Document aJkK0J1G6L0E624yYVj6LmRQR

,,KKICTI0N MATERIALS STANDARDS INSTITUTE INC., E-210 ROUTE M, FAKAMUS, NEW JERSEY 07652 November 20, 1978 TO: ASBESTOS STUDY COMMITTEE SUBJECT: REPORT BY OFFICE OF TOXIC SUBSTANCES (OTS) ON ASBESTOS Several weeks ago, Mr. Ike Weaver of Raybestos-Manhattan, Inc. sent along a copy of an OTS review on their "Phase I Report on Asbestos." this was a draft of a report circulated within the Office of Toxic Substances prior to further discussion with other EPA offices. Brake linings and friction materials were mentioned several times in the draft. In this draft, the OTS is considering various areas where asbestos can in some manner pollute the environment. In particular they mention the proposed Connecticut ambient air standards of 30 ng/m , and they indicate that there are levels of asbestos in many areas exceeding that level. Brake linings and friction materials are indicated as a source both for inhalation problems, and for ingestion (street sweepings discharged into streams). They mention the controversy on the nature and amount of fibers emitted from friction products. The report mentions a National Cancer Institute study suggesting that fibers greater than 5 micrometers in length and less than 0.25 in width are carcinogenic. The problem with resolution of fibers smaller than 0.25 micrometers in width not being detected by optical microscopy complicates this question when an analyst is attempting to determine the fiber length. They do make a conclusion that use of the optical microscope for regulatory monitoring appears to be inadequate. If it were accepted that only fibers longer than 5 micrometers were carcinogenic, it would run counter to the Mount Sinai position that smaller (shorter than 5 microns and not detectable by optical microscopy) may be more lethal than the long fibers. Also, Mount Sinai studies of wear debris (brake drum dust) have indicated that only in rare instances have long chrysotile fibers been observed and that most are shorter than 0.4 micrometers in length. There are sections in this report on epidemiological studies and a state ment that asbestos induced cancers are related to the severity and duration of exposure. Later in the paper it indicates that exposure may be significant in "auto supply stores," and I would imagine by this they mean from friction materials. The paper further indicates that if asbestos emissions from brake linings are considered significant, that the Toxic Substances Control Act (TSCA) might be used to control the asbestos content of brake linings, and to promote substitutes. They even suggested an interim step to require manufacturers to report any research results on asbestos substitutes. I have not enclosed the appendix list of materials previously covered in the Kearney report on consumer products containing asbestos. This was to keep the enclosure to 30 pages. This report is sent for your Information. E. W. Drislane Executive Director FMSI 06969 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 BULLETIN U 0. 6 3 4 November 16, 1978 FRICTION MATERIALS WORK PRACTICES GUIDE On September 12, 1978 we aslced Active Members concerning interest in a 'Friction Materials Work Practices Guide." This guide will be a small 5-1/2" x 8-1/2" or 6" x 9" booklet with 12 pages. It is aimed at the brake shops and medium size customers handling brake linings and clutch facings. The message has to do with good work practices and handline friction materials. In particular, it emphasizes that the worker should not use an air hose to blow dust from brakes and he should use the proper dust collection equipment if he is machining brake linings or clutch facings. It also has suggestions on respirator usage. Some of the suggestions in the booklet are in line with those made in a NIOSH Alert and in some cases quote directly from the OSHA standard for controlling asbestos in the workplace. There are actually only five pages of text along with five illustrations opposite each page. The front cover has an Illustration and of course the title. The rear cover indicate sources of additional information for some of the items mentioned in the text. This will be a profess ional booklet somewhat similar to a booklet which "was put out by the Asbestos Cement Pipe Producers Association. It's usage is primarily in the brake shop as I indicated earlier. Based on Member interest, we will order in quantities above 30,000, and based on that volume projection the booklet will be priced at 90 (U.S. $.09) per copy. We now have final copy and are ready for printing. Would you please place your order for these booklets on: Friction Materials Standards Institute East 210 Route 4 Paramus, New Jersey 07652 U.S.A. In order to expedite this shipment we are asking that you have your purchase order into the Institute Office by December 1, 1978. END/ere Distribution- Active Members- List C Regional Members Licensees E. W. Drislane Executive Director FMSI 06970 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-2IO ROUTE #4, FARAKUS, N.J. 07652 BULLETIN H 0. 6 3 3 November 14, 1973 REGULATftHY ACTIONS CONCERITIDG ASBESTOS Over the past several weeks the Institute has received correspondence coaccnaisr; activity by Federal regulatory sendee as concerns asbestos. Some of these activities are described in this bulletin. OCCUPATIONAL SAFETY AND HEALTH ADHIKISTBATIOTT (OSHA) DIRECTIVE AS CONCERNS EXPOSURE AND tEPICAL EXAMINATIONS I have copied from an Asbestos Information Association "Hewa and Rotes" of October 31, 1973 concerning this subject. In essence, OSHA issued a directive to its Regional Administrators concerning compliance with the medical examination requirements of the standard. This is an attempt by OHSA to answer the question as to what consists of exposure to airborne concentrations of asbestos in the workplace. They are advising their Regional Administrators that concentrations of 0.1 asbestos fibers Cor more) larger than 5 micrometers per cubic centimeter will be considered exposure to asbestos fibers. If these exposure levels are 0.1 or more, medical examinations are required. You may wish to refer to the text as forwarded by the Asbestos Information Association. CONSUMER PRODUCT SAFETY COMMISSION (CPSC) MEMORANDUM CONCERNING ASBESTOS IU CONSUMER PRODUCTS ' Mr. Jim Reis of Johns-Uanville sent along a Consumer Product Safety Commission memorandum concerning asbestos. This report based its recommenda tions on the Kearney report which was made to identify consumer products containing asbestos. In the Kearney review of products it was their conclusion that friction materials containing asbestos are not likely to be considered a consumer product becauae they are not under the jurisdiction of the Consumer Product Safety Commission. This CPSC memorandum concentrated in the areas of bulk asbestos fiber and dry mix texture paints containing asbestos for consumer usage. This report also discussed exposure to asbestos from ceilings and other structural surfaces. Friction materials were not marked for further Consumer Product Safety Commission study. EhVIRORI iEllTAL PROTECTION AGENCY <EPA) REVIEW OR ASBESTOS The Environmental Protection Agency's office of toxic substances ha-3 concluded a lengthy report on asbestos. Their concern, with asbestos is any area where asbestos usage could affect environmental exposure by air, water or food. Brake linings were mentioned several times in the. report as regards air and water exposure. There was no new epidemiological data as concerned asbestos exposure to friction materials workers. There ware references to brake lining wear being a source of asbestos in ambient urban air, and it mentioned possible exposures to Individuals from asbestoscontaining products in automotive supply stores. FMSI 06971 BULLETIN #633 -2- November 14, 1978 Towards the end of the report there was a comment to the effect that if monitoring determines that asbestos fibers are emitted from brake linings in significant amounts that the Toxic Substances Control Act could be used to control the asbestos content of brake linings and to promote safer effective substitutes. It noted that an interim step could be to require under the TSCA that manufacturers report any research results on substitutes. This report is in excess of fifty pages and it is being distributed to the Asbestos Study Committee for their review. If a member were interested in a copy of the complete report the Institute would be pleased to send one on request. The foregoing items are sent along as a matter of information to the Membership. E. W. Drislane Executive Director CC: Active Members - List C Licensees Regional Members (U.S. Dues) FMSl 06972 FRICTION MATERIALS STANDARDS INSTITUTE, INC Asbestos Exposure and Medical Examinations Matter of employers providing medical surveillance pro gram as set forth in OSHA asbestos standard for occupa tional exposure to asbestos dust has been an unsettled subject for several months (N s N Feb.). At issue has been lack of clarification of the term "...exposed to airborne concentrations of asbestos fiber..." as it re lates to requirement for medical examinations. Both U.S. Court of Appeals for District of Columbia and Occupational Safety and Health Review Commission have ruled that current asbestos standard requires such ex aminations be provided employees exposed to airborne asbestos in any measurable concentration. These deci sions related to a Jan. 1977 policy letter from OSHA to an individual employer which stcited medical examinations would be required only when employee exposures to air borne asbestos exceed 0.1 f/cc. A three-member OSHA panel was designated by Asst. Secretary of Labor (OSHA) Eula Bingham to study problem. AIA/NA requested OSHA in Mar. 1978 to provide workable and reasonable inter pretation at earliest possible date. On Oct. 11,1978, OSHA issued Program Directive #300-16 to its regional administrators providing uniform in spection and compliance procedures for medical exam ination requirements of the asbestos standard. Princi pal actions in this directive are: . The term "exposed to airborne concentrations of asbestos fiber.." is administratively inter preted to mean ''exposed to a minimum cf 0.1 asbestos fibers larger than 5 micrometers per cubic centimeter of air..." t . Medical examinations will be required fo.r any 7 to 8-hour time-weighted average concentration of 0.1 f/cc, or for a greater concentration. - An OSHA spokesman has advised that, agency's Oct. 11 direc tive is considered internal policy and, further,directive does not amend the asbestos standard, but rather provides an administrative interpretation of the standard for use by compliance officers. FMSI 06973 Reprinted from Asbestos Information Association. News and Notes of 31 October 1978