Document YDznr18D2abZjDGj1wYpRjV2y

I o :t> I. rri0 (!) Ss:fOTJl - (j) -l-l ~ rrl(j) tI!l ~_1_:.--ct<:::l:l \...,.) FMSI 02466 F~~ICTIOi:. il.'\.TERIALS f:TAl!DARlJS INSTITU'.i.'E, Ii::jC., E. 210 p,JUTE 4, PARt-.llUS, N.J. 07652 TO~ ASBESTOS STUDY COHlUTTE;:;; SU.dJECT: ACTIVITY CONCERNETG ASPESTOS December 26, 1973 Mr. I. H. Heaver, Chairman of the Committee has kept me abreast on various activities in government, industry and in the press concerning asbestos. Because of the considerable amount of literature I am only forwarding articles that your Chairman specifically suggested I send to the Committee ~!embers. These articles are: 1. "Type of Asbestos and Respiratory Cancer in the Asbestos Industry" (Types of asbestos and their carcinogenic potentials). 2. 'Asbestos Health Question Perplexes Experts" (A sununary of the Durham, N.C. meeting on the biological effects of ingested asbestos). In addition, I have listed all the articles received from !1r. ~.Yeaver which are related to the asbestos problem. Should you wish a copy of any of these articles, please let me know. One item is a 16 page booklet entitled "CAUTION: ASBESTOS DUST l do not have extra copies of this booklet but they are available at a price from ChanninE L. Bete Co., Inc., 45 Federal Street, Greenfield, !Iass. (or directly from l:JIOSU). See attached price list for this booklet. 'fhe foregoing is to keep the Committee posted concerning literature on asbestos. E\ID:llz Enc. E. P. Drislane Executive Director FMSI 02468 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, PARAMUS, N.J. 07652 ARTICLE (SYNOPSIS) SOURCE/AUTHOR DATE Asbestos, Talc and Nitrites in Relation to Gastric Cancer (A summary report on talc injections into hamsters indicating no carcinogenic effects) American Industrial Hygiene Association Journal May 1973 The Medical Surveillance of Asbestos Workers (Exposure and Radiological Surveillance) Lewinsohn, H.C., Royal Society of Health Journal April 1972 Don't Drink the Water, Don't Breathe the Air (Reserve Mining's Discharge of "Tailings" into Lake Superior) Nader, R., Harris, R., Environmental Action September 1973 CAUTION: ASBESTOS DUST--- (A booklet) Published by Channing L. Bete July 1973 Co., Greenfield, Mass. Available from NIOSH A review of CAUTION: ASBESTOS DUST--- Swetonic, M., for Asbestos Information Association July 1973 The Locus of Pathogenicity of Asbestos Dust (Pathogenicity results frompolyfilamentous structure) Gross, P., Harley, R.A. Arch Environ Health October 1973 Asbestos: Underrated Peril (A synopsis of Fritsch & Castleman allegations - primarily asbestos in industry) Environmental Action Bulletin October 1973 Anti-Pollution Device Approved for Asbestos (The JM PENTAPURE Impinger) Asbestos Magazine October 1973 Letter, Asbestos Information Association to Department of Labor (Comment on amendment to CFR permitting immediate public disclosure of monitoring results) Mereness, R. H., of AIA October 1973 Criteria for Hazardous Exposure Limits (An ev~rall survey on establishment of permissible limits for exposure to hazardous substances) Hatch, T.F., Arch Environ Health October 1973 The Asbestos Industry Struggles to Comply with-Tough New Standard (Industry approaches on OSHA Asbestos "11 Standards) -3: CJ) The New Dimension in Occupational Health (A history 0 of the asbestos standard) I\) eol:nlo CD Snider, R.J., Occupational Hazards Occupational Hazards October 1973 October 1973 -2- ARTICLE (SYNOPSIS) Asbestos Dust is Linked to Disease (Asbestosis, Lung Cancer, Mesothelioma, and Gastrointestinal- brief summaries of Dr. Selikoff reports) Crisis in Silver Bay (The Reserve Mining Co. court case concerning asbestos fibers in water) Occupational Health Factors in the United Kingdom (Diseases related to asbestos exposure) Data Sparse in Asbestos Scare (Reserve Mining Co. asbestos in Lake Superior - difficulty in establishing asbestos and gastro intestinal cancer link) Conference on Biological Effects of Ingested Asbestos, Durham, N.C. Reserve Mining Report (Dr. Paul Gross testimony - in direct opposition to Dr. Selikoff testimony) Health Effects of Ingested Asbestos Debated Inconclusively (A summary of the Durham,N.C. meeting) Type of Asbestos and Respiratory Cancer in the Asbestos Industry (Types of asbestos and their carcinogenic potentials) Asbestos Health Question Perplexes Experts (A summary of the Durham, N.C. Meeting on biological effects of ingested asbestos) SOURCE/AUTHOR Occupational Hazards TIME Magazine Lewinsohn, H.C., Holmes, S. Medical World News Mereness, R.H., of Asbestos Information Association report Special Report Environmental Health Letter Enterline, P.E., Arch Environ Health C & EN DATE October 1973 October 1973 October 1973 October 19 73 November 1973 November 1973 December 1973 November 1973 December 1973 ., ~ ~ ~ 0 N ~ 0 Asbestos Study Committee ), Mr. E. H. Feier abend Mr. R. A. Hemmelgarn American Brakeblok Division Grizzly Friction Products Abex Corporation Maremont Corporation Winchester, Va. 22601 700 West Caroline Street Paulding, Ohio 45879 Mr. C. N. Menz Friction Materials Division x Mr. Thomas Bell Bendix Corporation H. K. Porter Co., Inc. P. 0. Box 238 Thermoid Division Troy, N.Y. 12181 1849 East Sabine Street Huntington, Ind. 46750 Mr. William Simon Brassbestos Manufacturing Corporation 1' Mr. J. H. Marsh 45 East 5 Street Raybestos-Manhattan, Inc. Paterson, N. J. 07524 205 Middle Street Bridgeport, Conn. 06603 Mr. E. R. Zacharias Carlisle Corporation Mr. L. Burgess Molded Materials Division Wheeling Brake Block Mfg. Co. P. 0. Box P 100 West Boyd Avenue Ridgway, Pa. 15853 Bridgeport, Ohio 43912 Mr. L. Carreras Forcee Manufacturing Corporation P. 0. Box 607 Tappahannock, Va. 22560 Mr. W. M. Sleeth Royal Industries Brake Products Stewart Lane Danville, Ky. 40422 Mr. L. E. May World Bestos Company, Division of The Firestone Tire & Rubber Company 1112 South 25 Street New Castle, Ind. 47362 Mr. F. W. Barton, Jr. Reddaway Mfg. Co., Inc. 32 Euclid Avenue Newark, N.J. 07105 Mr. T. Terrell Molded Industrial Friction Corporation 327 Walnut Street Prattville, Ala. 36707 Mr. J. Clegg The S. K. Wellman Corporation 200 Egbert Road Bedford, Ohio 44146 Mr. R. J. Kick Staff Engineer Products Service Delco-Moraine Division General Motors Corporation 1420 Wisconsin Boulevard Dayton, Ohio 45401 Mr. J. Gallagher Thiokol Chemical Corporation Panelyte Industrial Division Enterprise Avenue Trenton, N.J. 08604 Mr. S. Comins Auto Friction Corporation 651 Andover Street Lawrence, Mass. 01842 Mr. E. R. Koss Chemical Division Chrysler Corporation 5437 W. Jefferson Trenton, Mich. 48183 Mr. F. T. Gatke Gatke Corporation 228 North La Salle Street Chicago, Ill. 60601 Mr. T. J. Laher Lasco Brake Products Corporation, Ltd. 2615 Magnolia Street Oakland, Calif. 94607 FMSI 02471 'frRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 July 6, 1973 To: Asbestos Study Committee Subject: Asbestos from Brake Linings as a Water Pollutant Enclosed is an article from the New York Times datelined July 3, 1973. In addition to alleging that the automobile is a major polluter of water, the first pollutant listed is asbestos from brake linings. This may be the sequel to the brake lining (and clutch facing) asbestos emissions tests run by the Bendix Corporation for EPA where 85% of the asbestos emissions were dropped out or deposited on the ground. a~D/erc Enclosure: E. W. Drislane Executive Director FMSI 02472 FRICTION MATERIALS. STA:NDARDS INSTITUTE, INO. N" ,""'.I rME s.. \ '3 I Cf"13 I E.P.A. Study Calls Autos Chief Polluters of Wattlr WASHINGTON, July 3 (UPI)A study carried out for the Environmental Protection Agency concludes that cars are prlmaor polluters of water. ltlospherics, Inc., of Rockville, Md., an '"dependent research concern, said in a report issued yesterday by the E.P.A. that pollutants spread on roads by autos befoul rivers and streams almost as much as municipal sewage. The pollutants include asbestos from brake linings, rubber from tires, zinc from oil and tires, lead from gasoline and nitrogen and phosphorus compounds. Rainstorms carry the pollutants Into waterways. FMSI 02473 ------------------------------ -1- ASliBS'fr)S A.1.m THE FillCTIO~! t1,\TERIAL IiiDUSTRY Hr. I. n. \,leaver of Raybestos-rtanhattan, Inc., uho serves as Chairman of the Friction i.1aterials Standards Institute Asbestos Study Committee addressed the Annual ~lembership t1eeting of the Institute. t1r. Weaver's address was delivered in Vail, Colorado on TJednesday morning, June 27, 1973. Mr. Heaver's address follows: Uhen Ed (ilrislane) asked me to attend your annual meeting last year, I had to decline, which may have been just as well in view of the confused status of both OSHA and EPA regulations at the time. This year things are only slightly less confused, but I am glad to be able to be here anyway to attempt to fulfill my responsibilities in reporting to you as your Asbestos Study Committee Chairman. Rather than present a detailed statement covering Committee activities for the year, I should like to use my time to review some of the more controversial and confused elements of the Federal Asbestos Regulations, and sive recommendations as to what I think the stance of the Friction ~~terials Industry should be in re8ard to them. In lieu of a detailed report covering the past year's activities, I have prepared a page and a half summmary of the Committee's work from June '72 thru June 1, 1973. Ur. Drislane will circulate copies of this summary to anyone ,.,ho may be interested in it, and if any of you have questions or recomnendations concerning our past work or future intentions, please feel free to bring them up here, or if you prefer, transmit them to Ed for our review later. Probably the single most significant event that occurred during the past year on the subject of asbestos hazards was the meeting of the International Agency for Research on Cancer that was held at Lyon, Prance last :::>ctober. This meeting was attended by more than a hundred and thirty medical researchers and representatives of government, industry and labor from virtually every major asbestos consuming or producing country in the world. For four days intensive sessions on asbestos were held by three different panels, each made up of ten to twenty-five of the foremost medical and scientific experts operating in the various fields of asbestos-health research. Following the meetings the committees issued a combined report on asbestos cancers. I think the following five items summarize their most important conclusions: {1) All major commercial types of asbestos can cause cancer. {2) Evidence suggests that excess lung cancer is not detectable uhen occupational exposure has been low. (Just what is meant by "low'1 was not stated.) EXH I BIT 14. 1 FMSI 02474 -2- Asbestos and TI1e Friction :>Iaterial Industry (cont' d) (3) Evidence has been greatly strengthened that all commercial types of asbestos except Anthophyllite may be responsible for mesothelioma. (Risk is greatest with Crocidolite, less with Amosite, and apparently still less with Chrysotile.) (4) Cigarette smoking is an important factor enhancing lung cancer risk in asbestos l7orkers. (5) Surveys of occupational groups have shown a small excess risk of types of cancer other than bronchial and mesothelial, especially those of the gastro-intestinal tract. The most important item here is the incrimination of all major types of asbestos as causal agents for carcinoma, particularly mesothelioma. Most of the other items only comfirm or substantiate previous conclusions. Since most of us use substantial amounts of Chrysotile asbestos in our formulations, association of this naterial with mesothelioma and other types of cancer is of serious concern. A number of individuals who attended the IRAC meetings came away ~rith the definite impression that government recognition of asbestos hazards has been accomplished and henceforth should be taken for granted. We can now look to the next major effort being geared toward worker education regarding occupational health hazards. The Occupational Safety and Health Act requires information be given by employers to workers concerning the degree of their exposure along with instruction in ways for minimizing exposure. Therefore, it is incumbent on allemploYers whose workers handle or come in contact with asbestos-containing materials to provide some kind of instruction or training to educate the workers concerning potential hazards and means of avoiding them wherever possible. Accordingly, it would be prudent for all friction materials manufacturers to develop programs to assure adequate co~ munication with their employees regarding asbestos dust hazards, and to inform them of monitoring results, good work practices, and their responsiblities in complying with OSHA regulations. If such measures are not taken promptly and properly by management, industry will leave itself ~dde open for intense, and in my opinion justified, criticism by organized labor, as well as potential severe enforcement action by government, and attack by any number of social and environmental activist organizations. If we don't do this ourselves, be assured that someone else will jump on the bandwagon and do it in a l'lay that will not be to our benefit. We can expect more and more activity by organiz~labor toward educating and training workers regarding health and safety problems and in pointing out to l-7orkers what their employers' responsibilities are concerning these matters. FMSI 02475 -3- Asbestos and The Friction llaterial Industry (cont' d) Hany union activists are really furious with government's failure to pursue the provisions of safety and health regulations to the letter, and there appears to be a good opportunity for industry to release reliable information concerning asbestos hazards both to their employees and to their customers before more inflammatory information of this type is aired in the media under organized labor's banner. These rules and regulations pose much more severe problems for other segments of the asbestos industry, particularly asbestos textile manufacturers, than they do for most friction material manufacturers. I have ~een involved in asbestos products manufacturing for over twentyfive years and have visited dozens of plants and am aware of only a few friction materials products manufacturing operations that I consider to represent major problems in achieveing conformance to either OSHA or ErA requirements, including the 2 fibre per cc thereshold limit value. Since significant polarization may be expected always to exist between management and labor and between management and environmental groups concerning asbestos-health subjects, and since control or conformance to both EPA and OSHA regulations appears to be generally feasible, as far as friction materials are concerned, my recommendation to friction material manufacturers is that they proceed as rapidly as possible towards conformance with the regulations. Also I recommend avoiding inclinations to misinterpret provisions where the intent of the regulation is clear, but the wording may be subject to question. There has been considerable disregard of a number of provisions mainly in the areas of labeling, monitoring, employee education, personal protection, waste disposal, and use of warning signs by segments of asbestos products manufacturing, and I believe this applies to friction material to some extent. One of the most obvious items has to do with industry's reluctance to accept asbestos products labeling as required by OSHA. There has been much advertising of asbestos textile products citing the benefits of treatments or coatings that purport to lock the fibre into the product in such way that it cannot become airborne during use. tfuile these claims probably are true to varying degrees depending on the nature of the product, its use, and the way in which it is handled. I do not think this claim is at all applicable to friction materials. I knmoJ of no way any of us can be absolutely sure that his friction products, regardless of \~hether they are sold as original equipment or on the replacement market, will not be subjected to additional operations or alterations in the field that could result in excessive exposure of workers or bystanders to airborne asbestos fibre. I have been appalled to learn of a number of instances where this problem has occurred, and some of these cases involved people that certainly might have been expected to know better. FMSI 02476 -4- Asbestos and The Friction <iaterial Industry {cont' d) If this kind of thing occurs in fabrication operations of major OE customers, it appears to me there can be no argument about the need for educational me~sures to reduce chances of unnecessary exposure during grinding, drilling or cutting operatio~q. To those who argue that labeling or other types of warnine need not apply to replacement materials because fabricators or appliers handling replacement quantities are ~xposed relatively intermittently, I say emphatically this just ain't necessarily so! Large volume replacement users present major potential hazards, and even small job shops can needlessly expose people to high fibre concentrations if operations are performed without controls. That these may be intermittent and of short duration does not preclude possibility for occurrence of adverse health effects in hyper-susceptible individuals, or in less sensitive individuals who may receive exceedingly high doses of short duration but who may be smokers, or who may experience effects because of synergism with other materials to which they may be exposed either at work or elsewhere. To me, labeling all containers or packages of asbestos-containing friction material is the very least the industry can do to fulfill moral obligation to its customers, their employees, and the public and at the same time conform with minimum requirements of the Occupational Safety and Health Act. I seriously question whether mere labeling is enough to fulfill this requirement. It bas been suggested by others as well as myself several times in the past that additional instructions, of a more comprehensive nature than is practical to provide on a label, be inserted inside each package 7here a possibility exists that the product might be used in such manner that an airborne dust problem could be created. A number of responsible asbestos products manufacturers already are following this procedure, and there is a good possibility that it may be made mandatory in future regulations. Adoption of these measures by industry would show good faith toHard compliance and should reduce possibilities of future criticism by consumer protection groups. 1 doubt very much that it ,.,ould have any significant effect on sales or consumption of asbestos friction materials. I know of no substitute for asbestos in normal automotive friction material service, and I know of little or no noticeable effect labeling has had on other products where cautionary labeling has been used thus far. Keep in mind that NIOSH and the OSHA Advisory Committee recommended a much more severe label than the one we are talking about. This subject was heatedly debated during the OSHA Advisory Committee deliberations, and their final recommendation called for use of the word "Danger" instead of "Caution" and specifically mentioned that breathing asbestos causes cancer. Very frankly, I was exceedingly FMSI 02477 .-5- Asbestos and The Friction :1atedal Industry (cant' d) surprised when the final OSdA Standa1;d came out in favor of considerably milder working. ~:m7 I am perple'ited that Industry resits the OSHA labeling requirement as virgorqu$ly aS it does. :1any other elements of the OSHA Regufat:J.ons came out more favorably toward industry than the recommendatio,As that were submitted by NIOSl! and the Advisory Committee, and stiff resistance by Industry will be needed to prevent OSHA from strengthening the regulations in months to come. Ue can expect considerable effort to be made by anti-industry elements of the medical profession, by organized labor, and by environmental groups who want the airborne standard lowered from 2 fibres per cc to 1 fiber per cc or even less. Some individuals even speak of asbestos in terms of zero TLV, which, of course, is completely impractical and would result in virtual banning of mining and use of asbestos for anythin~. Another controversial subject is fibre monitoring. This is pretty much of a disaster area because of lack of confidence in the membrane filter method for samplinp, and analyzing for airborne asbestos. Huch of this problem is attributable to the nature of the operation, which involves considerable judgement in addition to technical competency on the part of the people performin~ the tests. Even when performed by practiced individuals under the best possible conditions, the method is subject to wide variations in results. Needless to say, when performed by relatively inexperienced personnel under the widely varying conditions that e:~ist in the field and bebteen different laboratories, results can be extremely variable. In my opinion, the method is not at all suitable for enforcement purposes, but can be used to good advantage by industry for policing its own operations and for determining where to devote control efforts with maximum advantage or potential for improvement. In spite of its deficiencies, I think the membrane filter nethod will persist for quite some time, but I will not be at all surprised if future emphasis by OSHA shifts toward work practlce regulations rather than monitoring to a numerical standard. Another controversial item has been the protective clothing requirement. This has created considerable question and controversy, particularly in the textile industry where ceiling limits are difficult to control on certain operations. Different OSHA regional offices have applied different interpretations to the protective clothing requirement, and it's hard for me to see how some of them can be as liberal on interpretation as they are. The regulation specifically calls for full body cover including gloves, hat, and foot covering, where levels exceed the ceiling FMS\ 02478 -6- Asbestos and The ?rictton I~ate::ial Industry (cont' J) limit. In spite of this, certain OSI1A regional offices take the position that any protective clothing, even as scanty as a short sleeves shirt and trousers, is adequate, provided this clothinr, is changed before the employee leaves the plant. Personally I believe this lenient interpretation provides effective protection for most exposures, and I concur that the important thing is to make sure the employee doesn't take the contaminated clothinB out of the plant. Other OS.tiA offices st:i.ck to the letter of the requirement, which creates a major problem on many operations Where discomfort from full cover clothing can have a very significant effect on operator efficiency. This requirement is under vigorous attack by companies that are havine problems ldth it. l-:o doubt some judgement by the Occupational Safety and Realth Review Commission or the Federal courts will be forthcoming concerning this element of the regulations, and it is to be hoped that future revisions of the rule "rill permit more flexibility than the existing uording does. ~aste disposal has created problems with both OSt~ nad EPA regulations, and some friction material manufacturers already have extensive facilities in the works to cope with these problems. Of particular interest is the pelletization of friction material waste to reduce dust to a form that avoids necessity for bagging or otherwise containerizing the material. This also reduces or eliminates generation of fugitive dust during disposal in landfills. Several manufacturers have installed extensive pelletizing systems to solve their waste disposal problems, and this approach appears to be acceptable to both EPA and OSl~ as well as otate environmental control agencies. Other approaches have been to utilize wet disposal methods and, of course, some manufacturers are bagging and labeling the dry waste, where uet methods or pelletizing are impractical. Where bags or other containers are used for waste disposal, they should be labeled in accordance with osut. i'iedical examination requirements have presented problems, particularly the one of detenrJ.nin~ what constitutes "asbestos exposure". Some companies have adopted the attitude that all workers, including office and research people, even though they are not normally considered to be exposed to asbestos, should be included in the medical surveillance program. On the other hand, many seem to foll~l the tack that anyone exposed to one fibre per cc or less need not be included. My advice uould be to check everybody where there is any doubt about actual exposure. I could dwell at considerable length on other problems and inconsisof the ~SHA Rer,ulations and their various interpretations, but believe I probably have expounded on this enour~ for the moment. However, the one main point I 1-1ant to get across is that any FMSl 02479 -7- Asbestos and The Friction !:"aterial Industry comparison of the existin~ regulations with industry's position as stated in their input to the government prior to promulgation of the regulation, and compared with the recommendations of NIOSH and the OSHA Advisory Committee, will readily indicate that the existin~ OSHA standard, with the one serious exception of the two fibres per cc limit to be imposed in 1976, follows industry's position rather closely. If I appear to be defending the present OSHA Asbestos Regulations, it's only because I am very much aware of how much more strict these rules would be if the recommendations of HIOSI.l and the Advisory Committee had been followed. I doubt that many in the industry recognize or realize just how close they may have come to being rer,ulated out of existence. Future occupational safety and health legislation probably will rectify numerous inadequacies in present rules and may ameliorate some aspects of existing occupational safety and health standards. However, I seriously doubt that much relaxation if any is to be expected in regard to the Asbestos Rep;ulations. I think the industry is going to have to mount a very determined effort to prevent these regulations from being tightened in the future. The EPA regulations concerning ambient air control of asbestos are another r~atter. Although it was responsible for initially tagging asbestos as a hazardous pollutant, since doing so EPA has been much less diligent in pursuing its announced intentions toward regulation of the materials it declared hazardous. EPA first declared asbestos a hazardous air pollutant on March 31, 1971, and published proposed regulations December 7 of the same year. Hearings were held and much industry input was accepted and very deliberately reviewed by EPA before they finally issued the National Emissions Standard on April 6 of this year. This regulation was promulgated nearly a year later than called for under the requirements of the Federal Clean Air Act. For this EPA has been under considerable criticism ever since. In addition to being late, the EPA standard is a lot less stringent than I or any other industry people, nho have followed its development, expected. Nearly all the objections voiced by industy concerning the originally proposed standard were removed before they issued the final regulations. In addition, they modified some requirements to the extent that no one in industry expected, or even would have had the temerity to request, in meetings where these subjects were discussed between industry representatives and EPA. In essence, the standard boils down to the following statement as far as emissions are concerned: There shall be no visible emissions to outside air from any asbestos mill or manufacturing operation except when a specified method of air cleaning, also part of the standards, is used before the emission escapes. In general, the air cleaning systems specified, filter asbestos emissions to the point that visible emissions, other than possible condensed ~;rater vapor, would not be produced anyway. FMSI 02480 -8- Asbestos and The Friction ~Iate;.:ial Industry Other requirements concerning use of tailings for surfacing roads, the regulation of demolition activities, and controlled application of spray-on materials are of little concern to friction materials processors. Our biggest concern lies with the emission standard, which t.Jill require the tightening up of dust collection facilities and waste disposal practices wherever fugitive dust problems occur. The oiggest problem with EPA regulation I have found thus far has been non-uniform interpretation of what constitutes a visible emission. I know the EPA people ~<Tho drafted the regulation intended this to mean just what it says. If it's visible under any condition whatsoever. and EPA approved air cleaning systems are not in use, the emission is in violation. Since most friction materials manufacturers already are employing baghouses that meet EPA standards for cleaning their exhaust air streams, it is unlikely that any severe impact will occur to the industry as a t1hole on account of the EPA regulations as they now stand. Those few manufacturers l'7ho are relying on wet dust collectors that do not meet the EPA standard may have problems. The best t'lay to be sure of meeting EPA requirements is to sharpen up on maintenance and operation of existing bagnouse filters and replace existing to1et collectors uith baghouse filters to eliminate visible emissions. In summary, the OSHA and EPA Asbestos Regulations are alot more lenient than many interested and concerned parties wish. We can expect pressure to have them tightened. Friction materials manufacturers should support Asbestos Industry efforts to have them mitigated in hopes they at least aren't made more severe. In the meantime, we should conform to the regulations to protect our employees and our customers and to avoid criticism and enforcement actions. Your t~bestos Ztudy Co~ttee will continue to foll~T the interpretation of existing regulations, the trend of proposed changes, and the development of n~" medical and scientific study material that may affect future regulation of asbestos products. TTe t-7elcome your questions and any imput you may be able to make concerning our activities. FMSI 02481 ,'\1EMO from the desk ~~ I.H. WEAVER 6-19-73 The attached states the EPA Asbestos Emission Standard more succinct~ than any wording I have seen thus far. I suggest you use this wording if need for any further explanation arises. note that "visible emission" are permitted if specified air cleaning methods are employed FMSI 02482 NEWS FOCUS EPA Sets Final Emission Standards 1::or Asbestos, Beryllium, Mercury National emission standards for the first three air pollutants to he designated as hazardous to health under the 19i0 Clean Air Act Amendments-asbestos, beryllium, and mercury-were set by Environmental Protection .-\gency Administmtor William D. Ruckelshaus on March 30. The Act dPfines hazardous air pollutants as those which "may cause, or contribute to, an increase in mortnlitv or an increase in serious irreversible or incapacitating reversible illnes.,.'' The El'A action cor!1p!ied with order issued January 29 by U. S. District Court in \Yashinglon, D.C., in suit brought by the Environmental Defense Fund, Inc., and Ralph Nader's Health Research Group last December. The suit charged that EPA had illegally delayed issuance of the standards for more than six months, and the court ordered EPA to promulgate the standards "itbin60 day:<. i\Iany studies haYe shown a link between occupational exposure to asbestos ami a higher-than-expected incidence of bronchial cancer, HuckPbhaus s;<id. Asbestos also has been identified as a causal factor in development of cancers of the membranes lining the chest and abdomen. The proven efl"ects of beryllium on health inclncle both acute and chronic let hal ttdwlation effects a' well tl>i skin ami eYe effects. The Bcrdlitun Case Hegister at :\lussachusetts General Ho~pital in Boston now contains oYer i:i20 proven cases of beryllium-related diseases, mostly from occupational exposure. Exposure to metallic mercury vapors tnay can:-:e ~tutr:ll IH.'nou.~ ~ystern injury an< 1kidney damage, Huckebhaus noted. Laboratory data frnm animnl tests inclieate a risk of !1<-r:umulation of mercury in body systems tbat could result in brain dnmage, while pwlonged expo~me inYohe:; a d('finite risk of mercury intoxication, he s1id. A summary of specific regulations for each of the pollutants follows. Asbestos Standards The surfacing of roadways v.'ith asbestos tailings is prohibited, except for temporary roadways in an area of asbestos ore deposits. There shall be no viRible emissions to the outside air, unless the specified air-cleaning methods are used, from any operation which manufactures: cloth, cord, wicks, tubing, tape, twine, rope, thread, yarn, roving, lap, other textile products, cement products, fireproofing and insuiating materials, friction products, paper, mill~oard, fe!t, floor tile, paints, coatings, caulks, adhesives, sealants, plastics and rubber materials, and chlorine. 11 The regulations covering demolition of buildings are: (1) asbestos materials used to insulate or fireproof any boiler, pipe, or structural member shall be wetted and removed from any building before the wrecking begins. The asbestos debris shall be wetted at all stages of demolition and related handling operations. (2) No pipe or structural member covered v.'ith asbestos insulating or fireproofing material shall be dropped or thrown from any building but shall be carefully lowered to ground level. (3) No asbestos debris shall be dropped or thrown to the ground or from one floor to another. For buildings, 50 feet or greater in height, asbestos debris shall be lowered to the ground via dusttight chutes or containers. 11 Certain demolition operations are exempt from the regulations, except for the wetting of asbestos debris, if a building has been de~lnred to be structurally . unsound and in danger of imminent collapse. II There shall be no visible emissions from the spray-on application of materials containing more than one percent asbestos, on a dry weight basis, used to insulate or fireproof equipment and machinery. Spray-on materials used to insulate or fireproof buildings, structures, pipes, and conduits must contain less than one percent asbestos dryweight basis. Beryllium Standards The beryllium standards apply to extraction plants, ceramic plnnt~, fllunclries, incinerators, and propellant plants which process beryllium ore, beryllium, beryllium oxide, beryllium alloys, beryllium-containing waste, and machine shops which process beryllium, beryllium oxides, or any alloy when such alloy contains more than 25 percent beryllium by weight. The beryllium standards are: 11 Emissions from stationary sources shall not exceed 10 grams of beryllium over a 24-hour period. As a substitute for this standard, an owner or operator may request approval from the EP.\ Administrator to meet an ambient concentration limit on beryllium in the vicinity of the stationary source of 0.01 micrograms per cubic meter (.ug/m3). The burning of beryllium and/or beryllium containing waste is prchibited except in incinerators. Incinerator emissions must comply with the above 24-hour standard. Beryllium emission standards for rocket-motor firings at test sites arc: Emissions to the atrno<phere inm: rocket motor test sites shall not mu::;l.' time-weighted atmospheric concentrations of beryllium to exceed i5 microgram minutes per cubic meter of air within the limits of 10 to 60 minutes. accumulated during any 3 consecuti,e weeks, in any area in which an etlc,: adverse to public health could occur. If combustion products from the firing of beryllium propellant are co:lected in a closed tank, emissions from the tank shall not exceed 2 grams per hour and a maximum of 10 grams ver day. Mercury Standard The mercury standard applies ~,, stationary sources which process mercurv ore to recoYer mercurv and to tho~e whi~h usc mercun cl1lor-alh.a'i cells to produce chlorine gas and all;:a!.i m~tal hydroxide. The mercury standard is: Emission.:' shall not exceed 2300 grams of mercury per 2,1-hour period. The asbestos standards are: There shall be no visible emissions to thP out:<ide air from anv asbe>'to:; mill except when I< spec-ified .method of air cleaning, also part of these standards, is Uocd before the emi-~ions escape to the oubi<le ltir. In gPneral, these aircleaning systems filter asbe~to-; emissions to the point that visible emis;;ions would not be produced anywny. {Complex Source' Air Pollution Rules To Be Established by June 1l }{egulation.-; requiring states t0 review, prior to cow;truction, the air quality impact of ''complex sources" such as shopping center~, sport complexe~, highways, and :;imilar facilities, will be issued bv the Euviror;ment:ll Protection Agenc) by June 11. Rules will require states to determine whethe:actiYities as..,ociated with such sonrces, including newly generated auto traffic, 398 Journal of the Air Pollution Control Association FMSI 02483 ,, .. ffiiCTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 BULLETIN N 0. 478 June 14, 1973 Subject: ASBESTOS STUDY COMMITTEE ACTIVITIES At the June 1, 1973 meeting of the Asbestos Study Committee, it was recommended that the following information be distributed to the Membership. 1. OSHA Labeling Reguirements 2. In-plant CAUTION Sign (W. H. Brady Co.) 3. EPA Emissions Standards - A Discussion OSHA Labeling Reguirements Attached is Exhibit I, a display of four different OSHA CAUTION labels. One is with a gummed backing to attach to packaging. Another is in the form of a tag. Others are imprinted on the cartons or boxes when purchased from the box manufacturer. The Committee adopted a resolution at an earlier meeting which essentially recommended that Members obey the law. That resolution stated: That (1} where asbestos containing materials do not have their asbestos fiber completely locked in, or (2) where subsequent operationsmay b.eperformed on asbestos containing materials, the hazardous labeling practice be adhered to in accordance with the Label Specifications in the OSHA Standards for Exposure to Asbestos Dust. The Committee has decided to make no recommendations on style, minimum dimensions, etc. It recommends that the manufacturer comply with the requirements of the act, demonstrating "good faith" in their observation of the requirements. In other words, printing a miniature CAUTION label on the bottom of a large box would not be demonstrating "good faith-. 11 According to the Standards the labels 11 shall be printed in letters of sufficient size and contrast as to be readily visible and legible." In-plant CAUTION sign (W.H.Brady Co.) Enclosed also is a copy of a letter from the W.H.Brady Co., Milwaukee, Wisconsin, to which we've added a CAUTION sign as manufactured by the Brady Co. This sign conforms to the requirements of the OSHA Standards. Several Committee members feel the cost of these signs is attractive. See Exhibit II. FMSI 02484 - 2- :. i EPA Emissions Standards- A Discussion At this recent Committee meeting, the new EPA Emissions Standards were discussed. As there were several different interpretations by Members and Regional EPA personnel, a digest of the minutes of the meeting are enclosed. It will be noted that there are different interpretations concerning several items: (1) "new source11 versus "existing source," (2) whether to quantify machines under "Process Description," and (3) whether "Amount of Pollutant" - if given total into each Process- will then be construed as being 5 to 10 times the total asbestos entered into the process. See Exhi hit Ill. EWD/erc Enclosures: To: Active Members Regional Members E. W. Dr i sl ane Executive Director FMSI 02485 FRICTION MATERIALS STANDARDS INSTITUTE, INC. CAUinON Contains Asbestos Fibres Avoid Creating Dust BreatMng Asbestos Dust b\1ay Cause Serious Oodily Harm CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM Contaans Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust may cause serious ~oc1JD;y Ciarm 051-/A :r:. )(.. H 18 IT" CAUTION Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust Ma'/ C'-use Serious Ect!ily Harm FMSI 02486 ,v H t>HADY r.o 787 Westl Glendalr-1 Avo, Milwl-lukr-JO, W1-eJ. 632P1 lst.1914 Phone C414) 332-8100 Telex 26-677 Teletype B10-2BZ-!3151 Oable Oradyco Attention: Plant Engine~r Dear Sir: As a s~pplier of asbestos materials to industry and commerce we thought you'd like to know Brady has asbestos hazard signs in stock, ready for immediate shipment. The sign complies in color, and size and wording "'ith OSHA l910;93a(g). A repro-: duction of the ~ign is attached. Stock fiCAU-PP-11-5 signs are made of non-corrosive, non-conductive Brady B-450 linear pol>ethy~. The coptrasting color black and yellow signs can be used indoors or outdoora and have built-in ultraviolet light ~nhibiter for long life. J They are mechanically mounte4 with fasteners. 'rheRo l4 1'x20" tough, dur.ahlo signs atc priced nt $3.99 on. (10-ltO qllf\ntlty) and $3.79 each in 50-99 quantitiCS:--v:cr:B. Milwaukee, Wise. or from any Brady D~stributor listed on the enclosed sheet. A copy of our latest catalog MS-520 is also enclosed for your review of OSHA marl<ing requirements. \-1o 1oo\<. forward to receiving orders for your OSHA ,marking n>eds. Yours truly, ASBESTOS DUST~AZARD W. H. BRAUY CO, ;:~~:r- Sales Nanager Industrial Products Division AVOID BREATHING DUST WEAR ASSIGNED PROTECTIVE EQUIPMENT DO NOT REMAIN IN AREA UNLESS YOUR WORK REQUIRES IT BREATHING ASBESTOS DUST MAY BE HAZARDOUS TO VOUR HEALTH ~- FMSI 02487 fRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 EPA EMISSIONS STANDARDS FOR ASBESTOS- A DISCUSSION The following comments are digested from a June 1973 discussion of an Asbestos Study Committee meeting at the Institute. These comments may be of some interest to those filing the EPA Source Reports. Vlhi le the new EPA ami ssions standards appear to be reasonable, there is some di fficulty in inteq>retation. For example, the standards are not simply "No visible emissions, 11 but (1) there could be no visible emissions even if they do not meet the air cleaning requirements, or (2) one could even have visible emissions if they were using a collector with the specifications recommended by the EPA. In other words, if you have the EPA's recommended collector you could possibly have visible emissions and still be complying with the EPA requirements. It goes without saying, that interpretation of the requirements by individuals in the different EPA regions may vary quite a bit. The EPA is saying in their Standards that the wet collector is not as efficient as the dry-bag collector. If an EPA Enforcement Officer sees a vapor from the stack where a wet collector is used, the source best be able to prove there is no asbestos being discharged. In other words, it can be inferred that if a source has wet collectors they may more likely be cited for visible emissions. While it is apparent that the EPA's emissions standards promote the dry collection of asbestos in bags, many problems have been indicated with these collectors. One of the problems was repeated fires in the collection system. Another member stated that he too had this problem until-cigarette smoking was banned in the factory. Since discontinuing smoking in the factory, he claims they have not had more than one or two fires in the last 25 years. Another member said that may be, but they have had the No Smoking rule for many years and they still have fires. This party blames the fires on the incentive program where the workers receive a bonus for exceeding certain work standards. This promotes the taking of heavier cuts with grinding wheels and creates sparks which apparently promote the fires in the system. The operation that has not had any fires for the past 25 years does not have an incentive system and does not permit smoking in the work place. ~/here the wet collectors are now in use, apparently the EPA is permitting their use as complying with the requirements. At this point, the disposal of the materials picked up by the collectors was brought up. One member sent the dust to a pelletizing machine. In this process they add 51o-10% cement to the pelletizer. A volumereduction in the order of 3 to 1 was developed. The pellets are taken by truck and dumped as land fill. While the pellets could be broken down into a powder, if they receive reasonable handling they can be readily moved frqmthe pelletizing machineto the land fill operation. It is this member's intention to install a vacuum system from the collecting areas to go to a central pelletizing machine. One member described his handling of dust from (1) a central collector, to (2) a screw conveyor, to (3) a truck, and to (4) the land fill. The workers in this case use respirators. The pelletizing operation not only reduces the transportation cost by three times but eliminates the need for the watering truck and an individual to wet down the land fill. However, the costs of this pelletizing equipment are substantial. A manufacturer of pelletizing equipment is Ferro Tech Inc., 1231 Banksville Road, Pittsburgh, Pa. 15216. EXHIBIT !II FMSI 02488 - 2- Several members mentioned that in dealing with the EPA Regional Offices they were having difficulties deciding what was a "new source" and what was an "existing source." Also, where one manufacturer adds one machine to an existing collection system he may not be in compliance without getting a Waiver of Compliance. Apparently the EPA will not give a Waiver of Compliance that will take more than 12 months to complete. An applicant must give the steps to be taken and the schedule to be met. When each date arrives, the applicant must advise EPA concerning completion of that stage of the schedule. One member felt that we should review the EPA source report form to get a better understanding of what they were calling for. Page one of the report would be used for each factory. As there would most likely be several points of emission, page 2 would be completed for each stack or collector that emits asbestos. If a manufacturer wished to make an addition or modification in his plant withequipment that might put asbestos into the atmosphere, he must file with the EPA. On page 1 of the report he would cross off the words 11 Source Report" and type in either 11 Application to Construct a New Source, 11 or Application to Modify Existing Source. 11 In reviewing page 2 of the report under 11 Process Description,n some questions came up as to how to complete this section. One member who had worked on this report with the EPA said you should enter here the type of machinery used without quantifying. Another member indicated that the EPA insisted that he list the type of equipment and the numbers of each piece of equipment. If the EPA specifically said to list the numbers and types of equipment in this section it was suggestedthat they would have said so on page 2 of the report. The question of put-. ting down the numbers and types of equipment could become very cumbersome where a manufacturer wished to move a grinding machine from a location with one collector to another location where it would be hooked into another collector. The member who filed with the EPA worked on reports in 2 different jurisdictions: New York and Tennessee. He indicated that at neither location did he enter the number of pieces of equipment on this form. (Since the meeting he called to advise that the application filed in Tennessee without quantities was accepted by the EPA. His application in New York State had not been either accepted or rejected as of June 4, 1973.) It would appear that Regional Offices are not in agreement as regards quantification of the equipment under the "Process Description." The quest ion came up concerning interpretation of quest ion 3, the 11 Amount of Pollutant.11 In many factories a set of dry mix brake blocks could emit into a collection system at the mixer, at the briquette press, at the cut-off wheels, at grinding, at drilling, and at inspection and boxing. The problem is that this is the same original asbestos which entered the process and might be counted 6-8 times. So, in effect, a factory taking in one million pounds of asbestos might list one million pounds of asbestos going into 8 different collection systems. This, in turn, would make it appear that eight million pounds of asbestos is going into the operation. From the wording of the form, it would appear that this is exactly what the EPA wants. However, another member was told that this is not what the EPA wants. He suggests that if a factory takes in one million pounds of asbestos into the process that it should not report in total more t~an one million pounds of asbestos. If he had 10 different emission points, he would divide the one million pounds of asbestos by 10 to give the "amount of pollutant." Again, their apparently has been adiffer-; ence . in interpretation from different Regional Offices of the EPA. On page 3 of the report, under "Waiver of Compliance, 11 it was stated that Sect ions 2a and 2b did not have to be completed unless EPA specifically requests this information. FMSI 02489 3/1r SllviPLIFY LABELING OF ASBESTOS PRODUC'TS AND ASBESTOS \VASTE MATERIALS ; ~r.,. r"': q !~Ji ; . :::ju ,;t .! N.\m11 (-~-- :<-:- ~.; :~, ""',r;p.r~~ :on~ ~r-\:- v:: . ~. -~ .>. ---~....~-i~;..~-~..... ~........;~ .t~ No extra labels to buy or put on. No tags to come off. o No labels to come unglued. o OSHA specified wording printed directly on bag. e Continuously and conspicuously displayed. o Yellow lettering on a green background. o A vailable in two sizes and two thicknesses. e Ideal for waste such as stripped insulation, scraps, etc. Strong, durable polycthclene bags arc available in two sizes, 30"x48" and 30"x37", and two thickne5ses, 0.002 and 0.004 inches. These bags were conceived 1s a workable solution to labeling asbestos waste according to OSHA 191 0.93a. You will discover they have many other uses such as consolidating storage space for preformed asbestos insulation wh ::n removed iwm ~hipping uoxc:., auJ lri.ilisportin soiled coveralls to laundry facilities once used in asbestos work. Order today from: LOSS CONTROL PROD1JCTS OF HOUSTON P. 0. Box 52742 HOUSTON, TEXAS 77052 FMSI 02490 POLYI~Tlll::t.F"!'JF I\1\CS Wllll ASBESTOS WARN1N<; LABEL FLt Bags, Bottcw1 \ield Total Qui1ntity per Onl.:..cr;;;____ 1, 000 2,500 5,000 10,000 Cost per r:CJsd2QO)/Cust per ~000 . 004" t.hickncss .002 11 thickness 30'1 X 48" 30" X 37" 30 11 X 48" 30 11 X ]7" 53.60/2b8.00 L;2.00/210.00 29.00/145.00 23.50/117.50 52.90/264.50 41.68/208.40 28.50/142.50 22.75/113.75 52.00/260.00 41.00/205.00 28.00/140.00 22.J5/111. 75 51.90/259.50 40.80/204.00 27.75/138.75 22.15/110.75 Hinimur:- Order -- i case of 200 bags Prices F.O.B. Houston, Texas 7 inch twist ties -- $1.50 per 1000 ,.<>',Due to supply difficulties and pr~c~ng changes of raw materials caused by the fuel shortag0, prices are subject to change without notice. Current prices are available upon request. u__:ss CG~~TROL PRODUCiS OF il-OTJSTON P. 0. Box 5271~2 Houston, Texas 77052 Samples sent upon request FMSI 02491 .. 1. Diac: brake emissions collector (left) lrom back, showing Instrumentation; (right) ehowlng thermal control aida. .. ;' HOW MUCH ASBESTOS DO VEHICLES EMIT? 'I ,i I 1 '' ',I '': ~ i ,I Most of asbestos emitted from vehicle brakes and clutches Clition of l!mieslona trends for frlc. is converted to other products, with only 3.2% df total lion materials with continur.d uso, The third vehicle lest simulated a asbestos emitted entering the atmosp!'lere, according complete brake. reline, including to Bendix researchers. turned discs and drums. All friction malt,rials conlnirted 11slustos, anti ww rtpn~ntuth" of tho.,..~ ~upplittl hy lhr inriiiMiry. Mil A t'otutut>ht>u~ho h,,...~tlflution of gan 111111 Jutrtirulutt eml:;.~lnn~ from nulo motin llrakts lltlll clutclws during Surf:wr.11 ~nmplt>s, Including Wt'ar dthrill tm ltraktl 1111d collerlur shroud ,.urlacl.'!l, . , ltriul!t frurn AIJ.,x, Btfltlix, Ha)luslu" Munlutllt'll, 'fhiukul, und Wurltllll'~lu~ were used for original equipnwnl und actual whiclo optration ~hows that, Airhorne samplt'S, collected on aftermarket disc pads and drum on the avt"rllge, moro than 99.7% membrane filters. linings, selected in part ftf'CaU~C of of tht> asbt'slos emitted is comtrtt>d The clutch was sealed hy closing their high-volume usage. lo otht'r products, Tht> c{)ntrihution the remaining few holes in itS.~casing. to tlw atmosphl're is l'stimated to be Tlte lt'ft wheel brakes were kept in !'l060 lb tll"r year for the "d10le couth their normal configuralion. 'they were Collecting the eml11lon Fig. a :;hows a CI'OSIOSI'Ctionul vlttW lr)' -- or 3.2~(, of llu~ tulul usltcstos nsl'<l to monitor the nperalion of tlw ol the disc l.mke cmi:~.~iunH t<ttllt!lnr. t'tllilltd, ~hroutlt>tl hrakts. Wear dchris was Tlw ruhhing ll(lfl ill loc:alltl ut tlw Tlw:<tt figurt's lll'l'e uhlahwd wilh laktn rrmn the left hrakes as wt'll as '.hat or huh section of the rolur. The '' lllt'diumWtlght \ -18SO.Ih lest from those on the right. The.4tmounts seal is a spring-loaded, graphitl'-filled weight l, high-rolume passrnger car of dl"hris formed and the composi- Teflon seal of commercial manufae with a 3-sprttl mut)tud transmission, tions weer. u~d to <ltmonstrnte that ture. The main portion of the shroud \'t'ntihtltd tn~t-irun disc hrake.\ in tlw hrakl' ~hroutling did not signi was coated with black oxide. A water front, cast-irotl drum brakes in tht! ficantly affect oprration of the right- cooling system was added, and an rear, and a dry clutch. A front disc hand brakes. ppen "mag" wheel was used to aid brake collector (Fig, 1) and a rtar drum hrakt" colltctor (Fig, 21 in stalltd n till' ri~ht ~itlt or tho \'I' rreHow the tests run in cooling the encloeed hrukr. A cross-sectional view uf lhr tlruw Throe vt'h icit lt~sts were run: the hruke emi55iuns collrttur iK siJOwn in hiclt> t'ollltdtd lht wtur dtltris and fir:st wilh original equipnwnt fric- Fig. 4, aloug with details of the ruJ,. "'PIIralttl it into lltrtt fractions! tion materials; tlw seco11d simulating bing seal, which is the same type us ~ump samplts, including lhe we11r a partial reline - fropts only were that on the disc brake !'missions eol- debris on lining surf11ccs, In rhet relined, with the rears 'retained as is lector. The axle hub used to align holes, and on th~> brake dnun. to ghe a replic11te l!>st, and an indi- fhe drum was modifirtl with ' rr n-1 (?.\ FMSI 02492 ': ', ::l I 1r frk d u~ ott'd a h1ding ntainnd tiYo of \'. ~In .:u"'..'.'~',".~.~ nt 111ul thltlll lllfilll ,,, 1l yitw iltttor. .Ill till' r. Tlw l'fiill fllllf(ll' 'wiHHIIll , water nd an to alii .lrnn1 IWII in It' nth )p 1111 ... 1'111 tllgn . II Dit'C8 a. Auemblecl. ,.., drum breke eml..loM collector (left) shown from Inboard; (right) shown from outboard. '' lhat Wll~ rotll't'ntrio In the 11xlo htar ings within 0.001 in:: 10.0025 em L A tnpl'rrd lead facilitated ' drum mounting. Cln~e tolorances were ntN"5~ary on thl' cnrwtntricitjes to oh lain rl'a!'(mahll' t't'nl lifl'. Se,l'n ll'~t whicle drhing schedules ,t were u~d. Each was followeJ hy n mrn~uft'mtnt prncl'dllrl' that hH'Indl'd tnkinf{ tmi~inn~ l!lllllpll'l'. ml'u~uring lll'llr, in~pNting ~y~ltm~. and replllr iug worn pnrt11, H mct~~ury. Flr~t, tlmt lowhmperature testa wtre run Burni~h, Afterhurnish Ba~l'linl', und n..troit Trnffic. Thtsc wtre followed hy thl' high-tempera ture tests - 10-stop Fade, Afterfade 8ast'Jine, 15-stop Fade, and Final Ba!ll'iine. Measuring asbestos content E111h ,.f tim 'amplt~ wu~ unnlyztl fur u~hl'~tus t'tmftnt hy uplirlll und tlrl'lmn mirro~ropy. For \'l'hkll' 11'~1 1, ashl'slo~ content ol hmkt rmi~~ion~ run~rd from or1.65~( down to 0.5t:f,. lhr 47 dnalr,...:~ nporltq, only tw~ were nhow }.OW; . Fnr tr~t 1, thr o\rrnll IIIWU~tl wu~ 0.:~8~~. For h~t 2. tlw u~lw~h~ eonttnt nm~"'' from l.l2~; down In 0,0:-\~(,. or ntlw llllilly~..~ nported, only tmr \1 us uhow \.09~;, uno only thrrl' llrrr I>I'IWt't'll lU10 uno 0.96% I aU ollll'rs wl'rl' ll'~s than 0.50%. Thr ntrrall 8\'l'nt!!'t' wns 0.25%. For \'l'hicll' ll'sl :1, the run~e of a~lw>tns conlt'nl in l>rakl' l'mis~lons 1urinl from O.;'il'i tit~\\ II In O.oo:v;, Of till' '"'"I"~ npnrhcl, tltrt't' mrt l>thn1''1 0.211 ~Inti 11.51 ~(>; all ntlll'rs ''~'~''' h'~'>~ tlum 11.20%. Till' owrnll 11\l'l'lllft' was 0.07~(,. For allthrrt \'thidt~ It'll&, the over. nil U\'l'fD~I' nf u~htu~ l'llllll'nl In tht hmktl crni~~iuns wu~ 0.2:\~(,, A8 11 l'htl'k on Btnclix rcsuit8, in Ol'ptndrnl aslotsln~ unaly~ts wrre also rnudt', whil'l1 ~an slightly different n'sult~. For txumplt, Battelle Colum- hus Lnhorntoril's, which analyzed 24 ~ampll'll p-l'nl'ratrd tluring th<' pro ~rnm, ohtuintti on o\'l'ril#!l' of 0.171%. whi1h i~ 61)';(. uf tlw Bmlix U\'l'fii!!:O of 0.21'/f for thr Mllll' 21 tlnalysl'~. The t'll.planation fnr tlw hi~lret' Btndix ,ulul's is ao; fnllowF>: ull lur~l'r fihl'Ts I hurullt~ of fihrils) found were U~AIIInod In l~tl rylindtr" of prnjrctl'd lianwltr and ll'ngth, and u fiher with un l'ilipli!'al crn~s-Sl'rlinn was uclulllly smnllrr in \olnm!' than reportrd. In addition, all fi hi'F!< WI'TC IIS~IIIIIl'rl to "". )OOti~ n~lotllln~ I pnrtinlly tit! 1-!:radtcl n~htsto~ or ulhinn fil~trH wtrc wtak urul nuchunitnlly niurt!d to rwnfihron~ IIHtlrriul hy the ollwr unalytkul ltchniqut used, htrwt, mtly the nmuining n~lw~lo~ filtrils: ,were counted). To rompa l't' tmis~ions prop;rly, it wna lll'!'r~nry In calnrlaltl thl' u,t...~tus mission~ factors for Puch sumple in micrul-lrum~/milt, Value~ of thi'>'C' (ne. I<HR Wt'l'll nhtairwtl hy rnultiplyi~ tim wtif!ht~ of hrukt l(ohriH ~nrahd hy tlu <~pprnprialt u~l"'tns pPrTtnts, lhl'n dividing hy milrR (JI'r ltst schedulr. ThnA, tithN n hil!:h ushl'~lns ronltul or 11 larp-r ~ampl1 f!:IVI' n high factor, Thl' tnncl,. in mht~tns trniP~inns cnn ht Pllllllllll ri1.l as lollmvs: "~1~~~1"" cnri~inns nn hi;!lll'r lor 1ww lrirtion "urlnoc~ unci clt'nl'a~ \~ith ll~t. Till' tlrurn lralw Jtrotlucl',. mnn u~hNttnt\ tml!!~~<ltmll than tlw tiiMcl hruk11 inltinlly, hut tht tliiTcrcnt:c riN:nuHt'H 11~ tht~ frintiun muttriuls cnntinut iu use. HI'B\')' ( ahusive) duty do nnt ncccssurilr gini 11 hightr JWr crnt us!Jestos; tlu~ larg1 amount of dthrls producro, howenr, give a ~ignilic;J!ll ripe iR nshc~~olos tmissions, Ashtstos mis~iruu1 frorn hmk1K olo ""'I'"tnn~t from fudu or IH'U\'Yhrty I hightRf I hl hurni~h \n IIHHII'futu hraking llowl'st). for tlw tlisc patls only, thl'rto 1~ on incnus. in u.~lll'slos rmisslous "ith innensed o~lll'~los COIIII'III in the (ric lion material. IThere was no 11nch trerul for thl' drum hrak!' mahrial~.l Hnth frnnt disf' pnd~ anol tlrum linilli-(M nf nhld.. lt~t ;\ hml wonr rahK t'lllllfJIIflllolo In th11~1 lonrnl i11 th utlrer two nhidn ltst~. yo~t till' asill'slos trniFoSions wer11 !li~nificuntiy lowl'r. (Roth pad;~ and ~l'<'orHiury liuin~~ contuinl'd hra~R chip~. whith muy ha\1 hren in part rl'sptm~ihlc for tlw rnnrr cnmpltlt ronnr~ion ttf tht a~hi'Mio~ in hmke rmis~ionR, I For hollt tli~ urul olrrrm i>ruktH, lhtt srrrfmc~ Mumplt wus till' lnq!t'>l .. r tlu~ tlwc 1ulomrt 92t;r ), tlu Krrmp ~<umpln WIIH II!' XI (ah111rt 1'/r: I, nntl tlw uirl~tlfllt' Rumplt wnM ~nurllt~t (ahnut 1~ 1. How asbestos emissions add up An rstimatr of thr total emiR~ionR rrolll hrakl'~ uml rlntf'hl'~ i~ l!h I'll in Tnhlt 1. Vulrr lur tlu nrrmlur ol Hhil~ ill u~ an hn!41d on ~timnii'H frplfl tht 1'\ntittnul llil!hwar 'l'rufli., Snfrty Admini~trati..n, thf' ftdl'rul HiJ!II\\ay Admlllifllration, and other l'fltlff'ttt. FMSI 02493 ~'{; \ f: 1., r.[,. .. l'f~'IING DUST j-P.P (. ,, ..I , . ' ',.' ' '.., ,,:, '. ,, J, ',' l E 3. DIM brllt shroud shown schomltlc:lly. 4, Drum brake ahroud shown achamatlcally. Tulnl ""'"'"'"~ tml~~iou~ 1wr pnr ,,....,, tull'nlalrtl hy nmhiplylu!f 1111' '"'i~hl nf tmllnn pr \'rhklr-milt ''" tlw munt... r of milt-~ tlw Hhidt "."" .triwu pr pnr untl tin umnhtr 11f 'hid in nr, Fur ''"'nmplt. for pn~FI'Ilf!t'r rur~. lht fnllo>winl{ ~timnh's Wt'rt' nclr t'tl'mtion Jihr~: ~85..!J!~- X .Wr_ x 9.9iR X }03 \l'hitlrmilt> /tf( -mi-l<'sX -1- X 96.4 X 10 \'t-lll.d<'P y'nr 15 ~ I! = 60..100 lh prr }''Rr to optrnlt nt higllt'r hmpcrnturt'R. In ntlditlnn. the dut<'h is 11~1'(1 mnrtl ofhn. Wlwn tht'!'t' clifTtnruf'M nrc luktn into uccnunt, lntul utdtl'~tnH crni,;.~ions pl'r light Iruek ur 1'111 eululld at 87.51 p.g/milc. Distrihution fnctnf!l lurcl to hr modificd ltccilliSt the truck tlrum Tntul n~h..~tns Prni~~lon~ pl'r ,.,,, hkJ,.: 2R.51 ."!!/milt, whirh wa~ nhlahwtl h~ uwnt!lill!f tlw \nlnr~ from llw throo \Thld lt~t~. Tlw u~h"l"" from th tt11t H'hiclc hrukt i~ more OJll'll than thf' I'Ur clrum friction rnattrials 'wn~ l'akulnttd tn hrake ano, in many in~lunees, has no tnd up us fnllnw11: 81.9~;.; tlrpo~itto splush ~hi ..lcls. It was f'Stimuttd, tlu~rr "" tlw ;.trnlllui. 1 1-.1~;. ntuimtl in furt, thut only uluntt 25~; ns mueh tin hmlw urul/11r tli~P"~"d of durinf( dPI.riK ntnuinK In u trtll'k drnm l>rukto \lt'riiJ.!I' !lllllltUIIIIjiPIIJ!l' fur J'll~~l'll !!~'~' 1'111'~ ""~ l'sthnultc!ut t)<)jll mile. ~n lr, urul :1. i;; tmillod In il~ ttl "'""l'lwro, Th" pnnluf!t~ Wtn ""'''' In tltltnnint llw .li,.trlhutim'r uf us in 11 l"'~~nJ!t'I'I'Ur tlrum ltruk Till' tlist ri Itill ion ..r tmi~siunK ro r Iruck. wus, tlwrdnn, calt-ulal~tl to lu: \umlwr of l'lto~t'llllr rrhhlf'~l nti"-''""" fnr pu~"n~tr f'llrs. Hi.9~i road dropout, 2.9'fi uirltornl', lltl, 100.000, Trmk lmrks nsuully llfl' htu,il'f mul 9.2'it ntaitwd in thl' J.rakts. Sul>~thullniJ tlw~" \'lllur~ In tht' lhnn pu,ot'll!ll'r-t'Ur hruk1s 11110 tl'nli '. Teble 1 Summar, ot All Brake and Clutch EmiAiona (lb per rrl l Tbis work was perforrncd with the ~upport of the Emironmt'ntal Protec tion Agcncy, through contract t\n. 68-0 ~-0020. I A Passenger Care Light Trucka Medium Truch and auaea Heavy Trucke Miscellaneoue Number of Vehlclet B6.400.000 17,100,000 Total Asbestos Emiaslona 60,400 32,300 li,600.000 1.200.000 11,61!1,000 Totals % ol Total 16.300 32.900 16,300' 158,200 Dlatrlbullon Dropout 49,470 28,420 14,330 28.920 14,330 135,470 (8~.6) Airborne :!,230 940 470 950 470 5,060 (3.21 Brake Retention 8,700 2,940 1,500 3,030 1,500 17,670 (11.2) Michael G. Jacko, phyoionl elwmlt, Bendix R~searrh Loboratorleo: Robrrl T. DuCharm<', sur~nisor, Bruke t:nginecr lng Laboratory, Automothe Control Sy tm Group, B..ndlx Corp.: and Jost'ph H. Somer, Ofli<fi n! Air & Wuter Pro j!fnllJ, Emlronnwntol l'rotcctlon Awnry, Posed on SAE pa1nr No. 73054H, "Hruko and Clutrh t:rniion Generated during Vehicle Optrutions," preSf'nted ut the SAE eaumaled equl to medium trucka walghte of friction material JKed lor both cate Automobile Engineering MrAtllliC, May goriel are almoat equal. tnclud., motoroyolea. tralle,., nd the like, 1973, O.troil. 1 FMSI 02494 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. #07652 BULLETIN No. 471 March 9, 1973 To: Delegates and Alternates Subject: Recommendation of Asbestos Study Committee This Bulletin concerns Asbestos and related subjects (primarily in-plant problems). Please route this to those responsible for this work. Labeline Practices The Asbestos Study Committee, after considerable discussion and debate, and careful selection of the wording, unanimously passed the following resolution at the February 16, 1973 meeting: RESOLVED: That (1} where asbestos containing materials do not have their asbestos fiber completely locked in, or (2) where subsequent operations may be performed on asbestos containing materials, the hazardous labeling practice be adhered to in accordance with the Label Specifications in the OSHA Standards for Exposure to Asbestos Dust. In esser.ce, the Committee is saying that the members should comply with the OSHA regulations. At the next meeting, the Committee plans to make a recommendation on the size and style of the label. Enclosed are the final results of the survey which was made of the membership concerning labeling by members. We received 15 replies fron an original canvass of 25 members. }uto~jc Bae Opening Machinery In earlier bulletins we ha11a a.uviscd {ht:J mamhership of the availability of asbestos bag opening machinery. Among those listed earlier were: Fairmount Engineering, Hackettstown, N. J. Stuart Glopat Corporation, Zanesville, Ohio Fourier Steel Works, Quebec, Canada Vanco Machine Company, Van Wert, Ohio Another firm which has capabilities in the asbestos bag opening field is: Taunton Engineering Company, Inc. 700 West Water Street Taunton, 1\Jlass. ;;tl2780 ( 'D"' t Laboratories for Samplinp and/or Countine Airborne Asbestos Fibers VI) A list of laboratories who will do sampling and(~r~o~nt.ing of airborne asbestos FMSI 02495 - 2- March 9, 1973 Medical Examinations for OSHA Asbestos Reeulations In the OSHA Standard for Exposure to Asbestos Dust, medical examination requirements are spelled out for workers who may be exposed to airborne asbestos fibers. Most firms with members on the Committee have already instituted the required medical examinations. There is an interesting service available from International Compumedics Corporation (ICM) where they offer to do the examinations, maintain records, etc., on what appears to be a reasonable fee basis. Please refer to their letter to the Institute of February 6, 1973. The costs indicated were for a contract with the Institute- something that was not requested and which the Institute could not directly sponsor. Any work would have to be on an individual manufacturer basis. The contact is: Mr. Don Iverson International Compumedics Corporation 14 Washington Road Princeton Junction, N. J. ;;'08550 Incidentally, we are in no position to judge the quality of ICM 1 s work. One member plans to use their services. At the meeting one member mentioned that they have received the cooperation of the local TB and Respiratory Disease Association. The Association brings in their mobile unit and runs the X-ray and pulmonary function examinations. From this point the Company Physician conducts the balance of the exam, EVID/erc Enclosure: E. W. Drislane Executive Director Final Results- Institute Labeling Survey Laboratories- Sampling/Counting Airborne Asbestos Fibers International Compumedics Corporation FMSI 02496 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. #07652 To: Members of Asbesto~ Study Committee Subject: General Information ilarch S, 1973 Based on discussions at the February 16, 1973 meeting, and suggestions from your Chairman, the following topics are covered. Labeling Practices ,..~ Samples of the Asbestos Caution signs used by asbestos and friction manufacturers are attached. one label is not per OSHA standards. This information is sent to the Committee for review so that they will be in a position to propose label specifications at the next meeting. Enclosed also are the results of the labeling survey made of Institute members. Of 25 requests, there were 15 replies. Laboratories for Sampline and/or Countine Airborne Asbestos Fjbers A list of laboratories and the contact (if available) for sampling and/or counting airborne asbestos fibers was prepared by the Chairman. This is distributed to the Committee for their information. Similar data will be sent to the Membership. British Conference on exposure to asb,stos durioe brake and clutch maintenanc~ (1969\ Your Chairman has forwar~apers presented at a British Conference on exposure to asbestos during brake and clutch maintenance, for distribution to the Committee. The papers are: Asbestos and Asbestosis Hygiene Standards for Asbestos Technical Implementation of the New Asbestos Regulations Control of the.Use of Asbestos-Containing Friction Materials Exposure to Asbestos During Brake Maintenance Removing Dusts from Brake Assemblies During Vehicle Servicing- Alternate Cleaning Methods Possible AI ternatives to Asbestos as a Friction Material Work-shop on effect of Government Saf~ty and Health Reeyaltions and Sueeestions for Compliance The Committee resolved at the February meeting that it is interested in a workshop on the above. Such a work-shop would be geared toward those at administrative i-eve~-sactually responsible for compliance with regulations: Factory Management, PlantEngineering, Environmental Services, Administration, etc. This would cover items on control of asbestos, general pollution control, waste disposal and would concern equipment and techniques. The Institute would be happy to sponsor such a one day work-shop, perferably in the Paramus area but possibly at other locations. It is recommendodthat the CommittLL bring suggestions for a specific agenda. The Johns-Manville Corporation (through Bill Reitze) would like to give a presentation on their HEAF (High Energy Air Filter) pollution control equipment. lt would be up to the Committee to decide whether to invite Johns-Manville - no longer an lr.stitute member. FMSI 02497 Asbestos Study Committee General Information - 2- \"arch S, 1973 Heat Stress Measurem,ents ,NIOSH recommendations for a standard for work in hot environments along with some specifics on equipment and testing are enclosed. These had been distributed earlier to those Committee members who had attended the February 16th meeting. This subject was not discussed at the meeting. Statistical Evaluation of the Membrane Filter Method At tne February meeting those who attended received copies of the Conclusions and Recommendations from a private study (By LFE Corporation for the Asbestos Information Association/NA) on the precision and accuracy of the membrane filter method for measuring airborne concentrations of asbestos fiber. Copies are distributed for those not present. (Major heading "Conclusions and Discussion" with pages 43-46 of the report.) International ComQumedics Corporation (ICM) Enclosed is a copy of a letter received from Mr. Don Iverson of ICM. This was discussed at the Committee meeting and is sent to insure that those not present are informed. DVD/erc Enclosure: E. ~~. Dr i slane Executive Director Sample Industry Labels Final Results- Institute Labeling Survey Laboratories- s~mpling/Counting Airborne Asbestos Fibers British Conference papers (March 1969) Heat Stress Paper Statistical Evaluation of Membrane Filter Method International Compumedics Corporation fMS\ 02498 M8ReMONT CORPORATION GRIZZLY/LELAND DIVISION 100 WEST CAROLINE ST. PAULDING, OHIO 45879 TELEPHONE 14191 399-3015 February 19, 1973 I. H. Weaver Raybestos Na.l1hattan 123 E. Stiegel Street Manheim, PennsylVa.nia 175!~5 Dear Mr. \Ieaver: .... It \ro..s a pleasure to meet you at the FMSI Asbestos Neeting on February 16, 1973. Enclosed are samples of the Caution Label that ve are no\l using. The larger label imprinted on the carton by the carton manufacturer is nuch less conspicuous to the customer. I I \Till look forward to seeing you again at a future meeting in Paramus. RCid:et Encl. Sincere).y, MAREHONT CORPORATION a.j~Cw~ Ralph C. IJyat./1 Administration Nanager ----- --- ---- - - - --~ --~- -- ------- -------- CAUTIO~J -- CO~JTAirJS ft:J~B~STOS F~~~:-~s AVOID CREATifJG DUST ~Jt'lfJ:'~~If~U,~ ,,~~"";'-~-'" "I , - io~ ~.- "~... ......_.:;, " , rl 'i, , 1 1 "' ; ,.. ~... -~-- ~---- '-"' ....fi' ~~,;;;: ~-J .\d i:iiJ r----C- AUSE. SfRIOUS BODILY !IA-!lr~1--~ CAUTION Contains Asbestos Fibers Breathing Asbestos Oust May vCause Serious Bodily liarm Ci I (7-) FMSI 02499 -hattan February 19, 1973 Mr. E. W. Drislane Friction Materials Standards Institute, Inc E. 210 Route #4 Paramus, N. J. Cl7652 I. H. WEAVER II CORPORATE DIRECTOR ENVIRONMENTAL CONTROL N w !"1 (/1 -1 fT1 G) fT1 r (/1 -1 :0 fT1 fT1 ,:-l :;:: )> z I fT1 :;:: -o zfT1 z Dear Ed: Subject: Asbestos Caution Labels Attached is copy I promised to send showing various Caution labels that are currently in use. r have not sent additional copies of this to the committee members and will appreciate it if you will take care of this. The one I prefer is the Cassiar Mines label in the left center of the attached sheet. This is the one R/M is using on most of their textile products containing non-locked-in fibre. We still use the label marked R/M shown to the right of the Cassiar label for some special cases where rubber stamping is preferable to an adhesive coated printed label. I have forwarded sufficient copies for youto circulate to the other members. I am up-dating my tabulation of laboratories and consultants for asbestos monitoring and will try to get a copy of this to you in the mail tomorrow. Sincerely, '.kF I H. Weaver w FMSI 02500 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E.210 ROUTE 4, PARM'IDS, N.J, 07652 ASBESTI)S STUDY COHMITTEE - LABELING SURVEY (25 Requests 15 replies, all questions not answered) Question Not Yes No Undecided A2:2licab le 1.1 Now label replacement shipments 1 13 1.2 Now label O.E.M. shipments 2 11 2 2.1 Plan to label replacement shipments? 55 4 2.2 Plan to label O.E.H. shipments? 63 4 2 3.1 Interpret OSHA to require labeling ~ere subsequent machining is expected? 10 4 1 Comment D A,B c A. Member replying YES, states: "If such practice is required and/or adopted by FMSI." B. Hember replying NO, states: "Our material has been treated with a binder - therefore no raw asbestos is present." C. Member replying YES, states: "We will label if it is determined that our bonding or binding material does not meet the standard." D. Hember replying YES, states "tole imprint cartons 1/4" letters, two sides of carton. We do not imprint cartons for OEM service outlets where linings are completely drilled and taper ground requiring no subsequent operations on the linings." fMS\ 0250'\ ICM INTERNATIONAL COMPUMEDICS CORPORATION CH-436-73 14 WASHINGTON ROAD PRINCETON JUNCTION, N.J. 08550 609-799-2290-1 February 6, 1973 Mr. Drislane Friction Materials Standards Institute East 210 Route #4 Paramus, N. J. 076.52 Dear Mr. Drislane s Please accept this as our proposal to establish a medical examination program using mobile health clinics. This program will provide your participants with a medical examination to meet the requirements of the asbestos standard enacted by the Department of Labor. This program is offered to your company at an average cost of $18.00 per examination, providing full utilization of the mobile clinics. Each mobile clinic can test 96 participants in an eight hour day. We will provide the asbestos standard medical examination at a rate of $20.00 per examination for the first 48 exams per day, and $16.00 per examination for any additional examinations done during that day. We will develop, implement and operate the total program, including medical record keeping. We only require the names, addresses and telephone numbers of the sites and the. employees to be tested. Through the use of computerized scheduling techniques, we will cover the 48 states with one or more clinics as required. Our costs per examination will include the full price of the program, including administration, record keeping, etc. Depending on your demographic requirements, a travel fee may be required. The mobile clinic will operate eight hours per day and can be moved once during that day. We would like to limit this move to thirty minutes travel time in order to meet decent utilization and use the computer scheduling techniques effectively. We will provide a medical questionnaire to meet the asbestos standard, give the pulmonary function tests 'and perfo:rm a 14" x 17" chest X-ray. Our company physicians and radiologists will submit their CUrriculum Vitaes for your approval. We will provide a $.500,000 malpractice and MerTOrs and omissions" insurance policy to the company for this program. We will maintain a central data base of medical records on each participant tested, and will submit this information to whomever it is required, employer, employee, union or government agency. In addition, we will provide each participan~ with an identification card, showing the date of the last examination. FMSI 02502 CH-436-?3 Mr. Drislane - 2- February 6, 1973 EaCh mobile unit will be staffed with a minimum of two paramedical personnel, headed by a licensed X-ra.y teChnician. The equipment wUl include a 14" x 1?" chest X-ra.y, spirometer to perform pulmonary function tests, dressing rooms and a reception area. Medical questionnaires will be sent in advance to the participants for completion before coming to the medical van f.or testing. Full administration of this program wUl be maintained out of our Princeton Junction, New Jersey office. All medical histories, including X-rays and results of the pulmonary function tests wUl be maUed on a da.Uy basis to Princeton Junction in order to provide for the orderly processing of the results and to establish a central. medical records data'base. Formal progress reports wUl be presented to your company by ICM. Our enclosure outlines the type of unit we are planning to use for this program.. We look forward to working closely with your company and the Department of Labor to provide a quality service to fulfill the asbestos sta.ndard in the area of medical examinations and medical record keeping for the asbestos sta.nda.rd. We ask for your criticisms in order to better serve all parties. We look forward to meeting with you in the near future to discuss implementation of this program. Very truly yours, Don Iverson President EI/ra.b Enc. ICM INTERNATIONAL COMPUMEDICS CORPORATION FMS\ 02503 FRICTION MATERIALS STANDARDS I~STITUTE, INC., E.210 ROUTE 4, BULLETIN N 0. 4 6 9 January 26, 1973 TO: ACTIVE ~m~mERS SUBJECT: ADDITIONAL BACKGROUliD ON ASBESTOS There has been considerable activity in the asbestos field over the past several months. It is suggested that this bulletin be forwarded to those in your organization most concerned with asbestos in the work place. 1. ASBESTOS STUDY COMMITTEE Members of the Committee have been advised that a Committee meeting is planned for February 16, 1973. Among items to be discussed are labelling practices for brake linings and the EPA asbestos emissions standards. 2. ASBESTOS BAG OPENING MACHINERY In Bulletin #459 the membership was advised that there was a machine for opening asbestos bags available from Fairmount Engineering. Ur. t~eaver, Chairman of the Committee recommended that the membership be advised of others in this field. Among those listed are: Stuart Glapat Corp., 1639 Moxahala Ave. Zanesville, Ohio 43701 Fournier Steel Works, Box 460 - Black Lake Quebec, Canada Vanco Machine Co., Inc., 1059 West Main St. Van Wert, Ohio 45891 3. EPA ASBESTOS EMISSIONS STANDARDS We expect the EPA Standards for asbestos emissions to be published in the Federal Register about February 15, 1973. When these are published, we plan to send copies to the membership. 4. N~.J YORK TIMES MAGAZINE ARTICLE "ASBESTOS, THE SAVER OF LIVES, HAS A DEADLY SIDE" There was a feature article published in the New York Times magazine section on Sunday, January 21, 1973. The article emphasized medical histories of asbestos workers as concerns lung cancer, mesothalioma and asbestosis. The article relied heavily on data supplied by Dr. Selikoff of Mt. Sinai Hospital. One conclusion reached by the author (and of course by Dr. Selikoff) was that the 5 fibers/cc (TWA) concentration of asbestos fibers in the work place was too lenient. This is the standard that will be reduced to 2 fibers/cc on July 1, 1976. The Institute will provide a copy of this article to any member requesting one. E. W. Drislane Executive Director FMSI 02504 FRICTIOll iiATEP..IALS STAL~D."~RDS I~JSTITUTE, IUC. E. 210 P.OUTE 4, P.ARAMUS, N.J. 07652 I REPORTS FOR JULIE 19 73 !IEETING 1. President's Report 2. Neubership Committee Report .?.... Treasurer's Report 3.1 Balance Sheet- Projected to June 30, 1973 3.2 Income Statement - Projected for the 1972-73 fiscal year 3.3 Retirement Fund for H. G. Duschek 3. 4 Twelve Year Finandal Highlights 4. Investment Advisory Committee Report 5. Budget Committee Report 6. Fee Formula Committee Report 7. Legislative Activity Committee Report 8. Public Relations Committee Report r 9. Institute Development Committee Report 10. Historical Sales Program 11. Hydraulic Parts ~~ufacturing r 12. Data Book & Technical Committee Report 12.1 Imported Cars- Cataloging 13. ~ Brake Ferformance ~tudy Committee Report Asbestos Study Committee Report 14.1 Address by I. Weaver to Membership 15. Annual iieeting Committee Report FMSI 02505 -1- /iliB~STJS STUDY CO~friTTTEE PillPORT Nr. I. ll. \veaver, Chairman of the Asbestos Study Cormnittee delivered a written report on the Committee's activities during 1972-73. This was a listing, by date, of the activities of the Committee. In addition, r1r. 1t1eaver, delivered a prepared address to the l1embership. Hr. \-1eaver' s report on the Commit tee's activities follows. 6/20/72 Circulated tabulation by AIA/NA c-omparing items in the OSHA standard against industry's position and recommendations of lHOSH and OSlLll. Advisory Comndttee on Asbestos Dusts (ACAD). 7/11/72 Circulated bulletin regarding the equipment and training for monitorinc of airborne asbestos fibre in the ,\.rork place. 8/17/72 Committee meetinr at Paramus reviewed interpretations of OSHA rer,ulations, labeling practices, airborne asbestos sampling and fibre counting, Bendix automotive emissions study for EPA, status of ErA regulations, consideration of substitutes for asbestos, waste disposal, other hazardous materials, and alternate methods for monitoring for airborne asbestos fibres. 9/18/72 Circulated lists of information EPA expected asbestos products manufacturers to provide their regional offices \vithin 30 days after promulgation of emission standards for asbestos. 10/10/72 Circulated New York Times article quoting Dr. Selikoff and referring to automotive emissions of asbestos. 10/20/72 Circulated notice of issue of revised rules and regulations for OSHA standards and availability of up-dated standards from U. S. Government Printing Office. 11/6/72 Circulated survey of labeling practices and interpretations of uSiiA labeling regulations. 12/7/72 Circulated information concerning i'!ichigan Department of Labor requirements for labeling of hazardous substances. i .I I :I I II il J :j ij': 'I EXHIBIT 14 FMSI 02506 -2- Report of Asbestos Study Comrrdttee (cont'd) 1/11/73 Circulated report of IRAC Advisory Committee on Asbestos Cancers resulting from their meetin~ at Lyon, France, October 1972. 1/26/73 Circulated information on asbestos bag opening equipment and an assortment of articles concerning asbestos/health matters. 2/16/73 Committee meeting at Paramus covered labeling practices, New York Times magazine article on asbestos/health problems, medical examination requirements of OSHA, proposed institute seminar on safety and health, EPA emissions st&1dards, report of IRAC Advisory Committee on Asbestos Cancers, EPA study of automotive emissions, statistical evaluation of membrane filter monitoring method, and NIOSH criteria for heat stress. 3/8/73 Circulated results of labeling practices survey, list of laboratories or consulting services offering to perform sampling and/or counting of airborne asbestos fibres, 7 British papers concerning exposure to asbestos during brake and clutch maintenance, Niosa heat stress recommendations, copies of conclusions and recommendations from LFE study of the meFbrane filter monitoring method, and copy of proposal from International Compumcdics Corp. concerning their medical examination and computerized record keeping services. 3/26/73 Circulated notice concerning proposed new OSHA Asbestos Advisory Committee and an article from Plastics TechnoloeY reagazine concerning press treatment of the asbestos situation. r 4/17/73 Circulated EPA emission standards, nevi information from OSHA regarding asbestos, and notice of availability of standard asbestos hazard signs from commercial source. 5/7/73 Circulated information from EPA on emission standards, source reporting forms, and EPA Publication .~-117, COl~ROL TECHNIQUES FOR ASBES'I'OS POLLUTANTS. 6/l/73 Committee meeting at Paramus coveredlabeling, EPA emission standards, proposed institute seminar on safety and health, results of brake and clutch emissionsstudy by Bendix for EPA, and OSHA inspection experiences. FMSI 02507 -1- j ASBE!::'f"S iuW TEJZ FitlCTIO~J ~1!\TEJ.tiAL Ii!DUSTRY Hr. I. ll. ~1eaver of Raybestos-Llanhattan, Inc., uho serves as Chairman of the Friction iJaterials Standards Institute Asbestos Study Committee addressed the Annual ~1embership t~eeting of the Institute. Hr. Weaver's address '.ras delivered in Vail, Colorado on TJednesday morning, June 27, 1973. Mr. T.Jeaver' s address follows: lfuen Ed (Drislane) asked me to attend your annual meeting last year, I had to decline, \.rhich may have been just as Hell in view of the confused status of both OSHA an~ EPA regulations at the time. This year thinss are only slightly less confused, but I am glad to be able to be here anyway to attempt to fulfill my responsibilities in reporting to you as your Asbestos Study Committee Chairman. Rather than present a detailed statement covering Committee activities for the year, I should like to use my time to review some of the more controversial and confused elements of the Federal Asbestos Regulations, and eive recommendations as to what I think the stance of the Friction r~aterials Industry should be in reeard to them. In lieu of a detailed report covering the past year's activities, I have prepared a page and a half summmary of the Committee's work from June '72 thru June 1, 1973. Ur. Drislane will circulate copies of this summary to anyone tv-ho may be interested in it, and 'if any of you have questions or recommendation~ concerning our past work or future intentions, please feel free to bring them up here, or if you prefer, transmit them to Ed for our review later. Probably the single most significant event that occurred during the past year on the subject of asbestos hazards uas the meeting of the International Agency for Research on Cancer that was held at Lyon, France last 0ctober. This meeting was attended~y more than a hundred and thirty medical researchers and representatives of government, industry and labor from virtually every major asbestos consuming or producing country in the world. For four days intensive sessions on asbestos were held by three different panels, each made up of ten to twenty-five of the foremost medical and scientific experts operating in the various fields of asbestos-health research. Foll~1ing the meetings the committees issued a combined report on asbestos cancers. I thiru~ the following five items summarize their most important conclusions: (1) ft~l major commercial types of asbestos can cause cancer. (2) Evidence suggests that excess lung cancer is not detectable uhen occupational exposure has been low. (Just what is meant by ''lm.r'; ~..ras not stated.) EXHIBIT 14.1 FMSI 02508 -3- 1-..sbestos and The Friction Uaterial Industry (cont 'd) l1eny union activists are really furious with government's failure to pursue the provisions of safety and health regulations to the letter, and there appears to be'a good opportunity for industry to release reliable information concerning asbestos hazards both to their employees and to their customers before more inflammatory information of this type is aired in the media under organized labor's banner. These rules and regulations pose much more severe problems for other segments of the asbestos industry, particularly asbestos textile manufacturers, than they do for most friction material manufacturers. I have been involved in asbestos products manufacturing for over twentyfive years and have visited dozens of plants and am aware of only a few friction materials products manufacturing operations that I consider to represent major problems in achieveing conformance to either OSHA or E~A requirements, including the 2 fibre per cc thereshold limit value. Since significant polarization may be expected always to exist between management and labor and between management and environmental groups concerning asbestos-health subjects, and since control or conformance to both EPA and OSHA regulations appears to be generally feasible, as far as friction materials are concerned, my recommendation to friction material manufacturers is that they proceed as rapidly as possible towards conformance \>7ith the regulations. Also I recotmnend avoiding inclinations to misinterpret provisions where the intent of the regulation is clear, but the wording may be subject to question. There has been considerable disregard of a number of provisions mainly in the areas of labeling, monitoring, employee education, personal protection, waste disposal, and use of warning signs by segments of asbestos products manufacturing, and I believe this applies to friction material to some extent. One of the most obvious items has to do with industry's reluctance to accept asbestos products labeline as required by OSHA. There has been much advertising of asbestos textile products citing the benefits of treatments or coatings that purport to lock the fibre into the product in such way that it cannot become airborne during use. tfuile these claims probably are true to varying degrees depending on the nature of the product, its use, and the way in which it is handled, I do not think this claim is at all applicable to friction materials. I knm-1 of no way any of us can be absolutely sure that his friction products, regardless of whether they are sold as original equipment or on the replacement market, will not be subjected to additional operations or alterations in the field that could result in excessive exposure of workers or bystanders to airborne asbestos fibre. I have been appalled to learn of a number of instances where this problem has occurred, and some of these cases involved people that certainly might have been expected to know better. FMSI 02509 . ----~.........._.~---~-~-~- --~~- t - . . -4- Asbestos and The Friction illaterial Industry (cont' d) If this kind of thing occurs in fabrication operations of major OE customers, it appears to me there can be no argument about the need for educational measures to reduce chances of unnecessary exposure during erinding, drilling or cutting operations. To those who argue that labeling or other types of warninG need not apply to replacement materials because fabricators or appliers handling replacement quantities are exposed relatively intermittently, I say emphatically this just ain't necessarily so! Large volume replacement users present major potential hazards, and even small job shops can needlessly expose people to high fibre concentrations if operations are performed without controls. That these may be intermittent and of short duration does not preclude possibility for occurrence of adverse health effects in hyper-susceptible individuals, or in less sensitive individuals who may receive exceedingly high doses of short duration but who may be smokers, or who may experience effects because of synergism with other materials to which they may be exposed either at work or elsewhere. To me, labeling all containers or packages of asbestos-containing friction material is the very least the industry can do to fulfill moral obligation to its customers, their employees, and the public and at the same time conform with mini~um requirements of the Occupational Safety and Health Act. I seriously question whether mere labeling is enough to fulfill this requirement. It has been suggested by others as well as myself several times in the past that additional instructions, of a more comprehensive nature than is practical to provide on a label, be inserted inside each package where a possibility exists that the product might be used in such manner that an airborne dust problem could be created. A number of responsible asbestos products manufacturers already are following th!s procedure, and there is a good possibility th~t it may be made mandatory in future regulations. Adoption of these measures by industry would show good faith toHard compliance and should reduce possibilities of future criticism by consumer protection groups. I doubt very much that it would have any significant effect on sales or consumption of asbestos friction materials. I know of no substitute for asbestos in normal automotive friction material service, and I know of little or no noticeable effect labeling has had on other products where cautionary labeling has been used thus far. Keep in mind that UIOSH and the OSHA Advisory Committee reconunended a much more severe label than the one we are talking about. This subject was heatedly debated during the OSHA Advisory Committee deliberations, and their final recommendation called for use of the word "Danger" instead of "Caution" and specifically mentioned that breathing asbestos causes cancer. Very frankly, I was exceedingly FMSI 02510 -5- Asbes toe and The Friction l'laterial Indus try ( cont' d) surprised when the final OSifA Standard came out in favor of considerably milder working. !~11 I am perplexed that Industry resits the OSHA labeling requirement as virgorously as it does. . ' Hany other elements of the OSHA Regulations came out more favorably toward industry than the recommendations that were submitted by NIOSi: and the Advisory Committee, and stiff resistance by Industry will be needed to prevent OSHA from strengthening the regulations in months to come. \Je can expect considerable effort to be made by anti-industry elements of the medical profession, by organized labor, and by environmental groups who want the airborne standard lowered from 2 fibres per cc to 1 fiber per cc or even less. Some individuals even speak of asbestos in terms of zero TLV, which, of course, is completely impractical and lfould result in virtual banning of mining and use of asbestos for anything. Another controversial subject is fibre monitoring. This is pretty much of a disaster area because of lack of ~onfidence in the me~brane filter method for samplinp; and analyzing for airborne asbestos. Uuch of this problem is attributable to the nature of the operation, which involves considerable judgement in addition to technical competency on the part of the people performin~ the tests. Even "Then performed by practiced individuals under the best possible conditions, the method is subject to wide variations in results. Needless to say, when performed by relatively inexperienced personnel under the widely varying conditions that exist in the field and bett<Ieen different laboratories, results can be extremely variable. In my opinion, the method is not at all suitable for enforcement purposes, but can be used to good advantage by industry for policing its own operations and for determining where to devote control efforts with maximum advantage or potential for improvement. In spite of its deficienCies, I think the menb rane filter nethod will persist for quite some time. but I will not be at all surprised if future emphasis by OSHA shifts t~,rard work practj_ce regulations rather than monitoring to a numerical standard. Another controversial item has been the protective clothing requirement. This has created considerable question and controversy, particularly in the textile industry where ceiling limits are difficult to control on certain operations. Different OSHA regional offices have applied different interpretations to the protective clothing requirement, and it's hard for me to.see how some of them can be as liberal on interpretation as they are. 7he regulation specifically calls for full body cover including gloves, hat, and foot covering, where levels exceed the ceiling \ \ FMSI 02511 ~--- -7- Asbestos and The Friction I'aterial Industry comparison of the existine re~ulations with industry's position as stated in their input to the government prior to promulgation of the regulation, and compared with the recommendations of NIOSH and the OSHA Advisory Committee, will readily indicate that the existinr OSHA standard, with the one serious exception of the two fibres per cc limit to be imposed in 1976, follows industry's position rather closely. If I appear to be defending the present OSHA Asbestos Regulations, it's only because I am very much aware of how much more strict these rules would be if the recommenda of IUOSil and the Advisory Committee had been followed. I doubt that many in the industry recognize or realize just how close they may have come to being ref,ulated out of existence. Future occupational safety and health legislation probably will rectify numerous inadequacies in present rules and may ameliorate some aspects of existing occupational safety and health standards. However, I seriously doubt that much relaxation if any is to be expected in regard to the Asbesto~ Reeulations. I think the industry is going to have to mount a very determined effort to prevent these regulations from being tightened in the future. The EPA regulations concerning ambient air control of asbestos are another I~atter. Although it was responsible for initially tagging asbestos as a hazardous pollutant, since doing so EPA has been less diligent in pursuing its announced intentions tm1ard of the materials it declared hazardous. EPA first declared ashes a hazardous air pollutant on March 31, 1971, and published pr regulations December 7 of the same year. Hearings were held and industry input was accepted and very deliberately reviewed by EPA before they finally issued the l'lational Emissions Standard on Apri of this year. This regulation was promulgated nearly a year later than called for under the requirements of the Federal Clean Air For this EPA has been under considerable criticism ever since. In addition to being late, the EPA standard is a lot less strin than I or any other industry people, Hho have followed its deve ment, expected.- Hearly all the objections voiced by industy ing the originally proposed standard were removed before they the final regulations. In addition, they modified some requi to the extent that no one in industry expected, or even to1ould had the temerity to request, in meetings where these subjects were discussed between industry representatives and EPA. In essence, the standard boils dmo10 to the following statement as as emissions are concerned: There shall be no visible emissions outside air from any asbestos mill or manufacturing operation when a specified method of air cleaning, also part of the s is used before the emission escapes. In general, the air cleaning systems specified, filter asbestos emissions to the point that emissions, other than possible condensed to7ater vapor, would not be produced anyway. FMSI 02512 -8Asbestos and The Friction iIaterial Industry Other requirements concerning use of tailings for surfacing roads the regulation of demolition activities, and controlled appli of spray-on materials are of little concern to friction materials processors. Our biggest concern lies with the emission'standard, which tvill require the tightening up of dua'tf .,. lities waste disposal practices wherever fugitive d~ The biggest problem with EPA regulation I have been non-uniform interpretation of what constitutes I know the EPA people tvho drafted the regulation intended this to mean just '"'hat it says. If it's visible under any:,,condition what ever, and EPA approved air cleaning systems are not i.tCu&e the emission is in violation. Since most friction materials manufacturers already are employing baghouses that meet EPA standards for cleaning"' their exhaust air streams, it is unlikely that anysevere impact will occur to the industry as a whole on accountiofJthe' EPA regula- tions as they now stand. Those few manufacturers~ho"''a'rerelying on wet dust collectors that do notmeet the EPA sta~dard~may have ,.. problems. The best way to be sure of meeting EPA''requi'reinents is to sharpen up on maintenance and operation of existing:baghouse filters and replace existing \,ret collectors uith 'baghouse filters to eliminate visible emissions. ' a .In summary, the OSHA and EPA Asbestos Regulations:;, alot more lenient than many interested and concerned partie5'<wisti. We can expect pressure to have them tightened. Friction materials manufacturers should support Asbestos Industry efforts to have them mitigated in hopes they at least aren't made more severe. In the meantime, '"e should conform to the regulations to protect our employees and our customers and to avoid criticism and enforcement actions. Your Asbestos Study Committee will continue to follow the.interpre- tation of existing regulations, the trend of proposl7,~,:~anges, and the development of new medical and scientific study material that may affect future regulation of asbestos products. t~e t-1elcome your questions and any imput you may be able to make concerning our activities. ,, FMSI 02513