Document a1zE7opg86DKRqaM0n9EogYaa

23711 Southfieid Road Southfield, Michisan 46075 Telephone 313 424-88GO January 6, 1976 Mr, Ronald R. Eureka plant Manager TEMPO PRODUCTS COMPANY 6ZOO Cochran Road Cleveland, Ohio 44139 ear Mr, Eureka; UH t n jim . > j j j . ----- ~----------' ^ ^il- *M Presented herewith are three (3) copies of a report summarizing the results of our evaluations of pour vacuum cleaner (Model 75-D) for effectiveness in con tainment and control of asbestos-containing dust dur ing a series o experimental tests with actual brake lining dust conducted by Mr, Dennis D, Zaehst of our staff on December 16, 1975. In summary, we have concluded that, under normal con ditions or use, workers operating the vacuum cleaner in connection with service work on automobile brakes are not likely to be exposed to concentrations of air borne asbestos in excess of present or proposed occu pational health standards established by the Occupa tional Safety and Health Administration, assuming proper use and maintenance of the vacuum cleaner and filtration system. In the accompanying report we have recommended that industrial hygiene studies be conducted during actual use of the vacuum cleaners la typical garage or service shop environments to confirm the findings re sulting from our tests. In addition, we have recom mended that a rigid quality control program be imple mented to insure that the integrity of the vacuum cleaner components, particularly Che filtration elements, is maintained during large scale production. It has been a pleasure to be of assistance to you on this project. Please contact us if you have questions concerning any aspects of this report. , P. E. Vice-president Director, Industrial Hygiene Services RDS/kb Enel. 002872 PRODUCED BY FORD L Vacuum Cleaner Evaluation TEMPO PRODUCTS COMPANY Cleveland, Ohio INTRODUCTION Tempo Products Company retained Clayton Environmental Consultants to conduct an evaluation of a vacuum cleaner identified as "Part No,.75-D," The primary purpose of the test was to determine the effectiveness of the unit for containment and control of emissions of asbestos during use in cleaning asbestos-containing dust. It Is understood that these vacuum cleaners are intended to be used in automotive service centers for dutft cleanup associated with brake rebuilding operations, including the removal of dust from brake drums and dust produced by grinding and fitting of brake shoes. Results of this evaluation, conducted by Mr. Dennis D. Zaebst of Clayton Environmental Consultants on December L6, 1975, are presented in this report. DESCRIPTION OP TEST PROCEDURE The spatial arrangement and relative locations of the vacuum cleaner, air sampling devices, and operator are shown in Figure 1. The tests were carried out in a relatively small confined room (room volume was approximately 600 cubic feet) which was sealed to prevent air movement into or out of the room during each test. The only circulation of air within the room was that generated by the exhaust action of the vacuum cleaner. These conditions were imposed for the purpose of maximizing the sever ity of use conditions. During each of three tests, the operator of the vacuum cleaner cleaned approximately ten pounds of asbestos-containing brake dust (described below) from a cardboard container placed on the floor of the room. During each test, one air sample was taken in the breathing zone of the operator and two area samples were taken at stationary locations equidistant from the vacuum cleaner exhaust port. An additional area sample, located in the north east corner of the room, was taken immediately after the vacuum cleaner was turned off. The room was then ventilated for approxi mately two hours to minimize the possibility of interference with subsequent tests. To reduce the possibility that fibrous dust, which might normally be present in the indoor air, or fibers gen erated by a previous test might Interfere with the analyses of the test samples, "control" samples were taken immediately prior to each of the tests before any handling of the asbestos-containing dust. Since it would be d ifficult. If not Impossible, to simulate with ( a commercial asbest as produce actual "brake dust," with respect to particle and fib er size dlstributiansand thus to simulate the efficiency with whi ch the fibers were removed by the vacuum 002873 PRODUCED BY FORD -2- cleaner filtration system. It was desirable to use for the eval_ uation actual asbestos-containing dust generated in a manner simi lar to that associated with automobile maintenance procedures,' e.g., grinding of brake shoes. A bulk sample of dust produced by grinding of brake shoes was obtained from a local automotive axle plant. This dust had been collected by fabric filters incorporated in the plant's local exhaust ventilation systems. No other dust was mixed with the brake dust during or after entrainment by the exhaust-filtration systems. The dust was analyzed in the Clayton laboratory for percent fiber and fiber length distribution, by phase contrast microscopy at 4Q0X magnification. The results in dicated that the dust was composed of approximately IS. 2 percent fiber (i.e., fiber to particle ratio), and that fiber lengths ranged from approximately two micrometers to greater than fifty micrometers. Approximately ten percent of the fibers were less than five micrometers in length, about fifty percent measured be tween five and ten micrometers, and the remaining forty percent measured greater chan ten micrometers in length. SAMPLING AND ANALYTICAL METHODS Both general area and breathing zone Samples were collected by drawing air at a nominal flowrate of two liters per minute through 37-mm diameter cellulose ester membrane filters (Milllpore, Type AA, nominal pore size 0.8 micrometers) mounted in a three-piece cassette with the cover removed, using portable battery-operated pumps (Mane Safety Appliances Company, Model G). Breathing zone samples were obtained by fastening the pump to the operator's belt and the filter head to the outside of his collar at approxi mate breathing zone height. Thus, the breathing zone sample was representative of the time-weighted average conditions to which the operator was exposed during the sampling period. Each sample was analyzed subsequently for asbestos fibers using the method specified by the National Institute for Occupational Safety and Health. Briefly, this method consists of the following steps: a pie-shaped section of each filter is cut carefully from the filter and mounted on a standard microscope slide using a high viscosity solution of membrane filter material in a 1:1 fixture of diethyl oxylace and dimethyl phthalate to render the filter transparent. Asbestos fibers, defined as particles having an as pect ratio (apparent length to width) of three or greater, which were observable on the surface of the filter were counted using a. 10X eyepiece and a 40X objective with phase contrast Illumina tion. A minimum of 100 fields, selected at random on the sample, were examined and fibers greater than five micrometers in length were counted. The microscopic analysis, that is, fiber count data, was used In conjunction with field' sampling data (air flow rates and duration of sampling) to calculate the concentrations of asbestos fibers in air corresponding to each sample in units of fibers, greater than five micrometers in length, per cubic centimeter of air. This procedure is consistent with the method used by the Occupa tional Safety and Health Administration in its compliance effort. 002874 PRODUCED BY FORD -3 Data thus obtained were then compared to applicable standards promulgated by the Occupational Safety and Health Administration (OSHA) and by the American Conference of Governmental Industrial Hygienists (ACGIH), The present OSHA and ACGIH standards limit eight-hour, tiroe-weighted average exposures of workers to a con centration of five fibers (greater than five micrometers in length) per cubic centimeter of air. Effective July 1, 1976, the OSHA limit for eight-hour, time-weighted average exposures ia scheduled to be reduced to two fibers per cubic centimeter of sir. The present OSHA standard also establishes a ceiling (or peak) expo sure limit of ten fibers per cubic centimeter of air. On October 9, 1975, OSHA issued proposed rule-making to lower the present standard such that eight-hour, time-weighted average exposures would be limited to 0.5 fiber per cubic centimeter of air, and ceiling exposures measured over a period up to fifteen minutes would be limited to five asbestos fibers per cubic centimeter of air. The proposed standard is based largely on evidence of the carcinogenicity of asbestos in humans. PRESENTATION OF DATA Results of microscopic analysis of the bulk sample of brake dust for percent fiber and fiber length distribution are presented in Table I, Examination of these data Indicate that the bulk sample was composed of 18.2 percent fibrous material (by count) and fiber lengths ranged from approximately two micrometers to greater than fifty micrometers. Results of microscopic analysis of the filter samples taken dur ing the vacuum cleaning tests are summarized in Table II. These data indicate that the background level of airborne asbestos in the room prior to any testing was approximately 0.07 fiber per cubic centimeter of air. Control sampLes taken just before the second and third tests indicated that airborne concentrations of fibrous dust were approximately equal to the background level measured prior to the tests. Airborne concentrations of ftbrous dust as measured by the stationary monitors ranged from 0.07 to 0.4 fibers per cubic centimeter of air for all tests. The per sonal breathing zone samples indicated that airborne concentra- tions of fibrous dust in the operator's breathing zone ranged from 0.3 to 1.0 fiber per cubic centimeter. CONCLUSIONS Interpretation of the sampling data leads to the following concluslons: 1.. General airborne concentrations of fibrous dust, as measured by area monitors strategically located In the enclosed room, ranged from 0.07 to 0.4 fiber per cubic centimeter during vacuuming tests, well below the proposed OSHA ceiling concentration of five fibers 002875 PRODUCED BY FORD 4 per cubic centimeCer of air* the most stringent occu pational health standard applicable to short (15 minutes or less) exposures. In fact, the concentrations are be low the proposed limit for eight-hour, time-weighted average exposures of 0,5 flber/cc. Due to 'the extreme severity of the test conditions (small, confined room, no dilution of room air, vacuuming of a very large quan tity of brake dust), these data indicate that under nor mal conditions of use, emissions of fibrous (asbestos) dust from the tested vacuum cleaner are not likely to " result In room air concentrations In excess of present or proposed OSHA standards, assuming proper use and main tenance of the vacuum cleaner and its filtration system, 2, Airborne concentrations of fibrous dust in the breathing rone of the operator ranged from 0.3 to 1.0 flber/cc dur ing vacuuming test procedures, again well below the pro posed OSHA celling limit for short term exposures. It is apparent from the data that concentrations of airborne asbestos in the breathing zone of the operator averaged slightly higher than general area concentrations as measured by the sta tionary monitors. This is more likely due to the unavoidable primary generation of small amounts of dust from the container by the wand of the vacuum cleaner during vacuuming and to the close proximity of the operator's breathing zone to the point of generation of the dust than to the emission of dust from the vacuum cleaner. Again, due to the severity of the test condi tions, it is concluded with reasonable confidence that, under normal use conditions, workers using the vacuum cleaner are not likely to be exposed to concentrations of airborne fibrous (as bestos) dust in excess of present or proposed OSHA standards, assuming proper use and maintenance of the vacuum cleaner and filtration systems. RECOMMENDATIONS 1, Although the vacuum cleaner and Its filtration system appear to be effective in filtering out asbestos fibers present in brake dust from the air stream, it is recom mended that further industrial hygiene evaluations be conducted during actual use of the vacuum cleaners in typical garage or shop environments to confirm the con clusions presented In this report, 2. The conclusions presented in this report are based on the assumption that quality control of vacuum cleaners and filter bag systems is adequate. It la therefore recommended that a rigid quality control program be developed to insure that adequate performance of the vacuum cleaner components, particularly the filtration ( elements, is assured during large scale production opera tions . This report prepared by: Dennis D, Zaebst ^ Industrial Hygienist 002876 PRODUCED BY FORD L < 10 Feet O H* Q OP P a o H rt *4 a PF o Q *1 ?ooa0 Qa n ft Cfl ro A o *n n09 n h X ft H* 439" PT I w OP *1 ft ft rt E v a lu a tio n o f Tempo Vacuum C le a n e r 10 F e e t c 002877 PRODUCED BY FORD TABLE I CLATTON ENVIRONMENTAL CONSULTANTS, INC. MICROSCOPIC SIZING DATA TOR PARTICLES Date___ 12/15/75 Plant_ Tempo Produc ts Comp any proees s ______ Saaple No. Bulk Brake Dust ObJactive Phhco 4QI Eyepiece Periolan 1Qx Total Magaificat ion 4ooy SIZE DISTRIBUTION OF FIBERS: Length Range, Um Mean Length, 0.8-1.1 1.1-1.6 1.6-2.2 2.2-3.1 3.1-4.4 4.4-6.2 6.2-8.8 8.8-12-5 12.5-17.7 17.7-25.0 25.0-35,2 35.2-50.0 TOTAL 0.95 1.35 1.90 2.65 3.75 5.3. 7.5 10.6 15.1 21.3 30.1 42.6 >50. _ No. of Particles - 3 4 10 20 9 7 6 4 -4 67 Size Distribution by Count X of Total Cumulative X 4.5 6.0 14.9 29.9 . 13.4 10.4 8.9 6.0 6.D 4.5 10.5 25.4 55.3 68.7 79.1 83.0 94.0 100.0 Ratio, fibers: total particles 112:617 Fibrous Content , Percent 18.2 Any particle which haa an aspect ratio o 3 or greater is considered a fiber.' . 002878 PRODUCED BY FORD  C o n c e n tra tio n \ CLAYTON ENVIRONM CNTAL CONSULTAN IN D U S T R IA L 11YG1:e n e s a m p l in g s i Mb t e r i cn 00 04 <s <3 ,, JJ QJ 3 a 0 3 0 j*a4 <4 o *M >C0 * H5 *'T X < l , H* 0o -O u Cm aa cL 3 5 is3e 0 VI 4l 41 f-4 J5 o. e* S **4 e 4) w :* u P *0 H 0 H ^4 C- W 0 O41i to a. Q jj CO JJ 14 a 4J s <I 4 4J p(14. 4 tJ 4B 49 c3 r** JM aa f* 03 CM CM a o 4 n o o oo om cn N cn cn o** COM* ** 0 o vr o a4-J\ o r* a Ho o -J o -O' cn m** c*M o% m <mn 0% a JJ S 34 * J3 SK OS ao a o H6 Hcn W H u 4-1 u V 4o4 a ao U 0 O0 M-l u 4 > 404 H to at H Pm u 0u u3 co 0 44 U c 0 PEM uo3 OMO w *w 44 JJ jj S o a a 0 -4 ^ a jj 0P 404 -H JJ fc u 4 > XJJ U 0 > C0 0 1-4 u o 3 c T0*4 L3 O 55 44 0 CM m c% a C4 3o w Ba "a 03 (4 * s M * JJ 0 0 U J0J 09 33 U MU 3 00 o U > 41 jB C 0O O 4 M ^4 lU 44 41 CU JJ a > 3 0 0 j 44 0 cn m m o* o O ^4 44 o V e 0 s 4J 0 0 JUO J^ 0a fi jj 00 0 C4 14 0 0a 04 O 41 M ^a a. .a EE 43 MS *--1 ^4 <1 h CM <-J 1i 1 r 4 -cS -< < <! $ *! -< < -0 * *n 4 mH p4 f-4 xOH r-% ^ o> fl H CM cm H pM *4 CM H CM CM N o rth e a s t co rn e r o f room , a fte r vacuum Bhut o ff N o rth e a s t c o rn e r o f room , fo u r fe e t from vacuum exhaust S outheast c o rn e r o f room , fo u r ! fe e t from vacuum e xh a u st. % o cn oo V CM r^. <t CM 09 O o cn H91 O o ^4 CM CHM eM P4 OH m 00 o CM pH eM ^J fJ H o CM CM PH CD c CM a* o o u H to JJ 44 w E-t O 404 14 a 0 (4 55 jj a O O ao 0 44 wu C O H ^4 0 AJ J4 0 AJ > a0 O ^4 a0 4J 0 0 H 9 Q 44 ao *4 J4 0 > 0 0 U 0 404 14 9 3 44 0 0 JJ 0 > 0 i-4 V ofH tn 1 << < xO o iH CM H CM H M) i-4 CM p4 eM < ^4 CM > P la n t Tempo P ro d u cts Company C le v e la n d , O hio PRODUCED BY FORD f 1. P la n t Tempo P ro d u c ts Company C le v e la n d , O hio P e rs o n a l, b re a th in g rone o f o p e ra to r A c c e p ta b le 0S1IA e ig h t - h o u r , tim e w e ig h te d average c o n c e n tra tio n (TUA) Uw^ g r e a t e r . JJ 9) 3 0 (S 3 0 M -3 tn e o vd U L L d 0 u e 0 h * u a> a J2 U T< a--S 41 d su Pm 3 0 6u as o pH W > Sh4' VO dT iV ao r-* nN U s-- ^ H PS _< a w tn iH t* ?S < a V5 JH id H U 4k JJ ta S</l a o 4 PL, tj X t H u rJ <tn i4 < E- u -AJ a w w < aa a o > es i-( > a w J <M eG h o t* > V3 a3 kJ< o 41 JJ o, on e -4 41 41 trt fc fcfl e g -4 O CU |4 ft* VI a o u ta 4J Id 0 U CO en N tn a CM T"4 N i-4 co 04 ON * w CM ,H * s 0 0 U <w G3 VM (3 M O 4 O 4J JJ 1. U 3 4 V -G ft4 C BO (; L< 49 O 0 4J u 3 c3 3 -u a 00 0> 41 JP U hi V U 4J 0 M4 20 41 ft* #4' 4 Pm A 6e 03 ta 2: m r* m trt a^ c-. OV il < -< < sa <C f4 GS N p4 ^4 J66 G --J 0 Hj -4 3 41 HO iH .c JJ d Q O aH cn O N m3 Qo VV a HO m CM, O O v-1 Q JJ r- o vo < tn tn n n CM VC JJ od G 0 pH <3* o M w ^4- vn tn -H0" 4-4 'M p- <r p4 ** m r-- m a CM rn o n sT H Htf pH |4 9 O M Bw 0 O* O Q3 o L| a uX 4J Lm X JJ H 44 4) Q U 43 cn O 41 y w <4-1 u Li E Vu 3 0 U S3 3 14 a LI 3 *4 U 3 PS C 0 o a 0 i-i u M-l ti > 44 Pt*Mm U H e^ 0 e 0 OS 0 o -- *4 0 U -H C LJ 4J H JJ H 4A G U > LI 4J 9 G ft4 41 41 OH O V H U 41 E 'Ll 4i <N cn rH 14 9 O 44 K e 0^ 00 33 ft4 9 JZ MJ X JJ 0 41 01 41 M- S M 41 3 G 3 ft4 L* a 3 O9a V > 44 -LI g ao flj 14 41 44 pd JJ u 3V a ai E/3 *4 G O H U d > 41 4 9 CM fH tn -4pH Lt o h a0 GO a0 N ftj U4 <44 ca U Q Go H 4J Vf 3 4J 41 X 4 G4 4) Ll Li O 0 y 3 JJ U H ftd eq ^ G 0 9> P JJ C G G Li at U JJ ai H 43 (4 JJ ai a. a Lj p4 O 3 4 GO vO 1- < < < vd \Q 1-4 pH pH cm C4 CM H CM H 1 < <! N mO ^4 N 11 < <! < -< va 41 ^4 N CM fH Ll 41 > H rT3 43 4) -u > -G ^ DO JJ *H U 4) 0J 3 vh 1 vw 43 01 E H JJ JJ *4 0 - *H |J pH 3 0c *G 0 1H LI JJ JS do uG *H JJ or s o> <U 5= G VI Q O cj * 0 -H JJ 9 U JJ 0 01 Os 0 0 G 0 G G J0 Ll 00 c 0 *H* G ^4 d TJ 1 ftd 0 G JJ T3 0 JJ G 0 0O 0 4J 1j *H tJ H i <& on G in 0 ^4 O ; H --4 `d M4 43 V CJ 0 e Q0 < a. -G a: C U 03 D O fim M D 00 JJ JJ BJ 0 0U j4 H 46 00 .1 0 G1 H M tM n K t PRODUCED BY FORD NUMBER 4 As noted in the correspondence, the original cautions and warning labels are prepared by the manufacturer. They were then reviewed with the in dustrial hygiene office and Office of General Counsel for completeness and proper wording. 002881 PRODUCED BY FORD