Document d4JDekK9B0Gr5aRrn82VRXEe

FILE NAME Allied Signal Bendix ASB DATE 1975 Oct 24 DOC ASB010 DOCUMENT DESCRIPTION Meeting Minutes - Asbestos Study Committee TTC UCTION MATERIALS STANDARDS INSTIT INC., 310 ROUTE 4 PARNES N.J. 07652 UCTION N.J. 07652 \ bd a NENTITENENTSITES OF THE N - - of the ASSESTOS STUDY ITTEE 1508 1508 2 . Friday October October 24 1975 at 9:30 AM > . PLAINTIFF'S -? EXHIBIT Institute Office 210 Route 4 Paramus N.J. BDX 47 MEMBERS PR^ SENT H. Hagner Chairman 1. H. Feierabend D. E. Stone I. H. Weaver J. Dundardale OTHE PRESENT M. R. E. W. Cole Drislane . Carlisle Corporation Abex Corporation Bendix Corporation Manhattan Inc. Royal Industries Clapp & Eisenberg Friction Materials Standards 4 Institute M. Jacko E. P. Stefl Bendix Corporation H. K. Porter Co. The meeting was called to order by Mr. Wagner Chairman at 9:30 A.M. ee* ieee. on MINUTES OF PREVIOUS NESTING The Minutes of the Meeting held April 28 1975 had been distributed minutes were reviewed and a motion for their acceptance was made These Upon motion duly made seconded and unanimously passed it was RESOLVED To accept the minutes of meeting as written the April 28 1975 AGBESTOS INFORMATION ASSOCIATION CONFERENCCONFEERENCE The Asbestos Information Association AIA held their annual Government- Industry Conference in Washington on September 10-11 1975. members of 7 AIA were invited to attend this conference Several individuals representing friction materials attended - One of the items of interest was the proposed OSHA regulation which was due near the end of September It had been indicated that the OSHA standards would be oriented more towards work practices than to a numerical standard Mr. Weaver indicated that the OSHA individual who indicated this did so believing that the new standard would not have a neu numerical limit Apparently there was alot possibly labor unions and nunerical standard came in at the of movement within OSHA by other NIOSH that the proposed lower very end of the write as it was Minutes of the Meeting Asbestos Study Committee -2- prepared proposed for publication The standard which will be a mumerical standard of 3.5 fibers TWA z= discussed lazer Several attendees stated that this conference was most worthwhile It gave a good overview on asbestos The only criticism made was that the speakers did not have sufficient time to be questioned after their presenta- tions The Institute will continue to monitor this conference and expresses its support of the work of the AIA PLANS FOR INSTITUTE SEMINAR ON ASBESTOS Mr. Nagmar and Mr. Drislane had taken the initial steps to organize this seminar At the April 28 1975 meeting of the Asbestos Study Committee a resolution was passed recommending that the Institute sponsor a workshop on the asbestos problem in the fall of 1975. This resolution was reviewed with the President of the Institute Mr. Simon and it was decided to proceed with such a seminar Mr. Wagner contacted Nr Noel Hendry of Manville relative to his putting on a session similar to that which J- presented two years ago For reference Mr. Noel Hendry Denver Colorado telephone 303-770-1000 Extension 2142 It was suggested that the Hanville presentation would have to be the corner of any seminar and that this would have to be arranged first before arranging other presentations Mr. B. K. Kion of OSHA had been invited by Mr. Wagner to address this seminar H. Kron had indicated that he should be able to attend It was suggested that the seminar would be a good time for a synopsis of the major points of the new OSHA standard Also it would be well for Mr. Rucn to talk with people from our industry A comment was made to the effect that OSHA had misled those attending the conference in Washington indicating that the proposed standard would be work practices oriented The standard came out with a lower numerical limit It was stated that Mr. Kwon was knowledgeable in the industrial hygiene area but he was not a policy maker He was not responsible for the addition of numerical standard in the proposed amendments to the OSHA regulations Mr. Drislane indicated that he had talked with Mr. Bob Mereness of the Asbestos Information Association and Mr. Hereness indicated that he would be pleased to attend Also Mr. Drislane contacted Mr. R. Magdelain of Nilfisk of America Inc. Mr. Magdelain would be most pleased to put on a presentation relative to that type of vacuum cleaner for the work : place Mr. Wagner also talked with Mr. W. Engeleightener of Ferro relative to their pelletizing equipment Mr. Engeleightener will also make a presentation At the meeting Mr. Magnar called Noel Hendry to firm up the M participation In summary it was indicated that Mr. 3111 Reitze would discuss the medical aspects of the regulations Mr. Ed Fenner would revie OSHA and EPA regulations Mr. Noel Hendry handling The J- presentation will a require 35 screen along with a podium and a P^system Mr. would discuss fiber mm projector a 60 x 60 Drislane indicated that arrangements for these would be made Asbestos Study Commi -3- October 24 1975 for Wednesday The seminar will be scheduled December 4. The opening session December 3 and Thursday will be a presentation by Manville for the full afternoon on December 3. Other topics will be scheduled on Thursday morning with Mr. Horeness or someone else from AIA talking at the luncheon onThursday There would be a registration fee of 10for the seminar Mr. Drislane will try to make arrangements at either the Marriott at Saddle Brook the Ramada Inn in Rochelle Park or the Sheraton Heights in Kasbrouck Heights Mr. to officially invite them Drislane will write Mr. Magdelain and Mr. Mr. Wagner will write to Mr. Kwon </ Mereness Mr. Engeleightener and Mr. Hendry to firm up the arrangements The committee committee recommends that Messrs Wagner and Orislane plan and schedule the seminar It was suggested that the type of person to involved with plant problems but it should individual who could get across the message be invited should be someone also be the foreman or other to not use an air hose or a breos The possibility of a movie shom was discussed It was suggested that controversial being the controversial interview of Dr. Selikoff and Dr. Levinsohn of Turner Brothers would not be the right presentation Perhaps a movie that emphasized controls in the work place might be worthwhile No decision was made as regards a movie Another suggestion was to have a presentation by those whohave used foam work during to envelope the station so that no dust is raised during mixing Mr. Neaver felt felt that this was an interesting technique Stone had a discussed this at an earlier meeting but had made no further progress on this since that time It was decided that this would not be added to the agenda As regards the Nilfisk equipment it was noted that this is good equipment for local pick of dust and subject should be expanded to It was felt that this session place rather than Nilfisk debris in include a should be However the work place However this central system such as a Hoffman called housekeeping in the work the Nilfisk representative would unit. discuss his unique equipment The idea was to sell the concept of cleaning the work area not to sell the vacuum cleaner Mr Frislane will indicate this particular point to Mr. Magdelain in his invitation AIA BOOZE ASBESTOS AND BRAKE LININGS Mr. Mareness requested Mr. Drislane to have this booklet reviewed for update and corrections The first question raised was Who is this booklet ained at Also What is the purpose of this booklet It was stated that this write was not a complete presentation of any particular aspect of the asbestos problem and while interesting insofar as it went was not particularly convincing It is not the type of message that would ordinarily be given to customers of friction material manufacturers The message for builders and the garage people is to not create dust in the work place There should Se more emphasis if this was the direction of the booklet on such things as labelling possible use of instruction sheets the handlinogf lining and the proper use of exhaust systems One of the problems the field is that these customers will often groove chamfer or provide extra drilling It is during these subsequent operations that asbestos concentrations may be raised to levels above that allowable It was pointed out the Asbestos Study Committee could not write a draft unless it knew what the booklet was aiming at It was stated that the title is wrong Perhaps there should come ew . . - em en re ee eee nutes of the Meeting Meeting Meeting Asbestos Study CommitCotmmitteeCeommeittee Comite Comite Committee -4- October 24 1975 be two separate pauphlets one for the garage and the builder type operation for those who are doing brake service and another for the general public It was stated that the audience for this booklet as written must have been the environmentally concerned .. customer * Mr. Reaver suggested alternatives as regards this write 1 Drop it-- do not use materials it 3 2 Rewrite it for those servicing and installing friction Write a complete new article The write made has little impact One advantage may be the listing of reference material at the end of the booklet If the ALA believes that the booklet should get to the user the customer of the friction materials manufacturer it is suggested that information be given to the user as indicated in the proposed regulations under DANGER labels This concerns the requirement during any reasonably forseeable use handling storage disposal processing or transportation that no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed be released The items that follow this section on and waste disposal are particulary particularly housekceping particularly particularly pertinent to the users of friction materials prior to installa- particulary tiontiontion ou a vehicle Hr Drislane was advised that the Asbestos Study Committee will not write the art^>cie The Committee recommends emphasis on recommendations for ~ , garages and the builders The Committee would be happy to review a net write prepared by AIA which was aimed for this user with emphasis on the those who actually do subsequent work on friction materials such 25 grooving cutting grinding chamfering etc. ote RECOLRETCOLTEENDNED RECDOLTENDED ERDECOLTENDEPD RPRO OCECDUEPRROECEDDUREUPRORCEDEURE FOR FOR BRBRAAKKEE AND CLUCLUTCH TCLCUTHCH SERVICING SERVICING SERVICING This write had been prepabryetd he Manhattan Inc. Mr. Weaver distributed copies to Committee members Raybestos would welcome comments on this members office wriwishting e wishing along with any recommendations for changes wishing to comment should send their recommendations . Committee to the Institute - THE PROPUSED PROPUSED OSHA STANDARD AND THE 0.5 FIBER LIMIT Prior to discussing details on the proposed OSHA standards several members stated that they had been inspected by OSHA While in a few cases citations were made for higher concentrations of asbestos than permitted there had been many instances where counts were made without a citation While the values on the concentration are revealed when a citation is made OSHA does not provide information on the counts when a citation is not issued Several members indicated that they believed that OSHA will not provide written results on their test in the work place unless it is necessary to support a citation In other words where a citation is not involved they will not reveal the data Legal Counsel will check on the availability of this information and whether OSHA can be requested to provide this data when a citation is not involved and will report in writing to the Institute on this The proposed OSHA standard is far more difficult numerical standard list of rather specific items for item being that the comments must reaching The main problem is the new 0.5 fiber OSHA has put out a public participation with the main be postmarked on or before December B. 1975 Se eee oe eee = ee ee : ee + Seen = sae Hinutes of the Meeting Asbestos Study Committee -E- October 24 1975 any work that they might do which could bring their concentration above 0.5 fiber would now be a problem These people would now be covered by the requirements of the OSHA standard Many smaller operators have to drill materials to adapt then to unique shoes in the field Additional drilling would probably move concentration levels well above the maximum ceiling concentration of 5 fiber ; A point to be mentioned is not to adopt the tactic of You can't do it The point is that at the present time technology is not available in the factory to get down to these levels The industry does not know what the costs are How can comments be made on cost impact competition employment energy etc. when the technology to get there is not known Still further is such a linit necessary .. It is suggested that unless a member has specific medical information suitable to refute the proposals in the standard that he not attempt to resist the 0.5 fiber limit based on non professional observations of workers made in the past In other words if it was not good medical information don't use it The Asbestos Information Association will try to assemble some realistic medical information for consideration by the Department of Labor td 4 As regards the problem with cost impact on the consumers it may be that clean rooms for the elimination of asbestos may be required Without knowing figures perhaps costs will more than double with poorer performance at a time when the National Highway Traffic Safety Administration is calling for even higher performance Members have made extensive plans for equipment exhaust systems and procedures to get to the ? fibers limit on July , 1976. Since this equipment will not get them to the 0.5 fiber level this huge capital investment should perhaps be stopped until such time as a new standard is decided Should a manufacturer discontinue his heavy commitment to equip- ment for the 2 fibers limit when this equipment will not meet the 0.5 fibers limit . Could there be more emphasis on protective clothing with cover smocks boots and gloves as well as a respirators With reduction to the two fibers level on July 1 1976 and better work practices the clothing might do the job as well as the new difficult 0.5 fiber limit The members don't know how low they can get in fiber counts until this new collection equipment is actually installed and in operation Suggestions made for cleaning the work area are all well and good but the only proof that one has reached an arbitrary fiber limit is when the installation ^' is completed As regards energy who can say that if double the horsepower was added to collection systems that they would get down to the new limit How .can the energy cost be estimated until this same equipment has actually reduced the concentrations down to the new levels Where regulated areas are established where allowable concentrations may be exceeded it is difficult to get employees to wear the proper clothing If one were trying to operate a clean room along with proper protective clothing employees would want conditioning in the re ee ee oe / Asbestos Study Committs -7- October 24 1075 work place for the uncomfortable clothing To require conditioning in the work place while also maintaining the extensive exhaust systems would be prohibitively expensive it can be done at because one is at cross purposes with the other Costs also will be increased because of thenew monitoring requirements , . this is recards the effect on competition it was pointed out that may very well be the trigger which would close dom some marginal operations with jobs a resulting transfer of outside of where much medical information has been 0.5 the U.S. gathered Even in Great Britain they have not gonesufficient to the 0.5 fibers limit It does not appear that Great Britain has sufficient medical evidence to support such a limit Countries on the continent do not have this 0.5 fiber limit The Latin American countries haveno limits As regards the effect on capital expenditures required for additional jobs employment and competition the huge the U.S. plants may very well export of While some the worker the procedures recommended for handling asbestos and removing from contact with the product may show labor saving results the actual level of exposure to the remaining workmen from these changes still . will be quite high There a There would be considerable costs for members in the friction materials requalify industry to brake blocks and heavy duty segments for the require- ments of the SA Standard 121 which went into effect during 1975. There has been a considerable expenditure of funds for Standard 105-75 hydraulic brake systers standard by many members Any changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard would add additional costs for manufacturers in requalifving their materials The friction materials industry in particular is caught between the forces of improved performance of braking materials along with restric- tions on how to manufacture and distribute their materials There may be considerable testing to requalify materials if there should be a change in processing or compounding , As regards the costs to consumers and society in general the industry does not know what can be done if it is necessary to renove asbestos from brake lining The industry could be subject to 5 - 10 years of serious dislocation In addition to the problems with the OSEA standard that appear evident costs can not be quantified at this time Industry needs more time to respond to these far reaching regulations . One of the requirements for record keeping stated that the records must be maintained for forty years or for an employment interval plus 20 years which ever is longer This is a considerable record keeping requirement However it was stated that perhaps this is necessary in order for subsequent 1 study of the epidemilogy of asbestos It was suggested that perhaps this is one of the new proposals that can be lived with In prior meetings and at prior workshops the problem of correlation of fiber count has been discussed In general there seems to be some agreement that different experienced counters may total up results showing as much as a 30 variation in counts from the same sample This is already a problem However these counts where the 30 variation is evidenced are in the 2 fibers per CC to 5 fibers area A 30 difference with a 5 fiber count is 1.5 fiber Here OSHA is asking for a concentration limit of 0.5 fibers when with current observations there can be variations of as much as 1.5 fibers As concentrations move towards 0.5 fibers not only does technology Ret ct nee ene ene eee ee: Fe ee tee - wee ee oa: Minutes of the fleeting Asbestos Study Committee 080 October 24 1975 . Industry conditions in 1975 under the current 5 fibers limit are much improved over industry conditions which were in effect through most of the 1950's Each additional step approaching zero fibers is a lot more difficult than the steps that were taken to ger industry down to the 5 fibers limit While it will be burdensome to move the concentrations to the fibers known limit the steps necessary to get down to 0.5 fibers are not There are requirements in the proposed standard for worker assignment If many employees are moved to lesser and lesser duties maintaining the same premium pay that they had received for working with the asbestos products there will be a negative productivity result It has been industry practice in the past for night shifts and more difficult tasks to command higher pay preiums This rotation to another job with no loss in pay will be another penalty to productivity The recommendations that will be made by the FNSI or the AIA are not knorm at this time It is believed that the AIA stand will include background on medical information However it is most important that the individual companies make a response They should not expect that someone else will write it for them The Secretary will prepare a bulletin to be sent to the Dembership suggesting that they comment to OSHA on these requirements the will be pointed out that the comments must be those of the individual member and they should not echo the suggested outline of problems which the Institute will prepare 2 Pee ae, as we It was also pointed out that there are a lot of new items in the proposed regulations including items on loading unloading and storing of asbestos cargo The carrier it a railcar ship or other make a visual inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed Who does this Does the carrier do this Are the carriers aware of this problem A close standards revealed many problems of this out to others who may not feel that they regulations reading of the proposed OSHA nature which will have to be are affectead ffected by the asbestos pointed THE EPA NATIONAL EMISSIONS STANDARDS FOR ASEISTOS The Environmental Protection Agency published the amended standards for the National Inissions Standards for Asbestos This appeared in the Federal Register October 14 1975. Ordinarily the EPA amendments would be an item of prime concern to the manufacturers However the proposed OSHA standards are so extensive and so far reaching they must take priority over these new EPA Standards It was pointed out that the EPA notice is the adoption of the amendments to the standards These are not proposed amendments In particular the waste disposal requirements are of interest to friction materials manufacturers The friction materials manufacturer is responsible to see that fill operators and trucks carrying waste comply the requirements of EPA on disposal of asbestos bearing materials The manufacturer for is responsible out supervision to see that these requirements are carried Members reviewed the section 61.25 on waste disposal There was some difficulty with interpretation Mr. Weaver pointed out that the requirements for covering the asbestos containing material were applicable only if there were visible emissions to the outside air from tha sneen ase- 7: nutes oO nutes nutes nutes of the Asbestos Study Meeting Committee -9- October 24 1975 C7 of 61.25 do not come into play However these requiremereqnuiremtents srequirements for cover do take effect if there are any visible emissions The most difficult difficult areas of the new standart are in the waste disposal area There was no other business called to the attention of the cotion duly made seconded and unanimously unanimously unanimously passed it was committece ommittee : Upen RESOLVED To adjourn Adjourned 2:15 PM E. W. Drislane Secretary Ca