Document a4NB4Vw79o19ORZ4KMG8DdkVB

Otlice of Ihe General Counsel 5/8/80 K. Termaat My comments on the draft report of the Task Force are penned. Copies have been given to H. Epstein and the Litigation Department of/this office for review. // WJH/tb attachment 7)^ cc: M. Weiss N. Bernstein H. Epstein William J. Rooney / HFM - 004953 8003 1505 SCF-FORD-1888 Inter Ottice Engineering and Research Stall 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. Nickol Subject: Carcinogens Task Force Report to E&R M&S Subcommittees 9 The Task Force on Carcinogens in the Workplace was established by joint action of the E&R and M&S 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 j. w. D- urst ine HFM- 004954 8003 1506 /uiiut. Ct'- w. cl/'-'-t*- ^-A-l\us f-Uf* \U-Hv EXECUTIVE SUMMARY CARCINOGENS IN THE WORKPLACE -4_A.vty\- ;t/ vK<. **.- -i.^'OL +'JxUtx,,(. Introduction f I The Task Force on Coreinopens in the Workplace was established By the Engineering and Research and Manufacturing and Supply Subcommittees to identify carcinogens and quan 7Ac Tn*-n. tities in use,, set targets for elimination afecud-of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify jsubstunccs systematically. The- Task Force assignment responded to evidence that cancer may'be o'serious occupational ,\.V_v vx-VA1-/- L concern and to the Company's and public concern with regard to protection of the environ ment and public health. / Additionally,-the Company has been subjected to a growing number kA_ n. oLlaws which regulate material use, transport, handling and disposal. In summary, internal 7 AniVvvjVvmi;Atii II and external pressures regurdmg hazardous substance control and compliance have increased substanliQy smce March, 1977, when Directive B-I01 assigned responsibilities within the `"'Company. ^-fW Acn-o-y. tu-ce/t) ,Xii rA ' 1 f- v,V,vt -) * be -At'-yftvkfv.g -i past Company Actions .j/.a tb J.--a ((/!> ok if r b f /`IS5 Since 1977, tho--Company has removed lead chromates'and molybdates from paint (except special order), y'Tris" flame retardant from fabrics and instituted, controls'on asbestos, including a Vehicle Engineering directive that newly designed components should not contain asbcstosk(documented exceptions must be encapsulated or resin coated). Lrxuu J\J KfU.it /A, , K>, X. l\ i JUi-KfL --y Sprayed-on fireproofing has been asbestos-free since 1969 for new and reworked construc tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure ix a/w*V.vu^has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation -UaM-L^ Vas increased at Romeo to minimize hazards from paint-related chromium compounds. ' * ^ The Task Force has identified sixty-seven (67) carcinogens in use in the automotive Industry. Twenty-six (26) of those are currently regulated byOSHA; the balance have been proposed \ l=K for new regulation. More-restrictive-standards have been proposed for some of those sub stances 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 6-11 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 the Task Torce according to impact on the Company to identify the top eight (8). The top !: iCx . U.jx i pgfrt*1",`> of the eight-priority substances, asbestos, chromium compounds and benzene, werp Cc V.iA'l' jJX-v v examined in detail. * x -Uxkf g( \ ---------- . aij - Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets arid for nonproduction roofing, millboard and core/mold-making materials. Medical UiAr^ . . ,, , . evidence links inhalation of asbestos dust to lung cancer, mesothelioma and other diseases. The present OSHA limit is 2 fibers per cc of air (2 million fibers per cubic meter) Which is proposed to bo reduced to 0.1 f/cc as-early-as this year. j *, `-`S- LW UksuHk. (wmXw - Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links hexavalent chromium compounds to lung cancer, liyor and kidney damage and other diseases. The present OSHA limit is 52 mg per mJ of air which is proposed to be reduced to 1 mg/m'*. Co * oo Ul / "'u'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 V 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 C/I o -J weighted average in 8 hours. / -i~V\ O-fii Specific lists of bulk materials and parts for production and nonproduction use have been developed. A new computer dutn base is being developed. Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid o identification of curcinogcn;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 has been rewritten to require systematic review of suspect carcinogens and input to the data base. l> < -ftA tJ .i/nj Wr v_ i irt v-v\_ ** tV *V. A-t^ccC-rv. VvxJL A CMctvf ( t HFM - 004955 t/ as. HFM- 004956 EXECUTIVE SUMMARY (Continued) Strategy nnd Workplan The search for asbestos. chromium compounds nnd benzene defined the number of pnrts nnd materials containing these .substances ns listed in the table below. Where possible, the applications were divided into three groups: A - Known substitute material without major redesign, II - Known substitute material with mnjor redesign and C - No known substitute or advanced engineering required. The (latu is directional only. There remain muny suspect-- applications which require tiinc-consuming analyses for identification. _____________Bulk Materials nnd Parts e- Production . Nonproduction A B ' C Total ABC Total Asbestos Chromium Compounds Benzene 34 49 22 - - 25 - - _ 15 105 25 15 8- - 8 98 81 34 213 . 3 - 5 8 __ ^1*. i^^ ^_ Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these tlirce carcinogens by Job #1, 1985,' in light of competitive and regulatory pressures, and Company experience. VMiere elimination cannot be contained, institute controls on design, process und exposure. It is judged that the elimination timetable is practical for Croup 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 have to be adjusted to reflect Company cycle plans although.G.M. has stated un intent to eliminate ` asbestos by 1985. Finally, where no known substitute exists (Group C), advanced engineering will have to be completed before a elimination timetable can be established. A generalized- workplan has been prepared on the basis of the evaluation of the carcinogens 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 tlie 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 grams. ) V_ , r t- Recommendntions* 1 2 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 choired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2.__ Assign Carcinogen Program manager control responsibility to Environmental and Safety ____ Engineering Stuff. 3^--Rfoer-qthuee-s6t--7EnkvniorwonnmcaernctianlogaenndsSfaofretryevSitenwff-aSnod establish approval eareioogew-clrmination by the subcommittees. timetables (The Tusk ' Force has requested General Managers and Chief Engineers to recommend dircctionnl timetables.) . Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds nnd benzene for Job HI, 1985. B.1 Request that NAAO Product Engineering Offices and Manufacturing Staff present to the subcommittee specific action pluns nnd timing for the Group A applications identified. J8.A Provide ndvunce program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). T.^-Adopt-nS thO'Compnny carcinogen listing the 67 current OSIIA-rcgiilatnd nnd proposed ` Category 1 substances. Estubhsh the top eight priorities proposed by the Tusk Force as- dompany pmrUics. 8003 1508 Engineering Staff - F.&RS Manufacturing Stuff May 2, 1980 DRAPT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT HFM- 004957 .t May 2,1980 8003 1509 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 I 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 8003 1510 HFM- 004958 8003 1511 DRAFT FEDERAL AND MICHIGAN ACTS REGULATING TOXIC/IIAZARDOUS MATERIALS HAVING IMPACT ON THE COMPANY PIOUHE1 Regulatory Act* Occupational Safety and Health Act - 1970 O.O.L. (OSItA)* Hazardous Materials Transportation Act - I97S D.O.T. (IITMA) Toxic Substances Control Act - 1978 E.P.A. (TSCA) Resource Conservation and Recovery Act - 1978 E.PJV. (RCRA) Clean Air Act and Clean Water Aet Amendments - (CAA) 1977/78 E.P.A. Michigan Act 293, P.A. - 1972 Michigan D.N.R. (MDNR) Packaging & Slacking Federal Hazardous Substances Aet - 1970 Poison Prevention Packaging Act - 1970 Consumer Product Safety Act -1972 Waste Management Hazardous Waste Management Aet - 1979 Mlclu, P.A. 84 r Solid Waste Management Act - 1978 Mich., P.A. 841 ( Expected to be revised during 1980, to lower permissible exposure limit from present 2.0 fiberx/ec to 0.9 or 0.1 libers/cc of air. FIGURE 2 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) stair ESES Responsible Activity SSECO ro IHAT MFC. STAFF SAFETY Plant Engrg. Office Mfg. Engrg. & Systems plants BARS Frog. Anal. A Mails. Engrg. Research Staff . SUPPLY Trans. A Traffic OSHA TSCA Compliance Reporting REGULATORY ACT KCRA < A State Solid/ --" Raz.' Wastes' Compliance Reporting HMTA Compliance Reporting Identification of Controls Material Inclusion In EPA Inventory Monitoring Enforce Controls Chemistry In Data Base DOT Label in Data Base CLEAN AIR A WATER Compliance Reporting Monitoring MICH DNR Compliance Reporting %. Chemistry In DataBase Facility Controls Mon-Prod. h. Prod. Development Metis, Review Process Controls Non-Prod. Metis. Development Review Process Controls Non-Prod. Metis. Implementation Review Ptefllty Control Implementation Develop new matls., mfg. processes. A measurement devices. Production Mails. Review - Disposal Meth. A Pac. Dev. Waste Charac terization Packaging Storage Material Characteri zation . Facilities Rouge Consol Development idation Process Contr. Development Permit Reporting Usage Reporting . .L } I- Compliance Reporting - -17- May 2,1980 HFM- 004959 . 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 E&R and M&S Subcommittees. The Task Force Charter was to coordinate plans and efforts among Company activities, to 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 Scientific investigations into the occupational factors involved in the development 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/hazardous materials has been introduced. ,1 , . , " . Public concerns relating to the control of toxic/hazardous materials, are shared by Ford^ ,T- duerto'the'Company's regard for public health and the protection of the environment and " potential impact of legislation on our products 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 00 _o o 04 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 Kn rvi factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques as well as by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these "-v^Acts, a "knowing/willful" criminal violation can expose individuals, including officers of the ^ Company, to five years imprisonment. Civil and criminal penalties, include maximum fines <>; ^up to $25,000 per day, and a citation normally consists of multiple related violations. - Litigation is also a growing concern. tAt present the Office of General Counsel has three suits pending, involving deaths allegedly due to the inhalation of carcinogenic-substances.--^ ^7" Some'Work man's Compensation expense has also been incurred. The-greatest potential for \ -major expense, however, lies in the possibility of punitive action by the court. ' Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. a Federal Register 45(15): 5031;'January'22, 1980. -1 - . May 2, 1980 HFM- 004960 DRAFT FIGURE 3 PAST COMPANY ACTIONS Production > . Removal of lead and chromium from paints.. . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. __ Nonproduction . Removal of asbestos from, . - Structural fireproofing - Thermal insulation . - Molding compounds . Substitution of vacuum for air blowing in brake and clutch maintenance W lvt$' t (yOL^'` personnel protection against benzene in light oil tanker loading operations Substitution of lead-containing maintenance oils .U Substitution of benzene-containing adhesives at San Jose Reduction of lead-chromates in vinyl operations 8003 1513 o HFM - 004961 2f- . May 2, 1980 DRAFT PAST COMPANY ACTIONS jLfA. \ Production-Materials I" . cl VMrt'WVtV^t. Z.'\.>va-v,/,,4\.CL iAyH-t- 'XJ**'* i-fyO*- <-v'-L-fvtc fj i'1 <Vvy<f 6 Cwv*V,. ---V*' *1, , ' . . , 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 yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977, in response to an inquiry by NHTSAi 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. ^ 8003 1514 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-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 fon Romeo for late 1980.) .v'mxa . s ( rt w't HFM- 004962 -2 May 2,1980 DRAFT FIGURE 4 TASK FOnrE CHARTER The Task Force was chartered by FAK and MAS Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts to: 1. Identify substances in use (OSIIA Categories I and tl). ' 2. Determine quantities used (for mutcrials regulated by Michigan Department of Natural Resources). r 3. Set targets for elimination of as many Category I substances as possible.-- I c 4. Take aggressive steps to find substitutes for as many Category I substances as possible in anticipation of government regulations. (_ - $. Develop a policy and action plun for eliminating potential carcinogens where possible. 8. Organize to identify substances systematically. .1 FIGURE 5 USAGE OF MICHIGAN CRITIC AI, MATERIU.S AS REPORTED TO MAI'S* (ADJUMT.D IIV Till. I'l.W'IS IN flllTIt MDNR REPORTS) .-- ~ Material Acrylic Acid Lbs. of Usage 251,707 * PPV - Paint Principal Users Acrylonitrile 641,133 PPV - Paint ' Aniline SO 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 Dichlorobenzencs 2,542 FTO - Highland Park Formaldehyde 488,965 MCC, PPV - Paint * Hydrazene 130 PPV . Hydroquinone 1 PPV - Vinyl Hypochlorite 15,841,758 MSD - Monroe * Lead 626,027 AAD - Wayne/Dearborn, PPV - Paint Lithium 123 ED - Northville, T&C Sterling Nickel 126,624 MSD - Monroe, T&C Sterling Phenol 5,839 Mich. Cast. Cntr. Selenium 127 T&C Sterling Silver 25 T&C Sterling Silicon-Dioxide Coated Lead Chromate 2,317 PPV : Styrene 1,413,986 PPV - Milan, PPV - Vinyl Tetraclorocthylcnc 1,095 AADGO, Mich. Prov.' Grnd. ' Thiourea 18 PPV - Vinyl . Triaryl Phosphate Esters 160,022 Steel, T&C Sterling Trichloroethylene 91,849 EED - Rawsonville Vinyl Chloride 118 PPV - Vinyl Line 1,085,724 PPV - Paint. AAD, FPSD. FTO Michigan locations not reported to MATS: Detroit Industrial Engine Research A 1 ngmccruig Center . Research - C.IomJule Troy - Tractor Vulcan Forge . Dearborn Glass Dearborn Specialty Foundry Wixon Assembly - 3f - May 2, 1980 * C. 1 - - 1 HFM - 004963 s 03 o o 04 \J\ DRAFT IV / 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 I 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 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 indusr 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 asbestos onlv as articles. 81.377 Dounds of chromium comctounds. and wa* ki iv ivuwrf wt j * www tvw v vnuniKivvi ill uvvu*** 8003 1516 ou ,vy--< MA* i HFM- 004964 -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 . Bettzo (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 0.1 mg/m3 3 0.2 mg/m 3 0.2 mg/m 3 0.2 mg/m None established 2 ug/m3 100 ppm 8003 1517 HFM - 004965 - 4f - May 2,1980 DRAFT 8003 1518 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 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. HFM- 004966 .t -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 8003 1519 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard ' Asbestos Reinforced Paper Core & Mold Making Materials Safety Apparel HFM- 004967 - 5f - . May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES ASBESTOS' 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 in 1980. Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban on all non-critical uses may occur as early as 1985. ( 1A > 8003 1520 os HFM - 004968 -5- May 2,1980 DRAFT CARCINOGENIC SUBSTANCES 8003 1521 CHROMIUM COMPOUNDS FIGURE 10 Health Hazards of Chromium Compounds Effect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds V 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/m3 a/ 1 vg/m3 1/2 of above 3 25 pg/m 10 Hr workday - 50 pg/m /15 Minutes 1/2 of above a) 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 Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks HFM - 004969 - 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. 8003.1522, HFM- 004970 . t- -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 IS 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 <5c Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids 8003 1523 HFM - 004971 - 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) 8003 1524 HFM - 004972 May 2,1980 DRAFT .o CARCINOGEN SEARCH FIGURE 16 ^Carcinogen Identification - Reviewed all likely material 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). 0 . 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 8003 1525 t HFM- 004973 - 8f - May 2, 1980 PRA FT X'WVuOi CARCINOGEN SEARCH *1Xsk-{ &j- / -tX._ A. <_ Three Category I carcinogens were examined to determine material specifications, parts and nonproduction uses, was-tedious and inexact. Existing data bases containing Engineering, Manufacturing and Purchasing information were found-to--be--incomplete and not readily .( accessible. In the absence of one reliable system, the detailed steps in Figure 16 were under taken. 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<JcRS 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. ' i \ 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 (P<JcO Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental & Process Engineering Review System (Mfg. Staff). L. CO o 04 -* JC ** 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 nonproductionr 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. HFM - 004974 '-8- May 2, 1980 Asbestos-^ Cr Compounds3- / Benzene DRAFT CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts -1/ AB 34 49 - -- C 22 25 15 Total 105 25 15 8003 1527 Asbestos 4/ Cr Compounds- Benzene - Nonproduction Materials/Parts A B C Total 8-- 8 98 81 34 213 3- 5 8 Note: tul\MS n 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. HFM- 004975 - 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 were classified as: Known substitute material available for application without major redesign; _ /) . Known substitute material available for application with major redesign; . L* _ . No known substitute. Advanced Engineering Project required? f / ) 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. 8003 1528 HFM - 004976 -9 May 2,1980 DRAFT FIGURE 19 pf -J.. tct Ltuvck^lc-^' 6/| ! f CARCINOGEN STRATEGIES ' ' K>' Jn_ '\ - Continue OSH A Category I eareinogen control by design, process and exposure limits. Eliminate carcinogens-where substitutes are known when - required by regulation or business pressure, a/ ... t * t -j-f' , , ^ - 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. 8003 1529 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 HFM- 004977 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. NIOSH advised substance controls were deemed to be of lower ' priority. It was agreed by the Task Force and PEO chief engineers that 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 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. , oo o o u u wo .I HFM- 004978 -10 May 2, 1980 DRAFT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) Action - Manage Program Propose list of known and suspect -ft/ specifications o/ Verify proposed listn/ Identify known and suspect part 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 4 - 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 f. Block Timing Prod.(Nonprod Ongoing 1 Month (A) 1 '* -7 (A). 1 (A) 21 ) A.( 3) 7 ( 6 8003 1531 12 33 (TBD) 45 c/ Ongoing Ongoing D a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. c/ Complete for asbestos, chromium compounds and benzene. - nr - May 2, 1980 HFM- 004979 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. Without-such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogens. Overall program management is essential to this effort. 8003 1532 HFM - 004980 -11 May 2, 1980 DRAFT FIGURE 21 MEMDERSHIP 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 8 0 0 3 1 533 HFM - 004981 - 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 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&SES location was recommended. In view of budget constraints, it has been 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 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 financial measurement of the compliance effort, and-assuming development direction and control for the computer information system arid 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 responsible executives from the areas shown on the facing page. It is further recommended that the Committee be chaired by the E<5cSES repre sentative./ Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to-overcome present inadequacies. 8003 153* HFM - 004982 -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. 8003 1535 HFM- 004983 i 13f - . May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA 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: Establish a Hazardous Substances Control Committee chaired by the Director Environmental Control Office. The Task Force would be discontinued. >Kyju 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. VM/Vx' 5. Hu* / I 6. 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. 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. .: HFM - 004984 -13 - May 2, 1980 8003 1536 8003 1537 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-TrimethylBenzene Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibenz (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-Dibromo- Ethane, 1, 1, l-Trichloro-2, 2-bis (p-chlorophenyl) 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- HFM - 004985 May 2, 1980 CAS Number DRAFT CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II FIGURE 2 8003 1538 HFM- 004986 r* 80Q3 1539 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<5cO Staff) containing materials, their toxicological evaluation for worker/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 nonproduetion 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 carcinogens and its compounds are identified by IHicT. 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. 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 arc planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating with the exception of Chussts which currently does not participate in material control as required by PEP 3-189. ' May 2, 1980 ,t , ' ' HFM - 004987 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 Settlers -- 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 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 Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- --JU -- Primer for Adhesive -- _-- -- -- -- --- -- -- -- -- -- -- -- -- .-- '-- * , . . -- -- -- -- -- 8003 1540 DRAFT 5/2/80 HFM - 004988 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 Material Sealer Sealer Sealer Deadener Deadener Deadener Rust Prevent Gasket Gasket Seal Gasket Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A 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- pasic . Part No. -- -- -- -- -- -- DRAFT , 5/2/80 Part -- -- -- '-- ` '-- _-- Sprayable Wax Type Rust Preventative 7D026 7A136 4035 7052 7A247 15520 9004650 ' 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. TTans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer 19560 19560 19554 19515 Caulking Cord Rope Sealer Perfect Seal Undercoating 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 VC 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 : 8003 1541 HFM - 004989 -3- nr r cm istA 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 Felts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. t Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper HFM - 004990 BQ 8003 1542l -4- 1** * 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 Yendor 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. TTans. Int. Spline - Rev. Plate Assy. Ttans. 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 HFM - 004991 8003 1543 DRAFT 1 -5 - 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-AA ES-C8TA-2B282-A ES-C8TA-2210-D ES-C8TA-2010-C ES-D8TA-7550-A -- -- 9 Material -- -- -- -- -- -- -- -- -- -- -- Trans Vendor Vendor Vendor Heavy Truck -- -- -- --" -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- ---- 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 4 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. 8003 1544 HFW1 - 004992 Chassis ESE-M8G149-A Gasket -- -6- DRAFT 5/2/80 5F263 2284 2285 Exhaust Manifold Gasket Rear Brake Shoes HFM- 004993 ,f 8003 1545