Document byBKZgq30vq5RENB48Q09w6Ry

Inter Oltice Engineering and Research Stall May 1, 1980 Messrs. *Dt4>i Balter~ -jX-Ft-Dk>ek; MrPr ' J. H. Douma .. ft, f>. Faelorr W. H. Fike -- <: Mvi . Fray- v Otuieir- ^D. F. Hagen --M. H;-Hamburg- rP. C. --- U-*~ ^Er^'.-MaWey .Ogden Ji A. rfkrgr *"Jk~Wr~Potoezak ft'. ^r-OrRivard V. H. Sussman D. Velte. cc H. P. Freers GrO.-Retrtgen ^ ^ H. A. Nickol Subject: Carcinogens Task Force Report to E&R and M&S Subcommittees 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 b J. W. Durstine 8003 1591 PRODUCED BY FORD EXECUTIVE SUMMARY CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established by the Engineering and Research and Manufacturing and Supply Subcommittees to/Sdentify carcinogens and quan tities in use, set targets for diminution ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify substances systematically. The Task Force assignment responded to evidence that cancer muy be a serious occupational concern and to the Company's and public concern with regard to protection of the environ ment and public health. Additionally, the Company tins been subjected to a growing number of lows which regulate material use, transport, bundling and disposal. In summary, internal and external pressures regarding hazardous substance control und compliance have increased substantially since March, 1977, when Directive B-101 assigned responsibilities within the Company, Post Company Actions Since 1977, the Company has removed lead chromates and molybdates from paint (except special order), "Iris" flame retardant from fabrics and instituted controls on asbestos, including a Vehicle Engineering directive that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). Spraycd-on fireproofing has been asbestos-free since 1969 for new and reworked construc tion. Several manufacturing standards prohibit ssbestos as a constituent. Bqp&8Q$ cxpoftuce has been reduced or eliminated at San Jose 8nd Ventilatrbn\ was increased at Romeo to minimize haz^s^a-ffom ppint-felated chromium compounds^ Carcinogenic Substances ," <4* The Task Force^las identified snrtysnren {#rfoart>inogwt6 in use int^c-*Tomotive industry. TnuuUytiix (X>) of those are''currently regulated byOSHA^h^'*'ST7fnce have been proposed for new regulation. More resU*lC4i*^tandaKte^igYF:6g^rproposed 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 641 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 Force according to impact on the Company to identify the top eight (8). The top three of the eight priority substances, asbestos, chromium compounds and benzene, were examined in detail. Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets and for nonproduetion roofing, millboard and core/mold-making materials. Medical evidence links inhalation of asbestos dust to lung eRnccr, mesothelioma and other diseases. The present OSHA limit is 2 fibers per ce of air (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/cc as early as this year. Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links hexavalent chromium compounds to lung cancer, liver and kidney damage and other diseases. The present OSHA limit is 52 4ngTper ni of air which is proposed to be reduced to 1 tesglvn . M*** . i*, A/tbSH' if*m - Benzene oecurs^primarily in coke oven operations as a by-product. It is a residual constituent pfsolvents, primers, adhesives, lubricating oils, fuels and hydraulic 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 weighted average in 8 hours. Specific lists of bulk materials and parts for production and nonproduction use have been developed. A new computer data base is being developed. Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid identification of carcinogen applications (2nd quarter 1981). The engineering release system has been audited and is being updated to extend materials identification to all parts, jj Product Engineering Procedure PEP 3-189 has been rewritten to require systematic review of suspect carcinogens and input to the data base. 8003 1592 PRODUCED BY FORD 8G03 1593 EXECUTIVE SUMMARY " (Continued) ~ Strategy and Workplan The search for asbestos, chromium compounds and benzene defined the number of parts and 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, B - Known substitute material with major redesign and C - No known substitute or advanced engineering required. The duta is directional only. There remain many suspect applications which require time-consuming analyses for identification. _______ _____ Bulk Materials and Parts Asbestos Chromium Compounds Benzene Production /A % B i-1 ,49 C zUz Total IS- -- as - .nr/- 15 Nonproduct ion A B C Total 8 98 81 34 213 3 *r r Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three carcinogens by Job #1, 1985, in light of competitive and regulatory pressures, and Company experience. Where elimination cannot be contained, institute controls on design, process and exposure. It is judged that the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing parts and materials. For those applications requiring major redesign (Group B, e.g., drum broke linings) the elimination timetable would hove to be adjusted to reflect Company cycle plans although G.M. has stated an intent to eliminate asbestos by 1985. Finally, where no known substitute exists (Group C), advanced engineering will hove to be completed bcfore(aV)eOllimm ination timetable con 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/PPO Product Engineering Offices, Purchasing activities, Vehicle acti vities and the 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. Recommendations 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 chaired by Environmental and Safety3 EJnzg--in-e-e--ri>ng Ste/f. The 1-'esk-l Fo<rc$e?w.o*uld be discontinued. 2. Assign(ardinogeo5Program manager control responsibility to Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 6? known carcinogens for review and approval by the subcommittees. (The Task Force lias requested General Managers and Chief Engineers to recommend directional timetables.) 4. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job #1, 1985. ha rt> 5. Request that NAAO/Produet Engineering Offices end Manufacturing Staff present to the subcommittee specific action plans and timing for the Group A applications identified. 6. Provide advance program funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). 7. Adopt as the Company carcinogen listing the 67 current OSHA-regulated and proposed Category 1 substances. Establish the top eight priorities proposed by the Task Force as Company priorities. Engineering Staff - E&RS Manufacturing Staff May 2, 1980 PRODUCED BY FORD DRAFT ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT May 2, 1980 8003 1594 PRODUCED BY FORD OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT - MAY 27, 1980 Introduction Background . Post Company Actions Production - Nonproduction . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Arfonrlnr, ohi'amRjrTiytrem.uwt . Asbestos Summary . Chromium Summary Benzene Summary Carcinogen Search /m - Li^V specs. and parts Pi ,u (?Ar\ C-1 0 Identify items having no substitutes Identify substitutable items .. Elim/iatK^hen redesigned or reordered - Develop substitutes for others (advance engrg. funding) j&^vS / ^ - * & - - ' v * ^arejnogen Search Results | Carcinoger^strategies Generalized Workplan -- ------- Proposed Chemical Substances Control Proposed Priority Actions J . -Iiiat of '^OaiirtnuguL?" . MATS Appendices . Asbestos-containing parts and materials . Chromium-containing parts and materials . Benzene-containing parts and materials 8003 1595 PRODUCED BY FORD DRAFT FEDERAL AND MICHIGAN ACTS REGULATING TOXIC/IIA7.ARDOUS MATERIALS HAVING IMPACT ON THE. COMPANY FJOUItE I Regulatory Aeti Occupational Safety and Health Act - 1970 D.O.L. (OSIIA^, Hazardous Materials Transportation Act - 1975 D.O.T. (IITMA) Toxic Substances Control Act - 1976 E.P.A. (TSCA) Resource Conservation and Recovery Act - 1976 E.P.A. (RCRA) Clean Air Act and Cleon Water Act Amendments - (CAA) 1977/78 E.P.A. Michigan Act 293, P.A. - 1972 Michigan D.N.R. (MDNR) Packaging A Stacking Federal Hazardous Substances Act - 1970 Poison Prevention Packaging Act - 1970 Consumer Product Safety Act - 1972 Waste Management ^Hazardous Waste Management Act - 1979 Mich., P.A. 64 Solid Waste Management Act - 1978 Mich.. P.A. 641 / ' * Expected to be revised during 1980, to lower permissible exposure limit from present 2.0 fibers/cc to 0.5 or 0.1 libcrs/cc of air. FIGURE 2 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) Staff ESFJS Responsible Activity SSF.C-O PAO MAT MFC. STAFF SAFETY Flanl Ehgrg. Office Mfg. Engrg. A Systems Plants EARS Frog. Anal. A Malls. Engrf. Research Staff SUPPLY Trans. A Traffic REGULATORY ACT ______ _ OSHA TSCA Compliance Reporting A. /t \ Compliance Reporting Identification of Controls Monitoring 'Material InclusionV in EPA Inventory/ V------------- Enforce Controls A State Solid/ Her. Wastes Compliance Reporting Chemistry in Data Base IIMTA * DOT Label in Data Base CLEAN AIR _AJVATER Compliance Reporting Monitoring MICH [INK Compliance Reporting Chemistry in Data Rase Facility Controls Non-Prod. A Prod. Development Matts. Review Process Controls Non-Prod. Metis. Development Review Process Controls Non-Prod. Matls. Implementation Review Facility Control Implementation Develop new mails., mfg. processes. A measurement devices. production Matts. Review Disposal Meth. A Fac. Dev. Waste Chare cterization Packaging Storage Material Character t- ration Compliance Reporting Facilities Rouge ConsolDevelopment idation Process Contr. Development Permit Reporting Usage Reporting - If- 8003 1596 May 2, 1980 PRODUCED BY FORD 8003 1597 DRAFT CARCINOGENS IN THE WORKPLACE Introduction _____ __ The Task Force on Carcinogens in the Workplace was established during the 4th quarter, 11979 by joinyoction of>fne E6cR and M6rS SubcommitK-es. The Task Force Charter was to coordinate fflans and^Tforts among pdmpany activities, to identify carcinogens in use^apd climiDal. gr.-.Q.pntrjy them in future products and_ manufacturing operations. J Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the Exhibits and Appendieoc. 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 decodes 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. Public concerns relating to the control of toxic/hazardous materials, are shared by For dr* due to 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 (MAI'S) 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 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 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 Acts, a "knowing/willful" criminal violation con 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. At present the Office of^Generol Counsel has three suits pending, involving deaths allegedly due to the inhalation of carcinogenic substances. Some Workman'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. ttj Federal Register 45(15): 5031, January 22, 1980. -1- May 2, 1980 PRODUCED BY FORD 8003 1598 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 . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations -2f- May 2, 1980 PRODUCED BY FORD DRAFT PAST COMPANY ACTIONS Production Materials In response to OSH A regulations in 3 978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 3 980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977, i*-r^*prrv-XL_to an.inquiry by Numga, in response to initio) 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. vCar Engineering released a practice banning new desigas containing asbestos unless documented rationale for its use is provided and it is encapsulated! 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/cluteh 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-2C3 42 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 for Romeo for late 1980.) 8G33 1599 -2- May 2, 1980 PRODUCED BY FORD DRAFT FIGURE 4 TASK FORCE CHARTER The Task Force was chartered by E&R and M&S Subcommittees (Meeting of 10/24/79) for coordinating plans and efforts to: 1. Identify substances in use (OSMA Categories 1 end II). 2. Determine quantities used (for materials regulated by Michigan Deportment of Natural Resources). 3. Set targets for elimination of 8S many Category 1 substances as possible. 4. Take aggressive steps to find substitutes for as many Category 1 substances as possible in anticipation of government regulations. 5. Develop a policy and action plan for eliminating potential carcinogens where possible. 6. Organize to identify substances systematically. FIGURE 5 USAGE OF MICHIGAN CRITICAL MATERIALS AS REPORTED TO MATS* (ADJUSTED BY THE PLANTS IN' THEIR MDNR REPORTS) Material Acrylic Acid' Lbs. of Usage 251,707 Principal Users PPV'Paint" ` y'jf Acrylonitrile 641,133 PPV - Paint Aniline 90 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) - tCJ- yy fienzene 385,028 AAD - Dearborn Assy., Gen. Service ^ Cadmium 3,311 PPV - Vinyl yy Chromium 81,377 PPV - Paint, LED - Ypsi. Cloroprcnc 24,676 AAD - Utica Cobalt 210 PPV - Saline Copper 321,704 AAD - Dearborn, PPV - Saline, MSI) - Monroe Cyanides 923,069 MSD - Monroe " Dichlorobenzenes 2,542 FTO - Highland Park Formaldehyde 488,965 MCC, PPV - Paint Hydrezcnc 130 PPV Hydroquinonc 1 PPV - Vinyl Hypochlorite 15,841,758 MSD - Monroe yy Lead 626,027 AAD - Waync/Dearborn, PPV - Paint Lithium 123 ED - Northville, T&C Sterling y^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 Tctraclorocthylene -- Thiourea 1,095 18 AADGO, Mich. Prov. Grnd. PPV - Vinyl Triaryl Phosphate Esters 160,022 Steel, T&C Sterling Trichloroethylene 91,849 EED - Rawsonville Vinyl Chloride 118 PPV - Vinyl Zinc 1,085,724 PPV - Paint, AAD. FPSD, FTO Michigan locations not reported to MATS: Detroit Industrial Engine Research & Engineering Center Research - Glendale 1Toy - Tractor Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixon Assembly - 3f - May 2, 1980 8003 1600 PRODUCED BY FORD DRAFT 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, OSH A 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^^tf^Category 1 substances in use in the automotive indus 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 flsbootoa only aa{ffrti;l6iv.gl,377 pounds of chromium compounds, and 385,028 pounds orbenTene! ~--^ ^ ---j-. ----- */. -- Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances were examined in detail. 8003 1601 -3- May 2, 1980 PRODUCED BY FORD DRAFT FIGURE^ <o TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES Substance /^l. Asbestos Occurenee within Company Friction materials, gaskets, sealers 2. Chromium Compounds Chrome plating, paint pigments ^ 3. Benzene Sf *' Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy /' 5. Coal Tar Volatiles ^ *3enzo (a) Pyrerm, Coke oven and foundry emissions Coke oven and foundry emissions . Dmjer(a') Anthracene^ // //* 'll v K 6. tbylene^5ftkiiu>polyTn>r' Coke oven and foundry emissions Vinyl 7. Beryllium [^^fuminum foundry operations 8. Trichloroethylene 1 Degreaser Current Exposure Limits 2 fibers/cc O.-T'rng/m3 j 10 ppm 0.1 mg/m3 0.2 mg/m3 3 0.2 mg/rn 0.2 mg/m3 None established 2 PE/m3 100 ppm Co o o o - 4f - May 2, 1980 PRODUCED BY FORD DRAFT 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 os many Category 1 substances in Company materials as possible, was established. 8003 1603 -4- May 2, 1980 PRODUCED BY FORD 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 (Fibcrs/cc) 0.1 0.5 5 8003 1604 Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Broke Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core & Mold Making Materials Safety Apparel - 5f - May 2, 1980 PRODUCED BY FORD DRAFT CARCINOGENIC SUBSTANCES <0 // / 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 ss several forms of cancer. These include lung cancer, mesothelioma (cancer of / the membranes lining the chest and abdominal cavities), and gastro-inlestinal cancer. ^Asbestos is found in a ''variety of automotive components', and thus many occupational exposures arc possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to . rcpair._of rcgulatec National group, ai 0.1 in 19 controls. /\ 8003 1605 -5- May 2, 1980 PRODUCED BY FORD DRAF' 8003 1606 CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds FIGURE 10 Effect on Body Systems Respiratory Tract- Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds___ X X X X X Other Chromium Compounds X X X X FIGURE 11 Exposure Limits Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) 52 yg/m^ a/ 1 yg/m^ 1/2 of above 25 yg/m310 Hr workday 50 yg/m'Vl 5 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 - 6f - May 2, 1980 PRODUCED BY FORD DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems 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 / KTr 3 The current gitm<^ry-unul s.9 r&g/rp ___... 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 1607 -6- May 2, 1980 PRODUCED BY FORD DRAFT CARCINOGENIC SUBSTANCES 8003 1608 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 (\ _JtegrflatTon /o ^__ ^ ppm/15 miru-' ' Proposed 1 ppm/8 hr. 1 ppm/ 2hr. 'Sample collected at 1 liter/minute FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE OCCURS OR IS SUSPECTED Adhesives and Sealers Rust Preventives Thinncrs, 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 6c Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids - 7f - May 2, 1980 PRODUCED BY FORD 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 z" 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. May 2, 1980 8003 1609 PRODUCED BY FORD DRAFT 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 g o Reviewed the Michigan Critical Materials data ^ Surveyed previous assessment of production materials. 0 Communicated with material suppliers. Analyzed the production material list (PEO). 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 - 8f - May 2, 1980 PRODUCED BY FORD S0C3 1611 DRAFT CARCINOGEN SEARCH ^yj' ----- yCeJt'Cs' '^ j^f iss'sf &SJTC* --------------------- Three Category I carcinogens were examined to determine material specifications, parts and nonproduction uses, was-ledkaia oncf inexact. Existing! data bases-containing Engineering, Manufacturing, and Purchasing information were found' to-^e-4ftComptettr`Hiid uot--rendriy tny3*ssit3*e. 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&RS 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 arid to find out if there is a known substitute. Nonproduction materials were identified by similar methodscxccpt-foc4h PEO review. 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&O 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). 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 nonproduction, materials, Michigan DNR Critical Materials usage reporting, CATALOG of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide non- confidentiaJ' list of hazardous material usage and precautions for each plant. Tr f ^^ -8- d May 2, 1980 PRODUCED BY FORD Asbestos-2/ Cr Compounds3- / Benzene DRAFT CARCINOGEN SEARCH RESULTS FIGURE 18 Production Materials/Parts -- ^ A : 34 - B V - * c s7zft ''>5' Total 1 C- V T05r nysy Asbestos Cr Compounds4- / Benzene Nonproduction Materials/Parts AB 8- >r y- c Total -8 >r y Note: A = Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = No known substitute. Advanced Engineering Project required. 3003 1612 U Data are directional estimates only and refer to materials known to contain the particular carcinogen. 2/ Primary source - Car Engineering. V Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered; - 9f - May 2,1980 PRODUCED BY FORD DRAFT CARCINOGEN SEARCH RESULTS S' S 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; No known substitute. Advanced Engineering Project required; 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 1613 -9- May 2, 1980 PRODUCED BY P'ORD DRAFT FIGURE 19 CARCINOGEN STRATEGIES 7 Continue OSHA Category I carcinogpfi control by design, process and exposure limits. EIiminate_carcinogfi^where substitutes are known when required by regulation of business presluFel. a/ Proceed now to eliminate OSHA Category I carcinogens by Job #], 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 1614 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 thejowest 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 PRODUCED BY FORD 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 8re 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. 2003 161 5 - 10 - May 2, 1980 PRODUCED BY FORD DRAFT FIGURE 20 GENERALIZED WORKPLAN (for each Category I Carcinogen) 5 V; 4 Action Responsibility Production Nonproduction 1 Manage Program SSECO * g/ /VPsproepcoifsicealtiisotnosf known and suspect- /^SECO ./ ! o/ .'Verify proposed list- PEO's \' Identify known and suspect part-fi/ (lumbers PEO's SSECO SSECO Mfg. Staff Mfg. Staff b/ 0 Request supplier verification of suspect specifications and parts NAAO/DPO Purchasing Supply Staff * Request supplier verification of substitution feasibility t Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) NAAO/DPO Purchasing PEO's (NAAO Pch.) Supply Staff Mfg. Staff (Supply Staff) t Implement Group A actions Veh. Engrg. PEO's Mfg. Staff Implement Group B actions Veh. Mgr. PEO's Mfg. Staff * Implement Group C Actions Audit effectiveness Tech. Ping. PEO'S p* 0 SSECO Tech. Ping. Research Staff BMD fVO 4 SSECO Block Timing Prod. (Nonprod, Ongoing 1 Month (A) 1 (A) . 1 (A) 2 3 6 12. 33 (TBD) 45 jfh Ongoing Ongoing a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. e/ Complete for asbestos, chromium compounds and benzene. 8003 1616 Ilf - May 2, 1980 PRODUCED BY FORD 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 eliminati 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 essentia] to this effort. 8003 1617 - 11 - May 2, 1980 PRODUCED BY FORD DRAFT FIGURE 21 MEMBERSHIP 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 7Af -f FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER 8003 1618 - 12f - May 2, 1980 PRODUCED BY FORD DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff h8s 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 hove 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 Commpliance arid 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 1 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 and implementing the workplan as directed. ' The ongoing responsibilities of the Chemical Substances Cqnfrp>r Manager will be to coordinate the. product/facility/manufacturing/.isg(ense 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&SES repre sentative. Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. 8003 1619 - 12 - May 2, 1980 PRODUCED BY FORD A .. DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 J. 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 1620 - 13f - May 2, 1980 PRODUCED BY FORD DRAFT -\ PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA Category I carcinogens by Job HI, 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: 1. Establish a Hazardous Substances Control Committee chaired by the Director / /'i Environmental Control Office. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. 4. 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. 5. Adopt as thp^Company carcinogen listing, current OS1JA regulated Category I sub stances K%Ss) and proposed for regulation substances UEh Establish the top eight prior ities proposed by the Task Force as Company priorfties. 6. 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. 8003 1621 - 13 - May 2, 1980 PRODUCED BY FORD 8003 1622 DRAFT EXHIBIT I OSHA CATEGORY I CARCINOGENS A. n* ' : ' - * Regulated ** _ J? *<.* .// 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-Trimethyl- Benzene 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-Nitroso- 1-Naphthylamine. 2-Naphthylamine Serpentine Vinyl Chloride . Proposed for Regulation Acetamide Acetic acid, Lead (2-*) Salt Benzidine Sulfate Beryllium Beryllium oxide' Beryllium sulfate (1:1)T Cadmium Cadmium oxide' Cadmium sulfate^Dl) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate^ Chromic Acid, Chromium (3-0 salt (3:2) Chromic Acid, Dipotassium salt''* Chromic Acid, Disodium salt*" Chromic Apid, Lead (2-0 salt (1:1^ Chromiter Chromium''" Chromium (III) oxide (2:3; Chromium (VI) oxide (1:3Y' Dichromic Acid, Disodium salt'" Diethylamine, N-Nitroso- p-Dioxane Ethane, 1, 2-Dibromo- Ethane, 1,1, l-7'richloro-2, 2-bis (p-chlorophcnyl) Ethylene, ehloro-, 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- May 2, 1980 PRODUCED BY FORD CAS Number DRAFT CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II FIGURE 2 8005 1625 May 2, 1980 PRODUCED BY FORD 8003 1624 DR AFT 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&O Staff) containing materials, their toxicological evaluation for worker/consun7er protection and the chemical composition, the Engineering Material Approved Source List (E<5cRS) containing the material specification title, and the materials approved to~That specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction 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 ancH^tTcompounds are identified by IH&T. 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 crossreference 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 part1 or material is handled in AAD. Functions *75ij The primary (function op^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. Tne system also produces the CATALOG of Hazardous Materials as either a full companywide print o^ as a plant specific print. The CATALOG is used by health and safety and plant dojjfrofs, fend iS^ieauiged-^Tje furnished _tO--AhfcTJAW under the current contract. The system is'lffso available^othc plants-tmd the,Poison Control CenteTlrL the Rouge to be searched by supplier or specification for complete medical^"handlings 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 are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities are also participating uiilb . tJai wirr wtrnn n -Chftccis-. uihinh nfu Hrrrej itrrt pw>1 inipntA ip- piatArjfl) ^ftHtr^1 4 May 2, 1980 PRODUCED BY FORD This is in place of missing page. 8003 1625 PRODUCED BY FORD This is in place of missing page. 8003 1626 PRODUCED BY FORD