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, puuwm I* EKMKr _ s:.\.TjAi3s iwsnrjTi, n-:c., 1.210 rout: 4, pasascjs,;; w Airsm. ^i::c of cht F.lICTU.' tygiu; STANDARDS EBTITra. IMC. \- "tdaejday and Thursday, Juss 27 aad 28, 1973, 8:30 a. !{. at Lodge at Vail, Vail, Colorado issns PRESET Rg?8ESE.TA?!VgS Ah ex Corporation R. Cutler Auto Friction Corporation Stuart Cosine Iandi.< Corporation ' friction Materials division ?. . !lessiar Drassbestos Manufacturing Corporation W. Simon Carlisle Corporation Molded Materials Division E. R. Zacharlas Catha Corporation F. T. Catke Central Motors Corporation Delco-tloraine Division ' R, J. Kid Marenont Corporation Grizzly Brake Division J. W. Greenes Molded Industrial Friction Corporation M. I. Frazier Paybestos-Manhaccan, Inc. D. E. Gou foyal Industries Brake Products D. Ogilvie Scandura, Iae. (Centex) D. Easveld Scandco, Inc. J. S. Allen 5. IU Wellman Corp. J. E. Clegg 'heeling Drake Block Manufacturing Co. 1. Purges* World 3estos Company, Division of the Firestone Tire & Rubber Compeny C. Debar 3TK3S PRLS37 f 4 Abe* Corporation P. E. iielaon Auto Friction Corporation H. Couins Gatkt Corporation H. Boyle General Motets Corporation Delco-tloraine Division R. E. fottsrins tlareaont Corporation Grizzly Briko Division D. Carlson F. Skelton A. Laus Molded Indus trill Friction Corp. B. Ozaore Raybcstos-Kanhattan, Inc. R. R. iloalli Royal Industries Braks Products W. M. Slatch C. Wove11 S. Z, Wellman Corporation G. A. Cerrigan Wheeling Drake Slock Manufacturing Co. G. Stratton World Bestos Romany, Division of the Firestone Tire & Rubber Company - R. Alleasn Friction Materials Standards Institute W. Drlslaae Sticklas, Kennedy i Van Steenburgh L. 2. Stickle* 'M ea o .uai r Jvxe : vas ncted that the Treasurer's "o^ort was mace us durinc che first week of June 1573, and the June 30, 1573 figures had to be estiaated based on anticipated Jme expenses and the fiseal year-end accruab. In summary, che Tinancial jcaterents shewed ante than $100,000 in savings accounts and time deposits, and over $20,000 in Hiss Duschekb Retirement Fund. The Institute operated during the 1572-73 fiscal year with a net incone in e::cess of $10,000. It was noted in the 12 year Susstary of Financial highlights', that an Active fierier in 1961-62 with one category had an annual fee of $300. In the same year, a Regional Merrier paid a total of $1,300. 3y 1372-73 an Active Merrier with one category was prying $1,700 in annual dues whereas a Regional Met;er was paving $1,300. In other words, the Active '.'.ember was paying In excess, of 100Z more in 1572-73 than he was paying in 1961-62. The Regional Member had been increased only 302, from $1,200 to $1,300, during the same period of time. Til ere were similar disparities concernin'* the increase in dues vith Fa pional Associations and Licensees. Tpon motion duly made, seconded and unanimously passed, it was / RESOLVED: To accept the Treasurer's Report as read. ASBESTOS STUDY COISITTZE REPORT ' Hr. 1. R. Weaver. Chairman of the ,a:bstos Study Commietee, vu present^ to deliver a talk to the Membership concerning asbestos problems!* tbs friction nsterlals industry. Mr.*WesverJhad submitted'*Written Yeporr summarizing his Committee's activities during the 1972-73 fiseal year. Mather chan report strictly on the activities of the Consittee, lir. Weaver had been ashed to deliver a calk concerning the background and seriousness of the Mbeern* rjui4rt,jiu n they concern the friction materials industry. Mr. Heaver's Report"on the Asbestos Study Comaittee'i'ccivities Is IjCilSIIzlA: In addition, the address that Mr. Heaver',gave to che Membership at the June 27 Meeting is shown as EXHIBIT 14.1. fir. Weaver discussed some of the background for the 0RW\ md the EPA regulations. In particular, he pointed out that cha CSJ1A label requirement was considerably leas severe than that originally reeomaendad by the OSHA Advisory Committee. Mr. Weavtr particularly recomsended compliance with the spirit of thtOSBA regulations and. suggested chat if industry does not shor a vil^ngnsss to eosiply vith salsting regulations that the consumer activist groups sad organized labor may push for evta harsher regulations. Et also diseussad the EPA Emissions Standards which again ha found to be reasonable and attainable. Mr. Weaver closed his discussion indicating that tha Asbestos Study Consdttae would continue to keep on Cop of the regulations emanating from Washington. Mr. Weaver answered some questions at the end of his talk. One question had to deal with the accuracy of the mahrane filter method for measuring concentrations of airborne asbestos fiber. Mr. Weaver replied that it is* very difficult to get accuracy into this method. It takas considerable training, and even vith the training different operators will have different Annual ."sstir.e June 27-22, 1373 readings. '.'hila ire Indicated th*t there are definite problems vich the membrane filter aathod as regards enforcement purposes, it is a tool for the sanuiacturer to use in sectoring his wore areas. Hr. Veaver Eentioned tha^the Germans have been working with, a graviaecric system. A probler. is the fact that all airborne-materials ir. a friction caterials factory are not necessarily asbestos, and that the gravimetric system does not distinguish between asbestos and other caterials. Mr. ''eaver fait that any new system to replace the rarbrane filter method is fsr eff in the future. !. Member asked concerning the E?A emissions requirements where they are in effect legislating dty collectors over wet collectors. The question vas '!hy." Hr. Heaver replied that the wet collectors require very high horsepower to reduce the visible emissions to zero. In essence, It is very difficult to get "no visible emissions" with a vet collector. . Another question concerned clothing and the OSEA regulations. It vas pointed out that several manufacturers use an outside cleaning service fer the clothino that is worn in the work araa, Mr. Weaver emphasized thac the manufacturer should specifically notify the people doinn the cleaning that this clothinq is used in an csboscos handling vori: area. * Ancthsr question had to do with the recommendation that Hr. leaver aade that all-boxes or cartons containing friction materials have the OSUA label..,laprinted -thereon. In this case, the question concerned a drilled taper ground brake lining set ready for installation on shoes. Sid this require the CSuA libel, since it vas most likzly that there would be no subsequent drilling, cutting, or grinding to put asbestos dust into the attesphera? Mr. Weaver suggested that thare is always the possibility of-additional cutting, drilling, or grinding and that he felt the Gb'HA label.should be used hers also. Hi:- point ii that in these subseouent operations the asbestos can be raised to levels above the 5 fiber per cc lini: in the CS2A standards. This will be even store of c problem vhen the standard: drop to 2 fibers per cc. Mr. Weaver felt the OS'lA regulations lcdlcate that if thers sav be subsequent operations, the label should be used. upon station duly tsade, seconded and unanleously parsed, it vas PISDtVS: To ececpt the report of the Asbestos Study Commute* as presented. ;g3E83i? cmnng kpopt Mr. F^ank L GacUe reported on the activities of the ;i*ii>:*hip Committee during the l'J72-73 fiscal year, lee EXHIBIT 2, In suimary, Mr. Catke's Report shewed the following changes in Mesbership in the Institute: -1AS3MTCS .`u.D US miCTIQ:: "ATP.LM IiBPSTRY Mr. I. if- leaver of Raybestos-Uanhattan, lac., who serves as Chairman of the frictioajliri i Inis firm lirnti Inform;; e>,,,<T Committee addressed the&mual Membership Meeting of the Iascituiev^ Mr. Weaver's address was defiveilM lfi ^aZT7 Colorado oa Wednesday morning, June 27, 1973. Mr. Weaver's address follows: When id (Jrislane) asked me to attend your annual meeting last year, I had to decline, which may have been just as well in view of the confused status of both 0S3A and EPA regulations at the tine. This yeas things are only slightly less confused, but I am glad to be able to be here anyway to attempt to fulfill ay responsibilities in reporting to you as your Asbestos Study Committee Chairaan. lather than present a detailed statement covering Committee activities for the year, I should like to use my cine to review some of the more controversial and confused elements. of the Federal Asbestos Regulations, ani give recorendanions as to what I think the stance of the Friction Materials Industry should be in regard to then. In. lieu of a detailed report covering the past year's activities,. Ir have prepared a page and a half sumamary of the Committee's work from ^ June '72 thru June 1, 1973. Mr. Dzislane will circulate copies of this surnry to anyone who may be interested in it, and if any of yon have questions or recommendations concerning our past work or future Intentions, please feel free to bring thea up here, or if you prefer, transmit thea to Ed for our review later. Probably the single aost significant event that occurred during the past year on the subject of asbestos hazards was the meeting of the International Agency for Research on Cancer that was held at Lyon, France last October. This meeting was attended by oore than a hundred , and thirty medical researchers and representatives of governaent, industry and labor from virtually every aajor asbestos consuming or producing country 'in the world. For four days intensive sessions on asbestos were held by three different panels, each made up of ten to twenty-five of the foresost medical and scientific experts operating in the various fields of asbestos-health research. Following the meetings the comaittees issued a combined report on asbestos cancers. I think the following five items summarize their most important conclusions: (1) All major commercial types of asbestos can cause cancer. (2) Evidence suggests that excess lung cancer is not detect able when occupational exposure has been low. (Just what is meant by ''low'1 was not stated.) rvuiaiT 1/..1 0' f Asbestos and The Friction :tacerial Industry (cont'd) (3} Evidence has been greatly strengthened that all cotmserrial types of asbestos except Aachophyllice may be respon- . sible for mesocheUoma. (Risk is greatest with CrocidoU.ce, less vith Ascsite, and apparently still less with Chrysocile.) . (4) Cigarette sacking is an Important factor enhancing lung cancer risk in asbestos workers. (3) Surveys of occupational groups have shown a small excess risk of types of cancer other than bronchial and aesothelial, especially those of the gucro*intestinal tract. Ae most ii?ortanc itea here is the incrimination of all major types vof asbestos as causal agents for carcinona, particularly nuotheliona. Kost of the other items only confirm or substantiate previous conclusions Since most of us use substantial assists of Chrysotlle asbestos in. our formulations, association of this naterial vith aesotheliona and otha.* types cf career is of serious concern. , A nutber of individuals vho attended the IRAC meetings cane away with the definite i&prosslon chat government recognition of asbestos hazards has been accomplished and henceforth should be taken for granted. We can now look to the next major effort being geared toward worker educa tion regarding occupational health hazards. The Occupational Safety and Health Act reouires information he given by employers to workers concerning the degree of their exposure along vith instruction in ways for minimizing exposure. Therefore, it is incumbent on allemployera whose vorkers handle or cone in contact with asbestos-containing materials to provide some kind of instruction or training to educate the vorken concerning potential hazards and means of avoiding them wherever posalble. Accordingly, it would be ptudent for all friction materials manufacturers to develop programs to assure adequate com . mmieation with their employees regarding asbestos dust hazards, and to inform them of monitoring results, good votk practices, and their responsibUties in complying with OSEA regulations. If such measures are not taken promptly and properly by management,industry will leave itself 'ride open for intense, and in my opinion Justified, criticism by organized labor, as well as potential severe enforcement action by government, and attack by any number of social and environmental activist organizations. If ve don't do this ourselves, be assured that someone else will jump on the bandwagon aad do it in a way that will not be to our benefit. We can expect more and sore ' activity by organized labor coward educating and training vorkers regarding health and safety problems aad in pointing out to workers vhat their employers' respocsibiUties are concerning these matters. .. i -3- /Asbestos and The Friction liaterial Industry (cont'd) llauy union activists .are really furious with government's failure to pursue the provisions of safety and health regulations to the letter, and there appears to be a good opportunity for industry to release reliable inforaatlon concerning asbestos hazards both to their employees and to their customers before more inflammatory information of this type is aired in the media under organized labor's banner. These rules and regulations pose ouch more severe problems for ocher segments . of the asbestos industry, particularly asbestos textile manufacturers, than they do for most friction material manufacturers. I have been involved in asbestos products manufacturing for over twentyfive years and have visited dozens of plants and am aware of only a few . friction materials products manufacturing operations that I consider to represent major problems in achieveing conformance to either OSHA or ETA requirements, including the 2 fibre per ce cbereshold limit value. Since significant polarization may be expected always to exist between management and labor and between management and environmental groups concerning asbestos-health subjects, and since control or conformanceto bocn EPa and OSSA regulations appears to be generally feasible, as . far as friction materials are concerned, ay recommendation to friction naterial manufacturers Is chat they proceed as rapidly as possible towards conformance with the regulations. Also I recoomd avoiding inclinations to misinterpret provisions where the intent of eh* regulation is dear, but the wording may be subject to quest!on. Iher* has been considerable disregard of a number of provisions mainly in the areas of labeling, monitoring, employee education, personal pro tection, waste disposal, and use of warning signs by segments of . asbestos products manufacturing, and I believe this applies to friction material to some extent. One of the most obvious items has to do with industry's reluctance ea accept asbestos products labeling as required by OSEA. There has been much advertising of asbestos textile products citing the benefits of -treatments or coatings that purport to lock the fibre into the produce In such way that it cannot become airborne during use. While these claims probably are true to varying degrees depending on the nature os the product, its use, and the way is which it is handled, I do not think this claim is at all applicable to friction materials. ' t know of no way any of us can be absolutely sure that his friction products, regardless of whether they are sold as original equipment o; on the'replacement market, will not be subjected to additional operations or alterations in the field that could result in excessive -exposure of workers or bystanders to airborne asbestos fibre. I have been appalled to learn of a number of instances where this problem has occurred, and some of these cases involved people that certainly might have been expected to know better. -4Asbestos and The Friction '"iacerial Industry (cont'd) If this kind of thing occurs in fabrication operations of major OE customers, it appears to oe there can be no argument about the need foSa^lUlUS^mi measures 'to reduce chances of unnecessary exposure 'luring grinding! drilling or cutting operations. To chose who argue `^Sac,T3tieTS?,or other types of warnin'; need not apply to replace ment materials because fabricators or appHers handling replacement quantities are exposed relatively intermittently, I say emphatically this just ain't necessarily so! Largs volume replacement users * present major potential hazards, and even small job shogs_caa needlessly jxgose_c2la_gjilgk_fjhrj_ccncentn^on3 n operations are pertoraeT I Jwithout controls. That these mar be intermittent and of short duration does not preclude possibility for occurrence of advene health effects in byper-stacepdble individuals, or in less sensitive individuals who may recaive exceedingly high doses of short duration bat who may ba smokers, or who may experience effects because of synergism with other materials to which'they may ba exposed either at work or elsewhere. To me, labeling all coatainars or packages of asbestos-containing friction material la tha very least the industry can'do to fulfill* moral obligation to its custoean, their employees, and the publle and at the sa&a time.conform with minimum requirements of die j Occupational Safety and Health Act. ' I seriously question whether mere labeling is enough to fulfill this requirement. It has been suggested by others as well as myself several times in tha past that additional instructions, of a more comprehensive mature than is practical to provide on a label, be inserted inside each package where a possibility exists that the product might be osed in such manner that an airborne dust problem could be created. A nuaber of responsible asbestos products manufacturers already are following this procedure, and there is a good possibility that It may be made mandatory in future regulations. - ' .Adoption of these measures by Industry would show good faith tward cop Hanes and" should'reduce possibilities of future criticism by consumer protection groups. 1 doubt very much chat it would have any significant effect on sales or consumption of asbestos friction materials. I know of no substitute for asbestos in normal automotive friction material service, and I know of Httle or no noticeable effect labeHng has had on other products where cautionary labeling has been used thus far. Keep in mind that NIOSH and the OSIIA Advisory Committee recommended a cuch more severe label than the one ve are talking about. This Subject was heatedly debated during the OSUA Advisory Committee deliberations, and their final recommendation called for use of >che word "Danger" instead of-"Caution" and specifically mentioned that breathing asbestos causes cancer. Very frankly, I was exceedingly Asbestos and The Friction Material Industry (cont'd) surprised when the final OSHA Standard case out in favor of consider ably slider working, Mow I an perplexed that Industry resits the OSHA labeling requirement as vigorously as it does. Many ocher elements of the OSHA Regulations came out more favorably toward Industry than the recommendations that were submitted by NIOSS and the Advisory Committee, and stiff resistance by Industry will be needed to prevent OSHA from strengthening the regulations in months to cone. Ue can expect considerable effort to be made by anti-industry elements of the medical profession, by organized labor, and by environmental groups who want the airborne standard lowered from 2 fibres per cc to 1 fiber per cc or even less. Some individuals even speak.of asbestos in terms of zero TL7, which, of course, is completely impractical and would result in virtual banning of mining and use of asbestos for anything. . Another controversial subject is fibre monitoring. This is pretty ouch of a disaster area because of lack of confidence in the membrane filter method lor sampling and analyzing fer airborne ccbestes. Much of this problem is attributable to the nature of the operation, which Involves considerable judgement in addition to technical competency on the part of the people performing the tests. Even when performed by practiced individuals under the best possible conditions, the method Is subject to wide variations in results. Heedless to say, vhen performed by relatively inexperienced personnel under the widely varying conditions that exist in the field and between different laboratories, results can be extremely variable. In my opinion, the method Is not at all suitable for enforcement purposes, but can be used to good advantage by industry for policing its own operations and for determining where to devote control efforts with maximum advantage or potential for improvement. ' In spite of its deficiencies, I think the mensrane filter method will persist for quite some time, but I will not be at all surprised if future emphasis by OSHA shifts reward work practice regulations rather than monitoring to a numerical standard. Another controversial item has been the protective clothing - require ment. This has created considerable question and controversy, particularly in the textile industry where ceiling limits are difficult to control on certain operations. Different OSHA regional offices have applied different interpretations to the protective clothing requirement, and it's hard for me to see how some of then can be as liberal on interpretation as they are. ' The regulation specifically calls for full body cover including ;loves, hat,, and foot covering, where levels exceed the ceiling -$ Asbestos and Hie merlon Ilatarial Industry (conc'd) lisle. Is spite of cliis, certain 0SI7. regional offices take the position that any protective clothing, even as scanty as a short sleeves shirt and trousers, is adequate, provided this clothing Is changed before the eoployee leaves the plant. Personally I believe this lenient interpretation provides effective protection for oosc ' exposures, and I concur that the important thing is to sake sure the employee doesn't take the contaminated clothing out of the plant. Other OSHA offices stick to the letter of the requirement, which creates a major problem on many operations 'Aert discomfort from full cover clothing can have a very significant effect on operator efficiency. This requirement is under vigorous attack by companies that are having problems with it. i.'o doubt some judgement by the Occupational Safety and Health Review Commission or the Federal .courts will be forthcoming concerninc this element of the regulations, and lc is to be hoped that future revisions of the rule will permit more flexibility than the existing wording does. Waste disposal has created problems r.lth both OSHA nad ETA result- tiens, and some friction material manufacturers already have extensive facilities in the works to cope with these problems. Of particular Interest Is the pelletization of friction material waste to reduce dust to a form that avoids necessity for bagging or otherwise containerizing the material. This also reduces or eliminates generation of fugitive dust during disposal in landfills. Several manufacturers have installed extensive pelletizing systems to solve their waste disposal problems, and this approach appears to be acceptable to both SPA and OSHA as veil as state environmental control agencies. Cither approaches have been to utilize vet disposal methods end, of course, some manufacturers are bagging and labeling the dry waste, where uct methods or pelletizing are Impractical. Where bags or other container! are used for waste disposal, they should be labeled In accordance with OSilA. Medical examination requirements have presented problems, particularly the one of determining what constitutes "asbestos exposure". Some companies have adopted the attitude that all workers, Including office and research people, even though they are not normally considered to be exposed to asbestos, should be Included in the medical surveillance program. On the ocher hand, many seem to folia; the tack chat anyone exposed to one fibre per cc or less need not be Included. Hy advice would be to check everybody where there is any doubt about actual exposure. I could well at considerable length on other problems and inconsisof the ?SHA Regulations and their various interpretations, but believe I probably have expounded on this enough for the moment. However, the one main point I want to get across is chat any -7- Asbescos and The F:ic:ion '.'aterial Industry comparison of the existing regulations with industry's position as stated in their input to the government prior to promulgation of the regulation, and compared.vlth the recommendations of NIOSH and- the OSHA Advisory Cosaittee, vill readily Indicate that the existing OSHA standard, with the one serious exception of the no fibres per cc limit to be imposed.in 1976, follows industry's position rather closely. If I appear to be defending the present OSHA Asbestos Regulations, it's only because I aa very much aware of how much more strict these rules would be if the' recommendations of uIOSZ and the Advisory Committee had been foliated. I doubt that many la the Industry recognize or realize just how dose they may have coma to being regulated out of existence. Future occupational safety and health legislation probably will rectify numerous Inadequacies in present rules and may ameliorate some aspects of existing occupational safety and health standards. Hcwever, I seriously doubt that much relaxation if any is to be j expected in rrgard to the Avbestos Regulations. I think' the industry is going to have to mount a very determined effort to > ' prevent these regulations from being tightened In the future. ^ The EFA regulations concerning ambient air control of asbestos are another natter. Although it was responsible for initially tagging asbestos as a hazardous pollutant, since doing so EFA has been much less diligent in pursuing Its announced intentions toward regulation of the materials it declared hazardous. EPA first declared asbestos a hazardous air pollutant on March 31, 1971, and published proposed regulations December 7 of the same year. Hearings were held and much industry input was accepted and very deliberately reviewed by EFA before they finally issued the national Emissions Standard on April 6 of this year. This regulation was promulgated nearly a year later than called for under the requirements of the Federal Clem Air Act. For this EFA has been under considerable criticism ever since. $' In addition to-being late, the EFA standard is a lot less stringent chan 1 or any otl&ft Industry people, who have followed Its develop ment, expected. Nearly all the objections voiced by lnduscy concern ing the originally proposed standard were removed before they issued the final regulations. In addition, they modified some requirements to the extent that no one in Industry expected, or even would have had the temerity to request, in meetings where these subjects were discussed between industry representatives and EPA. .In essence, the standard boils down to the following scaterant as far as emissions are concerned: There shall be no visible emissions to outside air from any .asbestos mill or manufacturing operation except when a specified method of air cleaning, also part of the standards, is used before the emission escapes. In general, the air cleaning systems specified, filter asbestos emissions to the point that visible emissions, other than possible condensed water vapor, would not be produced anyway. -8- Asbescos and The Friction Ilacerial Industry Other requirements concerning use of tailings for surfacing roads, the regulation of demolition activities, and controlled application of spray-on materials are of little concern to friction materials processors. Our biggest concern lies with the emission standard, which will require the tightening up of dust collection facilities and waste disposal practicee wherever fugitive dust problems occur. The biggest problem with EPA regulation. I have found, thus far.has been non-uniform interpretation of what constitutes a visible emission. I know the EPA'people who drafted the regulation intended this to mean just what it'says. It It's visible under any condition vhatso^ ever, and EFA approved air cleaning systems are not in use, the emission is in violation. Since most friction materials manufacturers already are employing baghouses that meet EPA standards for cleaning their ezhaust air sereams, 1C is unlikely that any severe impact will occur to the industry as a whole on account of the EFA regula tions as they now stand. Those few manufacturers who are relying on wet dust collectors that do not meet the EFA standard may have problems. Ihe best way to be sure of meeting EFA requireneats is ' to sharpen up on maintenance end operation of existing barouse filters and replace e:dsting wet collectors with baghouse filters to eliminate visible emissions. In summary, the 0S2A and EFA Asbestos Regulations are alot more lenient than many interested and concerned parties wish. We can expect pressure to have them tightened. Friction materials manu facturers should support Asbestos Industry efforts to have them mitigated in hopes they at least aren't made more severe. In the meantime, we should conform to the regulations to protect our employees and our customers and to avoid criticism and enforcement actions.. Tour Asbestos Study Committee will continue to follow the laterpre- _ cation of easting regulations, the trend of proposed changes, and ' the development of new medical and scientific study material chat may affect future regulation of asbestos products. Tfe welcome your questions and any input you may be able Co make concerning our activities. .