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FILE NAME Brakes BRK DATE 2014 DOC BRK224 DOCUMENT DESCRIPTION Journal Article - History and Evolution of Warning Labels for Automotive Friction Products Regulatory Toxicology and Pharmacology 68 2014 402 41140241 Contents lists available at ScienceDirect Regulatory Toxicology and Pharmacology journal homepage www.elsevier.com/locate/yrtph History and evolution of warning labels for automotive friction products Luda M. Kopelovich Kerry A. Thuett Pamela S. Chapman Dennis J. Paustenbach Cardno ChemRisk 101 2nd St. Suite 700 San Francisco CA 94105 United States @ CrossMark ARTICLE INFO Article history Received 17 July 2013 Available online 8 February 2014 Keywords Clutches Asbestos Warnings Chrysotile Labeling Encapsulated Friction ABSTRACT There have been claims over the years that containing product manufacturers did not sufficiently warn end users early enough regarding the potential health hazards associated with their products 1930s To address this issue we compared the content of the warnings associated with containing friction products brakes clutches and gaskets manufactured by the US automotive industries to what was expected by regulatory agencies during the time period in which an understand- ing of asbestos health hazards was being developed We ended our evaluation around 1990 since asbes- containing manufacturer supplied automotive products were functionally removed from commerce by 1985 in the United States We assessed the warnings issued in users manuals technical service bulletins product packaging materials and labels placed on products themselves Based on our evaluation regulatory agencies had no guidelines regarding specific warning language for finished friction products particularly when a product contained encapsulated asbestos fibers i.e. modified by a bonding agent Even today federal regulations do not require labeling on encapsulated products when based on professional judgment or sampling user exposure is not expected to exceed the OSHA PEL We concluded that despite limited regulatory guidance the US automotive industry provided adequate warnings with regards to its friction products '2014 Elsevier Inc. All rights reserved 1. Introduction Warning signs or labels are intended to make people aware of the presence of a hazard provide guidance as to how the hazard can be avoided and provide information regarding the consequences of exposure to the hazard Rousseau and Wogalter 2006 Since the Pure Food and Drug Act of 1906 numerous federal regulations have been published which address hazard labeling of a variety of substances e.g. food poisons insecticides chemicals in general Ayres et al 1998 Warning labels serve several roles First they allow individuals to make an informed decision before using or purchasing a product Second they aid in limiting exposure by providing information on how a substance or product should be handled e.g. the need to wear rubber gloves while handling a hazardous chemical Third hazard warnings act as an intermediate policy between absence of regulation and more restrictive controls such as product bans or character alterations Viscusi 1996 In addition to federal regulations voluntary standards also exist for product labeling Even though voluntary standards are not legally enforceable they are generally offered by manufacturing associations and often are a major factor in * Corresponding author mail address Luda KupelovichocarcinoKupe.lovicchocaorcinmo.com Kupelovichocarcino.com Kupelovichocarcino.com M. Kopelovich http dx de org 10.1016 j.yrtph.2014.01 j.yrtph.2014.01 015 0273-2300 2014 Elsevier Inc All rights reserved regulatory agency decisions The first industry voluntary standards for products other than substances such as foods poisons insecticides and chemicals in general began appearing in the 1970s Ayres et al 1998 Modern labeling requirements are overseen in part by the American National Standard Institute ANSI 2535 Committee on Safety Signs and Colors ANSI 1991 The purpose of the ANSI Z535 Committee is to develop standards for the design application and use of signs colors and symbols intended to identify and warn against specific hazards and for other accident prevention purposes ANSI 1991 p iii The origin of the current ANSI began with the standardization of safety colors in the American War Standard which was developed by the War Department and approved by the American Standards Association ASA on July 16 1945 Peckham 2006 Five subcommittees were created to update and write the following five standards Safety Color Code Environmental and Facility Safety Signs Criteria for Safety Symbols Product Safety Signs and Labels and Accident Prevention Tags some of these standards have been combined and updated with time ANSI 1991 NEMA 2011 In 2006 a sixth subcommittee was created Product Safety Information in Product Manuals Instructions and Other Collateral Materials ANSI 2006b Together these six stan- dards contain information specifying format colors and symbols for safety signs used in environmental and facility applications LM Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402 411 403 in product and product literature applications and in temporary safety tag and barricade tape applications NEMA 2011 The standards suggested by ANSI are not a requirement but rather a guide to aid the manufacturer consumer and general public The ANSI qualified that precautionary labels cannot be expected to cover the complete information on the properties of a material or the complete details of its proper handling under all conditions ANSI 1976 p 7 The ANSI also stated that products that presented no hazard in normal handling or storage were not required to present a label ANSI 1976 According to Wogalter et al 2002 an effective warning label should contain four message components 1 a word to attract attention 2 hazard identification 3 hazard prevention instructions and 4 an explanation of the consequences following an exposure to the hazard Research conducted to evaluate warning label effectiveness can be generally divided into three categories signal word symbol and text McGrath 2011 The ANSI identified three signal words that can be used to call for attention danger warning and caution McGrath 2011 The description of each word is defined by the ANSI according to the perceived level of risk DANGER indicates a hazardous situation which if not avoided will result in death or serious injury WARNING indicates a hazardous situation which if not avoided could result in death or serious injury and CAUTION indicates a hazardous situation which if not avoided could result in minor or moderate injury ANSI 2007 p 4 Although some studies have shown that perception of the three words may differ from the ANSI definitions the ANSI recommendations can be a useful guideline With regard to using a symbol such as a pictorial or pictogram interpretations of the symbol may differ based on cultural background Lastly text that contains an explicit warning or those that contain specific information about the nature of the hazard particularly those with a statement of consequences have improved warning label comprehension and possible increased the perceived risk of these products McGrath 2011 p 50 Despite the expected benefits of warning labels functionally they may not ultimately insure protection of the user First the warning labels placed on products may not be read or a user may not follow the label instructions If that happens the language and content of the warning would not reduce hazardous behavior or exposure risk Viscusi 1996 For example research conducted on patient misinterpretation of prescription drug label instructions has shown that people with lower literacy rates have a higher rate of misunderstanding drug labels than do those with marginal or adequate literacy Wolf et al 2007 In a later study Wolf et al 2010 showed that using simplified text paired with icon labels improved warning interpretation among patients with marginal and low literacy rates Furthermore a warning label may be better understood by a worker if it is pointed out by a safety instructor during training McGrath 2011 Therefore a warning should be viewed as a supplement to the safety program rather than a sole substitute of it Wogalter et al 2006 The adequacy of warnings has a become significant issue in per- sonal injury and product liability litigation in the United States Wogalter et al 2006 The purpose of this review and analysis is to determine when and how warning labels associated with finished automotive friction products were first developed and how they changed or expanded over time and to examine what factors influenced their evolution Based on our review of the available lit- erature there is no published manuscript that has specifically reviewed or evaluated warning labels on automotive friction products such brakes and clutches We evaluated these warnings in conjunction with the state knowledge of asbestos science as well as with relevant legal and regulatory guideline devel- opment The history of asbestos use in US automotive friction products US regulatory guidelines with regards to asbestos and such products and the development of the science associated with asbestos toxicity are well documented 2. Method A search for documents containing information on asbestos toxicology as it relates to friction products and the requirements for warning relevant employees and consumers of potential exposure and adverse health effects was conducted Reference materials evaluated in this study included 1 toxicological data from reviewed published literature conference abstracts and meeting proceedings 2 warning standards and guidelines described in textbooks reviewed published literature industry publications government documents 3 regulatory guidelines presented in government documents 4 examples of labels from friction products and 5 various types of lawsuits mentioned in law reviews and legal meeting proceedings Multiple databases and search engines e.g. PUBMED Web of Science Medline Nexis and public and university libraries were searched to identify relevant books and reviewed literature Regulatoryrelated information was identified and collected primarily from government and professional organization websites as well as from books reports and other literature published by these orga- nizations such as the Federal Register For the collection of actual warnings and labels for friction- and automotive products such as clutches and brakes we reviewed corporate documents service manuals user manuals technical service bulletins TSBs Material Safety Data Sheets MSDSs and package labels Results were reported chronologically Each of the time periods included information on key asbestos scientific literature suggestions or requirements for labeling set forth by professional organizations advisory agencies or the federal government and examples of pertinent warning labels issued by automotive manufacturers 3. Results 3.1 Part I Regulatory requirements for containing products prior to the establishment of OSHA 3.1.1 1930s and 1940s No governmental regulation initial development ofguidelines During the 20th century the understanding of the toxicity and potency of asbestos fibers steadily increased The first death of a worker that was alleged from inhalation exposure to asbestos was reported in 1900 and the event is commonly referred to as the Montague Murray Case Merewether and Price 1930 p A3 Shortly thereafter although not as a result of this case report animal experiments were conducted by Professor J.M. Beattie which revealed that inhaling asbestos dust correlated with a mild degree of fibrosis in animals Merewether and Price 1930 In 1930 Merewether and Price conducted a study of workers in a textile as well as a brake and clutch lining manufacturing setting in the United Kingdom The authors concluded that the duration of exposure to asbestos dust and the type of work activity performed at the plant correlated with increasing risk of incidence of pulmonary fibrosis Merewether and Price 1930 This was basically the first time the term asbestosis was used to describe a unique disease due to exposure to asbestos rather than simply a pneumoconiosis Prior to this it was difficult to know whether breathing difficulties were due to exposure to silica dust dusts in general pneumonia tuberculosis or other risk factors In 1938 Dreessen et al evaluated the incidence of asbestosis in workers in the asbestos textile industry Similar to Merewether  404 LM Kopelovich et al Regulatory Toxicology and Pharmacology 68 2014 402-411 and Price they concluded that both the type of work activity and the duration of exposure contributed to asbestosis development Because asbestosis was found only in dust concentrations exceeding 5 million particles per cubic foot mppcf and was not found at lower concentrations the investigators concluded that 5 mppcf may be regarded tentatively as the threshold value for asbestosdust exposure until better data are available Dreessen et al 1938 p 91 Subsequently several states adopted this value Air Hygiene Foundation 1941 OSBH 1945 State of California Department of Industrial Relations 1945 followed in 1946 by the American Conference of Governmental Industrial Hygienists ACGIH which assigned a Maximum Allowable Concentration MAC value of 5 mppcf to asbestos ACGIHI 1946 The value identified by ACGIH was a recommendation for nonencapsulated asbestos fibers less than 5 ...min length and having an aspect ratio of 3 Similar to other cohorts studied in this era Dreessen et al 1938 and Merewether and Price 1930 measured the exposures in factories in which workers handled raw asbestos fibers In contrast to these raw fibers or friable products the chrys- otile asbestos fibers found in finished automotive brakes and clutches are encapsulated via phenolic resins or other bonding agents Once the asbestos fibers are encapsulated the majority of fibers in the product are prevented from becoming airborne even when manipulated Langer 2003 Furthermore encapsulation often changes size of the resin complex primarily reducing the capacity of fibers to become airborne and therefore logically resulting in a decreased hazard to workers Langer 2003 3.1.2 1950s and 1960s First involvement by federal agencies Official US governmental regulation of occupational exposure to asbestos began in the 1950s with the 1951 Healey Contract Act U.S. Congress - 74th 1936 USDL 1951 This Act required that contractors and manufacturers follow standard employment rules including those for health and safety when under contract by the US government The goals of the Act included ensuring the safety and being of workers and their families and mitigating the cost of accidents in terms of money and human resources To this end with regards to atmospheric impurities the Act accepted the exposure guideline recommended by the AC- GIH in 1946 for allowable concentrations of airborne asbestos USDL 1951 p 21 Asbestos was listed as a mineral dust with a suggested MAC of 5 mppcf USDL 1951 p 22 As a result of some of the research conducted in the early 1960s concerns over the risk of asbestos related diseases among end- users were raised For example Thomson et al 1963 performed autopsies of the general population in Cape Town South Africa to better understand the impact of airborne asbestos fibers on urban dwellers The investigators raised concerns regarding various sources of asbestos exposures including break wear debris i.e. brake dust noting that brake wear debris could have been a signif- icant source of asbestos in urban air although the researchers noted that the inhaled fibers were not in amounts sufficient to produce pulmonary lesions or disability Thomson et al 1963 p 81 Shortly thereafter Dr. Irving Selikoff reported on the relationship between asbestos exposure and the increased incidence of lung and pleural cancers in insulation workers Selikoff et al 1964 In part because of the Selikoff studies and increased awareness about the importance of latency concern grew that the 5 mppcf asbestos occupational guideline published by ACGIH was no longer adequate for protecting workers In 1965 at the Conference on the Biological Effects of Asbestos the 5 mppcf limit recommended by Dreessen et al was called inadequate to give complete working protection against all forms of asbestos Corn 1986 p 517 Following the conference in 1968 ACGIH recommended lowering the threshold limit value TLV regardless of fiber type to 12 fibers per cubic centimeter cc the prior limit of 5 mmpcf was roughly equal to 30 cc ACGIH 1968 This value was adopted by the WalshHealey Act in 1969 OSHA 1972 The reduced exposure limit was based on an understanding that not only miners and millers were exposed to asbestos fibers but also textile weavers carpenters insulators pipe laggers dockers rubber compounders and others ACGIH 1908 In 1970 ACGIH recommended lowering the asbestos TLV further to 5 cc Hosey 1970 Several studies occurred in the late 1960s and early 1970s that expanded the state of knowledge of asbestos with regards to exposure to friction products specifically These investigators concluded that the quantity of asbestos fibers and the length of those fibers released from brake lining was generally considered to be too low to constitute a public health or occupational health hazard Anderson et al 1973 Hickish and Knight 1970 Jacko et al 1973 Lynch and Ayer 1968 Hickish and Knight 1970 for example were the first to measure a daily time weighted average TWA exposure for brake repair workers Their work was initiated because at the time there was little known about the exposure concentrations resulting from maintaining passenger vehicle brakes and businesses were trending towards introducing a work flow system where one individual would potentially be engaged almost entirely in brake servicing Hickish and Knight reported that exposure to asbestos during brake maintenance is not as severe as was anticipated and that the personal exposure samples collected during car servicing were below the Hygiene Standard of 100 fi- year for 50 years Hickish and Knight 1970 p 20 In addition Boillat and Lob 1973 conducted an epidemiological study in which the incidence of asbestosis in workers assembling brake linings was evaluated the authors noted that exposure and risk of disease in this population had never been examined as of the time of their study The authors concluded that the rec- ommended American health workers exposure limit of 5-10 fi- bers for a quarter of an hour five times a day was not likely to be surpassed in this population and that the risk of asbestosis appeared small Boillat and Lob 1973 3.1.2.1 Contemporaneous labeling of encapsulated materials nonfriction examples Prior to 1970s there were no requirements for labeling containing products and we found no examples of any brake clutch or gasket warning labels in existence during this time period However requirements for warnings on other types of consumer products had been evolving for the prior decades and these guidelines may have influenced the content of future labels on friction products In 1932 Senator Hiram Bingham of Connecticut introduced a bill into Congress calling for labeling of certain chemical products Following this bill a committee from the chemical industry met with the Surgeon General of the U.S. Public Health Service to evaluate the matter further Murphy 1953 Thus evolved the voluntary Surgeon General's Agreement adopted by the U.S. chemical industry in 1934-1935 Under this agreement the texts of the precautionary labels used on specific products were agreed upon and made part of the executive agreements However the Manufacturing Chemists Association MCA replaced the Surgeon General in 1952 in overseeing the use of precautionary labels on certain products MCA 1961 In 1944 the MCA organized the Labels and Precautionary Information Committee LAPI a group composed of technical and legal personnel for the purpose of examining labeling Murphy 1953 Unknown 1945 The first guide developed by the LAPI Committee was published in 1945 by the MCA and was titled A Guide for the Preparation of Warning Labels for Hazardous Chemicals or Manual " Murphy 1953 According to this document although employee education regarding chemical hazards should remain the direct responsibility of employers manufacturers L.M Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402-411 405 ~ should also affix labels on hazardous chemical containers with pre- cautionary statements and instructions stated as simply and briefly as circumstances permit Unknown 1945 p 992 According to the guide the following general principles should be considered prior to the preparation of the precautionary label statements should be brief and simple uniformity of labels should be considered for different products and precautionary statements should be used only when necessary since indiscriminate use will tend to destroy the label's value Unknown 1945 p 992 The guide also stated that the following subject matters should be considered for inclusion when preparing a chemical label 1 chemical name 2 signal word designating degree of hazard 3 affirmation statement of hazard 4 instruction in case of accident Fig ) Since its first publication in 1945 Manual L was revised six times and was ultimately reorganized into the American National Standard ANSI Z129 in 1976 ACS and ANSI 2006a Additionally in 1960 the Federal Hazardous Substance Labeling Act FHSA was promulgated to regulate the distribution and sale of packages of hazardous substances intended or suitable for household use Scriba 1961 The Act was meant to protect users including children from serious illness or death caused by ingesting inhaling or absorbing a hazardous substance Scriba 1961 Hazardous substances were defined as substances or mixtures that were toxic or corrosive or an irritant strong sensitizer flammable or capable of generating pressure if such a substance may cause potential personal injury or substantial illness during or as a result of foreseeable handling or use Scriba 1961 The Act defined label as a written printed or graphic matter upon the immediate container of any substance Scriba 1961 p 373 The FHSA was amended by the Child Protection Act of 1966 U.S. Congress - 89th 1966 3.2 Part II Evolution of warning labels following the promulgation of OSHA 3.2.1 Early 1970s Establishment of regulations associated with warnings and labeling In 1971 OSHA promulgated a permissible exposure limit PEL for asbestos based on ACGIH's proposed TLV of 12 cc The PEL also reflected the Federal standard promulgated under the Walsh ley Act in 1969 OSHA 1971 A year later in 1972 OSHA lowered the PEL to 5 cc a value previously recommended by ACGIH in 1970 Hosey 1970. OSHA 1972 Despite the reduction of the asbestos standard by more than 50 in less than 2 years and even with the increased scientific knowledge that developed between the late 1950s and the 1960s as of the 1970s no agency or scientific body recommended applying a warning label for products in which asbestos fibers had been modified by a bonding agent or other material so that dur- ing any reasonable foreseeable use handling storage disposal processing or transportation no airborne concentrations of asbes- tos fibers in excess of the exposure limits will be released OSHA 1972 p 11321 These encapsulated products included brakes gaskets floor tiles and other products made with phenolic resins Chemical name 2. Signal word DANGER- WARNING CAUTION de- hazard designating gree of Column A Schedule 3 3. Affirmative of hazard statement Column B Schedule 3 4. Precautionary measures covering followed actions to be or avoided Column C Schedule 3 of 5. Instructions in case accident where advisable Column D Schedule 3 Fig 1. Subject matter to be included on a chemical label Unknown 1945 Nonetheless in the early 1970s although not required some automotive manufacturers began placing warning labels on their replacement brake and clutch products Several representative warnings are shown in igs 1-4 The earliest friction material lated warning that we identified from an automotive original equipment manufacturer was from a 1973 Chrysler Service Manual Fig 2 The text advised that proper equipment and ventilation should be used during resurfacing of brake shoes in order to min- imize exposure to asbestos dust The warning stated that asbestos dust can be detrimental to health Fig 2 This warning could be applied to most substances that create dust when manipulated Additionally a warning label appeared on Bendix brake boxes in 1973 and cautioned against inhaling asbestos fibers Fig 3 Although the warning label did not provide specific instructions to the user it advised that inhaling asbestos dust may cause serious bodily harm Fig 3 Such broad or generic warning labels were common during the late 1960s and early 1970s for a host of products including neat industrial chemicals various poisons insecticides and household substances 3.2.1.1 Other factors to consider the labeling of friction products While no organization was making recommendations specifically for labeling containing consumer products such as brakes clutches and gaskets in the 1970s the development of contemporaneous guidelines for other consumer products poisons and chemicals may have influenced the automotive industry as it developed its own warnings For example according to the ANSI specific language on precautionary labels may differ depending on the degree of hazard posed by the chemical ANSI 1976 One of the most detailed warnings recommendations for containers and wrappers was consistent with the Federal Insecticide Fungicide and Rodenticide Act FIFRA recommendations which have been in effect in some various forms since 1910. As of 1972 the requirements for labeling pesticides was highly detailed U.S. Congress - 92nd 1972b Other examples include The Poison Prevention Packaging Act PPPA that was enacted in 1970 and required that household substances be packaged and labeled in a way that would protect children from serious personal injury or illness CPSC 2008 and the Consumer Product Safety Act CPSA that was enacted in 1972 to develop uniform safety standards for consumer products Motor vehicles and motor vehicle equipment were not considered to be consumer products and thus were not directly regulated by these Acts and guidelines US Congress ~ 92nd 1972a However the wording on the two asbestos warnings previously shown in Figs 2 and 3 seems to be appropriate and in line with many of the label requirements of the time period for other toxic materials For example although the recommendations provided by the ANSI were not required and were not written specifically for asbestos or the automotive industry the representative Bendix brake box warning label Fig 3 while succinct included most of the components suggested by ANSI such as a proper signal word statement of hazard and a precautionary measure For comparison purposes with regards to level of detail we evaluated example warning labels associated with chemicals known to be highly toxic As previously described the sixth edition of the Manual - was published in 1961. This document classified vapor chemicals into three separate categories rapidly toxic or CAUTION When resurfacing brake shoes follow manufacturing recommendations for proper use of their equipment Whatever equipment is used ensure that proper ventilation is provided to remove asbestos dust which can be detrimental to health Fig 2. Warning text from a 1973 Chrysler Service Manual Chrysler 973 406 LM Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402-411 CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM Fig 3. Warning text from a 1973 Bendix brake box Bendix 1973 CHLOROFORM WARNING VAPOR HARMFUL Use only with adequate ventilation Avoid breathing vapor Avoid prolonged or repeated contact with skin Do not take internally Fig 4. Example chloroform warning label MA MA 1961 extremely irritating hazardous from prolonged or repeated exposures or physiologically inert The Manual contained warning labels for chloroform Fig 4 and trichloroethylene Fig 5 both known central nervous system depressants that can potentially be fatal at doses above the TLV Gosselin et al 1984 MCA 1961 Similar to the Bendix brake box label Fig 3 these labels were brief and concise with appropriate signal words statements of hazard and precautionary measures With regards to warning legal developments the landmark 1973 asbestos lawsuit Borel v Fibreboard Paper Products Corporation et al resulted in a substantial verdict for Texas insulation worker Clarence Borel against 10 asbestos manufacturers per a ruling by the U.S. Court of Appeals Fifth Circuit Borel v Fibreboard Paper Prod Corp. 493 F.2d 1076 1973 This product liability case involved an asbestos manufacturer's duty to warn industrial insulation workers of dangers associated with using asbestos Mr. Borel alleged that he had contracted mesothelioma as a result of his exposure to the defendants products during his 33 year career in the industry To our knowledge this instance of litigation was the first time that containing product manufacturers were held liable for warning end product users about the potential dangers of their products Borel v Fibreboard Paper Prod Corp. 493 F.2d 1076 1973 Manville Undated Although none of these defendants were automobile or friction product manufactur- ers the case likely had an impact on the future oflabeling develop- ment and use for all containing product manufacturers 3.2.2 Mid to late 1970s Sampling of auto mechanics and evolution of warnings and labels With the exception of the study published by Boillat and Lob 1973 prior to 1975 there were no epidemiological studies conducted characterizing asbestos diseases in brake mechanics It wasn't until Mt. Sinai researchers suggested a possible increased risk of developing an asbestos related disease in auto mechanics that further epidemiological and exposure studies were TETRACHLOROETHYLENE PERCHLOROETHYLENE Same label as TRICHLOROETHYLENE TRICHLOROETHYLENE ' WARNINGI VAPOR HARMFUL Use only with adequate ventilation Avoid prolonged or repeated breathing of vapor Avoid prolonged or repeated contact with skin Do not take internally Fig 5. Example trichloroethylene warning label MCA 1961 conducted to better understand this possible risk Lorimer et al 1976 The researchers reported that both the TWAS and the peak levels indicated significant asbestos exposure However they noted that the findings of their study could not be generalized to all brake maintenance workers Lorimer et al 1976 p 217 The researchers also concluded that asbestos disease will be pres- ent among brake repair workers and thus appropriate control measures should be urgently instituted Lorimer et al 1976 p 217 The meaning of will be present is unclear as to whether they recognized that lung cancer and mesothelioma would be present in this cohort whether or not they had any exposure to asbestos due to work with brakes Based on data collected although the number of samples collected were limited a letter was issued in the NIOSH Current Intelligence Bulletin CIB to all US industrial hygienists by William J. Lloyd the director of Office of Occupational Heath Surveillance and Biometrics Lloyd 1975 In a July meeting he alerted those active in occupational medicine as well as NIOSH staff about the limited state of understanding that existed regarding asbestos exposure in motor vehicle brake and clutch mechanics Lloyd 1975 Mr. Lloyd's letter suggested that more work should be con- ducted in order to determine any correlation between brake mechanical work and possible adverse health effects NIOSH 1975 According to Mr. Lloyd's letter potential exposure to asbestos among brake servicing personnel had not been extensively studied Even so the letter included interim procedures recommended by NIOSH to minimize dust exposures during brake and clutch work Specifically the letter recommended without force of law that entrances to areas in which brake and clutch repairs were performed should have an asbestos warning sign posted that would provide the following information 1 caution against inhaling dust 2 advice for assigning and wearing protective equipment and 3 warning that asbestos dust may cause cancer and asbesto- SIS Fig 6 The letter also contained information on removing brake dust as well as which cleaning methods should be avoided such as com- pressed air or dry brushing The letter recommended that an industrial type vacuum cleaner or a water soaked rag be used in order to reduce exposure to dust Lloyd 1975 : Simultaneously the automotive industry began developing and including warnings in its technical bulletins and service manuals consistent with the NIOSH CIB recommendations for premises warningFosr example in 1975 a warning cautioning against using compressed air during brake work appeared in the Ford Technical Service Bulletin Ford Motor Company 1975 The label advised that brake assemblies should be cleaned only with a vac- uum cleaner suitable for use with asbestos fibers Fig 7 Over time more information appeared on warning labels In 1976 for example the Small Car Brake Service Manual Fig 8 published by Delco Moraine Division of General Motors contained lan- guage that was more extensive than what had been used previously although the overall content remained the same The added language presented clearer instructions to avoid creating Asbestos Dust Hazard i ' Do Not Breathing Avoid Breathing Dust Wear Assigned Protective Equipment Remain in Area Unless Your Work Requires It Asbestos Dust May Cause Asbestosis and Cancer Fig 6. Asbestos warning sign that appeared in the NIOSH Current Intelligence Bulletin 5 issued on August 8 1975 to alert auto mechanics of the possible hazard of working with brakes The bulletin was titled Asbestos Asbestos exposure during servicing of motor vehicle brake and clutch assemblies Lloyd 1975 . LM Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402-411 407 CAUTION Dust and dirt conditions present on wheel brake assemblies and rotors and drums may contain asbestos fibers that can represent a potential health hazard when made airborne by cleaning with compressed air All wheel brake assemblies should therefore be cleaned only with a vacuum cleaner suitable for use with asbestos fibers This type of vacuum cleaner is available through the Rotunda Dealer Equipment Catalog Dust and dirt from the vacuum cleaner should be disposed of in a manner that prevents dust exposure Any repairs done on brake linings pads rotors and drums should be done using properly exhaust ventilated equipment Fig 7. Warning text from the 1975 Ford Technical Service Bulletin Number 99 Ford Motor Company 1979 WARNING WHEN SERVICING WHEEL BRAKE PARTS DO NOT CREATE DUST BY GRINDING OR SANDING BRAKE LININGS OR BY CLEANING WHEEL BRAKE PARTS WITH A DRY BRUSH OR WITH COMPRESSED AIR A WATER DAMPENED CLOTHI OR A SUITABLE VACUUM CLEANER SHOULD BE USED MANY WHEEL BRAKE PARTS CONTAIN ASBESTOS FIBERS WHICH CAN BECOME AIRBORNE IP DUST IS CREATED DURING SERVICING BREATHING DUST CONTAINING ASBESTOS FIBERS MAY CAUSE SERIOUS BODILY HARM Fig 8. Warning text from the 1976 Small Car Brake Service Manual published by General Motors Delco Moraine Division Delco 1976 dust during wheel servicing and also suggested alternative cleaning methods Delco 1976 There was some variability in the content and extensiveness of warnings information in the auto industry in the 1970s because no standard warning language existed For example text that appeared in the General Motors 1976 Small Car Brake manual noted that breathing dust may cause harm Fig 8 Delco 1976 Another example similar to previously discussed warning labels and in line with contemporary recommendations is the 1977 Chevrolet manual Fig 9 that encouraged using proper cleaning techniques Specifically this manual emphasized that brake lining grinding sanding or cleaning using a dry brush or compressed air should be avoided Furthermore the warning stated that a wet rather than dry cleaning technique should be used Chevrolet 1977 3.2.3 1990s Expanding knowledge of the hazards of asbestos and continued limited concern about the health hazards of brake dust In 1983 OSHA issued an emergency temporary standard ETS that lowered the PEL to 0.5 cc for airborne asbestos According to the Federal Register OSHA derived a response relationship and estimated that an ETS of 0.5 cc would reduce the mortality caused by occupational exposure to asbestos OSHA 1983 Some of the studies used by OSHA to support this change included Finkelstein et al 1983 Dement et al 1983 and Henderson and Enterline 1979 Using data collected from workers at an asbescement factory Finkelstein and others were able to analyze Warning When servicing wheel brake parts do not create grinding dust by or sanding brake linings or by cleaning wheel brake parts with a dry brush or with compressed air A water dampened cloth should be used Many wheel brake parts contain asbestos fibers which can become airborne if dust is created during servicing Breathing dust containing asbestos fibers may cause serious bodily harm Fig 9. Warning text from a 1977 Chevrolet Service Manual The information was printed on the first pages of both the hydraulic and air brakes sections Chevrolet 1977 individual exposure history and generate an exposure relationship for associated malignancies Finkelstein 1983 Dement et al 1983 performed a retrospective mortality study among chrysotile asbestos workers that estimated worker exposure associated with textile processes Lastly Henderson and Lnterlme 1979 proposed a response relationship for respiratory cancer using information collected from workers employed by a US asbestos company Initially because of many comments and concerns that were submitted after OSHA recommended the 0.5 cc ETS the limit was not promulgated as a final rule Most of the comments submit- ted by industry as well as by senators and congressmen argued that the PEL of 0.5 cc was not feasible from an economic or engineering standpoint Furthermore representatives of the maritime and construction industries asked that a ruling more suitable to their unique workplace be established Martonik et al 2001 However in 1986 after the review of existing and newly published epidemiological studies and a subsequent risk assessment OSHA ruled to lower the existing PEL of 2 cc not to the proposed ETS of 0.5 cc but to 0.2 instead According to OSHA work published by Dement Henderson and Enterline Finkelstein and Seidman and Nicholson and Selikoff showed that the current PEL of the time 2 cc was inadequate for protecting workers against the risk from lung cancer and mesothelioma as was the previously proposed 0.5 cc OSHA 1986 p 22619 22644 They further noted that according to their risk assessment a PEL to 0.2 cc was reasonably necessary to reduce the cancer mortality risk from exposure to asbestos OSHA 1986 p 22647 Specifically OSHA's risk assessment showed that lowering the PEL from 2 cc to 0.2 cc reduce the asbestos related cancer mortality risk from.lifetime from.lifetime exposure from 64 deaths per 1000 workers to 6.7 deaths per 1000 workers which corresponded to a 90 reduction in the risk whereas lowering to 0.5 cc would only reduce the number of deaths to 17 in 1000 OSHA 1986 p 22647 Additionally the Supreme Court had ruled that occupational exposure requirements could be imposed up to the limit of what was technologically achievable Accordingly OSHA conducted a technological feasibility study that showed that 0.2 cc was the lowest level that could feasibly be attained in operations in workplaces in both general industry and construction OSHA 1986 p 22648 Warnings were discussed in the 1986 Federal Register The regulation indicated that signs and labels should be placed on each regulated area or temporarily regulated area where occupational exposures could exceed the PEL OSHA 1986 p 22698 However two exceptions to the standard existed no warning label or MSDS was required in situations in which 1 asbestos fibers have been modified by a bonding agent coating binder or other material and the manufacturer could demonstrate that during any reason- ably foreseeable use including handling storage disposal processing or transportation employee exposure will remain below the action level and 2 the concentration of asbestos in a product was less than 0.1 OSHA 1986 p 22698-22699 As had been true for many years this exemption was intended for items such as brakes floor tiles and similar products that contained encapsu- lated asbestos Even though OSHA continued to exempt encapsulated products from asbestos labeling requirements warnings were still provided in automobile service manuals as a precaution For example according to the language in the 1985 Buick Service Manual Fig 10 it was recommended that brake lining grinding or sanding should be avoided along with using compressed air Furthermore this manual specified that a water dampened cloth or specialized equipment should be used to clean brake parts Buick 1985 In 1994 the asbestos PEL was lowered to the current as of 2013 value of 0.1 cc as an h TWA OSHA 1994 Again even 408 LM Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402 411 CAUTION When servicing wheel brake parts do not not create dust by grinding sanding brake linings or by cleaning wheel brake parts with a dry brush or with compressed air Many wheel brake parts contain asbestos fibers which can become airborne if dust is created during servicing Breathing dust containing asbestos fibers may cause serious bodily harm A water dampened cloth or water based solution should be used to remove any dust on brake parts Equipment is commercially available to perform this washing function These wet methods will prevent asbestos fibers from becoming airborne Fig 10. Warning text from a 1985 Buick Chassis Service Manual Volume I. The information was printed on the first page of the General Brakes Section Buick 1983 before this action the automotive industry proactively warned mechanics of the potential hazards of asbestos exposure Warnings had generally been added to documents and products that were associated with brakes after the 1975 NIOSH CIB even though the asbestos was encapsulated and the vast majority of asbestos in brakes was converted to forsterite or a similar breakdown products during the braking process Anderson et al 1973 Jacko et al 1973 Lynch and Ayer 1968 Exposures to asbestos during the grinding process presented a possibility for significant short term exposure but the duration of exposure was generally thought to be too short to pose a health hazard This conclusion was sup- ported by various industrial hygiene surveys conducted between 1975 and 2002 Paustenbach et al 2004 Later Weir et al 2001 concluded that grinding and drilling containing brake pads do not pose an important source of exposure to respirable asbestos fibers Wei and Meraz 2001 p 11490 The analysis of samples collected during a NIOSH survey from 1982 for example revealed that TWA concentrations for raw material mixers machine finishers drillers and slab cutters were below 2 cc the OSHA PEL at that time Zey and Klemme 1982 Nonetheless even though warnings were not necessary according to OSHA regulations and exposures were expected to be below the PEL from 1975 to the present the automotive industry included warnings statements regarding the brake replacement There was no standardized warning statement used across the automotive brake manufacturing industry during the 1990s which would be passed to the original equipment manufacturers but the one shown in Fig 11 was fairly typical of the era Interestingly this particular warning recommended that asbestos replacement parts should be used whenever possible Ford Motor Company 1993 4. Discussion Our analysis indicates that the US automotive industry was proactive with respect to issuing warning labels on finished friction products in response to the growing concern regarding the WARNING DO NOT INHALE DUST FROM BRAKES SHOULD BE LABELED BAG FOR DISPOSAL WEAR AN APPROVED HIGH EFFICIENCY CARTRIDGE OR AIR LINE RESPIRATOR AND USE EXTRA CAUTION TO AVOID BREATHING THIS DUST USE ASBESTOS REPLACEMENT PARTS WHENEVER POSSIBLE Fig 11. Warning text from a February 20 1993 Ford Technical Service Bulletin The information was printed in the Light Truck Shop Manual Section specifically under the Wheel Lock Brake Section Ford Motor Company 1993 occupational health hazards posed by asbestos At the time such warnings were issued absent any conclusive evidence that these products exposed mechanics to harmful levels of asbestos even later studies repeatedly failed to show evidence of harm to the mechanics from such fibers Thus there were no regulatory requirements for labeling or warnings and accordingly such warnings were not legally necessary The inclusion of these warnings was based on our research due to increased societal expectations regarding labeling of many different consumer products as well as the increase in asbestos litigation In 1986 the US EPA published a controversial document enti- tled Guidance for Preventing Asbestos Disease among Auto Mechanics also known as the Gold Book It was controversial in part because it was the first time that EPA chose to offer guidance regarding possible occupational exposures even though they had no mandate to be involved in this arena one which was under the purview of OSHA Throughout the pamphlet the US EPA makes statements regarding mesothelioma and brake mechanics USEPA 1986 However the document utilized dated case reports and disregarded the relevant epidemiological literature For example the US EPA neglected to include three control studies that were published in the 1980s McDonald and McDonald 1980 Spirtas et al 1985 Teta et al 1983 and these studies uniformly concluded that brake mechanics were not at an increased risk of developing an asbestos disease Wong 2001 The Gold Book also failed to note at least six different studies published between the late 1960s and early 1970s that found virtually no asbestos fibers in brake dust Anderson et al 1973 Hickish and Knight 1970 Jacko et al 1973 Lynch and Ayer 1968 Several studies published in the last decade have shown that asbestos exposures associated with automotive work are low Blake et al 2003 2008 Boelter and Spencer 2003 Boelter et al 2007 Coben and Van Orden 2008 Finley et al 2007 Jiang et al 2008 Madl et al 2008 2009. Paustenbach et al 2003 Richter et al 2009 RJ Lee Group Inc. 2004 In addition numerous epidemiological studies have been conducted examining the inci- dence of asbestos health effects in vehicle mechanics between 1975 and the present Agudo et al 2000 Butnor et al 2002 Goodman et al 2004 Hansen and Meersohn 2003 Hesse et al 2004 McDonald and McDonald 1980 Milham and Ossian- der 2001 NIOSH 2002 Olsen and Jensen 1987 Rake et al 2009 Rolland et al 2010 Spirtas et al 1994. Spirtas et al 1985 Teschke et al 1997 Teta et al 1983 Welch et al 2005 Woitowitz and Rodelsperger 1994 Wong 2001 These studies have consistently found no increased risk of any asbestos disease in auto mechanics Beyond these NIOSH currently maintains the National Occupational Mortality Surveillance NOMS database on its website which tracks associations between specific mortality and occupation and industry NIOSH 2011 According to the NOMS data there is no evidence of an increased risk of mortality from cancer of the pleura among vehicle and mobile equipment mechanics and repairers NIOSH 2011 As a result of several discrepancies identified in the original US EPA document a revised Gold Book was published in March 2007 entitled Current Best Practices for Preventing Asbestos Exposure among Brake and Clutch Repair Workers This document explained the engineering controls and proper cleaning methods that should be used during brake and clutch repair USEPA 2007 Currently as of 2013 the occupational standard for asbestos does not require that a warning label be placed on finished friction products Specifically the 1994 Federal Register states that no label is required on products to which asbestos fibers have been modified by a bonding agent coating binder or other materials provided that the manufacturer can demonstrate that during any reasonably foreseeable use handling storage disposal processing L.M Kopelovich et al Regulatory Toxicology and Pharmacology 68 2014 402-411 409 or transportation no airborne concentration of asbestos fibers in excess of the permissible exposure limit and excursion limit will be released OSHA 1994 p 41089 and 41090 Similarly the 2013 California Code of Regulations specifically states that requirements for labels and MSDSs do not apply when asbestos fibers have been modified by a bonding agent or other material and that during all reasonably foreseeable uses the airborne concentrations of asbestos fibers will not be in excess of the TWA permissible exposure level OSHA 2013 According to the current California OSHA Title 8 warning signs should be displayed near areas that are known to or presumed to contain asbestos fibers OSHA 2013 Based on that document the language on the warning sign should include the following text DANGER ASBESTOS MAY CAUSE CANCER CAUSES DAMAGE TO LUNGS AUTHORIZED PERSONNEL ONLY In addition when protective clothing and respirators are required signage should include the text WEAR RESPIRATORS AND PROTECTIVE CLOTHING IN THIS AREA The usefulness of such broad warnings is unclear However these requirements are specifically for premises signs no warnings or labels are required for brake clutch or automotive gasket packaging or users manuals There have been suggestions that the information placed on the warning labels by the automotive industry during the 1990s were insufficient Fgilman and Howe 2007 Egilman and Billings 2005 However based on our research such broad claims are unfounded based on what was and is known regarding asbestos toxicity and the epidemiology of automotive mechanics Beyond the fact that exposures of mechanics to asbestos were not determined to pose a significant hazard it was recognized by numerous researchers over the past 20 years that warnings might not serve their intended purpose if too much information were to be included or if too many warnings were issued for products which did not pose an appreciable hazard For example based on a literature review conducted by Frantz et al 1999 overuse of warning labels on a product can potentially produce unwanted consequences on the user's safety Empirical studies for example have shown that users only process certain sections of the information on a warning label rather than all of the information These findings indicate that even if large quantities of information about the plausible health hazards had been placed on the warning labels the user may not necessarily have received any additional benefits Further these researches noted that overusing warning labels may have a negative effect on user compliance The authors reported that as the number of warning labels increases especially on products which posed low risks users are more likely to disregard the labeling information Frantz et al 1999 The Food and Drug Administration FDA and the Consumer Product Safety Commission CPCS both advise that overusing safety messages weakens the effectiveness of information and in turn does not produce the desired warning effect on the user Sala et al 2011 Our historical review indicates that the warning labels set forth by the automotive brake and clutch manufacturers were thorough and appropriate for their time Despite the lack of regulations and requirements and the paucity and inconsistency of reports of the risk of asbestos disease in auto mechanics the language on these warning labels provided end users with information regarding product content proper use and possible health hazards associated with the product Furthermore the automotive industry warned against exposure to asbestos from brake and clutch repair despite the mounting scientific evidence that did not support the association between such exposures and an increased risk of developing mesothelioma lung cancer or other asbestos disease among auto mechanics Conflict of interest All of the work associated with writing this manuscript was conducted without outside financial support from any automotive or truck manufacturer or any group associated with brakes auto- mobiles or trucks Cardno ChemRisk has conducted a number of studies and has published nearly 20 papers on the hazards posed by asbestos in brakes over the past 15 years The firm also has had numerous clients who have been involved in litigation involving asbestos At least one of the authors has served as an expert witness on asbestos in the courtroom who was retained by auto- mobile truck or bus manufacturers Acknowledgment The authors would like to specially thank Ms. Claressa Mazzetti for her assistance with this review References ACGIH American Conference of Governmental Industrial Hygienists 1946 In Proceedings of the Eighth Annual Meeting of the American Council of Governmental Industrial Hygienists Chicago Illinois ACGIH American Conference of Governmental Industrial Hygienists 1968 In Transactions of the 30th Annual Meeting of the American Conference of Governmental Industrial Hygienists St. Louis MO Agudo A Gonzalez CA Bleda MJ Ramirez Hernandez S. Lopez1 Calleja A Panades R. Turuguet D. Lscolar A. Beitian M Conzalez J. 2000 Occupation and risk of malignant pleural mesothelioma A control stady in Spain Ani ] Ind Med 37 159-168 An Hygiene Foundation 1341 Digest of laduste Hygiene An hygien Foundation Pittsburgh PA Anderson A.E. Gealer R.L. McCune R.C. Sprys JW JW 1973. From Brake Dynamometer Tests SAE Technical Paper Asbestos Emissions 730549. Society of Automotive Engineers Warrendale PA ANSI American National Standards Institute 1976. American National Standard for the Precautionary Labeling of Hazardous Industrial Chemicals ANSI Z129.11976. American National Standards Institute New York ANSI American National Standards Institute 1991. American National Standard for Product Safety Signs And Labels ANSI Z535.4-1991 American National Standards Institute New York NY ANSI American National Standards Institute 2006a American National Standard for Hazardous Industrial Chemicals Precautionary Labeling ANSI Z129.1- 2006. American National Standards Institute Inc. New York ANSI American National Standards Institute 2006b American National Standard for Hazardous Industrial Chemicals - Precautionary Labeling ANSI Z129.1-2006 Revision of ANSI Z129.1-2000 American National Standards Institute New York ANSI American National Standards Institute NEMA National Electrical Manufacturers Association 2007. American National Standard for Product Safety Signs and Labels ANSI Z535.4-2007 National Electrical Manufacturers Association Rosslyn VA Ayres TJ Wood CT Schinult RA McCarthy RL 1998. behavioral choice Int J Cogn Figonom 1,35-57 1,35-57 Risk perception and Bendix 1973 Bendix Brakes Manual Honeywell Fiyna OH Blake CL Dotson GS Harbison RD 2008. Evaluation of asbestos expostie within the automotive repair industry A study inve ving removal of asbestoscontaining body sealants and drive clutch replacement Regul Toxicol Pharmacor 52 324-331 Blake CL Van Orden DR Banasik M Harbison RD 2003 Airborne asbestos concentration from brake changing does not exceed permissible exposure nut Regul Toxicol Pharmacol 38 58-70 Boeltet F. Spencel.J . 2003 Caterpillar equipment study asbestos expostul during maintenance and repau An evaluation of alboine of caterpillan equipmem Peona L. Boeltet FW Spencer TW Summons CF 2007 Heavy equipment maintenace exposure assessment c sing a time activity model to estimate sutiopat valles for replacement of missing data | Occup Environ Hyg 4 525-547 Boillat M.A Lob M. 1973 Risk of asbestosis in workers replacing automobile brake lining's Schweiz Med Wschi 103 1354-1359 Borel v Fibreboard Paper Prod Corp. 493 F 2d 1076 1973 Buick 1985 Group 5. Brakes in Buick Ed Chassis Service Manual Vol I. General Motors Detroit MI pp 5 1-5C3 5 Butnor KJ Sharma , Sporn IA Roggli VT 2002 M. lignant mesothehome and occupational expots o au sbr este os An analysiosf 1445 cases Ann Occup H 46,150 153 410 L.M Kopelovich et al / Regulatory Toxicology and Pharmacology 68 2014 402-411 Chevrolet 1977. Section 5 Brakes Vega & Monza Shop Manual Chevrolet Detroit pp 1-5 30 Chrysler 1973 Chrysler Service Manual Chrysler Motor Corporation Charlotte NC Cohen HJ Van Orden D.R. 2008. Asbestos exposures of mechanics performing clutch service on motor vehicles | Occup Environ Hyg 5 148-196 Com M 1986 Asbestos and disease An industrial hygienist's perspective Am Ind Hyg Assoc 47 515-523 CPSC Consumer Products Safety Commission 2008 Poison Prevention Packaging Act Codified at 15 US.C. pp 1471-1477 October 14 2008. United States Consumer Products Safety Commission Bethesda MD Small Car Brake Service Manual 170 13 Dated 1976 General Mctors Detroit MI Dement JM HarisRI RI Symons M.J Sly CM 1983 Exposures and mortality among chrysotile asbestos workers Part I Exposure estimates Am J Ind Med 4,399 4,399 419 Dreessen WC Dallavalle IM Edwards TI Muller JW Sayers R.R Fasom HF 1938 A Study or Asbestosis in the Asbestos Textile Industry US Govt Painting Painting Office Washington DC Cgilmas D. Howe S. 2007 Against anu health cpidemiology Corporate obstruction of public health via manipulation of epidemiology Int | Occup Environ Health 13 118-124 DS Billings MA manufacturers manufactured 2005. Abuse of epidemiology automobile manufactured defense to asbestos hability Int ] Occup Environ Health 1 360 371 Finkelstein MM 1983 Mortality among long rerni employees of an Ontario asbestos coment tactory Br Ind Med 40 138 144 Finley B1 Richter RO Mowal S. Mlynarek S. Paustenbach D Waunc~-dan~- JM Sheehan PJ 2007 Cumulative asbestos exposure for US automobile mechanics involved in brake repair circa 1950s 2000 | Expo Set Enviton Epidemiol 17 644-655 Ford Motor Company 1975.1echnical 1975.1echnical Service Bulletin ord Parts and Service Division Bule Number 99 October 24 1975. Ford Motor Company Livonia MI Iold Motor Company 1993 Technica Service Bulletin Bulktin No. 93-4A February 20 1993 Ford Motor Company Livonia Ml Fanz P. Rhoades TP Young S1 Schwer J.A 1900 Potential problems associated with overusing warnings Proceed Hussian Fact Ergon So Ann Mect 43,916 920 Goodman M. Teta MJ Hessel PA Garabiant DH Craven VA Scrafford C.G. Kelsh MA 2004 Mesothelioma and lung cancer among motor vehicle mechanics A analysis Ann Occup lyg 48 309-326 Gosselin R.E. Smith R.P. Hodge H.C. 1984. Section II Ingredients index In Gosselin RE et al Eds Clinical Toxicology of Commercial Products Williams & Wilkins Baltimore pp II.460 Hansen J. Meersohn A. 2003 Cancer mortality among Danish employees 1970 1997 by industry classification Kiacftsygelighed blandt da iske lonmodtager 1970 97 fordelt p^ Arbejdstilsynet Arbejdstilsynet 40 branchegrupper Institut for Epidemiologisk Kraefitorskning Kraeftens Bekaempelse Kobenhavn Henderson VL Enterline PF 1979 Asbestos exposite Factors associated with excess cancer and respiratory disease mortality Ann NY Acad Sc 330 117 126 bessel PA leta M Goodman M Lau L. 2001 Mesothelioma among brake mechanics An expanded analysis of control study Risk Anal 21,547-552 21,547-552 1ick DL Knight Ann Occup Hyg KL 1970 13 17 21 Exposure to asbestos during brake maintenance Hosey A.D. 1970. Development of criteria for standards In American Conference of Governmental Industrial Hygienists Ed Transactions of the 32nd Annual Meeting of the American Conference of Governmental Industrial Hygienists Detroit Michigan May 10-12 1970. American Conference of Governmental Industrial Hygienists Cincinnati OH pp 58-62 Jacko M.G. DuCharme R.T. Somers J.H. 1973. Brake and Clutch Emissions Generated During Vehicle Operation SAE Technical Paper 730548. Society of Automotive Engineers Warrendale PA Jang GC Madl A. Ingmundson KJ Murbach M. Fehling KA Paustenbach D. Dinley BL 2008 A study of airborne cluysotile concentrations associated with handling unpacking and repacking boxes of automobile cluich discs Regul Toxicol Pharmaco5l1 87-97 Manville Undated List of All Worker's Compensation Claims or Civil Actions Filed Prior to 1970 Against Manville Corporation Response to Interrogatory Titled 1STCLAIM.STD Langer AM 2003 Reduenon of the biological potential of chrysotile asbestos ausing from conditions of service on brake pads Regul Toxicol Pharmacol 38 11-11 Lloyd J.W. 1975 Asbestos Asbestos Exposure During Servicing of Motor Vehicle Brake and Clutch Assemblies Current Intelligence Bulletin 5. August 8 1975 Department of Health Education and Welfare Public Health Service Centers for Disease Control National Institute for Occupational Safety and Health Cincinnati OH Lommer W.V. Roll A.N Made A. Nicholson WJ Selikott LJ 1976 exposure of brake repan workers workers in the United States Mi Smar Med Asbestos 43.207- 43.207- 218 Lynch | R. Ayr~-IIE 1968. Measurment of asbestos exposure OccupOccup Med 10 21 24 Madl K. Gaftney > Balzer Balzer IL Paustenbach DJ 2009 Airborne asbestos concentrations associated associated wiwtihth heavy equipment brake removal Ann Cccup Hvg 53 830-857 Exposure to Madi AK Scolt 2008 , Murbach DM Feliling KA Finley 81 Pausienbach DJ chrysotileasbestos associated with unpacking unpacking and repacking boxes of automobile brake pads and shoes Aur Occup Hyg 463 479 Martonik 11. Nash rulemaking and E. Grossman E. some distinctive 2001 The history of OSHA's asbestos approaches that they introduced to regulating occupational exposure to Loxic substances Am Ind Hyg Assoc | 52 208-21 . MCA Manufacturing Chemists Association 1961. Guide to Precautionary Labeling of Hazardous Chemicals Manual L Sixth ed Manufacturing Chemists Association Washington D.C. McDonald A.D. McDonald J.C. 1980 Malignant mesothelioma in North America Cancer 46 2011 McGrath LM 2011 workplace Int J The role of equipment warning Occup Satery Ergon 17 49 60 Merewether ERA Price CW 1930. Report on Fflects labels in the industual of Asbesto Dust on the Suppression Lungs and Dust Stationery Office London in the Asbestos Industry Patt land Its Mapstys Milham S Osstander , 2001 Occupational Mortality in Washington State 1950- 1999 Washington State Department of Health Office of Epidemiology Olympia WA Murphy W 1933. Editorial Labels - Au ounce of prevention prevention Agic Food Chicat Chicat 1 353-353 NEMA National Electrical Manufacturers Association ANSI American National Standards Institute 2011 American National Standard Product Safety Signs and Labels ANSI Z535.4-2011 National Electrical Manufacturers Association Rosslyn VA NIOSH National Insitute for Occupational Safety and Health 1975 Minutes of Occupational Exposures to Asbestos Dust From Brake Linings Meeting July 21 1975 NationalInsutute for Occupational Safety and Health Atlanta GA NIOSH National Institute for Occupational Safety and Health 2002 NIOSH Hazard Review Health Effects of Occupational Exposure to Respuable Crystalline Silica 2002 Department of Health and Human Services Cente > fox Diseas Connol and Prevention National Institute for Occupational Safety and Health Cincinnati OH NIOSH National Institute for Occupational Safety and Health 2011. NIOSH Safety and Health Topic National Occupational Mortality Surveillance NOMS htp:/ww.cdc.gov/mosh/topics/surveilance/NOMS/n htp:/ww.cdc.gov/mosh/topics/surveilance/NOMS/n htp:/w.cd.gov/mosh/topics/urveilance/NOMS/n http://www.cdc.gov/mosh/topics/surveillanhtcp:/we.cd/.gov/mNosh/toOpics/MurveilSance//NOMS/nn ethod huml National Institute for Occupational Safety and Health Cincinnati OH Updated 1.02.2011 Olsen J.H. Jensen O.M. 1987 Occupation and risk of cancer in Denmark An analysis of 93,810 cancer cases 1970-1979 Scand J. Work Environ Health 13 Suppl 1 1-91 OSBH Oregon State Board of Health 1945 Rules and Regulations for the Prevention and Control of Occupational Diseases Oregon State Board of Health Portland OSHA Occupational Safety and Health Adnumustation Adnumustation 1971 National Consensus Standards and Established Federal Standards Fed Reg 36 10466 10500 OSMA Occupational Salety and Health Administration 1977 Standard for Exposure to Asbestos Dust led Reg 37 11318-11322 OSHA Occupational Safety and Health Administration 1983 Occupational Exposure to asbestos Emergency Temporary Standart Fed Rez 48 51086- 51140 OSHA Occupational safety and Health Administration 1986 Occupational Lxposure to Asbestos liemolite Anthophylite and Actinoute Liral Rules Fed Reg 51 72612 27790 OSHA Occupational Satety and Health Administration41 62 1994 Exposure to Asbestos Final Rule Fed Reg 59 40964 41162 Occupational OSHA Occupational Safety and Health Administration 2013 California Code of Regulations Title 8 Section 5208 Asbestos . hitp www.du www.du titles 5208 Accessed 11.06.2013 Paustenbach DI Finley BL Lu El Broby CP Sheehan Pl 2001 Environmental and occupational health hazards associated with the presence presence present of asbestos in brake linings and pads 1900 to eview , Toxicol Env.ron Health B Cut Rev. 7 25-80 A state Paustenbach DJ Richter RO Hinley BJ Sheehan PJ 2003 An evaluation of the historical exposures of mechances to asbestos in brake dust Appl Occup Favion Hyg 18,786 18,786 804 Peckham 6 2006. An overview of the ANSI 7535 standards for safely signs labis and tags In WogallerMS Ed Handbook of Warnings Human Factors and Ligonomics Lawrence Erlbaum Associates Maliwal N. pp 447 443 Kake C. Gilham C. Hatch , Darnton A. Hodgson , Peto , 2009 Occupational domestic and environmental mesothelioma risks in the British population A control study Br | Cancer 1175 1183 Richter RO Finley BL Paustenbach D1 Williams PR Sheehan PJ 2009 An Valuation of short exposures of brake mechanics to asbestos during automotive and truck brake cleaning and machining activities ] Expo 50 Environ Epidemiol Epidemiol 19 458-471 RJ Lee Group Inc. 2004 Observations during inspection of manual transmissions Project LSH307891 Rolland P CramondC. Lacourt A Asicul P. Chaming's S. Ducamp S. Fienay 2010 ( Galateau Salle F Ilg A.G Imbernon 1 le Nang N. Pairon JC Goldbe M. Brochard P. Occupations and industries in France at high risk for pleural mesothelioma a population control study 1998-2002 Am T Ind Med 53 1207-1219 LM Kopelovich et al./Regulatory al./Regulatory al./Regulatory Toxicology anu Pharmacology 68 2014 402 411 411 Rousseau Q.k Wogaliei MS 2000. Research Research on warning signs In Wogalter MS Ed Handbook of Wannings Human Factors and Figonomics Lawrence Erlbaum Associates Mahwali NJ pp 147 158 Sala B. Nichols EA Muhammad R Lakhiani SD Rauschenberger K Wood Cl 2011 Government warnings and safety information A comparison of agency regulations and guidance In Karwowski W Saivendy G. Eds Advances in Human Factors Figonomics and Safery in Manufacturing and Service Industries Taylor & hands Boca Raton pp 1047-1056 1047-1056 Scuba CT 1961. The federal dons substance labeling an The Business Lawyer 17 137 156 Selkoll LJ Chung J. Hammond FC FC 1964 Ashetos Ashetos exposure and neoplasia JAMA 188 72-26 Sputas R. Hememar FI Bernstein L. Beebe W Keehn RJ RJ Stark A. Harlow BL Benichou , 1994 Malignant mesothelioma Attributable usk of asbestos exposure Occup Environ Med 51 801-811 Spirras R Keehn R Wight W. Stark A. Beebe G Dickson L 1985 Mesothelioma usk related to occupational or other asbestos exposure Pieluummary results from control study Aut ) Epidemiol 122 518 State of California Department of Industrial Relations 1945 Dusts Fuines Vapors and Gases Safety Orders Division of industrial Sately of the State of California Los Angeles Teschke K. Morgan Weiss NS 1997 M.S. Checkoway IL Franklin Mesothelioma surveillance to G. Spinell J. van Belle G. locate sources of exposure to asbestos Can J Public Health 88 163-168 Tota M.J. Tewaschn HC Megs JW Vidone RA Mowad LZ Flannery J.1 1983 Mesothelioma in Connecticut 1955-1977 Occupational and geographic ssociations] Occup Med 75,749 75,749 756 Thorson JG Kaschula Kaschula ROC MacDonald RR 1963 Asbestos as a modern urban hazard S Afr Med 137,-81 137,77-81 137,77-81 US Congress - 74th 1936. The Statutes at Large of the United States of America from January 1935 to June 1936 Concurrent Resolutions Recent Treaties and Conventions Executive Proclamations and Agreements Vol XLIX In Two Parts Part 1 Public Acts and Resolutions Part 2- Private Acts and Resolutions Concurrent Resolutions Treaties and Conventions Executive Proclamations and Agreements U.S. Govt Printing Office Washington D.C. U.S. Congress - 89th 1966. Public Law 89-756 Child Protection Act of 1966. S. Govt Printing Office Washington D.C U.S. Congress - 92nd 1972a Consumer Product Safety Act Codified at 15 U.S.C. pp 2051-2089 U.S. Govt Printing Office Washington DC US Congress - 92nd 1972b Federal Environmental Pesticide Control Act of 1972 Amendments to federal nvironmental Insecticide Fungicide and Rodenticide Act US CPO Washington D.C. Unknown 1945 A Guide to the Preparation of Warning Label for Haz~-dous Chemicals Chem Eng News Arch 23 997 996 USDL United States Department of Labor 1951 Part 1 - Safety Programs Pay Dividends Safety and Health Standards for Contractors Performing Federal Supply Contracts Under the Healey Public Contracts Act U.S. Govt Printing Office Washington DC DC pp 1-23 USEPA United States Invironmental Protection Agency 1980 Guidance f Prevenung Asbestos Disease Among Auto Mechanics OPTS 86 002 1986 Office of Pesticules and Toxic Substances Asbestos Ausion Progic I Washington D.C. . USEPA United States Environmental Protection Agency 2007. Current Best Practices for Preventing Asbestos Exposure Among Brake and Clutch Repair Workers 04-004 March 2007. U.S Environmental Protection Washington DC Viscusi K. 1996 Individual rationality hazard warnings and the foundations of tort law Ruigers L. Rev. 48 625-671 Wen TW Metaz LB 2001 Morphological characteristics of released during grinding and dulling of fuction products Appl asbestos fibers Occup Envi^ a Hyg 16 147 1149 Welch LS Acherman Y. Haile L. Sokas RK Sugarbaker PH 2005 Asbestos and peritoneal mesothehoma among college educated men int Occup Environ Health 11 2544-238 Wogalter MS Conzola VC Jackson IL IL 2002 besearch guidelines for warning design and evaluation Appl Frgon 33 219-230 Wogatrci MS Silver NC NC Leonard S.D. Zaikum H. 2006 Warning symbol In Wogallet M.S. Ed Handbook of Warnings Humnal Factors and Eigonoarc Lawrence Erlbaum Associates Mahwah N1 pp 155 176 Wollowitz HI Rodelsperger K 1994 Mesothelioma among car mechantes Am Occup Hvg 38,635-638 38,635-638 Wolf MS Davis C. Bass PF Curtis LM Lindquist I.A Webb IA IA Bocchini MV Bailey SC Parker RM 2010 Improving prescription drug wainings to promote patient comprehension Arch Intern Med 170 50-56 Wolf M Davis 1 C. Shiank W Rapp DN Bass PI Connor UM Clayman M Parker RM 2007. To en human Patient musinterprctations of prescription drug label instructions Patient Educ Conus 67 393-300 393-300 Wong O 001 Malignant mesothelioma and asbestos exposite among mechanics Appraisal of scientific evidence Regul Toxicol Pharmacol 34 se.c 170 177 Zev N. Klemme C 1982 Raybestos fiction Materials Company Crawlordsville Crawlordsville Honda HETA 81-100 1110 1982. National Institute for Occupational Safety and Health Cincinnati OH