Document aMR4zb59EaXD42Gjw2kM6wKR

FILE NAME Brakes BRK DATE 1975 Aug 8 DOC BRK052 DOCUMENT DESCRIPTION Letter from Dept of Health with Attachments DEPARTMENT OF HEALTH EDUCATION AND WELFARE PUBLIC HEALTH SERVICE CENTER FOR DISEASE CONTROL August 8 1975 NATIONAL FOR OCCUPAT OCI CUO PAN TIA ONL AL SAFETY AND HEALTH 5600 FISHERS t ANE ROCKVILLE MARYLAND 20852 Dear Colleague This communication is intended to alert you to recently gathered information indicating a potential health hazard for persons exposed to asbestos during the servicing of motor vehicle brake and clutch assemblies On July 21 1975 the National Institite for Occupational Safety and Health convened a meeting of government and university scientists industry representatives and labor union officials to discuss the present state of knowledge with respect to this problem Data was presented by investigators from the Mount Siani School of Medicine in New York City indicating that workers engaged in the maintenance and repair of automobile and truck brake Linings are exposed to potentially hazardous levels of airborne asbestos dust Specific brake servicing operations studied included blow of automobile drum brake assemblies grinding of used truck brake linings and bevelling of new truck brake linings Average peak asbestos air concentrations for these three activities based on personal samples taken within ten feet of the operator were respectively 10.5 3.75 and 37.3 fibers 5 microns in length per ml An analysis of samples of brake drum dust revealed that almost all of the asbestos fibers found were shorter than 0.4 microns in length Previous studies of the extent of asbestos emissions from automobile brake lining wear showed that only a very small fraction of the original asbestos content of the brake lining is found in brake drum dust Ref 1-3 It was presumed that this is due to thermal degradation of the fibers during braking The present findings indicate that enough asbestos is preserved to produce significant exposures during certain brake servicing procedures The full extent of asbestos disease in brake servicing personnel is not known at present because not been studied systematically this particular occupational group has up to now However a review of the scientific literature on the association between asbestos exposure and mesothelial tumors of the pleura and peritoneum has revealed at least four cases of these rare tumors in persons who were employed in jobs involving automobile brake servicing Ref 4-6 36 Page 2 For your information and guidance we are enclosing pertinent references estimates of the population at risk a NIOSH interim recommendation for brake and clutch servicing procedures and a copy of the Department of Labor standard covering exposure to asbestos in the work place The environmental studies of brake lining servicing operations outlined above together with observations of mesothelial tumors in persons so employed affirms the necessity for instituting and maintaining recommended control measures in this industry so that the health hazards of asbestos are minimized Sincerely e f yours . J. William Lloyd SC.D. Director Office of Occupational Health Surveillance and Biometrics Enclosures REFERENCES Lynch J.R Brake Lining Decomposition Products Control Assoc 824-26 1968 J Air Pollution Hickish D.E. Maintenance and Ann Knight K.L Exposure to Occup Hyg 17-21 1970 Asbestos During Brake Jacko M.G. and DuCharme R.T Brake Emissions ments from Brake and Clutch Linings from Selected Report 68-04-0020 1973 Emission Sources MeasureEPA Newhouse M.L. and Following Exposure 261-69 1965 Thompson .: to Asbestos in Mesothelioma of Pleura the London Area Brit and Peritoneum J Ind Med McDonald A.D. et al Epidemiology of Primary Malignant Mesothelial Tumors in Canada Cancer 914-19 1970 Greenberg M. 1968. Brit J and Lloyd Davies T.A Ind Med 91-104 1974 Mesothelioma Register 1967- ESTIMATES OF THE WORKFORCE POTENTIALLY EXPOSED TO ASBESTOS IN THE MANUFACTURING AND SERVICING OF BRAKE LININGS AND CLUTCHES Auto Mechanics Garage Workers Manufacture original and rebuilding TOTAL ; 833,535 67,679 6,657 907,871 SOURCE Business Industry Adapted from 1972 Census of Manufacturers 1972 County Patterns and Census of Population 1970 Occupation by all are Department of Commerce Census Bureau publications RECOMMENDED INTERIM PROCEDURES FOR ASBESTOS BRAKE AND CLUTCH SERVICING for Occupational Safety and Health NIOSH has The National Institute brake and clutch research underway concerning dust exposures during asbestos data demonstrating significant servicing Due to preliminary presently used brake and clutch servicing techniques are exposures during alternate techniques whereby asbestos exposures NIOSH has reviewed fol owing recommended by NIOSH to reduced The following are interim procedures minimize dust exposures asbestos shall be designated for all brake and clutch 1 If possible an ar ie na to this area shall be posted with an son repairs Entrances exposure warning sign as follows Asbestos Do Not Breathing Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Remain in Area Unless Your Work Requires It Asbestos Dust May Cause Asbestosis and Cancer either single use . brake servicing an air purifying respirator the Mining we 2 During particulate filter as approved by or with replaceable Administration formerly Bureau of Mines or Enforcement and Safety starting with the removal NIOSH shall be worn during all procedures During manual clutch of the wheels and including reassembly removal and cleaning e shall be worn during such a respirator instal- servicing and housing assembly and during em of the clutch pressure plate we lation of the new clutch assembly cleaned from brake drums brake backing plates 3 Dust shall first be an industrial type vacuum brake assemblies and clutch assemblies using 99 efficiency with a high efficiency filter system cleaner equipped After vacuum cleaning any remaining until for 0.3 mdiameter aerosols soaked in water and wrung dust shall be removed using a rag shall compressed air or dry nearly dry Under no circumstances brushing be used for cleaning an approved respirator as 4. During arcing and riveting operations Grinding arcing machines e described in 2 above shall be worn such that worker et shall be provided with local exhaust ventilati1o9n76 OSHA asbestos em maintained at least below the dust bag of the exposures are At a minimum the et standard 29 CFR 1910.1001 with the hose of the high nee machine shall be removed and replaced arcing tebe vacuum described in 3 above efficiency industrial Rene ene we -2- . 5 Industrial vacuum cleaner bags containing asbestos dust and cloths used for wiping brake and clutch assemblies shall be scaled in plastic bags and labeled with the following warning label printed in letters visible and legible of sufficient size and contrast to be readily Caution Contains Asbestos Fibers Avoid Breathing Dust Breathing Asbestos Dust May Cause Asbestosis and Cancer j All asbestos waste asbestos regulation bags an approved worn shall be disposed of in accordance with the OSHA 29 CFR 1910.1001 During removal of vacuum respirator as described in 2 above shall be where brakes and clutches are repaired 6 All floor cleaning in areas cleaner as shall be done with the high efficiency industrialmachvianceusum shall also be described in 3 above Grinding arcing and remaining dust wiped with a cleaned with such a vacuum cleaner any described in 2 above shall damp cloth An approved respirator as be used during this cleaning should minimize any 7 Although adherence to the above procedures that the appropriate contamination of work clothing it o isn rasebqeusitroesd 29 CFR 1910.1001 3 portions of the OSHA regulations etc. be followed and ) concerning special clothing change rooms to the above procedures should minimize exposures NOTE Strict adherence These are interim recom- to mechanics during brake and clutch servicing results of ongoing NIOSH mendations and are subject to revision pending . research - Code of Federal Regulations was formerly 1910.1001 of the the Federal Register May * Section Section 1910.93a This change was noted in 28 1975 Division National Prepared By of Field Studies and Clinical Investigations Institute for Occupational Safety and Health Cincinnati Ohio eter be alr 20 determined by Hj^ method mes scribed a parapraph 6 of this section c Methods of compliane -- n- gineering methods 1 Engineering controls Engineering controis such as but not limited to isolation enclosure exhaust ventilation and dust collection shall be used to vitet the exposure limilis prescribed in paragraph b of this section ii Local cxhaust ventilution 0 Local exhaust ventilation and dust col- lection systems shall be destrued constructed Installed and mintelond in accordance with the American National Standard Fundmentals Governing the Design and Operation of Local danst Systems ANSI Z9.2 1971which is in- corporated by reference herein b See 1910.6 concerning the svall- ability of ANSI Z9.2-1971 Wiu the maintenance of a historic Ble tii connec tion therewith The address of the Amer- icon National Standards Institute is given in 1910.100 i Particular tools All hai crated and operated tools which may produce or release asbestos fibers in excess of the exposure Units pre- scribed in paragraph b of this section such as but not lifted io saws corers abrasive wheels and drills south south pe vided with local exhaust ventilation ventilation sv.tems in accordance with subdivision 11 of this subparagraph 2 Work practices- Weintetida Weintetida Insofar as practicable asbesta sill handled mixed applied remored oh scored or otherwise worked in s wr stato mufficient to prevent the emision of airbone fibers in excess of the ex- posure limits prescribed in paragraph paragraph paragraph b of this section unless the uerfutur a of the product would be dinwalsi eu 1910.93a Asbestos a Definitions For the purpose of this section 1 Asbestos includes chrysotile amosite crocidolite tremolite anthophyllite and actinolite 2 Asbestos Albers means asbestos fibers longer than 5 micrometers b Permissible exposure to airborne concentrations of asbestos bersStandard effective July 7 1972. The hour weighted average airborno concentrations of asbestos fibers to which any employee may be exposed shall not exceed five fibers longer than 5 micrometers per cubic centimeter of air as determined by the method prescribed in paragraph e of this section 2 Standard effective July 1 1976 The hour weighted average nirborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed two fibers longer than 5 micrometers per cubic centimeter of air as determined by the method prescribed in paragraph c of this section 3 Cciling concentration No em ployce shall be exposed at any time to airborne concentrations of . asbestos fibers in excess of 10 fibers longer than 5 micrometers per cubic centimeter of thereby 1 Particular products and opere- tions No asbestos cement moris - conf ing grout plaster or slinfier maloras~- containing nabasios shall be a move from ens cartons or other cal in which they pro shipped withou b oither weited or enclosed or ve <3 so as to prevent effectively the release in airborne asbestos fibers in excess of the limits prescribed in paragraph b this reation GD Spraying demolition or removal Employees engaged in the spr * asbestos the removal or demolicion demolicion c+ pipes struchaume or eculptent cove ed or inmated with asbestos.wo asbestos.wo asbestos.wo asbestos.wo ranoval or demolition of asperios insulation of cavoungs shall be provkinfl with respiratory eq.ipment in schord- schordance with paragraph d 2 HD of this section and with special clobin in seconvence with paragraph d of tida section d Personei profestive squisimani 1 Corapliance with the exposa linots premaribed by paragraph b of this section may not be achieved by the use of respirators or swift rotation of 941- ploveca cncept 1 During the the period neccss37 to i institute cagineering controls and to institute the work practices required by paragraph c of this section FEDERAL REGISTER VOL 39 NO THURSDAY JUNE 27 1974 ee i} RULES AND R c No employee shall be assigned to 2 Personol monitoring Sam-- acy) In work situatious in which the the use of respirators it ples shall be coliccted from within the mrothods pr^scribedin paragraph c of technically not tasks requiring b sedupon his most recent examination breathing zone of the employees on merabrane filtern of 0.8 micrometer po- this section are either feasible or feasible to an extent insufl- an examining physician determines that will be unable to function function rooted rooted in an open fitor shall be taken for the clent to reduce the airborne concentrafibers below the limits the employee normally wearing a respirator or that holder Samples of the houI time- tions of asbestos prescribed by paragraph b of this the safely or health of the employee or other employees will be impaired by his determination weighted average airborne concentra of section or use of a respirator Such craployed shall tions and of the ceiling concentrations iii In emergencies be rotated to another job or given the asbestos fibers iv Where both respirators and per- to transfer to a different po- D Sampling frequency and patter13 sonnel rotation are allowed by sub,, livi- opportunity duties he is able to perform After the initial determinatious required sions 1 it or iD of this subpara- sillon whose with the same employer in the same geo- by subparagraph 1 of this paragraph samples shall be of such frequency and guaph and both ard practicable personnel rotation shall be preferred and used graphical area and with the same senior- pattem as to represent with reasonable 2 Where a respirator is permitted by ity status and rate of pay he had just prior to such transfer if such a different accuracy the levels of exposure of em- In case shall the sampling be subparagraph 1 of this paragraph it shall be selected from among those np- position is available 3 Special clothing The employer ployees no done at intervals greater than 6 months to asbestos proved by the Bureau of Mines Departof the Interior or the National In- shell provide and require the use of special clothing such as coveralls or similar for employees whose exposure muy reasonably be foreseen to exceed ment stitute for Occupational Safely and clothing head coverings the limits prescribed by paragraph b whole body Health Department of Health Educe- gloves and fool coverings for any em- of this section } tou and Welfare under the provisions of ployer exposed to airborne concentra- 3 Environmentai monitoringof 30 CFR Part 11 37 F.R. 6244 Mar. 25 tlons of asbestos ^...berswhich exceed the samples shall be collected from asens asens 1972 and shall be used in accordance ceiling level prescribed in paragraph b a work environment which are represent- with subdivisions 1 ii iil and iv ative of the airborne concentrations of . of this subparagtank of this section rooms 1 At any fixed asbestos abers which may reach the Air purifying respirators A reuse- 4 Change place of employment exposed to airborne in ex- breathing zone of employees Sammics shall be collected on a membrane tille ble on single use air purifying respirator respirator described in subdivision concentrations of asbestos fibers limits prescribed in of 0.0 micrometer porosity mounted in or a 11 or ii of this subparagraph shall ccss of the exposure paragraph b of this section the em- for an open filter holder Samples shai be taken for the determination of the is- head head to reduce the concentrations of ployer shall provide change rooms airborne airborne asbestos fibers in the respirator in employees working regularly regularly at the place The employer hour weighted average concentrations and of the celling co - below the exposure luniis prescribed b of this section when the li Clothes lockers con- contrations of asbestos fibers paragraph .30 cellia or the hour weighted avor- shell provide two separate lockers or tainers for each employee separated II Sampling frequency and peth ns the initial determinations required required age abnorme concentrations of ashxaton reasonably expected to excer or isolated as to prevent contamination street clothes froin bis After by subparagraph ) of this pricavi ubers ace thien 10 times those limits of the employee's samples sbell be of such frequenes and no oir work clothes patiem as to represent with consonnoie * Powered air nmifying respiretora ii Laundering a Leundering of the levels of exposure of the A full facenere powered air purifying Asbestos contaminated clothing shall be accuracy In no case shall samplbie be cator or a powered air purifying described in done so as to prevent the release of airfibers in excess of the ex- employees at intervals greater than 6 months for as 1094027 or respirator dipaivision Hip of this subparagraph bere asbestos posure limits prescribed in paragraph b employees whose exposures to asbesto may reasonably be foreseen to exceed Jac be nad to reduce the concentre- of this section of asbestos abers in the the exposure limits prescribed in pac- tion airbome 5 Any candloyer who gives asberlos- asberlos- graph h of this section - esator esator below the exposure limits pre- contaminated clothing to another paison 4 Employee observation of monitor seibed in porcieph b of this section for Inundering shall infora such person ing Affected employees or their rep when the weighted coin average or the hour timeconcentrations of the requirement in c of this subdivision to effectively prevent the relceco resentatives shall be given a ressonante to obrorve any monitoring asbestos fibers are reasonably expected of airborne asbestos fibers in excess of opportunity and shall have to exceed 10 times but not 100 times the limits prescribed in para- required by this paragraph those limits exposure access to the records thereof graph b of this section g Caution signs and labels 1 Cau- ii Ture C supplied respirators c Contaminated clothing shall be fior signs i Posting Caution signs continuous flow or pressure class A type C continuous flow or pre--- transported in sealed impermeable bags other closed imperiveable containers shall be provided and displayed at ench where airborne concentrations concentrations demand supplied respirator or and labeled in accordance with parn- location ^ bers be in excess of the shall be used to reduce the concentra- of ashestes may Mons of airborne asbestos fibers in the graph g of this section oxposur Umits precoribed in paragraph respirator below the exposure limits pre- e Method of measurement All do- b of thin section Signs shall be pouled scribed in paragraph b of this section terminations of airborne concentrations of such a distance from such a location the celling or the hour time- of asbestos fibers shall be made by tho so that en employee may read the Highs when airborno concentra- membrane filter motbed et 400-460 and take necessery protective steps be- weighted average objective tions of asbestos ^...bers are reasonably magnification 4 millimeter fore entering the area marked by the expected to exceed 100 times those limits with phase contrast Wuminetion signs Signs shall be posted at all ap- iv Establishment of a respirator pro- E Monitoring- Initial determi- proaches to areas containing excessive gram a The employer shall establish nations Within 6 months of be publi- concentrations oi airhome ashaston a respirator program in accordance with ention of this section every employer fibers the requirements of the American Na- shall cause every place of employroont 1 Sian specifications The warning tional Standards Practices for Respira- where asbestos fibers are released to bo signa required by subdivision i of this tory Protection ANSI Z83.2-1969 which monitored in such a way as to determine subparagraph shall conform to the rc- Is Incorporated by reference herela whether every employee's exposure to quirements of 20 x 14 vertical format b Sec 1910.6 concerning the avail- asbestos fibers is below the limita pre- signs specified in 1010.145 4 ani this subdivision The signs shall dis- ability of ANSI Z88.2-1969 and the main- scribed in paragraph b of this section If the limits are exceeded the on1- to play the following legend in the lower tenance of an historic file in connection therewith The address of the American ployer shall immediately undertake a with panel with letter sizes and styles of a visibility at least equal to that specified National Standards Distitute is givon in compliance prograin in accordance $ 1910.100 puragraph c of this section in this subdivision FEDERAL REGISTER VOL 39 NO THURSDAY JUNE 27 1974 RULES AND REGULATIONS 23545 Legand Asbestos Seen we a sen eennew an Dust Hazard ....-.. ~ Nolation " Bann Sori Gothlo or Block Sans Serif Gothio or Block paragraph which indicates the employco's own exposure to asbestos Obers 3 Employee notification Any einployce found to have been exposed at any time to airborna concentrations of asbestos fibers in excess of the limits pre- Avold Breathing Dust___ ... Gothic scribed in paragraph b of this section Wear Acsigned Protectivo Equipment Do Not Remain In Area Unless Your Work Re- quires It Breathing Arbestos Dust May Be Hazardous To 4 Gothic ... Gothic 14 polat Gothic shall be notified in writing of the exposure a^ soon as practicable but not later than 5 days of the finding The employee shall also be tunely notified of the corrective action being taken 1 Medical examinations- Gen- Your Health eral The employer shall provide or mako Spacing between lines shall be at least equal to the height of the upper of any two lines 2 Caution labels- Labeling Cantion labels shall be aftred to all rev materials mixtues scrap waste debris and other products containing asbestos fibers or to their containers except thei no label is required where asbestos fibers have been modified by a bonding agent coaling binder or other material so that during any reasonably foreseeable use handling storage disposal processing or transportation no airborne concentrcaoncen-tra- tions of asbestos fibers in excess of the exposure limits prescribed in paragraph b of this section will be released available at his cost medical examinaLions xlative to orposure to asbestos required by this paragraph 2 Prepincement The employer shall provide or make vellable to each of his employees within 30 calendar days following his first employment in en occupation exposed to sirborne colcontrions contrions of rsbestos fibers a comprehensive medical oxamination oxamination which shall include as a minimum & chest roentGogom postcrior 14 x 17 aches a history to elicit symptomatology of respiratory disease and pulmonary function tests to include forced vital capacity PVC and forced oxpiratory volume of 1 second FEV 3 Annuc examinations On or be- il Lavel specifications The caution for Jouuery 51. 1973 and at least an- lobels required by subdivision i of this mually thereafter every employer shall subparagraph shall be printed in letters of sufficient size and contrast ns to be readily visible and legible The label shall state provide or make cvailable comprehenolve medical examinations to each of his emvioracs edin edin occupations exposed to airborne concentrations of as- CAUTION Dostow Abors Such annual examination Contains Asbeston Fibers Avold Creating Dust so include a minimun a chest 10migenogram posterior 14 x 17 Inches , 8 Motory to elicit symptom- Breathing Asbestos Drush May OMIS Geriona Body Form atology of spinatory disease and pulmory Suction bests to include h Housekeeping- Cleaning AG external surfrees in suy place of employ ment shall be maintained free of accu- mulations of asbestos fibers if with their " dispersion there would be an excessive concentration forced vital capacity PVC and forced ry volume of 1 eccond FEVL 4 Termination of employment The employer shell provide or mako ovaliculo within 30 calendar days before or after the termination of employment of 2 Waste disposal Asbestos waste scrap debris bags containers equipment and asbestos contaminated cloth- ing consigued for disposal which may produce in any reasonably foresceable use handling storage processing disposal or transportation airborne concen- trations of asbestos fibers in excess of the exposure units prescribed in paragraph b of this scrtion shall be collected and disposed of in sealed impermeable bags or other closed inpermeable containers i Recordkeeping1- Exposure rec- ords Every employer shall maintain rec- any employee engaged in an occupation exposed to airborno concentrations of asbestos fibers a comprehensive medical examination which shall include as a minimum a chest rentgenogram posanterior 14 x 17 inches a history to elicit symptomatology of respiratory discose and pulmonary function testa to include forced vital capacity FVC and forced expiratory volume at 1 second FGV ) . 5 Recent examinations No medical examination is required of any employee If adequate records show that ords of any personal or environmental monitoring required by this section Records shall be maintained for a period of at least 3 years and shall be made available upon request to the Assistant Secretary of Labor for Occupational Safety and Health the Director of the National Institute for Occupational Safety and Health end to authorized representatives of either the employe has been examined in cccordance with this paragraph within the past year period 6 Medical records Maintenance Employers of employees examined pursuant to this paragraph shall cause to be maintained complete and accurato records of all such medical examinations Records shall be retained by employers for at least 20 years 2 Employee access Every employee and former employee shall have reasonable access to any record required to be maintained by subparagraph 1 of this 1 Access The contents of the records 07 the medical cxaminations required by this paragraph shell be made available for inspection and copying to the Assistant Secretary of Labor for Occupational Safety and Health the Director of NIOSH to authorized phyalclans and medical consultants of either of them and upon the request of an cmployee or former employce to his physician Any physician who conducta a medical examination required by this paragraph shall furnish to the employer of the examined employee all the information specifically required by this paragraph and any other medical information related to occupational exposure to asbestos fibers FEDERAL NEGISTER VOL 39 NO THURSDAY JUNE 27 1974 A yaaa