ca) After the efi:ectJve date .'Of atl7 :- J.i based. and . . .. . . ., . . enda.ngerment. .. , . . ' '~. ".. . emission standard prescribed under this '<2> Notice of opporj;unity fo;r ~per- {C), A.s used in tWs gtWpe.rl.. 'inunine~t part, no person shall construct or modi!y. son to-present additional 1~tillD Qr ~dangennent"meansa.n.lmmedia.terisk a.ny st<.tionary source subject to .su~. satpapnldoavradlsowf tihtheoAudt lflilrllsllt.sotbratationriinng"aWccroitrtdenr,nce with tllis subpart, except under an arguments, orally or in Writing,, to the AB"U.~.(.C.'d..~h)..i.x.sAetqr~uaetsot rd. eptreirolrn .t.o ina .flnaJ a ction . tion to denY 0n any ,.o f.6<a1al.g>1,n1Bitalcsweadnativoheanr...'ri'tilh:'et9_,.tihn<.fe:o..rl.ucmima.taion,n bodY, pro- exemption gronted by the Presidenl; un- request !or approV'JLl will .be in wrttlng \ided in any re(!uest .under; 61.09 and der sect.icn 112 (c) (J!D of the Act. .and will set forth the sPOOUlc grounds <>n .any other lnformatiOJ;l, the A~tra!;Qr -(b) Ninctydaysaftertheelfective date which such denial isba.sed. .inay grant .a -waiv~::r '?f <:OID.Pliance wl,t,h of any emission standard prescribed by <e> Neither the submission of anaP- the_.appllcable e~SJO:Q, standa.rdfor a nus part;, no person shall operate any plication for approval or the Admin:!stra-. penod not exc~ 2 yearn~, . . . sta.tiilll!ll"Y source in violation <>f such tor's g}-anting of approval to construct tb> Any such ~_v~r ~harll be m wnt- standard except under a Waiver granted or modify shall: .. ing and shal_l: . .. . >.by the Administrator in accordance with tllis subpart -or under any exemption l e g<a1l>reR&epliOevnesibainlityowf onrercoomr pol ipaenrcaet.owr of ith . _ (1 '(2) Ident?y the :;:ourc~ c()~red. .specify the ~rnJJD?.tion 4ate -~ granted by the President under section any applicable provisions of this part or -the :wruver. ... ... : . . 112<c> (2) of the Act. of any applic~Ie.State or local reqqire- (3) Impos~ such reasonable conditions 61.06 De-termination of construction or mooiilcation. . . ment, or . ,. . (2) Prevent the Administrator .from an.e'!cetshsea;rAydz. n~iniasstsrau,rte(>~mdsteatllelrl-mfiiionnesotfo t be he ,. Implementing ar enforc1ng this ,part or necessary controls wit:llin the wa.tv.er pe a Upon n owne rworirtotepneraaptoprl,ictallt~ioAnd-mthienriesftorratboyr taking any otl:if!r action under the ACt. . . . rlod. and to assure. protection..of the health of personsfrom inlminent.endan w!ll :ro.'l.ke a determination of whether 61.09 Source reportmg. germent during the Waiver period. , . -. . .,: ~~ actions taken or il::tended to be taken by such owner or operntor constitute con- <a> The owner or operator'of any.' ex:!sting stn.tioxmr;y solll'Ce towhich a stand- <c> quest. Prl()r for a. wtaoi.fln~alp1::Yui.'.dsueannytintogtah;insy,sreec--. .. }. structlon or mod1flca~io? menc;ement thereof mthln or the co~the meanmg . sahradJlp. r:ewsoitrhlibne. d3o.lnd tbls ays aprrtoe-rt is applicable the. eff~ve ~o11, the Admipistra.tor. will .notlfy. the , person~ ~uch request of thEpf.d ofthlSpa.rt. 61_.0] Application for approval' for dmaitnelsotfr"astourchthsetafnoclltoaw.nttr;igpirnofvoidrme athtieonA:d'- :ininl!!trator's intentiOJl. to JBsue sUoh...: , denial, together with; .: " ... : ' . consnouction or modification. ' ' H > Name and address of the owner{)r (1). Notice of the in,formation anP. find- Ca) The owner or operator~' any 8 t a- operator. . , (2) Identification and location of the sticcrnibaerdy usonudrecre t.htoiswpbaicrht waUsItabnedao.Ir'Qisparpe-- .S011J"Ce;,. . . .. . .. ings'on whicli suGh'intendeli:denial is, based and ' . (2) Notice ,: ot' ..O"'"~'"":;''.....~,.r........-.~..t.y-... ., " or. such .. . .. .. plicable shall, not less than i)O days prtor orto the date on which construction or . . .(3) Brief description of the pature. size. deS18Jl, and method ofopera.tlon in- person to present add!tiona.llnfotination . or arguments. oraliy in\vr,lting, 'to the ' ' :. ~ modification is planned to commence; smtluoobndmiffioitcratoatipo.ptnhr.eo.A.-.d'. m0 fin~~i.s.ctrhactoornaswn:-uacp_"p.,-.,lnlc-oa-r (b) A separate application sha.U be eluding llSed for dtehsecrmipetaisolnU'eamt enatnoyr equipment control of Changesemissions. .(b) , vided under pa.r'.a1gnrat:hp~h! j.!i.n<fao>:rii:<1.I>1L.tal.no.nd:p,<rSo,>- Administra.torPrlol' ~p :qttal~~~ ~n rsaeunq<cd'udh>e.rw:eAiqllfufoiesrn.esatt.al .fdower.att.lie,ivretmrh.lew'nisl~.lp,.:'.e-tbceQif.l1edne.g:wrn.oyr.uintaiQnn.ygs submitted fo:r each stationary source. (c) Each application.sball include the following: . . . ... .. .. ''' , at this section Adminlst):ntor Wshiat..hllirlbe90prodvaiydsed<Itof. -th~e change. . _'0}1 ,"Wh1ch ~ch d.~ni~ is-~. . ... . 6(1a ?. 1 2EmiESmSiiosns i"ocnteStetssts. ~a n d numiroring. 'tnomtoril;lg of an be(1) Name and addreSs of the appll cadt. (2) Location or :proposed location of ' 61.1 0.' Request Cor waiver. of ance. (a) .The owner pr operator coinpl_iexist;. .J.rs,enhpaaolcliC'tQlnrtdlcsonreCnqd!luuwicrUteemhd~eanVnt'sd~r.~emseu:Ctltoshrto,l)rde1psnoarlltnheldds . the sourc<a. . Jng stationa;ry sou:rce unable to operate Jn p~~ort-. , . \ ..... ,. :' . / (3) Techrtl.cal iD1'0l'%119.tion describing eoxm>lta:ncewilliasta.ndjlrdors~ <b> At th~ reque.st':ot t;he, A~~. ''.,:;,;. tho :proposed. natm-e, size, design, a.nd: prescribOO 1n tlrJs part lJla..Y requeSt & trator,theownerot~torO!a~urce . ;,c, method of operation ot the 110U.Nie, in- wntver of compliallce with any ~cable .subJecti to. tb1B part .~ llrovldei: oi . ,,:~{ eluding a description of any ~en~ ez:nlss1oii standard under this pari;. for a . cause to be .provided;-> exmsston testjng. ::\. to be used for measurem~ or control period not ex~ ;a ~ . ... IacWttes aa follows: . " ' " > of emissions. . . (b). AnY. sudh..J:efluer;;t .sb2l1 be 1n Writ;;- (l) ~SamPling pOrta adeQuate for test 61.08 . Approv~ 'h7 4dminiskattir 1ng tmd $\!Ill iric:fude: : . , : methods applicable ;to 8liel1 roin-Ce; ' .. , !Od!"!(~sae)roTforhreeo.cA.-~.a-d.tmtoiofnraiosftprpal-biptcoaprrto1wOJ;ml,va.,.l~w~i._t.Lb......_.i.n.,t..h.0.,0 . <i> .The owner's or. QPerators nam,e a.ndeddress. . .. (2) ruen.ti:fica.tiOn and lOoo.tiqn, (J! the U>JSa.fesamplingplatform<s> . '' . . (3} :sate accesa ,.t.;, sampling pla.t... torm<sl. <4> Utillties .for..sa.mi:'lli.n;g. ,,a\,ndte,sting ., ,' proval of construction or modli'lcatiOill. 80Ul'!le-. ' . . . equipment. . ' . : >:'. .: ' :' . (b) If the Adminlstrator determines, based on informl!tion included tn an ap- <3> 'l'echnl03l t11e n&tu:re, .size. ln!ormati9D destgn, a.nc:t t'denScr~ibltolgr. 61.13 Availabil.itr~rintO... nUilio"'. . . u;,plication submitted under, .161.06 or .opemtto~ of Ule t!GUl'OO, mcludlng a de- ~ c~) Einissi~ data :':Provtdfld . o~; ,: ~ other information that a stationary scrripf;i~. of tm:V eqUipment USed f~ otherwi,se obtained by, the Ad~tor ' source for which an applica.Uon pur- : tnea.suremen.t orcontrol of emJ.sslons. t.ihaJI'suant to 61.06 wa~ submitted wm, !f <4> Description of the' controls n~- 1n pa accor rt d ance with be' availa btlheetOprtohveispijolbnlslco:.f this. P:l"OPe:ly opa-ated not -cause emisslonsln 'BIJJ'Y for eomllliance with the appliCable _ (b) .AnY record!;: repoxts,' or,"lhfonna~ ' VlOlation of an applicable standard, he ,-SIIanda.rd, ~ plans for.' instnllation of _tlon provtded.to, or otherwiSe obtained by, wm approve the con.stnretlon ot modifl- ~controls: : ; .. . :. : . . . theAdminl.stiator iii accordance with the. cation of su.eb source: . . , (~) :Atune schedulj! ?oi" Pb,talnlng, prO- 'J]i-ovisfoAI; 'ot .this part shall 'be available (c) Prior to denying any ~uest for ducmg, or installing; such ~trois. The" to thepublic, rxcept that upon a s:Qbwing ' approval of construction or modification schedule should include interim mees- satisfactory to the Administrat()r by any ~ pursuant to this section, .the Admlnistra- UI'E6 to achteve eompltance. ' ' . . , Perll()n tllat such records, 'reports; or iii_; ..~ ortor will notify the person J118ldni such ' . '(6) Descrtptian olthe e:m!Ssion c:Ont'rol 'fonnatJ.on. particula.- 'paz:t" thehx)f ' 'o/request of the AdminLstxa.tor's tntentton 'Btepe tn: ~ mellBUI'el5 -whlah Will be' <otherthl}ll e~s;on data),;~pub. ' .'to issue such, together Wl:th! . "' :.tnJteD, the: OWD~ dw:tric ~ '171'l'l.\ver De, WOWd di~ .lf'Cl;Jl~; OJ: ~~el'!ll!)a '\- '. fEDERAL ~!STER, VOi. 36, NO. 234--,.TUESQAY., DECEMBER 7, 197if ' ''., F ". :: -~. 4.1 FMSI 02876 23242 PROPOSED RULE "'AKING entitled to protection as trade secrets of <f). ''Air-swept: drilling" means the were treated in fabric filter installations such pe1-son, the Administrator shall PI'OC41SS of.dr1lllng holes 1n the eartlllin ~described 1n 11;11.23(d) . _ , consider such records, -reports, or in the flresence of'a fon:ed or 1ndUced air :. <c> Emissions to the:_atmosphere nom formation, or particular part thereof, stream, but not a liquid stream or mist- buildings, structures, or !acUities within confidential in accordance with the pur- . conte.ining_ stream: - whlch any fabricating or manufacturing poses of section 1905 of title 18 of the (g) ~wet drilling" means the process operation 1s carried. on !!hall be ltlnited. as United States Code, except that such of dr1lltng holes in the earth in the pres- follows: 1 .: .. . t-ecords, reports, or information, or par- ence of a '1orced llquid stream: or !Uist- <1> EmiSsions; in. dliect, forced. gas_ ticular part thereof, m~y be disclosed to conta.1nlng stream. . .. . streams, ot parttcuiate matter -J1lsultlng other officers, employees, or authorized <h> "Pa:rticulate matter" .mea.fis any from manufacturing or tabrlgat.U;g oper-' representatives of the Urilted States con- material, Qther than uncombined water, ations shall pot. exceed -the, amounts cerned with tarrying out the provisions which ex:l.sts ina finely divided form as a which would be emitted if such forced of the Act or when relevant in any pro- liquid or solid. . . . ., exhausts were treated to fabric filter in- ceeding under theAct; , ., m "Asbestos tail1ngs" meanS any 'stallations a8 described in. 6~.23(d) or, 61.14 State authority. solldwaste product of asbestos mining Where approved .by, the Administrator or milling operations which contains because of special process conditions, in The provisions of this part shall' not asbestos. ,. wet collectors as described 1n 61.23(f). be construed in any manner to preclude (j) !'ViSible emission" means, for the , (2) Emissloill! of particulate- .niatter any State or political subdivision thereof pw'J)ose of thiS subpart, any emission . from any manufacturing or fabrteating from: which is visually detectable. operation whicl). continuously generates .' ._ <a) Adopting and enforcing any emis- (kl "Asbestos mill" means any facility visible emissions 'shall not exceed the sion standard or limitation applicable to engaged 1ri the conversion of asbestos ore amount which would be emitted if. the air a stationary source provided that sueh into commercial ,asbestos. . Containing such. emissiOIUI were: treated emission stand!lfd or limitation is not .m "Manufactpring operation" means in fabric filter iristallat,ioilli a.sdescribed less stringent than the national emission the processing Of commercial a.sbestos or in 61.23 (d}. or,. where--approved I>Y the I standard for hazal'dous afr pollutants ap- the production of any product containing Administrator because iif speciat proce5s plicabl~to such source; commerclnl asbestos. . . conditions, in wet collectors a8 described (b) Requiring the owner or operator <m> ''Fabricating"' ineans the cutting, in 81.23<f). . , .: ',/. of a stationary ooutce to obtain-permits, Shaping, assembly, mixing or other Ill- (3) Visible emissions of partJculate licenses, or approvals prior to initiating tertng of any manufactUred product con- matter from any manufacWrtng or fabri- con.structi.on, modification, or operation taining commercial asbestos. . ' eating operations in an,area directly oiJi,n . -:' or' of such source. ' '"' SubSptacrntdBar-~-sNaftoiron-Aals Emission bestos , ", Ss6b<1ea>.s' 2to2Esm,m~iRtslisll-ie.loslrS5i.J-s1o\Stno:lslltb!hl~-nedllail.tllm'dso~ sdfpoalr:si:-efaroselb lefos;~wtoo~:s:m. to the <d> aVtmisiobslpeheemreiSasrieonpswhtoib' ittehde."'atmos~ phere of asbestos .p.ai-ticUiate matter resulting froM thtf repS.ir 'detnolition Ot . ."~' : --, .~:: 61.20 Applicability._ .< <ll Emissions Of particula~ matter any building or structure, ot~er than ca., ' .: from air-swept or dry drilling opera.tiollll single;.family dwellUi,g:.are prohibited. , ; The provisions of tllis subpart are 11-:P- shall not exeeed those v.rbich would -be' (e) The spraying of asbestos is limiteg , plicable to t):le follow.i)lg sources of at- emitted from an a.lr-swei>t or dry drill, . as follows: ,.:. : ' . : ~-. -:: '- -' ' mospherlc asbestos: respectively, equipped with a fabric filt<lr <1> The sprayingofany, product w:l\ich t'", Asboot.as mtnes; device for collection of dust generated containS asbestos on any pcjrtion of a Asbestoo mllJs; " from dlilling, as described in I 61.23.<a>. building or stru~ture:is-prohibiteel ' :; Buildings. structures:. or" facilities withb:l. <2> EmissionS . of J!articulate' matter which mai>'a!.aoturl?g -or !&br1cat1ng opera- :from wet drilling operations shall not ex- (2) The spraYing contains asbestos in aofn. aanryeaJ!droirdelc,ltcJtywohpiCenh . , .. ' .. t1ons }nvolving thll use ot oommerclal M-. .ceed those whic~ would' be emitted fr_om .. to'the atmosphere is prohibited;~ ' ! . besB<.u.oUo dalrnegesaorrnsetdruocnt,ures which :have been or a wet drill equlpped W'ltb a eyeIone gas (3) . Emis.sl'OUS' o_f . ...."_"_' ".'.~.,-ulate.: matter will be coru;tructed or mo<lliled using BBbestoe cleaning ,device for .collection of ~us_t or fronl. spraymg of anY product wh1~h con- tnsulating products~ mist generated from drilling as descnbed tatns asbestos, .if ,.such spraying is not Rcadw-ay fa.cUit!e.s which would be surfaced - in 61.23(b). . . . . . . . , . , specifiCatly prohibited in subparagraphs 0<' resurfaced using asbestos tailings. .. . (3) Visible em1ss1ons of particulate (!)'or (2) of. this ~Ph,, $all not 6121 Der. itions m . . inatter from any mine road suti'aced with exceed .. the :,$lllounl!$: Whtqh;.wou!d; be . asbestos "tnlllngs are prohibited: emitted. If the air cQntll,ining suCh em1s~ . >, As used in th1s.subpart, all terms not <bl Emissions to the atmosphere from sions were trooted.iilfabl'lo filter instal ...-,.- asdefined given in her!)in :;hall tile. Act and inhaSvueq~thret meaning A of tpis part. . . ~ ' - ' . . aSbestos tnillS shail be limited. as follows: ; '<1) ViSible ..em.I.S.sioll8 . of partlctUate matter from asbestos ore dumps, open .. lations qescribedo:in _; 6L23(d) or, , cwahtiesree appr_oved by the t\dm1niStratoibeof special process (:onditions; in . ;~;'~) (a) "Asbestos~ means any of six nat-- . :Storage ''ai'eas' fur 'asbestos~eon~g .wet collecrors a.s _described "ln., 61.23(~). tirai1y OCCUlTing, hyd.J::ated mineral s11i- 'materials, external- conveyors fot : Bs- '' (f) The surfaciliif. Or r-tl;su).'iac~g Of cates: Actiuoli~, ~osite, anthophyllite, ' bestoscontaiilin{t matelials~ or a.s~estoschrysotile, croCld?llte, and ta;~molite. . containing ta111ngsdumps are prohibited. "IlY' roadway prohibited, ,. ,:tP :,;,,, ; ~sb~stoS - . :: ~ -:;t.:a>ilings is va(rbie)ty"Cofomasmbee~trcciisalwahsbicehstioss me prod ans any uced'by . '(2) Emissions of... particulate matter from asbestOs ore dryers shall not exeeed "'-i,'.tf'e2a3tio. rItsf':fe' r~ced.;-<;-<:~P~.~n~ :. spec~"~:6 '" ",,, ,. the concentratiOn of asbestQs ore. those whiCh would be emitted from as- . . . . . . , . - - ..... ,., . ; .-;, .. , . . ' (c) "Asbestos mine" means any facti., ~bestos ore dryers equipped with fabric <a> Fabnc filters referred ro.m ~1.22 ity engaged in the extraction of li.s1Mfstos filte!" l.m!~llatJons a.s described,ln 61.23 (a.> <1)..are equipped ~-th ~abqps ba~n.g :,>:- . ore from the earth -forthe pw-pose of : reco\'ertng eominerc16lasbestos, :<c>.~ <Sl. J.l':i' n~, o:.ns._:of. 'i . particulate matter !4;l0.icrfflDow,l/ftp.erme/a..piijtie-s~-_1.1:P~...:exc, eec-ijng. ores'(d) "Air flow permeability" mearis the 'from air ..streams used to process a.s- , (b). Cyclolll:l_ .collectors referred. tp..in volumetric rate of air flow in cfm, pro- bestos or for exhausting partlculate ! 61.22(a) (2) ,are ,operated at_ not _less duced by .a pressw-e decrease of 0.5 1n. matter resulting from l:llilllng operations , than_ 7ln. w.g. pressure decrease as _mess- w.g. across a new, -elean filtering fabric. sbilll not exceed the .amounts whlcb ~d f~m- the. cyclone inlet to .the outlet, . divided by the area of the fabric in ft'. would.he emitted if such-air stream$ :were <c> Fabric filters.referred to _in I !)1_.22. , The test air stream 1s maintained at nommal atmospheric pressw-e ' "and temperature. ; _ (e) "Dry drilling" means the process of drilling holes iu the earth in the ab- sceonncteao~fnagnstarpepa!li!el do liquid streall), r air stream. mtst : _ ', treated 1n fabric. filter. insta.llations as .. <b> <2> .are eqpped With fabrics ha.:vmg < : :.: .. , . .. -..describedm _6q3(d). :-; ! _ : : . . a~w .permeabillties }I.<;!~ ~e~ -3~ __: <4> from iEmmyisnsl1liollnnsfi.i-"oofpep~atrttiocnul,awthelcmh actotenr- _cf<md>/f_.fF;abrlcfi. i~:rs refetted toW .61.22-;._ :-;., ttnuous!y generates visible ~ons <b> <~>.and (4), ~c)- U>: ~n!l, (2).,.e.nd :!'- swhoaullld-n.p~t_ ~c~~-d emit~ the. amounts ,w~ch if. .au6h a,tr ,streams <e> (3) Jl.te e,quipped :~tth ~'!Ititicotto~ . fabrics having alrfl.ow penne!""l .etJ no , " " FEDERAL REGISTER, ,VOL 36, N0.-234-TUES{)AY, DECEMB~R 7, 1971 ., :; "." ., .J./ FMSI 02877 PROPOSED RULE MAKING exceeding 20 cfm/ft". No bypass devices are utilized. and provisions a;fe made tor emptying the collection hoppers without creating vismle emissions of particulate matter. (e> Fabric filter devices do not meet the descriptions in paragraplu; <a), (c), and (d) of this section If any of the fol- lowing conditions exist: n) Leakage of. gases, containing par- ticulate matter, from the contrQI system prior to filtration. . (2) Tom or ruptured bags. (3) Improperly positioned bags. <4 l Badly worn or threadbare bags. en Wet collectors referred to in 6L22<c> (1) and (2) and <el (3) are of the high-energy venturi type operated with a minimum ga.s pressure decrease across the venturi throat of 40 inches w.g. (gl Wet collectors do not meet the descriPtion In paragraph <f> of this sec- tion U any of the following conditions exist: . <ll Leakage of g'II.Se6 containing par- ticulate matter from the control .system prior to filtration. w.g<.2>pr{e)spsuenre\tdioencreaatslee.ss than 40 inches .<3> Operation at a scrubbing medium flow rate less than specified 1>,- the manufacturer for optimum collection efficiency. these, the owner or oper-ator shall make avat.lable to the Administrator perform- ance data on comparative tests, using suitable standard test aerosols, on the substitute device and the device specified by the applicable standard. The perform- ance data sball lnclude, but not be limited to, the total mus efficiencies of the substitute device and the device speeifl.ed by the applicable standard. (e) The total .llWlS emciency of any substitute device for those specified by 61.23 <a>, <c>, or (d) shall not be less than 99.9 percent. (f) The total m<UJS efficiency of any substitute device for that specified by t 61.23-Cbl sha.ll not be less than 85 percen,. . (g) The total mass efficiency of any substitute device for that speeifl.ed by I 01.23(1) shall not be less than 99.5 percenir. 6i.24 Substitute d\'v"ic<'s or the 111- taiument or equhalent em~sion ~ontrol " (a) Compliance with any applicable standard of tb.l,.s subpart which refers to a control equipment specification in t 61.23 shall be demonstrated in accord- ance with th1s section if the referenced control equipment Is not used. <b> The owner or operator of the emis- sion source. shall make available to the Ad:ministrator sumc.tent informatioo a.s may be required to demonstrate that tile substitute equlpment will provide the degree of control which, in the JUdgment of the .Admtnlstrator, Is at least liB strin- gent as that whichwould be achieved by using the equlpment specified in the ap. pllcablestandard. To the maximum ex- ~ practicable, the determination of equivalent degree of emission control will be based UPOJ1 opemtion at the actual conditions Is or will at be which the .~ted sounbtshtietuteemdiessviiocne source. Factors which will be oonsldered inelude; but are not limited tO, collection efficiency, rcllabillty, and .maintenance PracticeS associated with proper opera- tion of the substitute device. (e) The owner or operator of the emis- sion source shall submit to the Adminis- trator performance data l.ncluding, but not limited to, total ma.ss collection em- ciency of the substitute control device tmder actual operating .conditions or conditions which are representative of those of the existing or planned optu:at- ing conditions. <d> In cases for which it is not rea.son- ownerable,ln the Judgment of the Admlnlstra;. tor,. to req~ an or ope1'ator to submit perform.anc8 d&ta whicb are based upon actual operatmg concll1;iooa or conditions which are representative ot ,1..1 FMSI 02878 Industrial Emission Sta~d~;ds ~;'~'For 3 Air Pollutants Prop~s~c( , - ' ~ r ' ' ,~-, .. ~.-'.-...~~ 'tf' '{lb By~ W. KENWORTII'Y'< ;~,; 211 {'": ..._.. i ,; ''. f.r &Peelt.l toTiiRewYoHtTtM ~, '!:\:.' .. '' ( >" bsWASHINGTON; 'Dec. . 3-:- 27.<Mr. RtickelshauS. in a~'neWJ iam D. Ruckelsh~us. ad- conference t.ada.y; said the de- - ~tor of the .Envtronmen- lay bad beeno-~used, first. by :Prote~tlon Agency, an~ the. "compl~~~ ~pf th.~ .prqbfdounced tOday proposed emlS !em, which .W8JJ" not 'nsolv wee-fibn .'standards for lndtistry on hazardous air pollutants wanitdh;insecthiendE.;.PbY.:Ath;'uen tni,ele'Sdeptht.e2r6e'-, t'al.:. tsbestos, ' be.rryllium. and after t~ ge~. thi.l._views of other mercury. . . agencle!l. . ':. _, .,, <1oAsbestos , fibers;, whlcli are . ~niro~~ctlc:es ~d In floor tile, lirake linings, , ~. . al>bestos paper, textiles, insula By way .(If ,UluslJ'IlUng ~e f4~MiolIfl'gt,iJs"tw,lahteecnraluals~seaa'lnleudnd-~flrcoeapvnrelcrlOerfl.lonngg. CO!fiplexity, l(r..' :Rilckelslui~s said' tllere were ,11,0 1'sfandar4: lzed methods'~ .;for~: measur~g ~~tBeeylllUD\, ,. a .haghly toxic emission lev~ls of asbesttl$. vy metal that can cause Thereto~ ht!'cJai(J,'ft has been faGpttt:uznonla among ' those OC decldlet Set the ,standards cupationally exposed, is used in "not. in :tenns'"' or:.1Jwnerlcal ~lichme shops, propellant eml$sio~J..ya.!ues", but ln; "control ;t~llm~. extraction plants' and practlces.,illat:wllt limit em,is.Tihlndries. However; the haz sions .to 811' ~cepttble levet~ Ji'tds' -Of; JJerylllum o1lllgldly conft'Olled exposure are b.Y industrial thCaot n'Wseiqllq ebhetlY-p,tu.tbhleis.hreegdU.,!lantl9tJhlSe Giealth regulations m force for Federal Register next. tuesday ~ 1S1ll1l!otastl<.1los.puesreadtl;o-n>:s; , in which ::;;;" ~ . the will require thel '!lse o~ filu-rs to trap asbestos f1bers m gases (')! ~hJiOnic~sureto.aitborne from..mining, .milling..manufac" fl!trdlry can ba.ve a: profound turing and. fa.brication of. !\S ~ect on the central nervous besto-containing material's. ~ot1he symptoms ofwhic f'u(th~... there wiUbe an ab- -ae tremor, ..ps~bologlcal dis- solute prohibitfohon the sppay- turbance, insomnia, losll. of ing of asb,estos fireproofing and -1!'lright and appetite. The stan- lnsulatlcm, except h.ere sueh w_ ilal'<fs . announced today are spraying Is done indoors ap$:1 4.ruMe&e;4. aq,mt[,ocshtlloyr~a-laktallmep!lla:unrtys the asbestos-ladeo,air before Its relea,e into cleaucd the sur- ltbat maJ<..ehJQrtile and .alkali rounding atmosphe're. Spraying nustlc.. , '. :: . ' . In .the open air has been .an Must Glw Warning' l~sue In many large ~itles, par" ~-lJn~iet .. ~lt .. , aAmcetn.adlmpeendtsbyt.or_r1etsha.e- tlculatly in New Yi!rlL . Most emissions of .asbestos come fro,m mining. and . mill ent .~axo~, ~ ~ 31, .1970, lilg, Mr. Rlickelshaus aaid. 1'b . J]~t ,..'~i,a.l~lalr.bd>UetmnPs~Ob~sUWu~-t~(iaeQrtnirCh~.Y-~;'~"~t~ht!Jadi~_a.ytrh~ee.Jtnta.eun.l.~.y~h~~t.i~~st 11udgmerit, might fn~reaae either sppeasleyitrdiimn. cgawetneovdtu.rJldatohv.r.-e~r~tqhtene:l~!n.!1C!.O-Jt~~etn,o-t.hfss~.. cU:!oo_.Imnhi_eg" price. . : . 1 11 lily, serio.US". irre,versil;lle f'or b.erylllum, .tJte emisSion . w.~ ~s~r.incaWl~~tin&Jllnes~. u~~ thJS,\llst. periodi yi.thln-1lil!.) .A . dan .of. J?Ublish bsooteftanaatldnmraaclovcdvereortargograrea.,m,3mo0tpo.-dpesanrt ye-cD:uhPbiaue1n.rcrif,<i.sd?mdr,eewdtloetlhrr~'11t the llst. the, .Admm1strator ~ to_pu)l,Ush P.roposed Br stltnd~ .f9r these a short.term expo~ure of 25 microgfa!nS ~ :"~il'bic jneter for a n)axlnllUJl of ~p. tnmutes. 1 1I ts. WlthJP). SO daya of . For me~. tbe, standards , ishing th~se,p he must set are desl$lled t~)nsure that at : . e ij.nd place, fo, public mosphenc concen!t&tlo~ do gs ..~ ,th~. an!i. ~n not exceed one microgl'41n per i~ ISQ days iss~ final cubic meter .f!.f ati' averagl!& dards. . .. over 30 days. . :, . '' t r..J~cll 3\, Mr. Ruckels- For merc\11}' mines, the cQst issupd an inltla,L list of of meeting ltll.e stanliards' will ' nu that Jn,~uded asbes- be 2.5 to 3.5 per cent of pro . 1If berryUiU~...~d merc11ry. due.t worth, and for chlor~~ ; proposl!d' ~tandarcls were kall plants .5 to .9 per cent Ol' : ~ be pu~lisl\ed on Sept. product worth. '1 FMS\ 02879 . F:ll. 11-1-1 bPt o~. LlrBa~- A.s~r.s'"o.s ey.P..s..u Title 41-PUBLIC CONTRACTS AND PROPERTY MANAGEMENT Chapter 50--Public Contracts, Department of Labor PART ~0-204-SAFETY AND HEALTH STANDARDS FOR FEDERAL SUPPLY CONTRACTS Standard for Exposure to Asbestos Dust Pursuant to section 4(b) (2) of the Williams-Steiger Occupational Safety and Health Act of 19'10 (84 Stat. 1592, 29 U.S.C. 653>. 50-204.50 of Title 41, Code of Federal Regulations. 1B hereby amended in the manner indicated below in order to prescribe a new standard limiting the expooure of workei"ll to asl.le~tos dust. The new standard llmit.ing the cxpo.,ure of employees to asbe.~too dust is that adopted uncler &cctwn 6Ccl of the WUllams-Stelgcr Occupational Safety and Health Act of 1970 and published 1n the FEDERAL REGISTER on this date. The standard 1B hereby determined to be more effective than that presently provided under 50-204.50 to the extent that it prescribes minimum kvels of exposure to nsbestos dust. Therefore, bY operation of section 4<b) <2) of the Act the new standard Issued under section 6(c) supersedes the construction safety standard relating to exposure to asbestos dust. _ Section 50-204.50 Is amended to read as follows in order to apply the new standard Umiting the exposure of workers to asbestos dust: 50-20~.50 Gases, vapors, fumes, dusls, and mists. <a> (1) Expooures by inhalation, ingestion, skin absorption. or contact to any material or substance (1) at a concentration above t,hose specified in the '"Threshold T.Jmit Values of Afrboruc Contaminants tor 1968" of -the Amcrlcnn Conference ot Oovernmeutal Industrial Hygteuists, (l;I[Cept for the ANSI Standards listed in Table I of this section a~1d e~cept for ~he values of mineral d~ liSted in Table Il of tblB section, and 01> concentrations above those specified' tn Tables I Blld n of this .section, shall be avoided, or ):lrotectlve equipment shall be provided and used. <2> The requirements of th~ section do not apply to exposures to :airborne asbest-os .dust. Exposures of employees to airborne !1-Sbestos dust shall be subject tp the requirements-of 29 CFR 1910.93a. <b> TQ ac~eve cOmpliance with para- graph <a> of tJUs section, feasible ad- ministrativeor engti),eering controls must first be determined and implemented tn . all cases, In cases whel1! protective equipment in addition to..other measures 1B used as the method or protecting the employee, such protection must be approved for each specific appllcation by a competent industrial hygienist or other technically qualified souroe. 1.1 TA!ILB 1!-MINR"RAL Dos'l" Mppel Blllca: CmtaWno: 'iff=Quam (""'plrnble) .7.. ___260_..:.~-'0ul.i/W-=~- Quorta (total dust)'::~~~:':':~. Crlstobllllta: Uao J.<J t.he valne oalmllated trom t.he count or mnss formulae !Or ~=to: Uoo j.<j t.he value calcnlated bom t.he lor~ mulao lor quartz. A:morpbollS, lnclnd!ng natural .. d.latomoceons earth _ Sllh:ates (IOSI! than 1% crys- ~fS~o~a'ps:t"o!ne..'. _._._._._._..__:_._._._._.."-.'. r21o1 TPoalrctland ----- eemen&. _ . . . 20 . 60 COYm:..r,.d\l~te~(~nPa~~>s--l-~-~~-~, u . . . : . 2.4m&tw P~moretb&n~%.8102__,._~-------------- . ~ Inert or Nnlsaooe Dust: Respirable fraction Total dUS'----------- %810;+2 18 Bma/MI 60 ~- Aerodynamic diameter (unit density sphere) 2 2.5 J.ft 6.0 10 . Per~hJ ..90 76 :1m10 0 'lbe meO.sutemenls under Gila DOte l'llfoio Ill. 11M __ f1l 1U1 ABO IDotmment. J1 &he noplrable .fncUoa otoeal d._iJll3t Ia til tba& d~e:t<ulr~mlntd w~ilhn.aeMtabRleBloUr c.oael ll&IsmunMltJ~M~1 . EDective dau. This amen.dment shall Decome efl':eetlve upon publication in the FBDEII!\L REGISTER (12-7-71): . (Seo. 6(ib) (ll). 84 stat. 15911, llll u.s.c." 1163;" Secretary's Order No. lll-'ll; 36 PA 87154). -: cmSyiogfnlDidecaetmbWeer shington, 19'11. . . D.C., . this 2d .. 0.- C. GUENTHER; .. .Assistant Secreta111 of Labor. .IPR Doc.7I-17834 Filed 12-6--71;8:47 am}' '' . " .:.!< . I' FMSI 02880 12-1-, I bcrPr P l~&o.c. ASIJI StbS- COt-~.lf~Tf"" .. Signed a~ Washington, D.C. this 2d day of December 1971. G. C. GUENTHER, Assistant Secreta111 of Labor. (FR Doc.71-17835 F1lc<112-{I-71;B:47 o.m) Chapter XVII--Occupational Safety and Health Administration, Department of Labor PART 191 0-0CCUPATIONAL SAFETY AND HEALTH STANDARDS Emergency Standard for Exposure to Asbestos Dust Pwsuant to section 6<c> of the WJJliams-Steiger Occupational Safety and Title 29-LABDR: Chapier X.III-Bureau of labor Standards, :Department of Labor PART 1518-SAFETY AND. HEALTH REGULATIONS FOR CONSTRUCTION Standard for Exposure to Asbestos D ust Pursuant to section 4<b> <:n of the Williams-Steiger Occupational Safety Health Act of 1970 <84 Stat. 1596, 29 u.s.c. 655>. Part 1910 of Title 29, Code of Federal Regulations <36 P A 10466, May 29, 1971) Is hereby amended 1n the mmmer indicated below 1n order to pro- vide n.n emergency stanc.lard dealing with the exposure of employees to asbestos dust. In light of increasing information on the results of exposure of employees to airborne asbestos dust, including recent studies by the National Institute for Oc- cupational Safety and Health and others, and recommendations by the Amerlcan a29ndu.Hs.eca.l6th53A),c1t 1o5f181.95750of<8T4itSlet at. 29, 1592, Code Conference of Governmental Industrial Hygienists <ACGm>, it Is hereby deter- of Federal Regulations, Is hereby mined that <1) exposure tmcler the pres- amenc:U:d In the manner Indicated be- ent standard !or asbestos dust In Table alorwo In order to limiting the prescribe exposure a new standof workem to G--3, 1910.93, of 12 fibei'B per mllllliter greater than 6 npcrons 1n length or 2 asbestos dust. The new standard llmJt- mllllon particles per cubic foot of air, J.ng the exposure of employees to asbes- whlcb Is derived f110m an established Fedtos dust Is that adopted under section eral standard promulgated tmder the &<c> of the W1U1ams-Stelger Occupa- Walsh-Healey Public Contracts Act on tio~ Safety and Health Act of 1970 May 20, 1969, constitutes a grave danger and published 1n the F'EDKRAL REGISTER tc) employees exPOSed to this 8-hour on this date. The standard Is hereby de- time-weighted average concentration; termined to be more effective than that and that <2> an emergency standard Is presently provided under 1518.55 to necessary to protect employees from this the extent that it prescribes mln!mwn excessive exposure. The National Instllevels of exposure to asbestos dust. tute tor Occupational Safety and Health Therefore, by operation of section 4<bl concurs that the proposed change 1n the <2> o! the Act the new standard lsBued asbestos dust standard recommended by under section 6(e) IIUPCr&edes the con- the American Conference of Governmenstruction snfety 11tandn.rd relating to ex- tal Indw;trial Hygienists should be the posure to asbestos dust. Section 1518.55 ts hereby amended by adding a new ~graph <c> thereto. All amended 11518.55 reads aa follows: &ubstantial base for the emergency sta.nda.rd. Action concerning the standard w1ll be commenced tmder section 6(bl 1n the 1518.55 Gases, vapors. fumes, dust.s, llnd mi~ts. <e> Paragraphs <a> and <b> of this sec- tion do not. apply to the exposure of em- ployees to airborne asbestoo dust. Whenever any employee Is exposed to airborne immediate future. Any notice of proposed rulemaking tmder section 6<b> will give notice of the emergency standard as a propoged rule and also of any appropriate subsidiary proposals which may be required under subparagraphs <5> and <7> or section 6<b> relating to the exposure of employees to toxic substances. asbestos dust, the requlremepts of Part 1910 Is amended as follows: - I 1910.93a of this title sha.ll apply, 1. Table G-3 following I 1910.93 <36 P.R. 15104, Aug. 13, 197U Ia hereby Effective date. This amendment' shaD amended by deleting the :!allowing: become effective UPOn publlca.lil.on in the Asbesto&-lllll.benl pezo mflllllter greater thaJ&. F'EDERAL REGISTER <12-'l-'11>. 5 microns m length Ol'--1.-----~ 2 Mppct. (Sec. 4(b)(2), M Stat. 1592, 29 U.S.C. 653; Trenwl1te ______ ______ 5- Mppcf. 20mg./M" B<!aretatTa Order No. 12-n, se P.R. 8154) ~-rue;;- FMSI 02881 -- I=". f. 12_,_,, t) t-f!"T oc t..Atl aL - 4s .s hotJ" c.~ .-rc..,c'71o..J As amended, Table G.:.a reads as be used to meet the exposure limits pre- comply wltb t~ requirements of these follows: scribed in paragta.ph <a> of this section. subparagraplls relating to, the operations Where such e'ngtneerfug methods a.re not involved. The req~e:nts of this para- feasible, CIT do not otherwise reduce the graph are in addition to those prescribed Sub.tanoo Mppef concentrations below those prescribed in in paragraph <b> of this section; paragraph <a> of this section, respira- (2) All hand- or power-operated tools Slllo": . .. Crystalllne' Qaartz (Nsplrable)........ . tory protective devices shall be provtded which produce asbestos dust such as, but and used in accordance wU.h paragraph not Umited . to, saws, scorers, abrasive 2Sl' lflmWM' <c> of th1s section. wheels, and drills shall be provided with QtllllU (total dust)~: ~~~-~~- ~; <c> (1) (1) When .the limits of exposure to a.Sbestos dust prescribed in local exhaust ventilation: and dust collectors in accordance with the American Crlstoballte: Use !1!1 the .. valui> calculat.!d fiom the count or msss .lonnu.tae (or ~=te: U;,.,!l!ithevahle enlculstA>d from lbe rormnlse lor quartz_ Amorphaos, lnclndiilJI: natmal. %S.Oo+ 2 paragraph <a> of thiS section are exceeded. and when engineering controls requirecl by paragraph <b> of this section are not; feasible. CIT do not otherwise re- duce the conCentration of asbestos dust below those p'rescribed in paragm.ph <a> of this section, the employer shall re- dlstomll<EGUS oanll ----- 20 IIOmi:IM' QUire the use of respiratory protective de- %810 vices. The selection of respiratory fHllcates 0(\."\S thtW: 1% crya- tnllinesllica)c pt-otective deyices shall be limited to those specifte<i in the remaining sub- MS olaopa s. t on e___-_-_-_-_--------.-- TPcolret.l.a.n. d--ee-m- -e-n-t-_-_-_-_-_-_-_-_--_-_ :Ill 20 :Ill '81 paragraphs of this pare.graph <c>. <11> The employer shall require that each employee test his respiratcsry pro- Graflblte (natural)----------- 16 Coal dnsl (respirable fmetlon less thanfi% 810>).:----------------- 2.4mgf!,p tective device before each use In csrder to 1nsure a proper fit according to the shallFormorethsn~Sto,____________________ lOomr aJU" mplaonyeurfacturefru'srthienrstprurocvtiiodnesf. orTehfefecetmive- National Standard Fund!Unentals Governing the Design and Operation of U!cal Exhaust Systems; ANSI Z9.~1S71. (3) Employees e~ .to tbe spraying of asbestos or the .demolit1on of pipes. structw:es, or equipment cov~red .or in-. sulated with asbe.stotl! shall, be provided with reap~tory J,Jrotectlve devices in accordancp with P!'J:a.u'raph <c> <4> ot this section. . , <e> Asbesios cement, mortar,coattnga, grout, and piaster shall .tie mixed in closed bags or othercontainers. ' (f~ Asbestos waste and serap shall be collected and diSposed of ln''sealed bag!i or other COI:\tainers. .~ .. .. . " ., ' <g> Au cleanup of asbestoS dust \lu<i ... 1~~~~:.:~... ~ dust.---------------- 16 81 %BIOH-11 . tra.i$g or superv1sion of employees in .'~.. the testing of respiratory protec1llve de- .........~- vices for fit before their use. blow~ shall be ~ornied, by vacuum cleaners. No dry sweepln,g"' sh,al.l be per~ formed. : , . . <2> For an atmosphere containing not 3. Section 1910.12 Is'. amended by Non: Conversion factors-- . llllPP<lfXU.B-mlllion Jl6rtlc!M por oublo meter "'!'Utticles per o:o. Or Mlll!ons particles per cnblc toot of air, based on Jmplnpr 1!8Dlples countod by Ugbt.-fleld loohnlos. ' The peroontnge of crystalline silica lq.,.the .fom)ula t=.::r:;elh~:~~~~~~b~~th~~::~r;~ $lin: :n:iemb~ rutet molliO<I at 43!1XJ)basa contrast mngnlllcatlon. eau!"!r~~~~~d:n:fn~"g,"m~:~f:~ passiilJI: a slz"""lector with the following characteristics: more than 26 fibers per milUUter greater changing paramp~ <al.ln.'o~;der to apply than 5 microns In length over an .8-hour . ~e emergency standard prescribed in the average; or more than 50 fibers per milli- new 1910.93a. whic:h is published m thts Uter over any period of 15 minutes, a document. to eoristruct.ton work whicb iii reusable or Bingle-use fllter type respira- tOr, operating with negative pressure subject to the Act; Tlte 'amendment Is necessari 1n light of the 'rule of regula: duringthe Inhalation phase of breathing, a.Pproved by .the us. Bureau of Mines tory constructionsej; torJ;h Uil1910.5<c>'. As amended, t 1910-U. reads: a,s .follows,:: w9d.. .. .under the provif!oions of 30 CFR Part 1~ <Bureau of Mines SChedule 21B>, or a 19lo.I2 Cons~~D anavalveless respirator providing equivalent ca> U> Adoption extensiim of es.: ana;protection, shall be used. tablishell safety' health standards Aerodl'1lllmlo diameter (unll donslt:v llhere) P.,..cnt passinK solocliar . <3>. For an atmosphere conta4ning not tor construction. The:. standards premore than 250 fibers per millUter greater scribed by. Part 1518 of thls~title and In than 5 microns in length over an 8-hour effect on April 28, .1971, are adopted . , 2 of2.6 !10 76 average, or more than 500 fibers per occupa,tlonal safety or. health standarllf milUUter over any period of 15 minutes, under section 6<a> the Act and sh~. 3.5 81, 6.0 26' 10 ~- otThe m085tll'<!IIlents under Ibis note refer to lbe use of adtonntshAlalsEt dCoft2Ie.nr4smMtrlungmc/Mdewniltni.thtUhaetMtbeeRblrEeerstophriercaofibog.l!uedreufrsCntOcItrslrotU!n9'PMOInUdc)4o_1on.aJ!( 2. A new 1910.93a is added to' Part 1910. The new 1910.93a reads as follows: ' a powered 1llter positive pressure. respiratcsr approved by the U.S. Bureau of Mines under the .provisions of. 30 CFR Part 14 <Bureau of Mines Schedule 21B> shall be Used. ' . <4> FCIT an atmosphere containing more than 250 fibers per milllllter greater than 5 microns in length owr an 8-hour average a type C positive pressure supplied-air respirator approved by apply, according : .to the provisioria. thereof, to every em.ployment and place of employment IJf .every employee en~ gaged In construction, work!: Each e~. ployer shal.l protect the ~ployment and places of emplo~t (Jf each of his employees engaged 1n cOnstruction work by complying with tpe. appropria~ standardll.prescribed bythia.paragraph. (2} The standards pfescribed in l910_.93a .Atibee,toa dust. the U.S. Bureau of Mines under the provisions of 30 CFR Part 12 <Bureau ot {a) The .8-hour time-weighted aver- Mines Schedule 19B> 'shall be used. age dus t a irb to orne whic concent.ra.tion h eul.ployees o~ are !1bestos exposed . <5 ,. The employer shall establlsh .a respirator program. in accordance with shall nat exceed -5 fibers per. milllliter the requirements o! American Na.tional 11518.55(c) of thls title shaU BPPlY In the case of the exposure of any em- ployee 1n construction work to alrbon'le asbestos dust. M.. ' greater than 5 microns In length, as de- Standard Practice for Respimtoty Pro- . Effective date. These 'amendments termined by the membrance fllter tection Z88~1969. ' shall become effective immediately upon method at 40~50X magnification <4 <ID The l'eSPh:ators 'provided each em- pubH(lation in ,the ''!WBilii. REGISTE!l millimeter objective> pba.se cOntrast illumination. Concentrations abQve 5 fibers per milllliter but, not to exceed 10 fibers per mil.l.lliter, may be permitted UP to a total of 15 minutes In an hour for up to 5 hours in an 8-hour day. <b> Engineering methods, such as but ployee shall be properly inspected, (12-7-71>. are stored.Cleaned, repaired and <d> (1) When an employer has e!ll- .a(Sec. 6(c), M Stat.-1696, 29 u.s.c. 665~ Sec- . retary'11 Order Jif(l. 12-'1~1 36 P 87M) ployees who exposed to asbe,stos dust exceeding 'Ute lbDits prescribed in paragraph <a> of th1s section and the ex- 811J11ed ai Wll.llhingtop, D;C., th19 2d day orDecembet 1971. . posure iesults from the opera.tiODB de- G. C. Gt1BNTHBR, not limited to, enclosure, \18Cllum sweep- aartb6d. in the remainlng aubpa.ra.grapha Asristant Secreta.t'11 ot Labor. lng, and local exlJaust ventilation, shall of this paragraph <d>, ~employer shall Lft'Doc.'ll-17838 Pllecl.li!-CI-71;8:4'1 am] 3.A FMSf 02882 Room 512 :J.,.iction fflate,.ia~ Stancla~ !ln:Jtilute, !lnc. 370 LEXINGTON AVENUE NEW YORK 17, N. Y. September 30, 1971 MUrray Hill 3..0572 To; Members of Asbestos Study Committee Subject: Proposed Emission Standard for Asbestos Gentlemen: In line with the discussions at the September 15, 1971 meeting of this Committee, Dr. Stefl, Chairman, is forwarding the below listed write~ups to the members of this Committee. We do not intend to distribute this data to the membership at large until the Committee has had the opportunity to review both the Federal Proposal and the draft of the AlA Comments and Suggestions. (1) Proposed Environmental Protection Agency Standards for Asbestos Emission. Comment: Dr. Stefl felt it worthwhile that the Committee see this draft copy, but he is certain that the Federal Standards will be quite different. (2) Comments and Suggestions from Asbestos Information Association/North America. Comment: These are the AlA Comments and Suggestions made regarding the initial draft of the proposed Federal Standards at a meeting held in Atlanta in mid-August. Dr. Stefl further advised, and this is to be considered confidential, that he and others from the AlA met with members of the Illinois Pollution Control Board on September 17, 1971. At this meeting he was advised that hearings would be held at three locations on different dates in October, and that AIA/NA would give written comments at the October 15 meeting in Chicago. Personnel on the Control Board had received comments from the motor companies on the brake lining ban. They were not aware of the E.P.A. tests on asbestos emission from brake lining that are being run by Bendix Research Laboratories. Copies of the minutes are enclosed. Sincerely, ,;.~}-' _9 EWDrislane/icb Messrs.: E. P. Stefl J. C. Henning E. H. Feierabend W. B. Reitze E. Spurgeon J. B. Graham, Jr. J. W. Greenan, ex-officio L. D. Stickles, Counsel Executive Secretary Raybestos-Manhattan, Inc. Firestone Tire & Rubber Company Abex Corporation Johns-Manville Corporation The Bendix Corporation Carlisle Corporation Maremont Corporation Stickles, Hayden, Kennedy, Hort & Van Steenburgh ,~ "Ic\ \_ FMSI 02883 '} November a9, 1971 Mr. Samuel T. lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicaao, Illinois 60602 Dear Mr. lawton: I realize that by this time the Illinois Pollution Control Board may have already acted on the proposed asbestos regulations. As most of the domestic brake lining and clutch facing manufacturers are members of this Institute, we are particularly concerned with Part VI I, Paragraph 702, of your Proposed Regulations on Asbestos: The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975 and sold for use in Illinois is prohibited. We were able to alert our domestic members as to the seriousness of these proposed regulations. We are aware that some of them expressed their views directly to you. In today's mail I received the attached from the British Friction Materials Council, an oraanization similar to ours in Britain. I think it is a well wrltten,,carefully worded and, I believe, well documented presentation. Having worked in the brake lining industry for over seventeen years with asbestos linings and metallics, I believe their Item #2 is most pertinent. If one measures the amount of free asbestos fiber in brake lining dust, they say it is about 1~ of the total products of ~ear. Were you to go to a brake relining shop and collect the weer remnants, you would not detect fibrous material in the wear products. The dust appears more to be like a talcum powder or flour with no fibrous structure evident. We trust that this work by the British Council be considered when you are drafting your final regulations. Sincerely, EWD/iob Encz E. W. Dr is lane Executive Secretary FMSI 02884 fRICTION MATERIALS STANDARDS INSTITUTE, INC., 370 LEXINGTON AVENUE, NEW YORK, N. Y BULLETIN N 0. 4 1 7 November 10, 1971 MEASURBAENT OF ASBESTOS FIBERS IN THE AIR Since the organization of the Asbestos Study Committee it has been suggested that all members be advised on monitoring asbestos fiber concentrations in the work place. This should be of interest since the Occupational Safety and Health Act of 1970 was effective on April 2$, 1971. Mr. William Reitze of Johns-Manville addressed the June meeting on this Act and subsequently we distributed literature concerning the Act and Threshold Limit Values. Mr. Reitze advised that there was a guide published by the Asbestos Textile Institute: "Measurement of Airborne Asbestos Fiber by the Membrane Filter Method." Source: Asbestos Textile Institute P.O. Box 239 Pompton Lakes, N. J. 07442 ..Price: $1 .00 Mr. Reitze cautioned, however, that this document might be misleading if personnel doing tha work do not have the proper background or training. For this reason, Mr. Reitze would be willing to give a talk and demonstration, including a discussion of materials, methods, costs, personnel requirements, and legal aspects. This would not be a training course but would be an information session where those responsible for making decisions could be given enough information to decide which course their firm should follow. There would, of course, be no charge for this presentation. If there are members of your firm who would be interested in such a session please advise. It generally would be planned to have the session, if interest is sufficient, sometime after mid-January in the New York metropolitan area. As Mr. Reitze now must travel in from Denver, it would be important for those interested to indicate rather positvely their intentions as regards attending such a session. Distribution: Active Members Asbestos Study Committee E. W. Drislane Executive Secretary FMSI 02885 l I 'I ~ ... ' ~I CT ION MATER! N.S 5TANPA$S I NST !TltrE. INC, 370 LEX! NGTON AVENUE. t:.EW VCR<. N, Y. 11um-i~. !2-~;:ce. I _AH~ j, ~-- '81 BULLETIN N 0. 4 1 6 October 28, 1971 PROPOSED !llii\OIS BAN ON ASBESTOS IN BRAKE LINING There has been considerable activity by members of the Asbestos Study Committee as regards the proposed Illinois regulations on "Asbestos and Spray Insulation". To quote from Part VI I, Section 702 of the regulations proposed by the Illinois Pol- lution Control Board: "The use of asbestos in the brake linjng of vehicles;manufact.ured after January 1, 1975, and sold for use in Illinois is prohibited," In the Board's explanation it notes that the prohibitio~ is worded to avoid the necessity of fitting vehicles manufactured prior to 1975 with "non-asbestos" brakes. ~owever, there is no question but that the ban includes original equipment linings, and there can be little doubt but that replacement linings on these vehicles must also be of a "non..asbestos" type. Further, interpretation of the proposed reg- ulations indicates that all vehicles are included: Passenger Cars, Trucks, Off High way Equipment, Farm_ Tractors and the like. Also, the Board apparently coQsiders "clutch facings tobe the same as brake linings". While the immediate effect would be on those supplylng original equipment linings, the secondary effect would be felt by all friction material manufacturers. In the Board 1s explanation they state: "These prohibitions have been made with full consideration given to the available alternative materials." From the Illinois hearings this pa'st month, the Institute has received several articles of interest: (1) Johns-Manville memorandum, October 20, 1971, by Mr. Swetonic summarizing the Chicago hearingson October 15, 1971, (2) Wr i Hen presentation by Dr . F. Pundsack of Johns-Manvi 1'1~ as given at the Chicago hearings. (3) Dr. W. J. Nicholson, Mt. Sinai Hospital, a presentation in support of the Board's regulations, at the Chicago hearings. (4) Chicago Sun-Times October 18, 1971 report on the Chicago hearings. ~ (5) Waukegan newspaper report of October 20, 1971 concerning the hearings in Waukegan. (6) Johns-Manville memorandum, October 20, 1971, by W. Raines summarizing ,I . ' - the Waukegan hearing;on October 19, 1971. ,..... Attached to the delegates copies only of this Bulletin are excerpts: . .Jf ~ (1) Entire J-M summary of the Chicago Hearings - Continued - FMSI 02886 ,. dullet in #416 -2- October 28, 1971 (2) Entire J-M summary of the Waukegan Hearings. (3) Pages 20, 21 of Dr. Pundsack 1 s presentation at the Chicago Hearings. All those who have appeared at the hearings feel it is most urgent that the brake lining manufacturers advise the Control Board of their position on this proposed ban. It has been learned that the Control Board was surprised over the lack of response to the brake lining ban from friction material manufacturers. Realizing the unreasonable deadline you must work against, comments should be in the hands of the Pollution Control Board by November 10, 1971. Please write: Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 The comments must be your own. We suggest that the prim~ry force of these comments might be the lack of availability of known substitutes at this time. A secondary point might be that the Federal EPA (Environmental Protection Agency) is currently having studies made concerning the extent of emissions in the general environment from brake li~ings, and these results will not be known till mid 1972. Unless you have specific medical background, we suggest you not question the proposed safety standards on asbestos concentrations. Further, as is the case with ~ost government bureaus, ~ny pleading on cost or economics should be avoided. Please note that the portion of~he proposed regulations that we are concerned with at this time is the general environment from brake lining emissions on vehicles in use. While the in-plant environment is also covered in the proposed regulations, we are advising our members ptimarily on the proposed ban on brake lining on vehicles. Should you write Mr. Lawton, it would be appreciated if you would send a copy to the Institute. If there are any questions, please give me a call. E. W. Dri slana Executive Secretary Distribution: Active FMS\ 02887 boo: itr. o. J. Weber Mr. o. tt. MUler Mr. G. t. WUson - Plt. I, Ak::ron .....--Mr., !.., w. Drislane ... FMSI -w.r. f" a:Nuel. 1'. tawtoa %ate of nUnob Pollution Ooatrcl Board 189 w.t 'M'd:tnn St7Mt SuUe 9) etdcago1 nUMb 60602 As a ..-nuf'act.u:rer of brake linin&, 1t. eu.e ae a 'lomplete shOGk to 'WorU '!mnoa 0~, Dirllrion of The "fi'irest~ Tiro & Ru'bbo.J" c~, t.o l..m of t.he ~ed l-''TS retttn.ct1cm ot the ue of ubeatu a the ~. ll.ning of vehicles meld ror ue a Ultnc1. 'For ne a widel;r at.reeting replat.1<m to have 'been propo$oo must '!lmre bllllul bued on a aubstantial .-unt ot daum.in~ maence of em uneqllivocal natun. ~. would like to be nppl.ied a llit ot :l"'ef'&"Mces or still b.tt. copies of all NietUu data upon llldeh \he pro a,o!Miil npl&Ue wu 'buecl 01" aNd u nppcrt eo tba.t w on 11a.k41o ft'l' ._~of sait data 'bq1n om' al\e'!."Utiw re~ Pli"'VD ~1&~. It then st.ulio for whieh the rephtlcms wn basH 1IJ*l are iftdu4 scistit':tc~ reliable, t~ a three~ w.'ltug perl~ is 1ll question. au you upld.n bow the thrtJe rear figUe vae a:rrived at and tbe thmldng and reumd.ng for such a rlelay and ~ period'l FMSI 02888 We ~ aln like t.o have made ti.VaU&'blE~t that. 1nfonrJatiu rre- pHlft\1 w1U.\ll.e avaUa~ d.t.enatlft -.n&1a ac1 - . ' - ' at&~.._ -.n&la. ~~ w ..:W lib H ... an11allle . . 1IIWt1l ~ . . al.~ utorl.alll 1a Wtlb :Un:IRC ~ . . . M Z'.,....lllit et ~ ~ tnt ad ~- 1ll4oor ~'mMODM\v tuta. We should lib "' uy that rol\~renco lifhioh w h.a'Ye eMil III.M :s.re aw.:re ot do w.t nam tnn bnke l..t.M.rt,; 1ni.tme . -... ftitl$te; 1m3" mhft Mal~ hoard. Th~on,- fel that~ propct~Jcd X'Ct;Ulation will not aoctMPliab in fact ita inten' {that 11, to r-.e ubutos le"t$l.a ill bien\ ail') tbrotstl\ Web d <H'Ui..Ct.~t. In eonelutt.ion cur ob3enation at tM pruent tiM u that ~ p:ro:pocrc Ngulatioa 1UJ r.. bl.eed em mnppurted alld ineutfb>ientl;r mmob.o~~r~&hctmdw data tc 'Rrtll.nt :JlJtm ~tve ac\1011 _. th ~to ot J!!Wrlka Attachment . .-~iCHU' T;?~1TOS CCl{FA.U'!. r~.u_/ C' :,:d:M~r Jaes c. w .M~ 1~~r, 'i'$ChM.oal-lf.eftU"Ch FMSI 02889 M8R9MONT COR PO RAT 0N 1158 NORTH MICHIGAN AVENUE CHICAGO, ILLINOIS 60601 TELEPHONE (312) 263-7676 November 5, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: I am writing you to register concern on the part of Maremont Corporation relative to the proposed Illinois ban on asbestos in brake lining, effective after January 1, 1975. Marernont currently produces, under the brand name "Grizzly", both passenger car and heavy duty vehicle brake lining for the aftermarket and has been a part of the Friction Material industry for over twenty years. We are most concerned with this proposed legislation since it is our combined technical opinion that there is not, at the present time, nor will there be in the foreseeable future, a suitable alternative to asbestos in friction material that will yield the performance characteristics required in today' s braking systems. Further, proposed federal improvements in braking systerns to be effective after 1975 will require those manufacturers now participating in the industry to devote their time and energies to sophisticated improvements within an asbestos based product, making the research for an asbestos substitute a goal beyond the available technical abilities of most manufacturers, should that substitute really exist. Mr. Lawton, I would appreciate your continued review of the matter and hope that Maremont's concern will be given appropriate consideration. Sincerely, AAL/gjk bee: R. B. Black/J. W. Greenen F. C. Skelton/E. Drislane Andre A. Laus Vice President and General Manager Brake Systems Division FMSI 02890 AUTO FRICTION CORP. MANUFACTURERS OF BRAKE LINING November 3, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 185 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: It has come to my attention that the State of Illinois is considering regulations or legislation which would prohibit the use of asbestos in the manufacture of brake lining for use in your State. I also understand, that there was ~ certain amount of disappointment expressed by members of your Board that there was a lack of response from the friction material manufacturers. The reason that we have not responded before this, is that until I read a recent article in Chemical Week Magazine, I "as not aware that regulations or legislation was being promulgated. I may state quite succintly two basic objections to this proposed regulation or legislation on the part of our Company: 1. There is a complete lack of availability of a known substitute at this time for asbestos in the manufacture of the broadest range of friction material products for safe and accepted use in automotive vehicles. 2. The Environmental Protection Agency of the U.S. Government has presently commissioned studies to be made concerning the extent of emission in the general environment from brake lining. The results of this study will not be reported until mid 1972. I appreciate this opportunity to inform you of our connnents, and remain, Sincerely, AUTO FRICTION CORPORATION Norman Comins Vice President bee: Mr. E. W. Dris lane 1 FMSI, New York NC/ah 651 ANDOVER ST, LAWRENCE INDUSTRIAL PARK, LAWRENCE, MASS 01842. TEL. 6171686-3326. CABLE: AUTO FR TN LAWRENCE FMSl 02891 (201) ARMORY 86655 45 EAST 5TH STREET PATERSON, NEW JERSEY 07524 QUALITY FRICTION. MATERIAL.$ SINCE 1919 _ _ _.... ~ ._.__... ..-.-... - .. ..__....... ~-- '- c.,; .N... >.' , Nov. 8, 1971 state of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Att: Mr. Samuel T. Lawton Gentlemen: As a brake lining manufacturer whose product contains asbestos we are much concerned over the Illinois Proposed Ban on Asbestos in Brake Lining, particulated by Part VII, Section 702 from the regulations proposed by the Illinois Pollution Control Board. our company, and our industry as an entity, is definitely not interested in procucing products which will have harmful emission effects in the atmosphere. But we do believe the above cited section of the proposed law does not have evidence to back up its severity---evidence that proves a harmful emission-factor as a result of/or because of the asbestos content in friction materials. On the basis of reports of testing emissions we believe that although ~t is within the power of the State of Illinois P6llution vontrol Board to have asbestos banned from brake linings, we feel that to do so would eliminate an effective and useful brake lining component without justification. We are certain that many of the emission tests have been forwarded to the Board, and that the Board is aware of the tests of emissions now being made by the Federal Environmental Protection Agency. We believe that this data will be most helpful in determining the effects of asbestos-emissions from use in brake lining, and will establish whether these emissions are of any danger or if they are negligible. FMSI 02892 ~_,}ASSBESTOS (201) ARMORY 86655 45 EAST 5TH STREET PATERSON, NEW .JERSEY 071524 If the emissions prove to be a harmful pollutant our company will certainly support your Board in eliminating this hazard. But until reliable evidence supports this possibility we are reluctant to accept any unsupported position. Our company has been producing brake linings since 1919. (The basic company was formed in 1917.) During this span of over 53-years we have produced hundreds of millions of feet of asbestos brake linings. In our process, we deal closely with raw asbestos fiber. Of course, we use protective measures in handling these materials---as well as other fine powders. , \'fe have never had, in our history, a case of asbestosis or any other asbestos-induced illness among any of our personnel. Webelieve this record is not uncommon among brake lining manufacturers. We are aware of the fact that in other industries who use asbestos there are systems which do not control or contain the material. However, our chief concern is with the brake lining industry, and the effects in the atmosphere of the use of asbestos in brake linings. We believe that the asbestos is locked-into the brake lining material, and that during its normal usage the heat of the friction converts any residue into an inert non-fibrous material which will not be hazardous in nature. We look to your Board for a full analysis of this matter, and a just decision based upon proved and repeatable data of a factual, non-emotional, nature. very truly yours, BRASSBESTOS MFG. CORPORATION WILLIAM SIMON President S:g FMSl 02893 Abex Corporation November 8, 1971 Research Center MAHWAH, NEW JERSEY 07430 Tl: 201-529-3450 Mr. Samuel T. Lawton State of Illinois Pollution Control 189 lest Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: In conjunction with hearings recently held regarding Regulation No. R71-16 "Asbestos and Spray Insulation" proposed by the Illinois Pollution Control Board, we believe it. would be helpful to you to have our comments as a major manufacturer of friction material. The Abex Corporation, through its American Brakeblok Division is one of the major suppliers of friction material for brake and clutch use in the United Stntes. During 1971, our sales of asbestos containing friction material for use in vehicles operating in the United States will be in excess of 20 million dollars. Our interest is specific to Part VII, Section 702 of the proposed regulations \qhich states "The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975, and sold for use in Illinois is prohibited". Our comments are as follows: 1. Asbestos fiber is an important component of organic friction material used in brake and clutch facings for vehicles manufactured and used in the United States. Of known fiberous material, asbestos imparts unique strength and thermal properties to friction lining, in addition to providing unique performance characteristics essential to safe and reliable braking and clutching of vehicles. 2. We are aware of investigations conducted on the nature of wear products from linings in use, as well as the identification of airborne particles from operating brakes. Air sample analysis conducted by our Medical Department to collect wear product particles during brake operation on our laboratory dynamometers confirms the findings of J. R. Lynch as reported in his study "Brake Lining Decomposition Products" published in the Journal of the Air Pollution Control Association, Vol. 18, No. 12, December, 1968. 3. Abex Corporation, in conjunction with Arthur D. Little, Inc., submitted a technical proposal to the Evironmental Protection Agency in response to that agency's request for proposal No. EHSD 71-NEG 102 "Characterization of Emission from Automobile Brake and Clutch Linings". In this way we are well aware of the investigation work now being carried out by the Bendix (Continued) FMSI 02894 Mr. Samuel T. La\\! ton -2- November 8, 1971 Corporation under contract to the Environmental Protection Agency. We understand that results from this contract research will not be known until the middle of 1972 at the earliest. It is our opinion that the results of this study will verify again that airborne particulate matter from vehicle brakes and clutches does not constitute a dangerous health factor in Urban air pollution. We believe that the proposed ban on manufacture and use of asbestos containing friction material is um.-1arranted and unnecessary. We reconmend that Part VII, Section 702 be removed and not made part of regulations proposed by the Illinois Pollution Control Board. Very truly yours, G. R. Graham Director Friction Materials Research GRG:nmp BC: Messrs.: N. G. Belury G. L. Romine F. B. Herlihy E. H. Feierabend E. w. Drislane, FMSI, Inc. w. P. Raines, AlA/North America FMSI 02895 BRITISH FRICTION MATERIALS CouNCIL BAKER, ROOKE 8c CO. CHARTERED AccOUNTANTS TELEPHONE; 01-242 0211 99, ALDWYCH, LONDON, WC28 4JY 362/m/BFMC The Secretary, Friction Materials Standards Institute, Inc., 370 Lexington Avenue, New York, N.Y.10017, u.s.A. 26th November, 1971. Dear Sir, We have been asked by our members in the British friction materials industry in the U.K. to put their views to you on the proposed Illinois State Regulations concerning asbestos and asbestos products. We enclose herewith their comments on the friction material aspect of these draft Regulations. We have no doubt that the American lining manufacturers will be making strong representations to the Illinois authorities for amendments to the proposals and perhaps you could let us know their comments. We shall also be grateful if you could make our views known as set out in this enclosure. Secretaries Enc. FMSI 02896 PHOPOSBD ILLINOIS :.J'l'A'l'E HAN ON A>.om..::.;Tu.S-13A.SBD BHAY.S LININIJS The British friction materials industry views with deep concern the proposed ban on the use of asbestos in brake linings by the ~tate of Illinois. It is not aware of any medical evidence that could possibly justify cuch legislation. On the contrary it would have the effect of withdrawing from the !llarket products that 111ere used to promote road safety, without producing any significant improvement in the levels of urban atmospheric pollution. It would expect any of the known alternatives to asbestos to produce general particulate pollution of a measurable mnount. 1. Whatever materials are used for brake linings the current state of the art is such that the action of braking will generate products of wear. The asbestos content of conventionn1 brake linings is almost entirely converted by the action of braking into forsterite or other amorphous, inert materials which are no longer asbestos. On the other hand, if non-asbestos alternatives are used (e.g. iron powder, sintered metal, ceramics, steel wool etc.,) the resulting wear products will be released unchanged. 2. Measurements have been made of the amount of free asbeuto.s fibre left in brake lining dust. It is an insignificant proportion of what is in any case a minute amount of total dust. 'l'he amount of free asbestos fibre that has been found in brake lining dust from vehicles, is about 1% of the total products of wear. (1). Indeed estimates vary down to 10-9g/g, i.e. for each gramme of wear products only 10-9 grammes of free asbestos may may remain. 3. We assume that the risk of contracting mesothelioma is the principal cause of environmental concern - there is cliearly no possibility whatever as a result of vehicle braking, of a community risk of asbestosis or lung cancer, which are solely occupational risks. For technical reasons only chrysotile asbestos is used in the manufacture of brake linings and disc brake pads. This is not the type of asbestos with which mesothelioma has been mainly associated. 4. Measurements of chrysotile asbestos in the ambient air in an industrial centre in the United Kingdom have shown that the level must be less than 10-7 g/m3 because of the limitations of the method used. This means that they must be a thousand times lower than the British Government acceptable level for occupational exposure. Current investigations using a more sensitive method indicate levels of 10-9 to 10-1 g/m3, i.e. 2 or 3 orders lower still. (2). Brake lining wear cannot therefore be a serious source of atmospheric pollution. 5. In one of the largest brake testing laboratories in the world, housing many dynamometers engaged 24 hours a day in wearing away friction materi<ua, the average monthly asbestos count is 0.2 fibres /cc, a tenth of the British Government's occupational standard. Footnotes 1. Hickish D.l:!.:. and Knight K.L. (1970) Annals of Occupational Hygiene Vol.13, No.1, page 20. 2. Letter to Nature attached. British Friction Naterials Council 26th November, 1971. FMSI 02897  ~;f. TUfif: v:t&l ~3~ NOVEMBER i:l. 1971 93 ./ Chrysoti1e Asbestos in Urban Air THE todustrial usc of chrysotilc a~bestos is increasing and th~ question of whether its concentration in urban air constitutes a h.tzard has been raised. But measurements of asbestos in air ncar asbc;.tos factories have proved oegat~ve with present analytical method,, so under the sponsorship of the Asbc:~tosis Research Councd we are developing a more sensitive teliliniquc. Thts article 1s a preliminary account of the estimation of chrysoTile ncar a large asbestos textile factory at Rochda.le, Lancashire. There arc several uncertainties in the technique, so we were, expecting to obtain only an order of J1.1agnitude estimate. Nevertheless this would have been an important figure to have because of the lack of data on the amour:r of asbestos in atr. As it happen~d. we were only able to det.:rmine an upper limit for the chry~otile concentration which turned out w be three orde~s of magnitude lower than the threshold value for orcupational exposure set by asbestos regulations. Obviously even more sensitive techniques are required and arc now being developed. We used an X-ray diffraction technique based on the measure- ment of the intt:grated area under the (002) peak of chry~otile. The equipment, which consisted of a Phillips 1010 generator, a vertical goniometer with a step scanning attachment, and a proportional counter with pulse height discrimir.ation, could be reliably calibrated down to 10 J.Jg of chrysotile comrxred with the 1 to 10 mg range reported by Cr:1ble 1, ar.d was cro:;s- checked by estimating the magnesium content of the calibration samples by atomic absorption spectroscopy. Sampling involved the collection of airborne solids from 1,000 m~ oo~ l.)'of air by an electrostatic device (H. Litton Systems Inc.) in wbich tip to 10,000 I. min- are drawn through a 20 kV cor!)na dist:h<trg~. Particles in the air are electrostatically precipitate'd onto e. 91~te and concentrated into - 100 ml. of liquid. The collection enicicncy depends on the size -distribution of ofthe particles and the sampling rate, but the size distribution chrysotilc in the atmosphere is not known. Therefore we estimated the collection efficiency indirectly by running the sampler in part of the asbestos factory where a low coru:entra- tior. of asbestos i~ known to occur (Fig. I) and we fount! the collection cfficienry to be almo~t 100% when the air is srimplcd at about 2,000 1. min-, Jropping to between 25 and 50% at the rute of 10.000 I. r.1i:1- 1, depending on the actual size diS antributicn present. As we wen! o1iming at only order of rhagni- FMSI 02898 94 ..... 0 ' Pumping speed (10 3 I./min) Fig. 1 Observed amounts of chrysotile in 5,000 I. of factory air, sampled at different rates. NATURE VOL. 234 NOVEMBER 12 1971 Tobie 1 VI eather Conditions during 'Samplmg Date (1970) Site Wind Weather Apri122 April 24 April 27 April29 May6 May J3 May 28 May 28 May 30 May 30 June 3 June 10 June 10 October 23 October 23 October 23 October 28 October 28 October 28 1 SW moderate Broken cloud 1 sw ~light Ground haze 1 NE moderate Ground haze 1 SW moderate Ground haze 1 S strong Ground huze 1 N fresh w3 w light 3 light Ground ha~ OVercast, dull Overcast, dull 4 Wlight Overcast, dull 4 Wlight 2 sw light Overcast, dull Overcast 2 SW slight Heat haze 2 SW sliGht Heat haze 1 W moderate broken cloud 1 W moderate Broken cloud I W moderate Broken cloud 1 Nlight Broken cloud 1 Nlight Broken cloud 1 N light Broken cloud tude assessment of asbestos in urban air, we were prepared to accept this uncertainty in the collection efficiency. The map (Fig. 2) and Table 1 show the location of the sampl- ing sites and the conditions in which the samples were obtained. The factory is in a hollow, and sampling site No. 2 is at the same height as the roof of the filter gallery, which is the chief air outlet from the factory. Sampling site No. 1 is about 30 foot higher than site No. 2. Sites 3 and 4 were in the gardens of houses, site 3 being about 5 km upwind of the factory and site 4 being about 300 m downwind. All the diffraction traces (for example, Fig. 3) contained strong lines of kaolinite and quartz, probably from the local soil, which made the assessment of chrysotile difficult because the broad (001) line of kaolinite (7.18 A) is close to the major (002) line of chrysotile (7.36 A). Fortunately chrysotile is easily decom- posed by boiling in 1 N hydrochloric acid whereas kaolinite is unaffected, so it should be possible to measure the amount of chrysotile present by sahjecting the ~amples to acid leaching and measuring the corresponding reduction of the intensity of the composite X-ray band. The fact that this process led to no reductions in band intensity for any of the samples indicated that the amount of.chrysotile present was below our detection limit. We ought to have been able to detect 10 r.tg of chrysotile by itself, but clearly the presence of kaolinite may have reduced the sensitivity. But the addition of 100 ~g ofchrysotile to our collected samples could easily be detected, so we can say that our samples collected from 1,000 m3 of air contained less than 100 Jtg of chrysotile-in other words, there was less than 0.1 Jtg of chrysotile per m3 of air. The threshold limit for DCcupational exposure set by the 1969 Asbestos Regulationsz is O.J !Jig m-:-l. 20 '"28(CuKa) 10 Fig. 3 X-ray diffraction pattern from a typical dust sample near . the Rochdale factory. Fig._ 2 . Plan of T.D.A. factory. Rochdale. The samplir.s sites arc tnd1cated by the arrows I and ~- F, Position of the chi-:f filter gallery exhausts. A more sensitive method for estimating chrysotile is required, and we are developing a technique based on electron micro- scopy. Preliminary examinations under the electron micro-.~ scope of samples collected by the Litton sam-pler indicate that the actual chrysotile level may be a further three orders of maenitude below the X-ray detection limit (that is, about 0.1 ng). The samples have so far been collected in the close.vicinity of the Rochdale factory. It is now proposed to sample air at certain representative urban and rural locations in VK and estimate their chrysotile content. A. L. RICKARDS v.D. BADAMI Turner Brothers Asbestos Co. Ltd, PO Box 40, Rochdale, Lancashire Received April IS; revised September 22, 1971. 1 Crable, J. V., Amer. Ind. 1/yg. Assoc. J., 27, 293 (1966). : Sta11dardsjor Asbestos D:m Conc~ntrarion/or Ust> witlz the Asb,stos Rrculatians 1969, nchnica/ Data No1c 13 (HM Factory lnspec torate, 196?). / FMSI 02899 October 22, 1971 Dr. E. P. Stefl Administrative Assistant to President Raybestos-Manhattan, Inc. 205 Middle Street Bridgeport, Conn. 06603 Dear Genet 11m writinQ this as a matter of record. I believe I may have mentioned it on the phone. On Wednesday September 29, 1971 (4r00 P.M.) I was called by a representative of the Center for Political R.::se::lrch in Washington, D. C. Miss Susan Simon Center for Political Research 1790 M. Street N. ~~. Washington, D. C. 20036 She had npparently decided (or had bean told) to contact the Friction Materials Standards Institute with the impression that we had material or compounding standards. The basic thrust of her question was: "What are the brake lining manufacturers doing about asbestos in the environment?" I told her we did have a committee studying asbestos in the brake lining industry for (1) general environment emissions, and (2) asbestos in the work place. I mentioned the Environmental Protection Agency's tests to determine the extent of any asbe9tos emissions in the general environment from the use of brake lining on vehicles, and the proposed r~tyl,tions of the Illinois Pollution Control Board. She brought up fiber glass as a substitute. I believe she is part of the activist anti-everythings, and while our conversation was polite and restrained, I don't believe she had much technical depth -as suggested by the usual "fiber glass substitute and the apparent pre-judament that asbestos in brake linings is a serious contaminant from the emission viewpoint in the aaneral environment. The foregoing is str ici:ly a maHer or record. Sincerely, ~WD/icb E. W. Drislane Executive Secretary c .n '3 --.j FMSI 02900 Mr. E. Dris lane Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York, New York 10017 CORPORATE HEADQUARTERS Ill DR. E. P. STEFL VICE PRESIDENT AOMINtSTRATlYE ASSISTANT TO PRESIDENT September 27, 1971 1\) !il ~ 0 0 rm- ~ m::tl ~ m ::tl 8 m ~ ~ 0 0;zz Dear Ed: I am returning your draft copy of the minutes of our meeting of the Asbestos Study Committee without change. I think you have covered the matters that were discussed quite well. As agreed upon at that meeting, I am also enclosing a copy of the Federal proposal for the emission standards for asbestos. You will recall that the members of the committee thought it well to see this draft copy even though we now know that the Federal standards will be quite different. Nonetheless it is being submitted for information purposes. You are to make copies and distribute such to the members of the committee. In addition I am enclosing a copy of the comments and suggestions that were made regarding this initial draft by the AIA at a recent meeting that was held in Atlanta about mid-August. These connnents and suggestions were given to the entire group assembled and we were advised that they would be given consideration in the revised version, which we have yet to see. Again, this is being supplied for information purposes. Further, I agreed to advise all the Committee members as to what happened at our unofficial meeting with some members of the Illinois Pollution Control Board held in Chicago on September 17. Since that meeting covered matters other than the ban on asbestos in brake lining, I will quote you from portions of the minutes I have received regarding that session. I would urge that you advise our committee members that this information is to be considered extremely confidential at this point, especially since the meeting was held in advance of the public hearings. i(I . / ~- (3) FMSI 02901 - 2- Those present in Chicago on September 17 were Timothy Harker, Administrative Assistant to the Illinois Pollution Control Board, and Walter Romanok, also of the Illinois Pollution Control Board on a part time basis. Representing them from a technical standpoint was Dr. Colin Hanvood, whom I believe was instrumental in writing a great portion of the proposed regulations. He is from an Illinois Institute of Technical Research, I believe is the proper title. Representing our side was Dr. George Wright of St. Luke's Hospital in Cleveland, E. M. Fenner, W. P. Raines and Dr. S. Speil of J/M, and myself. The two-hour meeting was quite cordial and useful. Despite Harker's great reluctance to schedule the meeting, and his suggestion on September 13 that it be cancelled, he proved to be quite communicative and certainly did not evidence hostility. We learned that public hearings will be held in Illinois on Wednesday, October 6, in Granite City at 9:30A.M. in the court house; on Friday, October 15, in Chicago at the Field MUseum at 10:00 A.M.; and Tuesday, October 19, in Waukegan at 10:00 A.M. at the public library. Harker indicated a preference that the asbestos industry, through the AIA/NA, testify as a unit rather than each asbestos company testifying separately. Harker indicated a strong preference that the industry present its testimony at the Waukegan hearing rather than at the Chicago hearing. They expect the Chicago hearing to be "crowded". It is neither necessary nor desirable to appear at more than one of the hearings. Testimony should be given verbally and in writing. Ten copies of the written version should be submitted to the Board in advance. We advised Harker that we would let him know which hearing we would present our testimony at, who would testify for the industry, and the amount of time that we would require. On the matter of the brake lining ban, this subject required surprisingly brief discussion. Harker called it "a weak point in our regulations". He implied--though he did not say so--that it was inserted in order to gain publicity for the proposed regulations and hearings. He said it would "stimulate discussion". Harker did say that one automobile company had told him that their company would be using only asbestos-free disc brakes by 1975 and that the asbestos ban would thus not affect them. FMSI 02902 -3- Dr. Harwood said that GM and Chrysler had told him that they saw no way of eliminating asbestos from brake blocks or discs without seriously diminishing the effectiveness of the brakes. Harker seemed impressed by this and commented that the Board didn't want to kill more people than it "saved" by any such ban. We mentioned the Bendix studies being conducted for the EPA relative to the emissions of moving vehicles. The Illinois people seem to know very little aboutWhat the Federal EPA is doing relative to asbestos emission standards and what the Bendix test involvement is. Harker also mentioned that New York City is testing the air in subways and other closed in areas to see what the asbestos fiber level is there, presumably being produced from vehicles. I believe that summarizes what transpired to a great extent at that meeting. In view of the time limitations for these hearings, from the standpoint of getting prepared, it would seem that the AINNA will carry the ball for the entire group since I do not think that the FMSI Committee can function with any realistic data at this point. This is a personal opinion of mine and I would appreciate any comments anyone might care to make regarding such a position. In the meanwhile, through Johns-Manville, the AIA has testified at various city and state hearings on the ban of asbestos in spray coating and also testified in Washington in a written form regarding the hazardous nature of asbestos so I believe we have a format which can be presented from that group in Illinois and be effective. Some of it will be written and in addition we will probably have people testify on the aspects other than the brake lining ban. I believe the portion on the brake lining ban will be limited to the publications which I submitted to each committee member at our first meeting. I believe this concludes my report to you and the items that I agreed to take care of. If there are any other areas where I can be of help, please let me know. Very truly yours, E. P. Stefl Attachments P.S. I have just been advised that the AIA/NA testimony will be presented on Friday, 10/15, in Chicago. Perhaps you would care to be present. The team representing us has not been decided nor has the time of day. I will advise you when I know more, FMSI 02903 SepiEifftber 23, 1971 Dr. M. G. Je.oko Bendix Research Laborat.vriee Bendix Center Southfield, tqichigan ;{Jt,SC75 While you ware at the mEMting of the Asbestos Study CommiHee last week, you ~eked for soma information about the Friction Materials Standards Institute. 1 believe you were trying to understand the basic services that the Institute performs with- out geHing Into the detail as spelled ovt in the ConsHtution antt By-Lawa. However to be speci fie, I am enclosing a copy of the Constitution and By-Laws.. The Friction Materials Standards lnstitute, is made up of most of the United States manufacturers of brake linings and clutch facings. One of its earliest services was a copyrighted numbering system for the brake linings and clutch facings. In this way if a eustomar were order'ing a set of brake 1inlngs to fit a 1963 Chevrolet, he would check our book end select 92065* for the fronts end II 2006* for the rears. ~.oat brake lining manufacturers would provide this lining with the II 0065* and 12006* number. The various brake lining manufacturers make this lining to the dimensions epell~d out for original equipment purposes from information we furnished thaD. le solicit and compile data on all new brake lining and clutch facing releases and we publish a book every other year. with suppleme;1te in the in-between yea.r, which keeps the fieid up to date on the brake linings and clutch facings used on the cars and trucks they will ba servicing. Further, we publish bulletins about six or eight times a year to bring the manners up to c:b.te on M)' chang.,;o that are happening, when they happen.. Because of the multiplicity of brake shoes and the ,robleme In determining whick shoe belongs on which vehicle~ we alr.o prepare a brake shoe identification catalog. The shoe assignments which we give are used by most manufacturers to describe the lining shoe package which theydistributo in the after market. All members of the Institute a.ra allowed to use the Fo :,1. S. 1. numbering system wmh.simchberiisnecosypsyterimghitnedt.heFirurothate&r7.ltohgesyaneadnonautthheoirrizep the rice ir customers sheets.. ,!'is to an use the ~le F.M.S.I. of the type of rk the F.M.S.I. is dolng currently In this area, "we workina on 1\ brake block identiftoatlon book which would allow people in the field to identify the F.M.S.I. maher for the block by aklng certain baeic measurSietlts. As you will note, our services are oriented to the replac...,t market. Brilk PforaM! Stuw CggpiHn r;lembars of the Institute over the past ten years ware being deluged with State lf19-islat ion in the automotive safety area which ws then followed by the Federal Gover~t legislation in 1966 setting up under tho Department of Transpot"tat ion, what is now the -- _'"_____________________F_MS_I 0_29_04_________ ur. ~cko 3endix Research Laboratories f~tional Highway Trafric Safety Adminetration- N.H.T.S.A. The Friction !Aaterlale Standards Institute orpnbed a C..lttee to help aive tM various safety GH.binstratore guidetnoe so that ruaonable regulations would be issued. When ragulatione estabUshina brake lining certification tests were set up by such States as New York, PEIMS)'lvanla, Maeaachusetta and othera, the Friction taterlals Standards Institute worked with the adltlnlatratora In establishing requlrG~~Mnts. During various hMrlnga in lashlngton for the N.H.T.S.A. on brake syat safety replathma, the FrioUon terln1e Mancarde Institute would rwi the propoaed at..-rc~s, ,.,.,.. taste ami oa~~pile ~ts em the propoeed standard&. le still lntaln a close tch on le.ehington and the various State M , . , . l.ialatlon an4 reaulaUons eonoernlna brake 1ininga. To this date, clutch facings haVe not been much or an It as r9rda automotive safety. Agisstgs Stuix Cqgpitttt Th em is part icula.r asbestos. It ComiHee, may take aassomyoeuvmaartesainwdatraer, is newly formed with posture as ihe 3rllke ita obvious Perfor.,_ llllphaela Study c..IH~ and ( 1 ) disseminate lnformat ion to the ~rs, and ( 2 ) pr..-r-:, fort eo Ill mnts to t.ba various environmental agencies where they may be dradng up reculaticme that concern as*tos in brake 1inings or clutch facings. IHhin tho lnstHuto we can take any raaaormbla steps that wiU further the frlctlon materials industry in line with the Oinstitution and 8y-~~s. Among other things, the lnatHute ha.s organi;red the aocumulaUon of information on historical sales by the members of friction articles- brake blocks, disc brake ltftings, other brake lininfa and ctut~h facinas. This information is submitted to a Certified Public Aocountan who revi'm& tho <idginal input f'rom the f!~Elmbers and prepares the $Uftl'tl'lriee of totals. This information iaefinnl form is confidential and is returned to the members. As I do not ool iwe you are interested in the Inat ituta concerning our catalog inro,..tion,.l am not sending any of t.hh type data.. Should you wish e oopy of' our Data Book and Shoo Qltaloa ploasa le\. me know. \fuen I hav& receiv~ a:1 approved copy of' the minytos of our recent meeting, I will send you a oopy. Dr. Spurgeon of COUt'M wiJ 1 be recetving a copy -:then the minutes are distributed. Executive Secretary FMSI 02905 !J~l Johns-Manville Environmental Control Systems Division Box 159 Manville, N. J. 08835 (201) 722-9000 August 24, 1971 Mr. Edward Drislane Executive Secretary Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York 17, New York Dear Ed: I would be very happy to serve on the newly formed Asbestos Study Committee. I wi I I plan on attending the proposed first meeting of this committee on Wednesday, September 15, 1971, at 9:30a.m., at the Friction Matierals Standards Institute's offices. I am looking forward to seeing you at that time. Sincerely yours, Wi I I iam B. Reitze, Manager Industrial Hygiene Engineering Services WBR/vam FMSI 02906 CORPORATE HEADQUARTERS II DR E. P. STEFL VICE PRESIDENT ADMINISTRATIVE ASSISTANT TO PRESIDENT August 24, 1971 ~ 3: 6 0 rm ~ lml ~ Ill ll 6 G) m "tJ 0 -~ (') ;z0z ~ Mr. E. Dris lane Friction Material Standards Institute 370 Lexington Avenue New York, New York Dear Mr. Drislane: Thank you very kindly for your letter of August 20 informing me that I have been appointed Chairman of the newly formed Asbestos Study Committee. I am delighted to accept and will you please advise Mr. J. W. Greenen of my acceptance. Thank you kindly. Very truly yours, FMSI 02907 CARLISLE HEAVY DUTY BRAKE BLOCKS AND SEGMENTS Mo:lded Materials Division C4RLISLE CORPORATION P.O. BOX 417, RIDGWAY, PA. 15853 TELEPHONE (814) 773-3187 August 23, 1971 Friction Materials Standards Institute, Inc. 370 Lexington Avenue New York 17, New York 10017 Attention: Mr. E. W. Drislane Dear Mr. Drislane: In reference to your letter of August 20 concerning the Asbestos Study Committee, please be advised that I will be pleased to accept an appointment to this committee. Also, I plan to attend your initial meeting on September 15th. Sincerely yours, MOLDED MATERIALS DIVISION JBG/vb cc: Mr. E. R. Zacharias FMSI 02908 t;. F. E. IeMler Friction Materials Dlvlalon The BendiM Corporation P. 0. Box lil499 Cleveland, Tennessee 137311 Dear F'rans August 2, 19711 ...,... j.f1t::l Subject: Asbestos Study Committee (Friction Materials) This concerns the possible addition of a new committee within F'.M.S.I.an "Asbestos Study Committee" as discussed in Bulletin II.IJ6. Acopy of Bulletin ~ is enclosed. While the bulletin covers the essential points, I did want to make a personal contact to see if Bendix could contribute to such a eorrmittee. Our ooncern is pxpreesed for asbestos ln brake linings because of several outside stimuli: 1. A proposed Illinois regulations "The use of asbestos in brake lining of vehicles manufactured after January 1, 1975 and sold for use in Illinois is prohibitedft. 2. Possible effects of the new Occupational Health and Safety Act of 1970 as r&~ards asbestos in the work place. J. Some concern for particulates in the air - particularly asbestos ln the air. Fran, J don't really know what approach you would take. I do kaow that Bendix Research in Detroit has done some studying on particulates (rubber, asbestos, etc.) in the air. Also, perhaps at Troy or Cleveland someone has been made responsible for monitoring asbestos in the factory area. If you ~ve someone in either the factory area deali, with asbestos, or in the llrldical or hygiene area who could contribute, 'd appreciate word. Let me have your COI'tlftents on this. Sincerely Secretary EWDr islane/hgd Enclosure FMSI 02909 World Bestos Company DIVISION OF THE FIRESTONE TIRE &-RUBBER COMPANY HARVEY 5. FIRESTONE FOUNDER NEW CASTLE, INDIANA 47362 Hr. E. "ftJ. Drislane, Secretary Friction Haterials standards Institute, Inc. 370 Lexington Avenue New York, New York 10017 Dear r1:r o Drislane: l~: Asbestos Stuqy Committee We do not have an industrial hygenist at our 'irforld Bestos Divlsion so do not have anyone to offer that has specific talents that might be used on this committee. If, however, there is difficulty in getting sufficient talent to serve on the committee, we would be happy to offer the services of our Technical Ha.nager, J. C. Henning. Nr. He:rming has a Masters Degree in Chemistry and has served in the Research and Development Department of The Firestone Tire & Rubber Company for a period of ten years before joining the World Bestos Division as Technical Hanager. CJVJ:da Yours very truly, e1u_/~, { Co J. Heber General Hanager r Your Symbol firestone lv. of Quality and Service FMSI 02910 Friction Matetials Standards Institute, Inc., 370 lexington Avepue. New York. N. Y. BULLETIN N 0, 4 0 6 July 16, 1971 - ASBESTOS STUDY C0~11TTEE This notice is being sent to all Active Members concerning the President's intention to form a new committee within F.M.S. I. We are considering the establishment of an "Asbestos Study Committee11 , to consist of a chai~ and probably four members. BACKGBOUND While the talk delivered by~~. W. B. Reitze of Johns-Manville at the June meeting dwelt mostly on in-plant environment, there was some discussion relating to asbestos factory environments and brake lining particulates in the air. Well before this talk, there had been concern expressed on an Illinois Law which would eliminate the use of asbestos in brake linings. ASBESTOS INFORMATION ASSOCIATION OF NORTH A~RICA This association was recently formed by the asbestos companies of North America. It would be our intention to work with them through our new committee, and essentially speak for the brake lining and clutch facing manufacturers. Obviously, our committee would review and comment on rules and regulations proposed by the State and the Federal Government. There would be no costs to the Institute in any of our work with this association. STAFFING THE COMMITTEE We would 1ike to staff this committee with experienced and skilled personnel, preferably from the manufacturing, or Industrial Hygiene areas. Please give this bulletin your careful review. If you feel there is someone in your Company with the background necessary to serve as a member of this Committee, please advise with a brief description of this person's background. "' " ..- r .') ,, '' -' ;6 '~) f { l I (' \ 0 'I ! ! .. ! ' E. W. Dr islane Secretary Distribution: B FMSI 02911