Document a11GwZr10Daev3QgZnXdb0xNy
FRICTION MATERIALS STANDARDS INSTITUTE, INC., E. 210 ROUTE 4, PARAMUS,N.J.07652 -
MINUTES OF THE MEETING-
of the
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. ASBESTOS STUDY COMMITTEE
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Friday, February 16, 1573, at 9:30 A.H. at the
Institute Office, E. 210 Route 4, Paraaus, N.J.
MEMBERS PRESENT
I. E. Heaver, Chairman J. C. Henning
H. Wagner
E. H. Feierabend
Rsybestcs-Mahhattan, Inc. Firestone Tire & Rubber Co.,
World Bestoe Division
Carlisle Corporation Molded Materials Division
Abex Corporation American Brakeblck Division
MEMBERS NOT PRESENT
T. Bell V. Spurgeon
fi. Z. Porter Company Bendix Corporation
OTHERS PRESENT
R. C. Wyatt E, V. Drislane'
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Maremont Corporation Friction Materials Standards Institute
The meeting vas called to order by Mr. Weaver, Chairman, at 9:30 A.M.
. MINUTES OF PREVIOUS MEETING
The Secretary read a summary of the Minutes of the Meeting held August 17, 1972.
These minutes had been released and a notion for their acceptance had been
obtained.
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Upon motion duly made, seconded and unanimously passed, it was
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RESOLVED: To accept the minutes of the August 17, 1972 meeting as distributed.
LABELING PRACTICES
The subject of labeling of finished friction materials was the first item'on the agenda. While interpreting the OSHA requirements, it is noted that the hazardous warning label must be used where subsequent,working of the materials would create airborne concentrations of asbestos fibers in excess of the exposure limits of the OSBA Standard. In many drilling and grinding operations without dust collectors. Committee Meobers indicated that the 10 fibers/cc celling concentration has been exceeded.
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Minutes of Meeting of Asbestos Study Committee
-2- February 16, 1973
The Chairman nenticroed a survey made is the Metropolitan :area nconcerning the
relining of .bakery trucks. The survey (conducted by an * individual,affiliated
with Mt* Sinai Hospital) -indicated that during radius grinding end drilling of brake lining^ that the airborne concentration of asbestos.fibers .was,.in .
excess of the 10 fibers/cc - ceiling value,
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The results of our survey on Menber practices for 'labeling .vas -reviewed>'The results had been updated showing that 15 Menken had replied of .the 25.Members questioned* The results indicate that the Membership Is not *now labeling in accordance with the OSHA requirements, and while they interpret the OSHA regulations to require labeling where subsequent machining is expected, they are undecided as to exactly what they will do as regards labeling. - In the survey, 2 Menken indicated that a "binder** treatment makes it unnecessary .for the Mesber to label: He believes he is complying with the labeling requirement "Mo label is required where asbestos fibers have been modified by a bonding agent,..so that during any reasonably foreseeable use...processing...no-airborne concentration of asbestos fibers in excess of the exposure limits.. will be re leased. "
It is the view of most Menbers of the Committee that the 5 fibers/cc (TWA) is exceeded in many areas such as inspection, drilling, and grinding where, .there is no adequate dust collection machinery. This could happen in garages where subsequent drilling and grinding is often required and where there is no adequate dust collection equipment. While the Members with OEM accounts are dealing with manufacturers who should understand the OSHA regulations, the biggest problem may be with the small.shops that are exempt from the requirements of the OSHA regulations. In an interpretation of the regulations, it is apparent that where subsequent working of the material can raise the airborne asbestos concentrations above the limits that the manufacturer is required to label the material. Would labeling of cartons suffice? The Committee felt that, yes, this would be labeling that would meet the spirit of the OSHA Regulations. Would It be necessary to put the warning label on individual segments? A Mesber mentioned that in many cases the carton, or wrapping, for the brake lining is disposed of before the brake lining moves in to the working area. It was felt that if the warping label were on the carton or skid when it was received by the customer that the customer has some responsibility to pass the information on, and It was not necessary to label the Individual segments. In the discussion concerning labeling requirements, the Maskers had to distinguish between "where subsequent working will be required" as against **where there is any possibility that subsequent working will be required." Again the point was made that with undusted linings from a manufacturer it is likely that customer inspection, or possibly opening of cartons, could show airborne fiber concentrations in excess of the 5 fibers/cc (TWA).
In discussion of the reasons to support or oppose labeling requirements, the question was raised as to whether objections centered around .the cost of the labeling. Menbers indicated that the direct cost of labeling could be minimal. Most labeling could be put on by the box manufacturer at little additional cost to the friction material manufacturer. The rejoinder to this was that the Menbers felt that it was not the direct cost that bothered them. Rather, it is the indirect cost of the customer reaction tc the warning label. Will the customer be tempted to purchase his linings from a manufacturer who does not put the warning label on the cartons, giving an advantage to the manufacturer who does not comply with the law or to the foreign manufacturer who Is not aware of and cannot be punished by the law?
Minutes of Meeting of Asbestos Study Committee
13- February 16, 1973
Opon motion duly made, seconded, and unanimously passed, it vas
RESOLVED: That (1) where. asbestos containing materials
&ot have
the asbestos fiber completely locked in, or (2) where
subsequent operations may be performed on asbestos containing
- materials, the hazardous labeling practice be adhered to in
- accordance with the Label Specifications ip the OSHA Standards
* for Exposure to Asbestos bust.
The Michigan requirements for labeling toxic and hazardous materials were
discussed. These had been sent to the Keafcers of the Committee in Decenter 1972.
The Ford Motor Company had called to the attention of manufacturers "the labeling
requirements for hazardous substances pursuant to Act #282 of Michigan Public
Acts of 1967. '-On the Michigan Standards there are specific labeling requirements
concerned primarily with flammable and toxic materials. They do not specifically
include asbestos. There are certain label requirements such -as ''DANGER, WARNING,
CAUTION." The Federal OSHA requirements for asbestos specify CAUTION, which is
the least sensational of the type
used. Of course, the DANGER warning
in the Michigan regulations is for materials that would he almost instantly
lethal. However, it is difficult to tie in asbestos to the specific label
required. It is felt by the Committee Mesbers that adherence to the Federal
OSHA requirements should be the first step taken. While the issue cannot he
specifically resolved, it is felt that compliance with the Federal OSHA regulations
for asbestos would indicate compliance with the Michigan regulations. While it
Is desirable that any label used by the Meobers should also cover the requirements
of various state codes, the first step would be to get the Menbers to label
according to the Federal OSHA regulations.
As regards the Committee's recommendation to the Membership, a decision cannot be made as yet cm the size of the label. The OSHA regulations state that the label shall be "of sufficient size and contrast as to be readily visible and legible*" Mr. Weaver has received some data on typical caution labels now in use. Mr. Wyatt will furnish the Secretary the label type that his firm is using. Based on the labels now in use, the Secretary will distribute this information to the Menbers of the Committee for their review. With this information, the Coomlttee should be in a position to propose label specifications to meet the Federal OSHA req uirements.
NEW TORE TIMES MAGAZINE ARTICLE "ASBESTOS. THE SAVER OF LIVES. HAS A DEADLY SIDE"
Copies of this article had been distributed to Members of the Committee. In addition, based on requests from Menbers not associated with the Conodttee, there were additional copies of the article distributed. As the brake industry as such was not a specific target, it vas felt that no reply to the Times article vas called for by the Institute. Mr. Weaver brought to the meeting copies of another article in the Saturday Review of the Society entitled "An Asbestos Town Struggles With a Niller." This particular article concentrated on the Johns-Manvllle plant in Manville, New Jersey. This, of course, was not their brake lining facility. Other than the specifics of the individuals from Manville, the article relied on much of the same background that appears in the article in the New Tork Times.
No action is planned on these articles, hut they are almost required reading.
Minutes of Meeting of Asbestos Study Consulttee
-4- February 16, 1973
HEALTH EXAMINATION BEQPIREMEKTS OF OSHA
ATI Members of the Committee are aware of the medical examination Tequirementa in the OSHA regulations. ^I'All have taken .steps to-comply with these .requirements. The basics of the OSHA requirements are.-a preplacement'examination,'* annual *. examination and a requirement as regards termination' of *= employment IfeThese sv.; ; requirements are for.workers who are."exposed to airborne concentration of 5\Y asbestos fibers.*' Rote that there are -no specific limits which tell whether an
office employee who must make occasional trips :lnto the factory area Is exposed to airborne concentrations of asbestos fibers. The treatment of this is possibly best carried out by meeting the spirit of the regulations in including those employees in the examinations Who are exposed to concentrations in excess of 1 fiber/cc (as used by one menber).
The interesting service by International Compumetlcs was discussed. i-Xhe International Compumetlcs Corporation, located in Princeton,* Hew Jersey/'-proposes a series of mobile medical tests which would include the full examination *requirement, computerized medical- records, at a price that appeared "Interesting to the Members. They will also provide a $500,000 "Errors and Omissions'^Insurance policy to the company for their program. Two of the Committee Members .had investigated International Compumetlcs and while they were not long on experience as regards medical background, they apparently did have some computer capabilities. Also, it was felt that they may have the talent to accomplish what they propose to do. One Menber planned to use the ICM services in one of their factories. Another Member. considered using their services in a factory which later was scheduled for closing.
Another Committee Member suggested that while the International Compumetlcs proposals are Interesting that It might be possible to do what they have done even more reasonably. They work with their local Tuberculosis Society in scheduling examinations in the mobile unit. The Tuberculosis Society does the X-Ray and pulmonary function examinations. The company doctor, in the meanwhile, does the balance of the medical examination. Where local tuberculosis units wish to cooperate, this might be advantageous to both the manufacturer and the worker. In a review of the proposal by International Compumetlcs Corporation it is indicated that they will do everything that Is required by the OSHA regulations.
The Institute Office will let the Membership know of the availability of the services of International Compumetlcs Corporation. We will not make a-specific recommendation. The Chairman also mentioned that there was a New York group that had proposed some similar services and that we should also let the Menbership know about them.
One Member who has already planned to use the International Compumetlcs Corporation proposal will let us know his evaluation of them after they have finished their tests. In direct answer to the question from Mr. Iverson, President of Internation' Compumetlcs Corporation, we will not give them our mailing list. Rather, we will advise our Mesbers of their services.
ASBESTOS BAG OPENING MACHINERY
The Institute had sent out to the Membership information on manufacturers of specialized bag opening machinery. The problem here is to keep the asbestos fiber concentrations minimized during bag opening and to properly dispose of any asbestos dust still left in the bags. The list of those manufacturing bag
Minutes of Meeting of Asbestos Study Committee
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February 16, 1973
opening equipment should be expanded to Include the:
*-> r Taunton Engineering Company
700 West. Water Street
_ v -SCTaunton, .Massachusetts" 02780 wprSjgf-*
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:-l' ;INSTITUTE SEMINAR ON SAFETY AMD HEALTH REGULATIONS
A Member mentioned that the dissemination of information on the bag opening machinery vas interesting. Perhaps there is more information that -can be given to the Metfcers concerning disposal, collection, and other techniques used to comply with the various regulations. In response to a direct question, the Secretary Indicated that-as long as any proposed activity in the area stayed within the guidelines of -our Constitution there should be no reason why activity could not be planned in this area. These would be specifically covered by a few objects in our Constitution such as maintaining and raising the standards of all products,' and the cooperation with the United States Government through its various departments -and bureaus, etc. The Meekers suggested a workshop or a seminar which concerned "Asbestos regulations as they affect the work place or the environment." It was recommended that the Committee's interest in such a semi nar or workshop should he approved by -the Institute before further action is planned.
Upon motion duly made, seconded and unanimously passed, it was
RESOLVED:
That the Comdttee is Interested in a workshop on the effect of Government safety and health regulations and proposed solutions thereto.
The Secretary is directed to have this Resolution reviewed so that the Committee could draw up a formal agenda for such a workshop. It would be the Committee's Intention to have the Institute sponsor this workshop in some convenient location as soon as it is reasonably possible.
EPA EMISSIONS STANDARDS
The Environmental Protection Agency had advised the Secretary that they expected to have the new EPA Emissions Standards regulations published by the middle of February. The Committee Chairman advises that publication of the regulations has been delayed and It is now expected that these regulations will be issued possibly by February 23, 1973.
In the regulations there will be source reporting requirements. These have been extended to 90 days rather than the 30 days that had been indicated earlier. Control practices are still the basic means of applying the standard. Control practices will he'required where visible emissions exist. It is not known whether waste disposal will be included in the regulations.
REPORT OF ADVISORY COMMITTEE ON ASBESTOS CANCERS
At the request of the Chairman, the Members of the Coonlttee had bean sent a copy of the report of the Advisory Coonlttee on Asbestos Cancers. The meeting vas held in Lyon, France, on October 5 and 6, 1972. This report had been reviewed by the Menbers of the Coonlttee and there were no comments made thereon. The
Minutes of Meeting of Asbestos Study Committee-'
-6- February 16, 1973
Chairman advises that *** report was to have .restricted circulation and "that
the International Agency'.for'Research on Cancer'had not officially released *
the report. *--As ve may have been premature :n -distributing the report,-=t-is
suggested, that the Menbere-xestrict*their*circulation-of^any-informationrcontained
in that ..report.'
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The Bendlx Corporation has been running tests on vehicles and on dynamometers. to
entrap the wear debris of brake linings and clutch facings. This study is under
contract to the Environmental Protection Agency. * Originally, the -report'vas to
have been made in 1972. '
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Dr. Spurgeon, of the Bendlx Research Laboratories,'advises that a /finalrreport should be published on these particulate emissions sometime vithln the next -.six weeks. There is no indication as to what these results show,..as the work (at this stage) is not for publication. -
STATISTICAL 'EVALUATION OF THE MEMBRANE FILTER METHOD '
The Chairman distributed to the Comdttee the conclusions and recommendations in a report made for the Asbestos Information Association cm the precision and accuracy of the Membrane Filter Method for measuring concentrations of asbestos fiber. This report was done by the LFE Corporation under contract for the Asbestos Information Association. The evaluation vas not reviewed by the Committee Menbers at the meeting.
NIOSH RECOMMENDATIONS AS REGARDS HEAT STRESS
This particular area does not pertain specifically to asbestos. Hewever, most of the brake lining and clutch facing manufacturers work with hot presses and various ovens. The recommendations as regards heat stress will affect most of the Members. A Meaber's work in the area of heat stress measurements was distributed for their review, along with a copy of the NIOSH recommendations. Again, as tills information vas new to some of the Committee Members the data was distributed and not discussed.
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There being no further business brought before the Committee, upon motion duly made, seconded and unanimously passed, .it vas
RESOLVED: To adjourn.
Adjourned at 1:00 p.m.
E. W. Drislane Secretary