Document ZYE4nB4nyy16KLnNmVVy6en8

I Inter Qtlice To: J. P. Bernard L. T. Dixon R. L. Ervin . E. P. Francis cc D. D. Baker D. L. Block _ H. F. Cromwell J. H. Douma A. V. Duff ~" P. 0. Fadow K. H. Gillis J, B. Huebner G. T. Luzanski E. J. Karke H. P. Freere S. M. Frey D. F, Hagan i M. H. Hamburg ' A. B. M. Houston Z. T. Mabley Car Engineering June 16, 1900 C. A. McfCenney E. R. Price G. A. Schley L. L. Smith V. K. Ttibu H. A. Nickol H. A. Patoczak J. G. Rivard V. H. Sussman E. B. Tennant J. D. Volte Subj ect: Toxic and Hazardous Substances - Product Engines ring Substitution Actions Recommendations from a task force on Carcinogens in the Workplace presented May 27, 1980 to the Engineering and Research and the Manufacturing and Supply Subcommittees have oeen accepted. A copy of the Executive Summary and recommendations (Attachment 1) shows the assignments to the Product Engineering Offices as: - Eliminate Group A (known substitutes without major reassign) asbestos, hexavalent chromium components and benzene for Job #1, 1985, where possible. - Assist in defining redesign/devalopoent required to eliminate Group B (known suastitutes with major redesigns). - Recommend advanced programs that will define the Job of eliminating Group C (substitutes unknown). -- Vehicle Materials Development and Planning proposes to coordinate these assignments and take overall responsibility for assuring they are done with the least additional workload an each FEO. We hope to do this by staying in touch and assisting at the working engineer level. Bob Huasn, 1^413^, will be the VME&F engineer in charge. Please contact him or me with your thoughts on any aspect of what we are planning (Attachneat 2). ' RAH:vc attachmenta Jf.? G. F. Bolling f 003204 PRODUCED BY FORD 105566 EXECUTIVE StIMMMI Y CARCINOGENS IN THE WORKPLACE irfACSMEKT 1 Introduction At the October I9T3 joint meeting of the Engineering and Research and the Manufacturing and Supply Su6eommitl.ee*, a rcoort on the Occupational Suietv and Ho tlth Atfmimairnlicn (OSI)A) Policy for Eleguinling Workplace Carcinogens presented bv Personnel and Organisation Sluff This report noted that linai regulations for carcinogens m the workplace were anticipated by the end of 1979 tl was agreed that efforts to eliminate the use af potential carcinogens, where possible, should be preceded bv analysis of tno affected materials and processes. In this regard, a Test, Force was established bv the Subcommittees la identify potential carcinogens and quantities m use, set targets for elimination of such substances it possible ahead of regulation, tyke .steps to find substitutes, develop u directive and workplan and organize to identify and control poicriliullv eurcinogumc substances. Since October. OSEtA has released its Poliev which establishes criteria and procedures for the identification, classification, and regulation af potential carcinogens in the workplace. The Policy defines Category I potential carcinogens as substances known to be carcinogenic tn humans or winch have been demonstrated to be carcinogenic in two separate loOdfatory animal studies. Category II substances are those where data are suggestive of carcinogenicity in humans and test animals. The Policy also outlines criteria for classifying a substance into Categories t or II and establishes the mechanism for issuance of standards governing use of a particular substance. No soecific substances ware categorized or standards promulgated with the issuance of the Poliev. Normally, once the need lor a standard is determined by OSH A, it could take one to two years before the standard is issued. If an "Emergency Standard" is set, the ruling is issued and immediate compliance is required. A number of court challenges of the new Policy tire expected to center primarily on stringent rules whicn virtually ora elude use of negative evidence studies when defining the carcinogenicity of a substance and an lack of a cost/bencfit criteria in the Poliev The draft List of candidate substances issued by 0511A two years ago is. to be revised by July, 1990 followed by a prioritised extract in September The Task Force has concentrated on dcveloumg the capability for managing the elimination or control of Category 1 potential carcinogens in the workplace A start has been made in Identifying specific i aophcations for subsequent elimination or control of asbestos, hexavalent chromium compounds and benzene. Accomplishments Based on an MVM * report the Task Force has identified thirty-sis !IGI substances assoc iated with automotive production included in the drait 0311A candidate List. Eleven ill I are currently regulated bv OSflt as potential carcinogens, tite balance have potential for new regulation. The list of substances was reviewed by the Task Force considering impact on the Company and potential for further regulation resulting in definition of eight priority substances. The highest priority substances, asbestos, hexavalent chromium compounds and benzene, were examined by identifying application to materials and parts and assessing possibility of substitution. \ list of asbestos production material* and parts has been devel oped and forwarded Co purchasing for supplier verification of content and nvtnldbiluv of possible substitutes. The benzene and hexavalent chromium compound lists are being analyzed by the product offices and Manufacturing Staff to define specific parts usage. Strategy and Workplan The initial search for usocstos hexavalent chromium compounds and ben/ene defined a preliminary bui not complete lisl of parts and mn tennis containing these suosthnees ns listed in the table below The npnlieaucns were judqomcnl.iUy cilegonzcd into three g*onns known substitute material without major redesign, known substitute mnteriui with major redesign and no known substitute with advanced engineering required Substitution Category Production MiuennlsiTirtt Asbestos t,hro<n mm Un/cn A - Known without redesign B - Known with redesign C - Ngt known, a<to. en^rg1 fcq'tl IS :i 7fi VI - * 3 ms 11 3 Nonorodiunmn 'Wucrwlv/Pnns Ashestox rnrommm lrTl/f'tl'2 9 *4 - 29 -4 i i - 9 1H i 003205 . v PRODUCED BY FORD 1 The following strutegy mo timetable are recommended for asbestos. hceavalont chromium earn pounds and benzene For abdications vit.h k'own substitute materials sot 'equirinj major redesign, eliminate f apcropriate ay Jao *1, 1991. . Far a collections with known substitute nat**,ali out -ecturing major 'edesign, eliminate if expropriate consistent with cvele alans nna . jciii1./ projects. - . For applications wilt out denned sunst"j:cs. idvanced enginee"*ng will ae -cqui'ed before i j.rategy and 'tmeuale can ae oaveiooed, [f elimination is not aporeor'ite or passible, provide adequate controLs on exposure Strategies and time'aoles remain 'a be ceve'ooed for .he balance of "he eight prone/ potential esrc.nogens A generalized workplan has Seen presa-ed an the Sasis of the evaluation of the soas.jneea referred to Wove The workplan reduros central arog's-t -nunagement im aefon implementit'on Sv VAAOiDPO Product S.ig'nacnng Qt.iees. "urchasmg aet.vsties, a-jduct Planning, Vehicle activities. Manuiaetu-mg accvtlies end -he `lanufiictur n; and ouoolv Staffs. The workplan timing requires one year to detino the uses or a potentially dsrotnogtme substance with cUmina.' an requiring t.vq additional years for a suoatanee having a known substitute with ho mi,or "edesign required. for .rutarul sooucaiions requiring major "edesign the timing is consistent with new orocuct phase V timing et 11 months lor vehicle and S3 months Jsr powertrain programs Although a sfa'egy md workolan are orooosed n this aeoe* and efforts have been started in these areas, .no-e are conside'scle -lining and feasibility 'ssues m eacn of the -cent . ed applications. w'sthout 'und "J or dt-ee'ed oror tization ave- other engineering et.ort, 'he work on Che ident.red asoestos, nevsvalent enromtur comoound 3r senzena ibplicat.ans cannot proceed under present economic conditions. Veve-the'ess. a measured Comoanv reaction is necessary to initiate orderly suosutution prog*ams with sutfieicnt flexibility to adapt to engineering and economic limitations. Materials and Toz.colory System fM ATS) A new computer data Base -S being develooeo wmeh links health, product, and manuuei-r.nj data bases to facilitate rapid idem meat ion of potential carcinogens and other toxic suostanoes. The ur--s between '"esc svstems will irovide a method (or jent*avng a list of production and 'onproduction mate- a! woc'i iCi'ions vnich contain Ti'egorr juoj;o"Ces To dote, of the four major MAT9 suosvstems. two nave been completed and .'C ct-e"s are being manuellv ooe'b'ei. !n addi' on, 9E 2-139 v.hie1* sceei.ies prooedures fo* the review of no v hdi,sr dls j song -evised .o inc'ude tr.e -ecossarv actions for ente-mg oats on oxic and hazardous suOstanoes inro the data base The work ;o date in Ceveloomei't ot he Mater.uls It Totieologv System (MATS) has emphasized te neea ior mate-.d! detmit on la all part releases Ta >hu end the .otal engmee-mg re'ease ule has teen audited and tne responsible PEO's are preparing maternal deuru.iort .or all part releases. Recommendations Achievement of ihc elimination or control at potential carcinogens -squ'-es a corpora.a commitment to foster ah 'n.eg'iucd and sustained effort throughout the Comoanv ove- e numbe- ot years To accomplish .his, .he .allowing aclions and resaons.lnl tics are recommended. 1 Assign hazardous substance oont-ol orocam manage'neiu resoonsihtl, tv to Environments'and Safety Enj'iiee'sng Slatf (Responsibility environmental ft Saisly Eng.nee--ng $taff - ESaS) 2. Estaolish a Hazardous Substance Cont'ol Cammuteo chaired By Eivironmc-ta! and Safety Engineering Stalf. The Task Force would be discont.nued. (RcSDoni.oituy E5C31 - 3. Revise Directive R-101 (Oocupat'onal Safotv and Health and Cont-ol of 'lararcous Materials! to reilec' adjusted *csrns,oili',rs tor mo and staf'. Vo now Pnlicr is required, i.ho matter is covered 01100" Policy C"3, Standards of Corporate Conojot. (Rospoasibit 1 ty ESRS Program Manager) 003206 PRODUCED BY FORD ATTACHMENT 1 3 4. Adopt as the Company potential carcinogen listing, the 38 current 0511 Wepulntcd and proposed Category I substances Used in automotive production. Establish (lie top eignt priorities proposed by trie lisk force as Compnnv priorities Direct tint the listing be Updated semiannually {Responsibility PAO Stuff) 5. Complete strategies and nmetulilcs for the eight prioritized potential carcjnopieru (or review and approval by the suocommitlees (Responsibility t5CS Program lluiuiger) S. Continue the development of 3! ATS by Environmental 4 Snfetv engineering SLafT. A budget and headcount transfer from Engineering Staff hus been agreed to (Responsibility E315 Program Manager! The Company has demonstrated a commitment to protect workers while seeking to eliminate specific substances. Directions on the use oT and protection fop numerous substances hove been issued, Worker' a're protected by restricting esposure nnd Sv special clothing and engineered sareguurds designed to keep eeposurc within known permissible limit' Specific recommendations for eliminating asbestos, hetavalonl chromium compounds and benzene follow 1, i Proceed with the elimination of Croup A (known substitutes without major redcsignl not later than Job (1, 139S where appropriate as determined bv the Hazardous Substance Control Committee. (Responsibility PEO's. SMD's, Purchasing! 8 Include Croup 0 (known substitutes with major redesign) elimination actions m Phase V of vehicle and powertrain programs and m new plant and renovation projects where appropriate as determined by the Hazardous Substance Control Committee (Responsibility ESC5 Program .Manager, Product Planning, Vehicle Dngmoa-mg, Manufacturing Staff) 9 Recommend advanced program funding to develop designs and/or suostitutes for new production and nonproduction parts and materials la identify feasibility, reliability, cost and weight implications of alternative materials/designs for Croup C apoUcatioits (no known substitute, advanced engineering required). (Responsibility PEO's, QMD's. Technical Planning, Scientific Research Staff) The implementation of the above actions and responsibilities should be reviewed oeriodtcallv by the Enginee-mg snd Research and Manufacturing and Supply Subcommittees to provide a forum Tor discussion, Corporate overview and endorsement of appropriale funding and prioritization of efforts Engineering Staff Manufacturing Staff May 27, ljao t Vertical line indicates revision at subcommittee direction. 003287 PRODUCED BY FORD I f ATTACHMEHT 2 COORDIttATINO PRODUCT OFFICE; TOXIC MATERIAL SUBSTITUTION' ACTIONS aHD " DRAFT STATUS REPORT As discussed la the meeting with materials responsible personnel in G. F. Balling's office on May 7, 1900, it was concluded that remote "nmnagement-by-eesigri^nt11 will not do the job required for control of toxic and hazardous materials, Evan the suaole compiling of a full list of ashestos, haxavalent chromium and benzene anplications, for example, requires experienced research which today's austerity hudgets cannot aDsorb. Therefore, as agreed in principle at tne meeting, VHDSc? proposes to do the following: 1. Assist in refining the initial listing and class if icatioa of the top three hazardous material applications. 2. Coordinate substitution development among the FEO's to avoid duplication of effort. 3. Report both FED and Corporate status of actual elimination and'status of development to the ESES program menager. VMDSiP reports would be against a product family group. Status by part number detail, if necessary, would remain a FSO responsibility. Furthermore, simplification of ES-M's in NAAO is a part of the VMD&P charter, and a broaa review of materials such as this ought to turn up many like ES-M's in like apolications. VMD&P will therefore highlight and include m the substitution, recommendations every possibility for commomzing. The jab IS large enough to require that it be taken a bite at a time. The bite size should be established by a carefully considered classification of like materials and function. For example, bite size might be: asbestos m friction materials, asoestos in gaskets for high temperature; etc. Draf Statue Report A draft status reDort (Exhibit 1) has been prepared oy TMDi? for asoaatoe removal from product families with general classification of friction materials. The reoart is incomplete, out smould serve as a thought starter for content, organization snn format. As written, the report is m tva parts. . Recap of each FEO's position and a spread sheet removal aotion/issues summary. . Snmmary of the key aspects of the ds_sign development job facing Ford product engineering: government regulation, scope of Ford use, survey of substitute availability *performance, oibliography, and miscellaneous information of a general nature. {This is the basic technical reference information (the ` glue) that will keep the program on course and avoid duplication.) Development and the continuing update of this report would oe the responsioility of Vehicle Materials Development and Planning based on input by the responsible PSQ materials and design engineers, suppliers and staffs. Periodically, a brief general meeting of the materials engineers night oe necessary to adjust our course. Vehicle Materials Development and planning June, I960 003208 PRODUCED BY FORD P.ThiV.'t X Page 1 of 7 I PARI 1 - FRICTION MATERIALS I STATUS flZFORT HO, 1~| i Vehicle Materials Development and Planning June, 1900 ` 003209 PRODUCED BY FORD t Lrfiibit 1 t a yr 4125 4J P<t 'll -VH> a4 A un J a *a 3 0- % U 1a i-- J2 "S f 8 t* T '(a0? 4 j -dj jf 1 < Page 2 of 7 ' 4 12 a l i 52i -** 5 J1' P 3s j 'j j o JT5 ^ r d "Z 0 7 a JH U vi -- V U ' C 'l O * 0 H P \ l U t J Ci.^<j 0 S p *2 >/' -^c Q o. j3 d Y J . o' gn Li-J D> 'S .r D 3i O J 7D |^ v1U P J2 O 7 ?> ai fi Y r? 1 N5 2 dJ 3% ll fi *4 11 9 'i c j i 'ie UJ d i 0 -p j aA. <c Y fv 17 5 7 |I -i 63 I 2 -r </i (*J -}4>' y a 4 Q' 5 F 'jl^ l* U ( J 1 - jT l-lO ., \F .ff\0 i* 003210 PRODUCED BY FORD f Exhibit, 1 Page 3 of 7 'asbestos elimination FRICTION MATERIALS CATEOOEI SECTION 2 - PRODUCT ENGINEERING REPORTS Activities Review - Brakes . Passenger Car Chassis - Asbestos free semi-set front disc brake pada were first used in the 1979 Mustang turbo option and Fairmont police paolcage. Usage spread in I960 models to all Mustang, VS Fairmont and T-Bird, 1981 usage will increase again to all Fox vehicles and Grenada." Bendix is the sola supplier. Semi-nets have provan the least expensive way to improve capacity. The trade off is generally greater rstSr wear. All rear brakes are drum with asbestos containing lining. _ A general asba3tos-free lining development has been initiated by Car Chassis Braks Department vith a letter to all the leading lining manufacturers. The letter invites manufacturers to demonstrate feasibility of asbestos free linings by comparing per formance to current release over a single set of vehicle test parameters. Light Truck - All I960 nodel light tni^uttlise semi-met front disc brake supplied by Bendix. Rears are all drum typ&.Vip^asbestos containing shoes. Ho non-asbestos suostitutes are being invest!gates./ Heavy Truck - The majority^tf^oyd heavy trucks are equipped with drum brakes, front end rear, of conventional arbeptos material. The very heavy class 16,000 to 20,000 pound capacity front axre'trjicks utilise disc brakes with semi-met pads. Thera are no plans to evaluate addi'tfponal non-asbestos hraka materials. Statistics i - 6/80 Number of End Item Brakes PEG Front Car Chassis Rear Actual 1981 Model Total j gJoc-Abs * ist. Est. 198s Hodel 1980 Moael Total %Non-Abs i Total ^Non-Aos Lt. Truck Front Rear Front Hvy. Truck Rear 1 1' 003211 PRODUCED BY FORD Exhibit 1 Pigs 4 of 7 ASBESTOS ELIMINATION - FRICTION MATERIALS CATEGJKI SECTION 2 - PRODUCT ENGINEERING REPORTS ' , Activities Review - Clutches yK?v Transmission and Axle - T&A. lacentisw \vb-develop asbestos substitutions has been largely policy. All vat operatirg--iiieni&A transmission clutch plates *<nd bauds and locking differential clutch fie.tks/'have been converted to non-asbeatos facing as of ( ). V/ A. non-asbestos (fiberglass) compound, developed for manual transmission clutches by Raybestos, was uaed in production of I960 200 CD Fairmonts. The sane material is currently released as an option to all conventional asbestos containing facings. Production of non-asbestos clutches however, will be limited by Raybestos product ion facilities until other sources are approved (Thermoid in process). Higher cost might also inhibit early release. , Heavy Truck - clutch facings ore being converted to ceramic materials as performance and costs become known. Conventional organics are not adequate. . Ligat Truck - No non-asbestos substitutes bave shown equivalent performance to date. Possible development for Tuma with Ashai (Japan!, Current 90% supplier, ` Thermoid, assures he can meet EPA proposed exposure limit. All facings beginning 81 are seal coated far assembly safety. tatistics | t V 1 of Pud Product Clutches PEO TleA Light Truck Heavy Truck Actual Est. 1961 Model | 1982 Model ' Total %Non-Abs 1 Total %Non-Abs ! !i 11 ! ;I I ^ ____________ 1 1- 1 ---- - Est. 19S5 Medal Total SNob-Ads 1 | : 003212 PRODUCED BY FORD ASBESTOS ELIMINATION PROGRAM - FRICTION MATERIALS Exhibit 1 Pago 5 of 7 SECTION 3 - BACKGROUND TO CURRENT DESIGN fTtS&CTKiN Brakes and Heavy Duty Friction Application* /' Asbestos has unique physical anH chemical propertiM''^which are very difficult to reproduce m a substitute. These properties include a consistent natural lubricity, high temperature function, good peraiability to heat generated gases, low cost Furthermore, braking performance is Judged against a highly developed [on asbestos) envelope of CPAS and FMVSS tests. Three categories of non-asbestos compounds are currently being investigated, 1) Sami-metallics (Semi-net) - essentially spounge iron and steel wool plus graphite and bonum sulfate held togetner in an organic matrix. The graphite is required to_prevent_welding to the drum or rotor, but has a very . low coefficient of friction when vat - it effectively restricts passenger car use to power disc brakes; although they have been applied to heavy trucks, . Semi-met disc brake pads supplied by Bendax today for car and light truck are a composite sandvich of semi-met surface bonded to a reinforced organic back ing in turn riveted to a conventional steel pad. The sandvich construction is used primarily because the semi-met material does not have the compressive strength for riveting. 2} Sintered metallic* - mixtures of iron and copper, some in variable density, used in clutch discs, aircraft brakes. Hot likely to become fsasiole for automotive brakes. 3) Non-asbestos organic (N.A.O.) - essentially the sane as the current asbestos shoes/pads but with other fibers such as glass. These would seen the best prospect as a substitute involving least product development but N.A.O, materials are not strong structurally & delaminate in the high speed manufacturing process used for passenger car drum brakes. They are compatible with Less automated process used m some large truck drum brakes. Consensus among passenger car product engineers and suppliers is that an N.A.O. material would require a three to five year combined development of drums, snoes, linings oefore release. Regulation and General Corporate Policy (TED ) tens of asoestos are released to the environment annually as a result of wear of friction material containing asbestos.- There is a strong difference m pro fessional opinion as to the hazard from wear debris. Sigh temperatures and pulverizing during wear change asbestos into a different form. The disagreement is to the toxicity of the deans. 003213 PRODUCED BY FORD t l I Section 3 Page 2 Exhibit I Page d ef 7 Regulation and General -Corporate Policy {continued) There is no doubt, however, that asbestos mining and manufacture of asbestos contain ing products will be increasingly regulated. Regulations will be- in the fora of airborn exposure limits, and banning of more products containing asoestos in a free con dition (as va. a filler m gaskets and plastics}. A ban on the use of asbestos con taining friction material is not expected in the near future but regulation will make them more costly and reduce their availability.3^ More information about regulations and the intentions of private sector leadership will be exposed at an EPA sponsored conference July l4, 1980 in Washington D.C. Mr. A. Anderson of the Scientific Lab will attend. NAAO Car and .Truck Policy on product usage of asbestos is defined m CEFL-^IO: - with certain exceptions, "Newly designed components should not contain asbestos". 1/ Bibliography item reference Vehicle Materials Development and Planning June, 19flC 003214 PRODUCED BY FORD | APPENDIX A5BE3T03 ELIMINATION PROGRAM, PART 1F ric tio n M a te ria l Suppllere B) u El e iBI e vQ 9O [O3 M. nv o IE*3m "'Cca so u ffaa *a V3 u +3 9ba aobLie eoan 31 fa -j IaS jj Lodi 9 2 oadcI be9aoe fbScafl 8. afa !--aa3aI -3anb4e rH*u Ch -S Oaff3aa j-c3>j CJ -WO j fa *0 3fya H O < Cw a aoCL 9>e d m3 \ \ Exhibit 1 P*S 7 of ? D93 fGa fSa dse jf9dOa 9 Mdfa 33 acdfa fa 3Sd j3 CO f0ccG3a3a 1 f5a eHUO> 3 J3 fda- ^d9 4fsa0 hfGJa Gd 9 aC. a ca 9 9 HU3 9C M 9fa n Mdfa OQ sabe aDC faWdn `Gfcfaa -CU 9 icH3j cafaa <faaGbudfa<o bGrlfl fca fdteefaao *8 n AdG. f0a o afa fa 9 u CQ O o 3fa S>&d9i 1 to ifffCaaa JCfb9sDa5! CfbGodmae acdfa i--3d< JZ Hcacfaaj t9dfC-a O cd X 1 C99dm j-9faa 3fCa Fo3fa 99 kd; 'S UaH 0q33 fha o 3 a * ** * . it * ^ovic0-O01t- -oo~ C--i O'* fe(a . d f^a a& aa *u 3 *THJ ifLa e Qco Wud -cwd rIj ao -Hh -s9S d ^B ~s uri*j\ c- ofa m -QH Ja= '-s u *fJh0oa*! imfaOa ifea a ^nJD f9f0Baa: Oo!-It %J3o* *r f9a fHG atO*-fa9i ^o ** uo JEof0d3ma a0 g OOINN m NO T 930 ff3asa s mH 2a *-- fa ud 9 >9* a" 9 fa 9Gfa 5 cbfoase 003215 V e h ic le M a te ria ls Development and P lanning * June, 1900 I PRODUCED BY FORD i Responses from PEO's - Asbestos 1. Climate Control Division 2. Body and Electrical 3. Engine Engineering 4. Ford Parts ic Service Division . 5. Transmission <Sc Axle Engineering 1 $, Electrical it Electronics Division 7. Truck and Recreation B. Truck Operations 9. Chassis Engineering Supplier Survey Request and Purchasing Activity Responses - Asbestos 10. Climate Control Division 11. Casting Division 12. Electrical A Electronics Division 13. Glass Division Responses from PEO's - Chromium and Benzene ' I June 6, 1990 003216 PRODUCED BY FORD