Document YjKXoN65k4mN3NBN3EkMEXkLO

s Offlc* o( th* OMtarai CourtMl 5/8/80 K. Termaat My comments on the draft report of the Task Force are penned. Copies have been given to n. and the Litigation Department, office for review. WJR/tb attachment cc: M. Weiss N. Bernstein H. Epstein WTOmm J. Roo*y 800V 0300 Inter Office Engineering end Research Staff May 1, 1980 Messrs. D. D. Baker D. L. Block, M.D. J. H. Douma P. D. Fadow W. H. Fike S. M. Frey S. Gratch D. F. Hagen M. H. Hamburg G. C. Hedges C. D. Lauer ' E. T. Mabley J. H. Ogden J. A. Pflug ' H. W. Potoczak P. E. Prill J. G. Rivard V. H. Sussman J. D. Velte cc H. P. Freers G. O. Keutgen H. A. Niekol Subject: Carcinogens Task Force Report to EAR and MAS Subcommittees The Task Force on Carcinogens in the Workplace was established by joint action of the E&R and MAS Subcommittees, with representation from affected line and staff activities. The Task Force was chartered to coordinate plans and efforts to identify and quantify carcinogenic substances in use; to develop action plans, take aggressive steps and set targets for elimination of as many carcinogens as possible; and to organize to identify substances systematically. The Task Force will present its report to the Subcommittees on May 27, 1980. Attached is a draft of the report. Your comments are requested by May 9, 1980, so that we may meet the timing of the several pre-reviews scheduled. Attachment 8004 0301. EXECUTIVE summary CARCINOGENS IN THE WORKPLACE ^j#Ajy>*iAs<d*s yS /0U` A^VCliV The Task ce on Corclnogcns In thn Workplace was established By the Engineering nn< Research Manufacturing and Supply\Subeommittccs to identify/eorcinogcns and quui tlties in use, set targets for climinntion-^ahoud of regulntionrfnkc~ffcps toTmB'sUbstTtuj " develop a directive and workplan and organize to identify, substunees systemotically^^TheTask Foree ar-signrwont responded to e-vidcnce- that-eancee -may--be-V-SCTioos~oecopattoat concern encHoTWrCuiiipuny's mia~pm>Ui' cuml-ltii with tvgara mani-anrl public healthy of Tqi and-owternnl .paf/ssures regarding hazardous subGtnnce control and compliance liuvc inercused subotantiaHy since March, 1977, when Directive B-101 assigned responsibilities within the Company. , a-^-axIkaaaKa 'XT' ----- oJ~t/ Past Company Actions j^aXL^ l>x f /9 Since 1977, ttjp<Jompany has removed lead chromates'and molybdates from paint (except special order,); ."Tris" flame retardant from fabrics and instituted/'controls ori asbestos, " including^ Vpmcle Engineering directive that newly designed components should not contain & umented exceptions must be encapsulated or resin coated). -iAAZ+s /Jaajl- Kaa/ / ~ Sprayed-on fireproofing has been asoestos-free since 1969 for new and reworked construe- , \ . tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure 7U) been reduced>or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazeardtjs fi rom paint-related chromium compounds. The Task Force has identified sixty-seven (67)farcinogens in use in the automotive industry. Twenty-six (26) of those are currently regulated byOSHA; the balance have been proposed for new regulation. More restrictive standards nave~Bceir-propo3od for soma of those sutr- atanees currently regulated. Thirty-one (31) substances are reported to the Michigan- Department of Natural Resources for computation of water surveillance fees. Michigan - plants used 1.3 million "pounds of the twelve (12)?carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. SirrHlar-data-wTiotTrur- reatly_fc^uired. to bo roportad in-tho-other stews. The Itat-of carcinogens were priorUteed by he Task Force .according 4e 4mpaet orrthc-Compftny-loidcntify thc Jop eight -(8). The~tep- hree f the eight -pftortty substances, asbestos, chromium compounds, and benzene, examined in detail.. \ e^<(-- ----- v.___ Asbestos ts used by the Company primarily in vehicle brakes, clutches) gaskets and for nonprodubtion roofing, millboard and eore/mold-making materials. Medical evidence link 1 inhalation of asbestos dust to lung cancer, mesothelioma and other diseases. Thi present OSllA limit is 2 fibers per cc of air (2 million fibers per cubic meter) vhich is proposed to be reduced to 0.1 f/cc as early as this uar. ^ (l/vtvtv - Chromium compounds are used primarily in paints and inks for production and nonproducti<m use. Medical evidence links hexavalent chromium compounds to lung cancer, liver and kidney damage and other diseases. The present OSHA limit is 62 mg per tn pt air which is proposed to be reduced to 1 mg/m . 4 Benzene irs primarily in coke oven operations as a by-product. It is a residual r Q-----:--------t' constitue it of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids, cdical evidence links inhalation and contact with benzene to leukemia, blood dh rs and other diseases. OSHA has proposed a limit of 1 ppm in air time wclghtt average in 8 hours. vvfu; Specific lists of bulk malccials'and parts for production aftd nonproduction use hove been developed. A/ncw epmf>utcr data base is being developed Materials and Toxicology System (MATS), which links hcnlttv^yiflincciiaff. and manufacturing data bases to facilitate rapid Identification offcarcinogci^yplrioations (^nd quartcrX^Sl). The engineering release system has been audited and is Being updoica to extend materials identification to ell parts. Product Engineering Procedure PEP 3-189 has tx^h rewritten to require systematic review Vf suspcctKHrcinogcns and input to the data basj KJLstyudL&Ste>AA^. F l. 00 o o >o UJ o N> v>r a*s s I)At.L.U IIV I-. SUMMARY (Continued) ,U> uJLls Strategy nnd Workplan The search for usbestos, chromium compounds nnd benzene defined the number of ports and materials containing these substances ns listed in the table below. Where possible, the applications were divided into three groups: A - Known substitute materiel without mnjor redesign, B - Known substitute material with mnjor redesign nnd C - No knoivrTsubstTtuto or J advanced engineering required. The duuTuTdirectional only. There remain muny Mpcct~'3> applications which require time-consuming analyses for identification. J Ast>fcto8 Chromium Compounds Benzenq^ Bulk Materials nnd Parts Production B c Total 34 49 22 - 25 - IS 105 2S IS A B C Total 8-- 8 98 81 34 213 / 3 *- S 8 ^ ./ JL, V Strategies hive been formulated to eliminate or control these substances. The recommcndct strategy Ls to proceed now to eliminate these three 'carcinogen^ by Job #1, T985} of competitive nnd regulatory pre9ure,-~gmt Company experience. Where elimination^Hmnot bo contained, institute controls on design, process and exposure, it is Judged that the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing parts and materials. For those applications requiring major redesign (Group B, e.g., drum brake linings) the elimination timetable would hove to be adjusted to reflect Company cycle plans allhough.G.M. hos stated an intent to eliminate asbestos by ISfctb. Finally, whereno knowrTisubstituteybxists (Group C), advanced engineering will have to be completed before ^elimination timetable can be established. A ganeeatteed'workplan has been prepored on the basis of the evaluation of the^cafcinogone^ already referred to. The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle acti vities and the Manufacturing and Supply Staffs. It is judged that approximately a year is required to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is judged that one additional year would be required to implement the most feasible product actions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro- % Brams- _______ _______ / Recommendations Achievement of the recommended strategy requlrbs^m integrated approach throughout the Company and a sustained effort over a number of yeers^Thc Task Force recommends: I. Establish a Hazardous Substance, Control Committee chaired by Environmental and Safety Engineering Staff. Th^Tw Force would be discontinued. J. Assign Carcinogen Program manager control responsibility to Environmental and Safety Engineering Staff, ^ 'XKi^ST --hl^Mt Bnviunmental and Fnfaty'siaU-ir nttabttsh oaroinagen elim4nat4on timetables^ ft goMhe-Wtknown carcinogens for review end approval by the subcommittees. (The Task ' Force has requested General Managers and Chief Engineers to recommend directional timetables.) p,"3 Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job * 1, 198S. , - c 9.H Request that NAAO Product Engineering Offices and Manufacturing Staff present to the subcommittee specific action plans and timing for the Group A applications Identified. pS Provide advance program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C)._________ . , ; y.^Adopt-s~Thc Company cncoioogoiv-ttstmg^j^^F'Currerrt OSHA,iTgntgTCff nfid pfoposCtk Jf1 .A A Category! subsTlmees.--EstabHsh 4iui-lop eight'pr4oMUot-propo6ed-byThfr T^sk-foree es / 8004 0303 Engineering Staff - F.&RS Manufacturing Staff May 2, 1980 DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2,1980 8004 0304 T*T>rorr> r>\' OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production - Nonproduction . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Asbestos, chromium, benzene . Asbestos Summary . Chromium Summary . Benzene Summary 1 Carcinogen Search - List specs, and parts - Identify items having no substitutes - Identify substitutable items .. Eliminate when redesigned or reordered - Develop substitutes for others (advance engrg. funding) . MATS . Carcinogen Search Results . Carcinogen strategies . Generalized Workplan . Proposed Chemical Substances Control . Proposed Priority Actions Exhibits . ** . List of "67" Carcinogens . MATS Appendices . Asbestos-containing parts and materials . Chromium-containing parts and materials , Benzene-containing parts and materials i 800* 0305 DRAFT FEDERAL AND MICHIGAN ACTS REGULATING TOXIC/IIA7.ARDOUS MATERIALS HAVING IMPACT ON TIIF. COMPANY MOURE I Mfublorji Act* Packaging ft Stacking Occupational Safety and Health Act - 1970 d.O.L. (OSHA)* Hazardous Materials Transportation Act - 197$ D.O.T. (IITMA) Toxic Substances Control Act - 1974 E.P.A. (TSCA) Resource Conservation and Recovery Act - 1974 E.P.A. (RCRA) Clean Air Act and Clean Water Act Amendments - (CAA) 1*71/11 E.P.A. Michigan Aot 191, P.A. - 1971 Michigan D.N.R. (MDNR) Federal Hazardous Substances Act - 1970 Poison Prevention Packaging Act - 1970 Consumer Product Safety Act - 1972 Waste Management Hazardous Watte Management Act - 1979 Mich.. P.A. 04 i Solid Waste Management Act - 1971 Mich.. P.A. 041 aaJUtnCtM ^ Expected to be revised during 1990, to lower permissible expoeure limit rom present 1.0 flban/ec to 0.0 or 0.1 itbera/co of air. FIGURE 1 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) i I Staff ESES Responsible Activity SSECO PftO IHftT . MPa STAFF SAFETY Plant tngrg. Offlea Mfg. Engrg. 4a, Systems Plant* . EARS Prog. AnaL ft Metis. Engrg. Research Staff UPPLY Trane, ft Traffic REGULATORY ACT --------------------------------------31*1-------------------- ftfltaft Solidi CLEAN AIR OSHA TSCA <-- ---RaxT-WeaUaJ HMTA * WATER CompUance Reporting Compliance Reporting Compliance Reporting Monitoring Compliance Reporting * Identification of Controls Material Inclusion in EPA Inventory Chemistry in Data Base DOT Label in Data Bata Monitoring InforM Control* MICH DNR Compliance Reporting Chemistry in Date Base Faculty Controls Non-Prod, ft Prod. Bevetop aunt Matt*. Review Proceaa Controls Non-Prod. Metis. Development Review Procaea Control* Non-Prod. Matt*. Implementation Review Faculty Control Impl* mentalk* Develop new snetts.. mfg. processes, ft measurement devloea. Production Metis. Review Disposal Math, ft Fee. Dev. Wette Choreeteriaatlon Packaging Storage Materiel Charactor1- zetloa 4P CompUance Reporting Facilities Rouge Consol Development idation Process Contr Development Permit Reporting Usage Reporting i' .May 2.1980 8004 0306 ppnrtTTrcn rv cnori u nDRd Aa FT tAjt. j CARCINOGENS IN THE WORKPLACE / Introduction The Task Force on Carcinogens in the Workplace was established during the 4th quarter, / 1979 by joint action of the E4cR and M6cS Subcommittees. The Taskforce Charter was to / coordinate plans and efforts among Company activities, to identify Carcinogens in use, and urii^ ,eliminato-or control them tin future products and manufacturing operations. Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendices, j Background ^ Scientific investigations into the occupational factors involved in the deyelopment of cancer, conducted in recent years, have provided evidence that occupational'related cancer is a serious concern. It has been estimated that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.S. might be associated with occupational factors. Accordingly, Personnel and Organization Staff, Employe Health Services, has .exerted- a continuing effort to provide employe protection, as knowledge of toxic/hazardou? materials / has been introduced. <-vO Public concerns relating to the control of toxic/hazardous materials, are shared by Fordjv A due to the Company's regard for publio health and the protection of ttie environment-ttnd * `W, - potential imp&ot-of legislation-on-our-produets and manufacturing-operations. Also, the right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Resolution of workplace exposure concerns relating to the management of toxic/hazardous substances, materials, and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through mere efficient manufacturing techniques as well as by materials substitution. OO o o o wo -4 t/ ^ During the past decade, the Company wdssubjeeted to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these a "knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines i^te $25,000 per day, and a citation normally consists of multiple rilated violations. J Litigation is also a growing confeern.. At present the Office of General Counsel has three suits pending, involving deaths/allegedly due to the inhalation of oaroim _ ybrCmnnia f?omppn<iatio) PYponw has also been incurred.,J^Fhe-greatOBt--tx)tefttiei-f< major expense, however, liesjn the possibility-of-punitive^ctiQa-by-the-eourtj Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. a Federal R^ler5(l)^^ / *4 -1 - May 2, 1980 rn Ar>T tr DRAFT FIGURE 3 PAST COMPANY ACTIONS Production . Removal of lead and chromium from^paints^JL. . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. Nonproduction . Removal of asbestos from, - Structural fireproofing - Thermal insulation - Molding compounds . Substitution of vacuum for air blowing in brake and clutch maintenance (personnel protection*against benzene in light oil tanker loading operations 7- Substitution flead-containing maintenance oils J ^ u. Substitutioni ff''bbeennzzeennee--eeoonnttaaiinniinngg adhesives aTsan Jose y Reduction of lead-chromates in vinyl operations 8004 0308 - 2f - May 2, 1980 DRAFT 8004 0309 PAST COMPANY ACTIONS Production Materials s^***>/ (AJJL A-L. (''-***'^4 -kp ^ 7 i S'*2- In response to OSHA regulations in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellorf and fleet vehicles were excepted#/Also, "Tris" flame retardant treatmen/for fabrics, was removed during 197lp in-response to-an-inquiry byNHTSAt In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. AU domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination.{'Car Engineeringreleased~ a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. ^ y Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with the lead naphthenate free M-2C142 materials, and deleted the use of asbestos .- bearing molding compound at Sheldon Road. In 1978, an adhesive used at / San. Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories was^ceyisedto eliminate benzene, the volume of lead-chromate employed in vinyFpIarir-^4 operations was reduced and ventilation/protective measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used in painting. (The substitution of non-haz&rdous paints is targeted fets Romeo for late 1980.) I/ 1 ( 2 - May 2,1980 DRAFT PIOURE 4 TASK FORCE CHARTER The Task Force was chartered by F.AH and M&S Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts to: 1. Identify substances In use (OSIIA Categories I and II). 3. Determine quantities used (for materials regulated by Michigan Department of Natural Resources). 3. Set targets for elimination of as many Category I substances as poaaiblar 4. Take aggressive steps to find substitutes for as many Category I substanc :: anticipation of government regulations. 5. Develop o policy and action plan for eliminating potential carcinogens who 6. Organize to identify substances systematically. PIOU USAGE OF MICHIGAN CRITICAL MATERIALS AS REPORTED TO MAIS* (ADJUSTED UY THE PLANTS IN THEIR MDNR REPORTS 8004 0310 Material Acrylic Acid Lbs. of Usage 2si,7d7 * T'PV - Paint Principal Users Acrylonitrile 841,133 PPV - Paint Aniline 90 MCC, Dbn. Glass, T&C Sterling Antimony 830,871 PPV - Vinyl Arsenic 11,157 T&C Vandyke, PPV - Vinyl Asbestos (not reported as a material - present in articles only) Benzene 385,028 AAD - Dearborn Assy., Gen. Service Cadmium 3,311 PPV - Vinyl Chromium Cloroprene 81,377 24,678 PPV - Paint, EED - Ypsi. AAD - Utica Cobalt Copper 210 321,704 Cyanides 923,069 Dichlorobenz'enes 2,542 Formaldehyde 488,965 Hydrazene 130 Hydroquinone 1 Hypochlorite 15,841,758 Lead 626,027 Lithium 123 Nickel 126,624 Phenol 5,839 Selenium 127 Silver IS Silicon-Dioxide Coated Lead Chromato 3,317 Styrene 1,413,986 Tetracloroethylcne 1,095 Thiourea Triaryl Phosphate Esters 11 160,022 Trichloroethylene 01,840 Vinyl Chloride ns Line 1,085,724 Michigan locations not reported to MATS: Detroit Industrial Engine Research & Engineering Center . Research * Glendale Troy * Tractor PPV - Saline AAD - Dearborn, PPV - Saline, MSD MSD - Monroe PTO - Highland Park MCC, PPV - Paint PPV PPV * Vinyl MSD - Monroe AAD - Weyne/Dearborn, PPV - Paint ED - Northville, T&C Sterling MSD - Monroe, T&C Sterling Mich. Cast. Cntr. T&C Sterling T&C Sterling PPV PPV * Milan, PPV - Vinyl AADGO, Mich. Prov.' Grnd. PPV - Vinyl Steel, T&C Sterling EED - Rawsonville PPV - Vinyl PPV - Paint. AAD. PPSD. FTO Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixon Assembly - 3f- May 3,1980 draft TASK FORCE CHARTER To implement tmi'-djarter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminatelthe use of these substances and initiated plans to find substitutes for substances ahead of government regulations. The complete Task Force Charter is shown in Figure 4. In 1977, OSHA issued a draft policy listing numerouscl is that could be classified as "Category I" and "Category II^-earSTnogens. According^ to OSH policy, Category 1 substances'are known to be carcinogenic in jmans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are so classified where data is suggestive or carcinogenicity in test animals and humans, or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. , - A listing of 67 Category I substances in use in the automotive indus;try has been prepared. (Exhibit I). reyjJLKju. V AA <9 For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used , asbestos only as articles, 81,377 pounds of chromium compounds, and 385-,-0-2-8 pounds of benzene. Action on the remaining items in the Task *V k VII ^^| VI IV I V III m ill*, i^ i v v tv i.i vil v *Fvorcwev Cv .hma*rter will vbev dvis^cvu, ssed on the following pages. Category 1 substances were examined in detail. / t. os*. 8004 0311 -3- May 2, 1980 draft FIGURE 5 TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES Substance_____________ 1. Asbestos .2 Chromium Compounds 3. Benzene 4. Cadmium/Cadmium Oxide 5. Coal Tar Volatiles . Berfzo (a) Pyrene . Benzo (a) Anthracene .6 Ethylene Chloropolymer 7. Beryllium .8 Trichloroethylene Occurence within Company Friction materials, gaskets, sealers Chrome plating, paint pigments Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions Vinyl Aluminum foundry operations Degreaser Current Exposure Limits 2 fibers/cc 0.1 mg/m3 10 ppm 3 0.1 mg/m 0.2 mg/m3 3 0.2 mg/m 3 0.2 mg/m None established 2 yg/m3 100 ppm 8004 0312 -4f- May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that are contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6. The current exposure limit for these substances is also provided. It is important to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed are presented in order of priority as established by Task Force consensus. The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3, respectively) as test cases because they-are -considered t>yQparations and Staffs-to-have the greater? impact on the Company.NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to elimjnate/cQntrol these material^ in a practicable mannerJin anticipation of Government regulations, were formulated. A plan tov' extend the strategy formulated for asbestos, chromium and benzene, to as many Category 1 substances in Company materials as possible, was established. 8004 0313 -4 - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Fibers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Fibers/cc) 0.1 0.5 5 8004 0314 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Lining* Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reunforced Paper Core it Mold Making Materials Safety Apparel - 5f - May 2, 1980 CARCINOGENIC SUBSTANCES ASBESTOS' n During the pask several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities),\and gastro-intestinal cancer. Asbestos is found in a variety of automotive\components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair./A small numbet of Ford employes are potentially exposed dua/to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHM is 2L0 fibers per cubic centimeter of ambient air. The National Institutyfor Occupational Safety and Health (NIOSH), an advisory group^and-QSHA-have recommended that limits be tightened to as low as 0.1 in 1980.. Industrial Alygiene and Toxicology has issued bulletins detailing 'trols. A* EPA ban^on all non-critical uses may occur as early as 1985. .! ' -5 May 2, 1980 8004 0315 DRAFT CARCINOGENIC SUBSTANCES 8004 0316 CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds X X X X X Other Chromium Compounds X X X X FIGURE 11 Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) Exposure Limits 52 yg/m a/ 1 yg/m3 1/2 of above 3 25 yg/m 10 Hr workday - 50 yg/m3/15 Minutes 1/2 of above a) Measured as ehrdmium. No differentiation is made regarding valence or type of disease due to exposure. FIGURE 12 Classes of Materials Containing Carcinogenic Chromium Compounds Production Topcoat Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks - 6f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (e.g., sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of their handling of materials, primarily in paint making and application. Protective measures are employed to assure .regulated limits are not exceeded. ^ ^* 3 The current statutory limit is 52 mg/m although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. 8004 0317 -6 May 2,1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE FIGURE 13 ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENE Contact Dermatitis Eye Irritation Narcotic and Central Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyscrasias (disorders) Time-Weighted Avg. Ceiling FIGURE 14 EXPOSURE LIMITS Regulation 5 ppm/15 min. Proposed 1 ppm/8 hr. 1 ppm/ 2hr. Sample collected at 1 liter/minute FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealer* Rust Preventives Thinners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases and Oils Lubricating, Hydraulic & Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids 8004 0318 - 7f - May 2, 1980 draft CARCINOGENIC SUBSTANCES BENZENE Benzene is a leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, and employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no possible way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. (See Exhibit III) 8004 031$ -7 - May 2, 1980 DRAFT J$ Si K CARCINOGEN SEARCH FIGURE 16 f&kjL J ^ Carcinogen Identification Reviewed all likely material specifications and manufacturing standards. Reviewed the IHicT CATALOG of Hazardous Materials. Reviewed NAEPIS to identify Industry Standard Materials Reviewed the Michigan Critical Materials data Surveyed previous assessment of production materials. Communicated with material suppliers. Analyze<ythe production material list (PEO). . Carcinogen Usage Reviewed the NAEPIS cross-reference for production material/part usage. Reviewed proeesses/uses involving the substances in nonproduction materials. - Confirmed the NAEPIS usage list for completeness/verification. MATERIALS AND TOXICOLOGY SYSTEM FIGURE 17 8004 0320 3 May 2, 1980 I DR A PT $CARCINOGEN SEARCH / Three Category I oarewogei^ were examined to determine aterial specifications, parts and nonproduction uses, was-tedious-and inexactr Existing ta bases containing Engineering, Manufacturing and Purchasing information were found be..incomplete and not readily ctooeasibte In the absence of one reliable system, the detailed steps in Figure 16 were undertaken. For production materials, each PEO reviewed the material/usage list for completeness and established a list of parts and bulk materials of their design responsibility suspected of con taining the subject substances. These lists were returned to Engineering Staff. E&RS con solidated the lists (See Appendices) and provided them, along with the approved source and material identifications* to Purchasing and Supply Staff for supplier contact to determine substance usage and to find out if there is a known substitute. * Nonproduction materials were /identified by similar methods, except for the PEO review. / . s. ti - MATERIALS AND TOXICOLOGY SYSTEM (MATS) 8004 0321 To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (P&O Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental 6c Process Engineering Review System (Mfg. Staff). L. These Systems can be linked together with some manual effort to search for uses of suspect carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing suspect chemical compounds can be identified in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list. Purchasing can determine quantity used and Manufacturing En gineering can determine processing methods. J Other functions of MATS include Approved Source Lists for production and nonproduction^'''#^ materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide nonconfidential list of hazardous material usage and precautions for each plant. -8- May 2,1980 Asbestos -2/ Cr Compounds3- / Benzene draft CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts -1/ AB 34 49 - - C 22 25 15 Total 105 25 15 8004 0322 Asbestos * 4/ Cr Compounds- Benzene Nonproduction Materials/Parts AB 898 81 3- C 34 5 Total 8 213 8 Note: MAUk / A =' Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = No known substitute. Advanced Engineering Project required. NA*# Not available 1/ Data arc directional estimates only and refer to materials .known ** to contain the particular carcinogen^ 1 2/ Primary source - Car Engineering. j3/ Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered. - 9f- May 2,1980 draft 8004 0323 CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium, benzene, a partial list of production and nonproduction material applications has been assembled. These were classified as: Known substitute material available for application without major redesign; ^ \ / Known substitute material available for application with major redesign; J ' No known substitute. Advanced Engineering Project required# c.) / Even in group A, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. .^ -9- May 2, 1980 draft FIGURE 19 IUw>avX4wv (JU^_ (? U-'^W't^JL CARCINOGEN STRATEGIES--^ / - Continue OSHA Category I eafemogoh contrd^By design, process and exposure Emits. Elimin/te carcinogena-Wliere substitutes are known when required by regulation business pressure, a/ khtdUYyf* Proceed now to eliminate OSHA Category I-carcinogens'by Job #1, 1981 Where elimination cannot be contained, control the design, process and exposure, b/ - Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. a/Current Car Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos.. In documented cases precluding alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. b/Advanced funding would have to be provided where elimination cannot be ~ contained in the 1985 timeframe. lOf - ......... . May 2,1980 8004 0524 draft CARCINOGEN STRATEGIES Three major strategic alternatives were considered for the elimination and control of carcinogenic substances. Twenty-six (26) OSHA Category I substances and Forty-one (41) substances that affect the auto industry and are proposed for regulation (MVMA analysis) provide the basis for these alternatives. NIOBH advised substance aontrolo were deemed to bo of lower priority. It was agreed by the Task Force and PEO chief engineers that th^ Company should proceed now to eliminate asbestos, selected chromium compounds and benzene by Job #1, 1985. Where eli mination -cannot -be-containeq, design, process and exposure controls would continue for specific applications. Implementation of the recommended alternative can only proceed by specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) can be initiated now but cannot with confidence be expected to be fully implemented in the 1985 time frame. Implementation decisions will have to be made for each applicatipn in the context of the vehicle cycle plan, component redesign, plan4 facility renovation/replace ment and the practicality of the substitute. | V .t 8004 0325 10- May 2, 1980 DRAFT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) Action Manage Program o/ Propose list of known and suspect specifications Verify proposed list-ft/ Identify known and suspect part-ft/ numbers Request supplier verification of suspect specifications and parts Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) Implement Group A actions Implement Group B actions Implement Group C Actions Audit effectiveness Responsibility Production Nonproduction SSECO SSECO SSECO " SSECO Block Timing Prod. (Nonprod.) Ongoing 1 Month (A) PEO`s PEO's Mfg. Staff Mfg. Staff b/ ' /7 (A)1 NAAO/DPO Purchasing NAAO/DPO Purchasing PEO's (NAAO Pch.) Supply Staff Supply Staff Mfg. Staff (Supply Staff) 2 3 6 Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO's SSECO Mfg. Staff 0 / 12 Mfg. Staff / 33 (TBD) j 45 c/ Tech. Ping. Research Staff BMD SSECO. Ongoing Ongoing 8004 0326 a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. e/ Complete for asbestos, chromium compounds and benzene. - Ilf- May 2,1980 draft GENERALIZED WORKPLAN The foregoing strategies, even though having been tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination. The first three actions of the workplan have been completed for asbestos, chromium compounds, and benzene. The fourth and fifth actions have been initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. Completing the actions by these dates requires Corporate direction that the elimination/control of these substances is a mandatory priority effort. construction"'programs will continue with insufficient emphasis--oir~tbe~' Bliminationlcontfol--of--carcinogens. Overall program management is essential to this effort. 11 - May 2,1980 8004 0327 DRAFT FIGURE 21 MEMBERSHIP HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control Office . Environmental and Safety Engineering Staff . Purchasing and Supply Staff . Personnel and Organization Staff . Scientific Research Staff . Manufacturing Staff . Car Engineering . Body and Assembly Operations . Ford Parts and Service Division . Ford Tractor Operations . Powertrain and Chassis Operations . Basic Products Operations * . Electrical and Electronics Division . Climate Control Division . Truck Operations . European Automotive Operations . Office of the General Counsel FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER 8004 0328 - 12f - May 2, 1980 DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the requirements for chemical substances control. It was concluded that designation of a Program M costly and disruptive means for improving cooi activities and would help to surface crucial issue would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an EicSES location was recommended. In view of nstraints, it has been agreed that the exist pliance anc Department would perform the Prograr function. 1 jer should be responsible for implementing control stra _ >rdinating Company response to potential and promul gated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to.B-101, establishing a financia measurement of the compliance effort, an^agsuming development directior and control for the computer information system and implementing "the workplan^ as directed. The ongoing responsibilities of the Chemical Substances Control Manager will be to coordinate the product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forecasting/regulatory'impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of shown on the facing page. It is lee be chaired by the E<5cSES represibilities of Staffs and Operations >opt-wheffr-sttpplenieiited-or -elat4fied_ / 8004 0329 -12- May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 1. Hazardous Substances Control Committee 2. Program Manager 3. Direct elimination of Asbestos, Chromium Compounds, Benzene 4. Request Operations Workplans 5. Adopt the priority carcinogen listing 6. Request the establishment of overall elimination timetables. 8004 0330 - 13f - May 2,1980 draft PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSH A Category I carcinogens by Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force on Carcinogens in the Workplace recommends that: ^-- i. Establish a Hazardous Substances Control Committee chaired by the Director - Environmental Control Office. The Task Force would be discontinued. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering Staff. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. . 4.' Request that NAAO/DPO Product Engineering Offices and Manufacturing Staff VJ^Lpjesent to the Subcommittee specific action plans and timing for the Group A (M/J applications identified. 5. Adopt as the Company carcinogen listing, current OSHA regulated Category I sub stances (26) and proposed for regulation substances (41). Establish the top eight prior ities proposed by the Task Force as Company priorities. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene by Job #1, 1985, as outlined in the workplan. j* 8004 0331 -13 - May 2, 1980 8004 0332 draft EXHIBIT I OSHA CATEGORY I CARCINOGENS Regulated Acrylonitrile Amosite Anthophylite Arsenic Asbestos Benz (e) acephenanthrylene Benz (a) anthracene Benz (a) anthracene, 7, 12-DimethylBenz (a) anthracene, 7-MethylBenz (a) anthracene, 7, 8, 12-TVimethylBenzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibcnz (a, h) acridine Dibenz (a, j) acridine Dibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso1-Naphthylamine 2-Naphthylamine Serpentine Vinyl Chloride Proposed for Regulation Acetamide Acetic acid, Lead (2+) Salt Benzidine Sulfate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3+) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt Chromic Acid, Lead (2+) salt (1:1) ! Chromite Chromium Chromium (m) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Diethylamine, N-Nitroso- p-Dioxane Ethane, 1, 2-Dibrom'o- Ethane, 1,1, l-Trichloro-2, 2-bis (p-ehlorophenyl) Ethylene, chloro-, monomer Ethylene, Trichloro- Hematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (II) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid Tannin o-Toluidine Urea, Thio- May 2, 1980 CAS Number draft CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II FIGURE 2 8004 0333 May 2,1980 (  DRAFT CARCINOGEN SEARCH Materials and Toxicology System (MATS) EXHIBIT II To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALOG of Hazardous Materials (P&O Staff) containing materials, their toxicological evaluation for worker/consumer protection and the chemical composition, the Engineering Material Approved Source List (E<5cRS) containing the material specification title and the materials approved to that specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction material standard and the approved materials; and the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. , Carcinogen Search Strategy Developing the links between the above systems will, in the future, provide a method for locat- ing suspect carcinogens in nonproduction materials and production parts and bulk materials. / The search methodology is numbered on the facing page to correspond to the following search / stePs: / 1. The Chemical Abstracts Service numbers of the suspect qw'emogens and its compounds are identified by IH&T. The system will then generate a list of materials which contain that chemical. 2. Utilizing the NAAO supplier code, the specification number and the product name, the , system will then identify other suspect materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a cross- reference list of all parts which use that material. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. Functions ' ' The primary function of MATS is to maintain and produce the Approved Source List for non- production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract. The system is also available to the plants and the Poison Control Center at the Rouge to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. - Jo o o g The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g., chromium. Affected Activities All Corporate Staffs concerned with materials/toxicological/environment controls are currently involved in using/developing the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with the exception of Chassis which currently does not participate in material control as required by PEP 3-189. H. * May 2,1980 PRODUCTION MATERIALS CONTAINING ASBESTOS Group A ~ Known Substitute Material Available Without Major Redesign Specification Material Basie Part No. ___________ Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Gasket Gasket Dcadener Sealers -- 7086 4035 350038 350038 9900000 Trans. Ext. Gasket Carrier Gasket Econ. PDV Box Assy. ,, Eeon. PDV Box Assy. Courier Box Assy. Body ESB-M2G58-C ESB-M2G171-AB ESB-M2G188-A ESB-M3G95 ESB-M4G1-B ESB-M4G31-A ESB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A ESB-M4G177-A/B Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Seller Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler Sealer Sealer Sealer Sealer -- -- Primer for Adhesive -- -- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- ---- -- ;~ -- '~ _ -- ~-- ---- -- -- ---- ______ ---- __________ ._ .... 8004 0335 APPENDIX r DRAFT 5/2/80 Specification ESB-M4G188-A ESB-M4G197-A ESB-M4G198-C ESB-MSGS-A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A Trans ESE-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A Material Sealer Sealer Sealer Deadener Deadener Deadener Rust Prevent Gasket Gasket Seal Gasket -- Sealer Sealer Sealer Coating . Phenolic ESF-M3D113-A ESA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A -- CCD ESF-M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket- Gasket Gasket Gasket Gasket Gasket Sealer -2- Basic Part No. -- -- -- -- -- -- -- 7D026 7A136 4035 7052 7A247 15520 9004650 Part -- -- APPENDIX I DRAFT 5/2/80 -- -- Sprayable Wax Type Rust Preventative * Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer 19560 19560 19554 19515 Caulking Cord Rope Sealer Perfect Seal Undereoating \ 18B374 8K621 17B616 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator 1/C Lamp Socket Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket 19D970 2A792 A/C Comp. Gasket . P/B Cable Opening Cover 8004 0336 -3- APPENDIX I DRAFT 5/2/80 NONPRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts - 15 lb. Asphalt Saturated Asbestos Roofing Pelts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper 8004 033? -4- APPENDIX I DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group B -- Known Substitute Material Available With Major Redesign Specification Material Basic Part No. ___________ Part Light Truck ESE-M8G106-B ESE-M8G140-A Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor Vendor , Vendor Vendor Vendor Vendor Gasket Gasket Phenolic Phenolic -- -- -- -- -- -- -- -- -- -- 5B266 5B266 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. D-ans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy. Trans. Clutch Plate Assy. Chassis ESB-M8G106-A ESA-M8G140-A -- Gasket Gfcsket --> 5B266 5B266 2022 2021 Resonator Gasket Assy. Tesonator Gasket Assy. Front Disc Brakes . i' 8004 0338 5PRODUCTION MATERIALS CONTAINING ASBESTOS DRAFT 5/2/80 Group C -- No Known Substitute. Advanced Engineering Project Required. Specification Light Truck ES-C8AA-2B282-A ES-D20A-2B072-BB ES-C8AA-2B282-A ES-D20A-2B072-BB Vendor Print Vendor Print ES-EOTA-2B120-A A ES-D6TA-2B118-A A ES-C8TA-2B282-A ES-C8TA-2210-D ES-C8TA-2010-C ES-D8TA-7550-A -- -- Trans Vendor Vendor Vendor Heavy Truck -- -- -- -- -- --' -- -- -- -- Material -- -- -- -- ~ -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- ---- Basic Part No. Part 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 Lining Front Wheel Brake Outer Lining Front Wheel Brake Inner Shoe and Lining Inner * Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake Inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch Clutch Plate Clutch Plate Parking Brake Lining 4797 4A435 7550 Rear Axle Diff. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A596 7550 7E434 Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Brake! Compressor Fan Clutch Assy. Clutch and' Bracket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Brake Assy. 8004 0339 Chassis ESE-M8G149-A -- Gasket --- -6- 5F263 2284 2285 AAA* 4Jn JLViA A DRAFT 5/2/80 Exhaust Manifold Gasket Rear Brake Shoes 8004 0340 Inter Ollice ce- SrtK^s ' Cf rrt-aff'vtS Engineering and Research Staff May 1, 1980 Messrs. D. D. Baker D. L. Block, M.D, J. H. Douma P. D. Fadow W. H. Fike S. M. Frey S. Gratch D. Fi Hagen M. H. Hamburg G. C. Hedges C. D. Lauer " E. T. Mabley J. H. Ogden J. A. Pflug H. W. Potoczak P. E. Prill J. G. Rivard V. H. Sussman J. D. Velte cc H. P. Freers G. O. Keutgen H. A. Nickol Subject: Carcinogens Task Force Report to EAR and MAS Subcommittees The Task Force on Carcinogens in the Workplace was established by joint action of the EAR and MAS Subcommittees, with representation from affected line and staff activities. The Task Force was chartered to coordinate plans and efforts to identify and quantify carcinogenic substances in use; to develop action plans, take aggressive steps and set targets for elimination of as many carcinogens as possible; and to organize to identify substances systematically. The Task Force will present its report to the Subcommittees on May 27, 1980. Attached is a draft of the report. Your comments are requested by May 9, 1980, so that we may meet the timing of the several pre-reviews scheduled. Attachment h J. W. Durstine 1004 0341 EXECUTIVE summary CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established by the Engineering and Research and Manufacturing and Supply Subcommittees to identify carcinogens and quan tities in use, set targets for elimination ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify fubstanees systematically. TheTask Force assignment responded to evidence that -8S&&Colmt/w^enal eoncernjind to the Company's and public concern with" regarcTto protection of theenvYronmenf'and public health. Additionally, the Company has been subjected to a growing number of laws which regulate material use, transport, handling and disposal. In summary, internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101, assigned responsibilities within the ComPflr>y- Past Company Actions lsl tFi/ Since 1977, the Companyremoved lead chromates and molybdate$tfrom paint (except special-order), "Tris" flame retardant from fabrics and instituted controls on asbestos, includnS^a Vehicle Engineering directive that newly designed components Sfcoflfffnot contain asbestos (documented exceptions must be encapsulated or resin coated), Af ofMlJfaW*6-TM fircPboofing-W3een asbestos-free sinooettffiS for new and reworked construe- ^ ' tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazards from paint-related chromium compounds. Carcinogenic Substances The Task Force identified sixty-seven (67) carcinogens in use in the automolive industry. Twenty-six (26) of those are currently regulated byOSHA; the balance havojfoon proposed for new regulation. More restrictive standards hafa*f5f%n proposed for some af Uiwa sub stances currently regulated. Thirty-one (31) substances are reported to the Michigan _ Department of Natural Resources for computation of water surveillance fees. Michigan ~7 s plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNR list. The largest ( use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur- rently required to be reported in the other states. The list of carcinogens was prioritized by?--------c the Task Force according to impact on the Company to identify the top eight (8)^TlTe top ' three of the eight priority substances, asbestos, chromium compounds and benzene, were examined in detail. . -'* *** - Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets and for nonproduction roofing, millboard and core/mold-making materials. Medical evidence links inhalation of asbestos dust to lung cancer,uinjoothHimmcand other diseases. The present- OSHA limit is 2 fibers per cc of air (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/cc,as early as this year. - " Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links hexavalent chromium compounds to lung cancer, liver and kidney damage and other diseases. The present OSHA limit is 52 mg per nr of air which is proposed to be reduced to 1 mg/m . - Benzene occurs primarily in coke oven operations as a by-product. It is a residual constituent of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has proposed a limit of 1 ppm in air time weighted average in 8 hours. Specific lists of bulk materials and parts for production and nonproduction use have been developed. A new computer data base is being developed. Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid identification of carcinogen applications (2nd quarter 1981). The engineering release system has been audited and is being updated to extend materials identification to all parts. Product Engineering Procedure PEP 3-189 rewritten to require systematic review of suspect carcinogens and input to the data base. 8004 0342 EXECUTIVE SUMMARY " (Continued} Strategy and Workplan The search for asbestos, chromium compounds and benzene defined the number of parts and materials containing these substances as listed in the table below. Where possible, the applications were divided into three groups: A - Known substitute material without major redesign, B - Known substitute material with major redesign and C - No known substitute or advanced engineering required. The data is directional only. There remain many suspect applications which require time-consuming analyses for identification. __________ Bulk Materials and Parts _producction Total' Nonproduction B C Total Asbestos Chromium Compounds Benzene 34 49 22 25 15 105 25 15 88 98 81 34 213 3 58 Strategies-have*-boon- formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three carcinogens by Job_#l, 1985,. in Jight of competitive and regulatory pressures^and Company exj>cnence.^'iVhe>> . Celiniinationjeannot ie cantatnedr instiUlTe^ controls on design, process and exposure./'Tr is judged tKat the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing parts and materialgj. <jr those applications j-equirincr w / major redesign (Group B, e.g., drum brake linings) thevjelimination timetable J,i ** Cent {rdi ov des/f^ 5 ftfeSu/ter 4At' t\r M's/iVt//re ba,adjuted-to reflect Company cycle plansffltrfwglrti.M. has stated an intent to eliminate asbestos by 1985. Vmere no known substitute exists (Group C), advanced engineering a <*c yu will hawa >>* aampUtad before ^elimination timetable can be established. s A/^gceneralized workplanJ>aff-bm prepared,on the basis of the evaluation of the carcinogens ^aTready referred toV The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities, Vehicle acti vities end the Manufacturing and Supply Staffs. It is judged that approximately a year is required to complete the sorting of thethree carcinogens into the known substitute, major . redesign and advanced project gtififfiln'^'lt is judged that one additional year would -b (s required to implement the most feasible product actions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro grams. Recommendations 8004 0343 Achievement of the recommended strategy requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force recommends: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibility to Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by the subcommittees. (The Task Force has requested General Managers and Chief Engineers to recommend directional timetables.) 4. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job #1, 1985. 5. Request that NAAO Product Engineering Offices and Manufacturing Staff present to the subcommittee specific action plans and timing for the Group A applications identified. 6. Provide advance program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). 7. Adopt.as the Company carcinogen listings the 67 current OSHA-regulated and proposed Category I substances. Establish the top eight priorities proposed by the Task Force as Company priorities. Engineering Staff - E&RS Manufacturing Staff May 2, 1980 DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2,1980 8004 0344 OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production - Nonproduction , . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Asbestos, chromium, benzene , Asbestos Summary . Chromium Summary . Benzene Summary . Carcinogen Search - List specs, and parts - Identify items having no substitutes - Identify substitutable items .. Eliminate when redesigned or reordered Develop substitutes for others (advance engrg. funding) . MATS , Carcinogen Search Results . Carcinogen strategies . Generalized Workplace . Proposed Chemical Substances Control . Proposed Priority Actions Exhibits . List of "67" Carcinogens . MATS Appendices , Asbestos-containing parts and materials . Chromium-containing parts and materials , Benzene-containing parts and materials & _ 8004 0345 DRAFT FEDERAL AND MICHIGAN ACTS REGULATING TOXIC/HAZARDOUS MATERIALS HAVING IMPACT ON TIIF. COMPANV piouke i . Regulatory Act* Occupational Safety and Health Act - 1970 D.O.L. (OSI1A1* Hazardous Materials Transportation Act - 1975 D.O.T. (HTMA) Toxic Substance* Control Act - 197$ E.P.A. (TSCA) Resource Conservation and Recovery Act - 1975 E.P.A. (RCRA) Clean Air Act end Clean Water Act Amendments - (CAA) 1977/71 E.P.A. Michigan Act 293, P.A. - 1972 Michigan D.N.R. (MDNR) Packaging A Stacking . . Federal Hazardous Substances Act * 1970 . Poison Prevention Packaging Act 1970 . Consumer Product Safety Act - 2972 Waste Management . ^Hazardous Waste Management Act - 1979 Mich., P.A. 64 . Solid Waste Management Act - 1979 Mich., P.A. 641 8004 0346 Expected to be revised during 1980, to lower permissible exposure limit from present 2.0 fibers/cc to 0.5 or 0.1 fibers/cc of air. PIOURE 9 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) Staff ESES Responsible Activity SSECO PAO IHAT MFO. STAFF v SAFETY Plant Engrf. Offie* Ufg. Engrf. 9t$y>UM Plant* EARS Prog. AnaL A Matts. Engrf. Research Staff SUPPLY Trans. A Traffic OSHA TSCA Compliance Reporting REGULATORY ACT RCRA A State Solid/ Haz. Wastes Compliance Reporting hmta Compliance Reporting Identification of Controls Materiel Inclusion In ERA Inventory Monitoring Enforce Controls Fecility Controls Non-Prod. A Prod. Development Metis. Review Proem Controls Non-Prod. Matla. Development Review Process Controls Non-Prod. Metis. Implementation Review Facility Control Implementation Develop new metis., mfg. processes. A measurement devices. Production Matls. Review Chemistry In Data Base DOT Label In Data Base Disposal Meth. A Fac. Dev. West. Charac terization Packaging Storage Material Characteri zation Complinnee Reportlr* CLEAN AIR A WATER Compliance Reporting Monitoring MICH pN.R Compliance Reporting Chemistry in Data Bate Facilities Rouge Consol Development idation Proceaa Contr. Development Permit Reporting Usage Reporting -If- May 2, 1980 DRAFT 8004 0347 CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established during the 4th quart 1979 by joint action of the E&R and M<5cS Subcommittees. The Task Force Charter was-To coordinate plans and efforts among Company activities, .* identify carcinogens in use, and eliminate or control them in future products and manufacturing operations. Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendices. Background KtzseAiuh Scientific investigations into the occupational factors involved in the .devetepment of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It-hdifen estimated that in SoJSwg decades up to 2096,and perhaps as much as 40%, of cancer in the U.S. might be associated with occupational factors. Accordingly, Personnel and Organization Staff, Employe Health Services, has exerted a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials is 'bs6rbeuR introduced. Public concerns relating to the control of toxic/hazardous materials, are shared by Ford, due to the Company's regard for public health aed=fch-protection of the environment andye potential impact of legislation on our products and manufacturing operations. right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Resolution of workplace exposure-concerns relating to the management of toxic/hazardous substances, materials; and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been ipereased by governmental authority. These factors reinforce, the desirability -hi reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques aswen"Hs by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handUng.,and. dispostU (Big. 1). Under certain of these Acts, a "knowing/willful" criminal violation can^eS^oS^inaividuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fine^ or up to $25,000 per day^and a x j Litigation is also a growing concern. At present the Office of General Counsel has three suits pending^ involving deaths allegedly due to the inhalation of carcinogenic substances. Some Workman's Compensation expense has also been incurred. The greatest potential for major expense, however, lies in the possibility of punitive action by the court. Internal and external pressures regarding hazardous substance control and compliance hove- increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time, new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. a Federal Register 45(15): 5031, January 22, 1980. -1 - May 2, 1980 draft FIGURE 3 PAST COMPANY ACTIONS Production . Removal of lead and chromium from paints. . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. Nonproduction . Removal of asbestos from, - Structural fireproofing - Thermal insulation - Molding compounds . Substitution of vacuum for air blowing in brake 8nd clutch maintenance . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations 8004 0348 - 2f - May 2, 1980 DRAFT PAST COMPANY ACTIONS Production Materials , In response to OSHA regulations/(in 1978, the Company removed lead chromates and lead molybdates from paint* used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Aieo, "Tris" flame retardant treatment for fabrics, was removed during 1977, in response to an inquiry by NHTSA. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. Car Engineering released a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with the lead naphthenate free M-2C142 materials, and deleted the use of asbestos bearing molding compound at Sheldon Road. In 1978, an adhesive used at San Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories revised to eliminate benzene? the volume of lead-chromate employed in vinyl plant operations was reduced; and ventilation/protective measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used in painting. (The substitution of non-hazardous paints is targeted for Romeo for late 1980.) 8004 0349 -2- May 2,1980 DRAFT FICURE 4 TASK FORCE CHARTER The Task Force was chartered by E&R and MAS Subcommittees (Meeting o( 10/24/79) (or coordinating plans and efforts to: 1. Identify substances in use (OSHA Categories I end It). 2. Determine quantities used (for materials regulated by Michigan Department of Natural Resources). 3. Set targets for elimination of as many Category 1 substances as possible. 4. Take aggressive steps to find substitutes for as many Category 1 substances as possible in anticipation of government regulations. 5. Develop a policy and action plan for eliminating potential carcinogens where possible. 6. Orgaaiae wjScntify substances systematically. FIGURE 5 USAGE OF MICHIGAN CRITICAL MATERIALS AS REPORTED TO MATS* (ADJUSTED BY THE PLANTS IN THEIR MDNR REPORTS) Material Acrylic Acid Lbs. of Usage 251^07 PPV - Paint Principal Users Acrylonitrile 641,133 PPV - Paint Aniline 90 MCC, Dbn. Glass, T&C Sterling Antimony 830,571 PPV - Vinyl Arsenic 11,157 T&C Vandyke, PPV - Vinyl Asbestos (not reported as a material - present in articles only) Benzene 385,028 AAD - Dearborn Assy., Gen. Service Cadmium 3,311 PPV - Vinyl Chromium 81,377 PPV - Paint, EED - Ypsi. Cloroprene 24,676 AAD - Utica Cobalt 210 PPV - Saline Copper 321,704 AAD - Dearborn, PPV - Saline, MSD - Monroe Cyanides 923,069 MSD - Monroe Dichlorobenzenes 2,542 FTO - Highland Park Formaldehyde 488,965 MCC, PPV-Paint Hydrazene 130 PPV Hydroquinone 1 PPV - Vinyl Hypochlorite Lead 15,841,758 626,027 MSD - Monroe AAD - Wayne/Dcarborn, PPV - Paint Lithium Nickel 123 126,624 ED - Northville, T&C Sterling MSD - Monroe, T&C Sterling Phenol Selenium Silver- 5,839 127 25 Mich. Cast. Cntr. T&C Sterling ' T&C Sterling Silicon-Dioxide Coated Lead Chromat* 2,317 PPV Styren* Tetracloroethylena 1,413,986 1,095 PPV - Milan, PPV - Vinyl AADGO, Mich. Prov. Grnd. Thiourea Triaryl Phosphate Esters 18 160,022 PPV - Vinyl Steel, T&C Sterling Trichloroethylene Vinyl Chloride 91,849 118 EED - Rawsonville PPV - Vinyl Zinc 1,085,724 PPV - Paint. AAD. FPSD, FTO Michigan locations not reported to MATS: Detroit Industrial Engine Research & Engineering Center Research - Glendale Troy - Tractor Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixon Assembly -3f- May 2,1980 8004 0350 < DRAFT TASK FORCE CHARTER To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. The complete Task Force Charter is shown in Figure 4. In 1977, OSHA issued a draft policy listing numerous chemicals that could be classified as "Category I" and "Category II" carcinogens. According to OSHA's draft policy, Category 1 substances are known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are so classified where data is suggestive or carcinogenicity in test animals and human^ or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. A listing of 67 Category I substances in use in the automotive indus try has been prepared. (Exhibit I). For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used asbestosj>nly^^rtTcles^6l,377 pounds of chromium compounds, and --;385,023rpbunds of benzene. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances were examined in detail. 8004 0351 -3- May 2, 1980 draft 6 FIGURE Ji TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES t Substance 1. Asbestos 2. Chromium Compounds 3. Benzene 4. Cadmium/Cadmium Oxide 5. Coal Tar Volatiles . Benzo (a) Pyrene . Benzo (a) Anthracene 6. Ethylene Chloropolymer 7. Beryllium 8. Trichloroethylene Occurence within Company Friction materials, gaskets, sealers Chrome plating, paint pigments Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions Vinyl Aluminum foundry operations Degreaser Current Exposure Limits 2 fibers/cc 0.1 mg/m^ 10 ppm 0.1 mg/m3 0.2 mg/m3 3 0,2 mg/m 0.2 mg/m3 None established 3 2 vg/m 100 ppm g o 8004 0352 - 4f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that are contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6. The current exposure limit for these substances is also provided. It is important to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed^are presented in order of priority as established by Task Force consensus. U The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3, respectively) as test cases because they are considered by Operations and Staffs to have the greatest impact on the Company. NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to eliminate/control these materials, in a practicable manner in anticipation of Government regulations, were formulated. A plan to extend the strategy formulated for asbestos, chromium and benzene, to as many Category I substances in Company materials as possible, was established. 3004 0353 -4 - May 2, 1980 draft CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Fibers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Fibers/cc) 0.1 0.5 5 8004 0354 Summary of Asbestos Usage FIGURE 9 Production Clutch Platey Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core <Sc Mold Making Materials Safety Apparel - 5f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES -ASBEST' -O--*S * 4 During the past several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHA, is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group, and OSHA have recommended that limits be tightened to as low as 0.1 jin 1980. Industrial Hygiene and Toxicology has issued bulletins detailing "controls. An EPA ban on all non-critical uses may occur as early as 1985. - 5 May 2. 1980. 8004 0355 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds / X X X X X Other Chromium Compounds__ X X X X FIGURE 11 Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) Exposure Limits 52 vg/m3 a/ 1 yg/m3 1/2 of above 3 25 vg/m 10 Hr workday 3 50 Vg/m /15 Minutes 1/2 of above o/ Measured as chromium. No differentiation is made regarding valence or type of disease due to exposure. FIGURE 12 Classes of Materials Containing Carcinogenic Chromium Compounds Production Topcoat Points Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks - 6f - May 2, 1980 8004 0356 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (e.g., sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of Ujfer handling 0 materials, primarily in paint making and application. Protective measures are employed to assure regulated limits are not exceeded. 3 The current statutory limit is 52 mg/m although NIOSH^^recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. -6 May .2.1980 8004 0357 DRAFT CARCINOGENIC SUBSTANCES BENZENE FIGURE 13 ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENE Contact Dermatitis Eye Irritation Narcotic and Central Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyscrasias (disorders) Time-Weighted Avg. Ceiling FIGURE 14 EXPOSURE LIMITS Regulation 5 ppm/15 min. Proposed 1 ppm/8 hr. 1 ppm/ 2hr. 'Sample collected at 1 liter/minute FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealers Rust Preventives Thinners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases and Oils Lubricating, Hydraulic & Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids 8004 0358 - 7f- May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE Benzene is a leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes*^i&employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no possible way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. (See Exhibit III) May 2,1980 8004 0359 DRAFT CARCINOGEN SEARCH FIGURE 16 . Carcinogen Identification/^ Reviewed aRffikoffimaterial specifications and manufacturing standards. Reviewed the IH&T CATALOG of Hazardous Materials. Reviewed NAEPIS to identify Industry Standard Materials Reviewed the Michigan Critical Materials data Surveyed previous assessment of production materials. Communicated with material suppliers. Analyzed the production material list (PEO). . Carcinogen Usage Reviewed the NAEPIS cross-reference for production material/part usage. Reviewed processes/uses involving the substances in nonproduction materials. Confirmed the NAEPIS usage list for completeness/verification. MATERIALS AND TOXICOLOGY SYSTEM FIGURE 17 8004 0360 - 8f- May 2,1980 DRAFT CARCINOGEN SEARCH 1TP>' S<- ,r** o* ^Three Category I carcinoger^_wfing_examine^/to determine material specifications, parts and *7 ] nonproduction uses, (SjasTjedious and inexact?^ Existing data bases containing Engineering, ' ^Manufacturing and Purchasin|; lMprmation were fouhd to be incomplete and not readily accessible. In the absence of^M^reliable system, the detailed steps in Figure IS were under taken. For production materials, each PEO reviewed the material/usage list for completeness and 8004 0361 MATERIALS AND TOXICOLOGY SYSTEM (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (P6cO Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental fc Process Engineering Review System (Mfg. Staff). These Systems can be linked together with some manual effort to search for uses of suspect carcinogens in Company products as follows and diagrammed in Figure 17; 1. Materials containing suspect chemical compounds can be identified in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list, Purchasing can determine quantity used and Manufacturing En gineering can determine processing methods. Other functions of MATS include Approved Source Lists for production and nonproduction, materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide nonconfidential list of hazardous material usage and precautions for each plant. -8- May 2, 1980 Asbestos2- / Cr Compounds3- / Benzene DRAFT CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts -1/ AB 34 49 -- 9, - C 22 25 15 Total 105 25 15 8004 0362 Asbestos Cr Compounds4- / Benzene Nonproduction Materials/Parts A B C Total 8-- 8 98 81 34 213 3- 5 8 Note: A = Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = No known substitute. Advanced Engineering Project required. NA= Not available 1/ Data are directional estimates only and refer to materials known to contain the particular carcinogen. 2/ Primary source - Car Engineering. 3/ Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered. - 9f - May 2,1980 draft CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium/benzene, a partial list of production and nonproduction material applications has been assembled. These ja/Mf>classified as: A Known substitute material available for application without major redesign; 5 Known substitute material available for application with major redesign; C No known substitute. Advanced Engineering Project ^squired; Even in gCaretcu&pMA, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. 8004 0363 -9- May 2, 1980 DRAFT FIGURE 19 CARCINOGEN STRATEGIES Continue OSHA Category I carcinogen control by design, process and exposure limits. Eliminate carcinogens where substitutes are known when required by regulation or business pressure.. a/ Proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985. Where elimination cannot be contained, control the design, process and exposure, b/ Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. 8004 0364 a/Current Car Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos. In documented cases precluding alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. b/Advanced funding would have to be provided where elimination cannot be contained in the 1985 timeframe. - lOf- May 2, 1980 draft CARCINOGEN STRATEGIES Three major strategic alternatives were considered for the elimination and control of carcinogenic substances. Twenty-six (26) OSHA Category I substances and Forty-one (41) substances that affect the auto industry and proposed for regulation (MVMA analysis) provide the basis for these alternatives. NIOSH advised substance controls were deemed to be of lower pP*ri*ov`ri*tvyJr. J -Jtjwas agroed-by Ihe Task Force and PEO chief engineers/fthat the Company should proceed now to eliminate asbestos, selected chromium compounds and benzene by Job #1, 1985. Where elimination cannot be contained, design, process and exposure controls would continue for specific applications. Implementation of the recommended alternative(i&can only proceed by specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) can be initiated now but cannot^with confidence be expected to be fully implemented in the 1985 time frame. Implementation decisions will have to be made for each application in the context of the vehicle cycle plan, component redesign, plans facility renovation/replace ment and the practicality of the substitute. 8004 0365 - 10 - May 2, 1980 DRAFT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) Action Manage Program Propose list of known and suspect -fl/ specifications fl/ Verify proposed listIdentify known and suspect part-ft/ numbers Request supplier verification of suspect specifications and parts Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) Implement Group A actions Implement Group B actions Implement Group C Actions Audit effectiveness Responsibility Production Nonproduction SSECO SSECO SSECO ' SSECO PEO's PEO's Mfg. Staff Mfg. Staff b/ NAAO/DPO Purchasing NAAO/DPO Purchasing PEO's (NAAO Pch.) Supply Staff Supply Staff Mfg. Staff (Supply Staff) Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO'S SSECO Mfg. Staff Mfg. Staff Tech. Ping. Research Staff BMD SSECO Block Timing Prod. (Nonprod, Ongoing 1 Month (A) 1 (A). 1 (A) 2 3 6 12 33 (TBD) 45 c/ Ongoing Ongoing 8004 0366 a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. c/ Complete for asbestos, chromium compounds and benzene. - Ilf- May 2, 1980 draft GENERALIZED WORKPLAN The foregoing strategies, ev#4hough having -boon tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination. The first three actions of the workplan have-been completed for asbestos, chromium compounds, and benzene. The fourth and fifth actions have-been initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. Completing the actions by these dates requires Corporate direction that-tbe3elimination/control of these substances is a mandatory priority effort. Without such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogeas. Overall program management is essential to this effort. 8004 0367 - 11 - May 2, 1980 DRAFT FIGURE 21 MEMBERSHIP HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control Office . Environmental and Safety Engineering Staff . Purchasing and Supply Staff . Personnel and Organization Staff . Scientific Research Staff . Manufacturing Staff . Car Engineering . Body and Assembly Operations . Ford Parts and Service Division . Ford Tractor Operations . Powertrain and Chassis Operations . Basic Products Operations . Electrical and Electronics Division . Climate Control Division . Truck Operations . European Automotive Operations . Office of the General Counsel FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER 3004 0368 - 12f - May 2, 1980 DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff -*>f5fr- completed an analysis of the requirements for chemical substances control. It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issued. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an E<5cSES location was recommended. In view of budget constraints, it agreed that the existing Comm- pliance and Liaison Department would perform the Program Manager function. The Manager should be responsible for implementing carcinogen control strategies,coordinating Company response to potential and promul- gat-&$- toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to B-101, establishing a financial measurement of the compliance effort,^ff^assuming development direction and control for the computer information system and implementing the workplan as directed. The orj^oing responsibilities of the Chemical Substances Control Manager will be 4W' coordinate*} t*Re product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forecasting/regulatory-impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page. It is further recommended that the Committee be chaired by the E&SES repre sentative. Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. 8004 0369 - 12 - May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 1. Hazardous Substances Control Committee 2. Program Manager '' 3. Direct elimination of Asbestos, Chromium Compounds, Benzene 4. Request Operations Workplans 5. Adopt the priority carcinogen listing 6. Request the establishment of overall elimination timetables. 8004 0370 - 13f - May 2, 1980 PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSH A Category I carcinogens by Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force on Carcinogens in the Workplace recommends ih* w 1. Establish a Hazardous Substances Control Committee chaired by the Director Environmental Control Office. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. 4. Request that NAAO/DPO Product Engineering Offices and Manufacturing Staff present to the Subcommittee specific action plans and timing for the Group A applications identified. 5. Adopt as the Company carcinogen listing, current OSHA regulated Category 1 sub stances (26) and proposed for regulation substances (41). Establish the top eight prior ities proposed by the Task Force as Company priorities. 6. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene by Job #1, 1985, as outlined in the workplan. 8004 0371 - 13 - May 2, 1980 8004 0372 DRAFT EXHIBIT I OSHA CATEGORY I CARCINOGENS Regulated Acrylonitrile Amosite Anthophylite Arsenic Asbestos Benz (e) acephenanthrylene Benz (a) anthracene Benz (a) anthracene, 7, 12-Dimethyl- Benz (a) anthracene, 7-MethylBenz (a) anthracene, 7, 8, 12-TrimethylBenzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibcnz (a, h) acridine Dibenz (a, j) acridine Dibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso1-Naphthylamine. 2-NaphthyIamine Serpentine Vinyl Chloride Proposed for Regulation Acetamide Acetic acid, Lead (2+) Salt Benzidine Sulfate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3-*) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt Chromic Acid, Lead (2+) salt (1:1) Chromite Chromium Chromium (III) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Diethylamine, N-Nitrosop-Dioxane Ethane, 1, 2-Dibrom`oEthane, 1,1, l-Trichloro-2, 2-bis (p-chlorophenyl) Ethylene, chloro-, monomer Ethylene, TrichloroHematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (II) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid Tannin o-Toluidine Urea, Thio- May 2, 1980 CAS Number CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II FIGURE 2 8004 0373 May 2, 1980 draft CARCINOGEN SEARCH Materials and Toxicology System (MATS) EXHIBIT II 8004 0374 To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALOG of Hazardous Materials (P6cO Staff) containing materials, their toxicological evaluation for workeT/consumer protection and the chemical composition, the Engineering Material Approved Source List (E&RS) containing the material specification title, and the materials approved to' that specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction material standard and the approved materials; and the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. I, Carcinogen Search Strategy Developing the Jinks between the above systems will, in the future, provide a method for locat ing suspect carcinogens in nonproduction materials and production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the following search steps: 1. The Chemical Abstracts Service numbers of the suspect carcinogens and its compounds are identified by IH&T. The system will then generate a list of materials which contain that chemical. 2. Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other suspect materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a crossreference list of all parts which use that material. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. Functions The primary function of MATS is to maintain and produce the Approved Source List for non production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as either a full companywide print or as a plant specific print. The CATALOG is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract. The system is also available to the plants and the Poison Control Center at the Rouge to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g., chromium. Affected Activities All Corporate Staffs concerned with materials/toxicological/environment controls are currently involved in using/developing the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with the exception of Chassis which currently does not participate in material control ns required by PEP 3-189. May 2, 1980 PRODUCTION MATERIALS CONTAINING ASBESTOS Group A -- Known Substitute Material Available Without Major Redesign Specification Material Basic Part No. Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Gasket Gasket Deadener Sealers -- 7086 4035 350038 350038 9900000 Trans. Ext. Gasket Carrier Gasket Econ. PDV Box Assy . Econ. PDV Box Assy. Courier Box Assy. Body ESB-M2G58-C ESB-M2G171-AB ESB-M2G188-A ESB-M3G95 BSB-M4G1-B ESB-M4G31-A ESB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A ESB-M4G177-A/B Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler Sealer Sealer Sealer Sealer Sealer Sealer Sealer _ -- Primer for Adhesive ---- -- ---- -- ---- -- -- ---- -- ._ ---- ---- ---- ---- ---- -- -- __ ---- ---- -- ---- -- -~ .-- -- .-- -- 8004 0375 APPENDIX I DRAFT 5/2/80 Specification ESB-M4G188-A ESB-M4G197-A ESB-M4G198-C ESB-M5G8-A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A Trans ESE-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A Material Sealer Sealer Sealer Deadener Dcadencr Deadener Rust Prevent Gasket Gasket Seal Gasket -- Sealer Sealer Sealer Coating Phenolic ESF-M3D113-A F.SA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A -- CCD ESF-M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket Gasket Gasket Gasket Gasket Gasket Sealer -2- Basic Part No. -- -- -- -- -- -- 7D026 7A136 4035 7052 7A247 15520 9004650 19560 19560 19554 19515 18B374 8K621 17B616 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 19D970 2A792 APPENDIX I DRAFT 5/2/80 Part -- -- -- -- .-- Sprayable Wax Type Rust Preventative Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer Caulking Cord Rope Sealer Perfect Seal Undercoating A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator 1/C Lamp Socket Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket A/C Comp. Gasket P/B Cable Opening Cover 8004 0376 -3NONPRODUCTION MATERIALS CONTAINING ASBESTOS appendix I DRAFT 5/2/80 Group A -- Known Substitute Material Available Without Major Redesign Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts - 15 lb. Asphalt Saturated Asbestos Roofing Felts - 30'lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper 8004 0377 -4- APPENDIX I DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group B -- Known Substitute Material Available With Major Redesign Specification Material Basic Part No.Part Light Truck ESE-M8G106-B ESE-M8G140-A Gasket Gasket 5B266 5B266 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Phenolic Phenolic -- -- -- -- -- -- -- .-- -- -- 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy Trans. Clutch Plate Assy. Chassis ESB-M8G106-A ESA-M8G140-A Gasket Gasket 5B266 5B266 2022 2021 Resonator Gasket Assy. Tesonator Gasket Assy. Front Disc Brakes 8004 0378 -5- *** i UlA | DRAFT 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group C -- No Known Substitute. Advanced Engineering Project Required. Specification Light Truck ES-C8AA-2B282-A ES-D20A-2B072-BB ES-C8AA-2B282-A ES-D20A-2B072-BB Vendor Print Vendor Print ES-EOTA-2B120-AA ES-D6TA-2B118-A A ES-C8TA-2B282-A ES-C8TA-2210-D ES-C8TA-2010-C ES-D8TA-7550-A -- -- -- Trans Vendor Vendor Vendor Heavy Truck -- -- -- _ -- -- -- -- -- Material -- -- -- -- -- -- -- -- -- -- -- -- -- -- _. -- -- -- -- -- -- --- -- -- ---- Basic Part No. 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 4797 4A435 7550 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A596 7550 7E434 Part Lining Front Wheel Brake Outer Lining Front Wheel Brake Inner Shoe and Lining Inner Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake Inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch Clutch Plate Clutch Plate Parking Brake Lining Rear Axle Diff. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S~Cam) Air Brake Compressor Fan Clutch Assy. Clutch and Bracket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Brake Assy. 8004 0379 Chassis ESE-M8G149-A Gasket -- 5F263 2284 2285 APPENDIX I DRAFT 5/2/80 Exhaust Manifold Gasket Rear Brake Shoes 8004 0380