Document ememg096ej3e13n3Nxn9NMmRq

FILE NAME: Z< DATE: DOC#: Z< DOCUMENT DESCRIPTION :Z,ZZZZ t>ZZZ&ZWZ Contents lists available at Sciel1ceDirect Regulatory Toxicology and Pharmacology journal homepage: www.elsevier.com!locate!yrtph History and evolution of warning labels for automotive friction products Luda M. Kopeiovich x, Kerry A. Thuett, Pamela S. Chapman, Dennis]. Paustenbach Cardno ChemRlsk. 101 2nd St.. Suite 700. San FrancIsco. CA 94105. Umted States CrossMark ARTICLE INFO Artide Ilistory' Received 17 July 2013 Available onlme 8 February 2014 Keywords' Brakes Clutches Asbestos Warmngs Chrysotile Labelmg Encapsulated FnctlOn ABSTRACT There have been claims over the years that asbestos-containing product manufacturers did not sufficiently warn end users early enough regardIng the potential health hazards associated with theIr products (19305-19905). To address thiS issue. we compared the content of the warmngs associated with asbestos-contaimng fnctlOn products (brakes. clutches. and gaskets) manufactured by the US automotive Industries to what was expected by regulatory agencies dunng the time penod in which an understandIng of asbestos health hazards was beIng developed. We ended our evaluatIOn around 1990. SInce asbestos-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 fnction products. 2014 Elsevler Ine. 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 (Hou~."'<1U ,md Wogaltcr. 20(6). 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) CAyres 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 m 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 (V1S(11~i. 199G). 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 * Correspondll1g author. -mmI address Ludd 1\\ ,peipVi(ilt(!'( dH;!IO! om CL M. Kopelovlch). !-irtp-i;clxch>J orgflO l016/l,yrtpi;,2014.01 OL, 0273-2300/ 2014 Elsevler Inc All fights reserved. regulatory' agency decisions. The first industry-speCIfic voluntary standards for products other than substances ~uch as foods. poisons, insecticides, and chemicals in general began appearing in the 19705 (Avres et <It., 1(98). Modern labelmg requirements are overseen, in part, by the American National Standard Institute (ANSI) Z535 Committee on Safety Signs and Colors (ANSL 199]). 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 A'.!SI 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 (Pcckham. 20(6). 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 (ANSl, 1991: NEMA, 1011) In 2006. a sixth subcommittee was created, Product Safety Infonnation in Product Manuals, Instructions, and Other Collateral Materials (ANS!, 2006b), Together, these six standards contain information specifying format, colors. and symbols for safety signs used in environmental and facihty apphcations. LM Kopelovlch et all 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" (ANS!, 197(1, P 7). The ANSI also stated that products that presented no hazard in normal handling or storage were not required to present a label (ANSL 1976). According to Wogalter el at :2002j, an effective warning label should contain four message components: (1) a word to attract attention: (2) hazard identification: (3) hazard prevention mstructions: 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 categones: signal word, symbol. and text (McGrJth, 2011). The ANSI Identified three signal words that can be used to call for attention: danger, warning, and caution (McGrJtll, 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" (ANS!, 2007, p. q). 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 (M,Crath, 2011, p. 50). Despit~ 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 (Vl<'ClISi, 19Q6). For example, research conducted on patient misinterpretation of prescnption 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 Jl., 200'1). In a later study, Wolf et al. (2(J1O) 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 (MCGf2th. 2011). Therefore, a warning should be viewed as a supplement to the safety program, rather than a sole substitute of it (Woga!! er et a! , 2006). The adequacy of warnings has become a significant issue in personal injury and product liability litigation in the United States (Wogdltcr et dl., 20(6). 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 mfluenced their evolution, Ba~ed on our review of the available literature, there is no published manuscript that has specifically reviewed or evaluated warning labels on automotive friction products such. as brakes and clutches. We evaluated these warnings in conjunction with the state-of-the-art knowledge of asbestos science, as well as With relevant legal and regulatory guideline development. 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 warnmg relevant employees and consumers of potential exposure and adverse health effects was conducted. Reference materials evaluated in this study included: (1) toxicological data from peer-reviewed published literature, conference abstracts, and meeting proceedmgs; (2) warning standards and guidelines descnbed in textbooks, peer-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 III law reviews and legal meeting proceedings. Multiple databases and search engines (e.g., PUBMED, Web of Science, Medline, Lexis-Nexis) and public and university libraries were searched to identify relevant books and peer-reviewed literature. Regulatoryrelated information was identified and collected primarily. from governm~nt 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 warmngs 'and labels for fnction- and automotive-specific 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-related 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 asbestos-containing products, prior to the establishment of OSHA 3.1.1. 19305 and 19405: 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" (Mer('wf'ther dfld Pmf', FJ;JU, j). A3). Shortly thereafter. although not as a result of this case report, animal experiments were conducted by Professor j.M. Beattie, which revealed that mhaling asbestos dust correlated with a mild degree of fibroSIS in animals (Melcwether Jnd ['lice, 1930). In 1930, rvierewether 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 increaslllg risk ofmcidence ofpulmonary fibrosis (Merewrthpr and Price. EnO). This was basically the first time the term asbestosis was used to describe a unique dis- ease 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 III general, pneumoma. tuberculosis, or other risk factors. In 1938, Dreessen et al. evaluated the inCidence of asbestosis in workers in the asbestos textile mdustry. Similar to Merewether 404 L M Kopelovlch et ai/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" (D1'('e5,en et aI., i cnll, p, 91), Subsequently, several states adopted this value (Air flygwrw Foundiltwll, 1941, OS3H, 194,); S,at(" of Cal!f()rni,~. Department of IndustllJl Relations, 1945), followed in 1946 by the American Conference of Governmental [ndustrial Hygienists (ACG[H), which assigned a Maximum Allowable Concentration (MAC) value of 5 mppcf to asbestos (ACClll, 1(46). The value identified by ACGIH was a recommendatIOn for nonencapsulated asbestos fibers less than 5 /-lm in length and having an aspect ratio of 3: 1. Similar to other cohorts studied in this era, Dreps'iPI1 et aL (lS'cl;:i; and ;\;1rn'wNlwr and ['nee (19'-$0) measured the exposures in factories in which workers handled raw asbestos fibers. [n contrast to these raw fibers or friable products, the chrysotile asbestos fibers found m 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 becomlOg airborne even when manipulated (Lange:, :wrr3). Furthermore, encapsulation of- ten changes ,the size of the fiber/resin complex, primarily reducing the capacity of fibers to become airborne, and therefore logically resulting in a decreased hazard to workers (Langcl, 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 Walsh-Healey Contract Act (US Congre,s - 7'lth, 1936; USDL. ll),) 1). 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 well-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 ACGIH in 1946 for "allowable concentrations" of airborne asbestos (USDL 1951, p. :1.1). Asbestos was listed as a mlOeral dust, with a suggested MAC of 5 mppcf (U;'f)!. 1951, p, )2). As a result of some of the research conducted m the early 1960s, concerns over the risk of asbestos related diseases among endusers were raised. For example, Thomsoll et at. (10G3; 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 significant source of asbestos in urban air, although the researchers noted that the lOhaled fibers were "not in amounts sufficient to produce pulmonary lesions or disability" (Thomson et <11., 1963, p. 81). Shortly thereafter, Dr. [rving Selikoff reported on the relatIOnship between asbestos exposure and the increased inCIdence of lung and pleural cancers in insulation workers (SdikoH ct J!., i 9(4). [n 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 A:;bestos, the 5 mppcf limit recommended by Dreessen et al. was called "lOadequate to give complete working-lifetime protection agalOst all forms of asbestos" (Corn, 1986, p. Si7). Following the conference, in 1968, ACGIH recommended lowering the threshold limit value (TLV), regardless of fiber type, to 12 fibers per cubic centimeter (f{cc) (the prior limit of 5 mmpcf was roughly equal to 30 f{cc) (ACGIH, 19GB). This value was adopted by the WalshHealey Act m 1969 (OSIIA. 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 UICCIH, 19CiH). [n 1970, ACGIH recommended lowering the asbestos TLV further, to 5 f{cc (Ho,ey. 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 (;\mlcrson. er aI., EJ73; fhrklsh and Knight, 1970; lacko et dJ., 1qn; Lynch ;md AYf'f, 1%8). HlCkbh and KnIgh1 (197U), 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 resultlOg from maintaining passenger vehicle brakes, and businesses were trending towards lOtroducing a work flow system where one individual would potentially be engaged almost entirely m brake servicing. Hickish and Knight reported that "exposure to asbestos during brake malOtenance is not as severe as was anticipated," and that the personal exposure samples collected during car servicing were below the HygIene Standard of 100 fiber-year{cm3 for 50 years (lliC!osh and Knight, 1970, p, 7,0). In addition, Boillat <1nd 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 recommended American health workers exposure limit of 5-10 fibers{cm3 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 (Bolll,]t and Lob, 1973). 3.1.2.1. Con(emporaneous labeling of encapsulated materials: nonfriction examples. Prior to 1970s, there were no requirements for labeling asb(;!stos-containing products, and we found no examples of any brake, clutch, or gasket warmng labels in existence dunng 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 lOfluenced the content of future labels on friction products. In 1932, Senator Hlram Bingham of Connecticut introduced a bill into Congress calling for labeling of certain chemICal products. Following thiS bill, a committee from the chemical lOdustry met with the Surgeon General of the U,S. Public Health Service to evaluate the matter further (Murphy, 195'3). Thus evolved the volun- tary "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 (MeA, 196 I), In 1944, the MCA organized the Labels and PrecautIOnary Information Committee (LAP[), a group composed of technical and legal personnel for the purpose of examinIng labeling (Murphy. 195',: U11 knowll, 194::;). 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 L-1" (MurphV. EJ53). According to this document, although employee education regarding chemical hazards should remalO the direct responsibility of employers, manufacturers LM KopelovlCh et ai/Regulatory ToxIcology and Pharmacology 68 (2014) 402-411 405 should also affix labels on hazardous chemical containers with precautionary statements and "instructions stated as simply and briefly as circumstances permit" (Unknown, 194J, p, 992). According to the guide, the following general principles should be considered prior to the preparation of the precautionary label: statements should be bnef 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" (llnknovvn, 194'), 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 (rig. 1). Since its first publication in 1945, Manual L-l was revised six times, and was ultimately reorganized into the American National Standard (ANSI Zl29) in 1976 (ACS and ANSl, 2()Oba). 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 (Smoa. : 96]). The Act was meant to protect users, including children, from serious illness or death caused by ingesting, mhalmg, or absorbing a hazardous substance (Senb,)' 1% l). 'Hazardous substances' were defined as substances or mixtures that were tOXIC or corrosive, or an irritant, strong sensltizer, 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 (Sn iba, 19G1). The Act defined 'label' as a "wrItten, printed or graphiC matter upon the Immediate container of any substance" (Smbd. 1961, p. 373). The FHSA was amended by the Child Protection Act of 1966 (US (ongres<, . gtHh, 1966). 3.2. Part II: Evolution of warning labels following the promulgation of OSHA 3.2.1. Early 19705: Establishment of regulations associated with warnings and iabeling In 1971, OSHA promulgated a permissible exposure limit (PEL) for asbestos based on ACGIH's proposed TLV of 12 flce. The PEL also reflected the Federal standard promulgated under the Walsh-Healey Act in 1969 (O'iHA, 197 l ). A year later, in 1972, OSHA lowered the PEL to 5 flcc, a value previously recommended by ACGIH in 1970 (lIost'y, 197(). OSflA, 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 "during any reasonable foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits will be released" (USllA, 1972, P 11321). These encapsulated products included brakes, gaskets, floor tiles, and other products made With phenolic resins. 1. Chemical name. I 2. "Signal word" (DANGER-'\IVARNING-CAUTION) designa.ung de~ gre.. of l""zanJ(CoL...:nn A, Schedule 3). S, Alfirma~ive tltatemeut of "hazllJ'd" (CMumu B. S.,hedule 3). 4. 4'Preca:etj(mary rueaauresf ) 4!nveriag Ilcti<)llll to be followed Oor avoided (Column C, &nOOn\" 3). 5. Instructiona in case of a.ecldent, wben advisable (Column D, Sehedule 3). Fig. 1. Subject matter to be mcluded on a chemIcal label (IJni,nown. 1'14C,) Nonetheless, in the early 1970s, although not required, some automotive manufacturers began placing warning labels on then replacement brake and clutch products. Several representative warnings are shown in llgs. 1-4. The earliest friction material-related warning that we identified from an automotive origmal equipment manufacturer was from a 1973 Chrysler Service Manual (Fig, I.). The text advised that proper equipment and ventilation should be used during resurfacing of brake shoes m order to minimize exposure to asbestos dust. The warnmg 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 (f Ig. :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. ''l). Such broad or genenc 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 non-fnction products. While no organization was makmg recommendations specif- ically for labeling asbestos-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 precautionilry labels may differ depending on the degree of hazard posed by the chemical (ANSI, 1(76). 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 m effect in some various forms since 1910. As of 1972, the reqUirements for labelmg pesticides was highly detailed (US (oogl CSS - 92od, 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 ((PS(, 200H) 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 (U S. Congll''>s - 92nrl, 1972,1). However, the wording on the two asbestos warnmgs previously shown in Fig" 2 JnJ 'j seems to be approprIate and in line With many of the label reqUirements of the time penod 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 m.ost of the comp!Jnents 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 toxie. As previously described, the sixth edition of the Manual L-1 was published in 1961. This document claSSified vapor chemicals into three separate categories: rapidly toxic or rCAUTION: Wh'll" rfl'!Smfi'lcing brak. shoes follow milllufadurlng ~.oC(lmm.n<lation& for proper use of their equlpmem. Whatever ",quipment is uS9d, eoaur," that proper ventilation is prQVld&d to JOitmOVIflI a$blfllliit~ dust. whu;h CBn be detrimental to lIealth," Fig. 2. Warnmg text from a 1973 Chrysler ServIce Manual ((,h,y,;,', ,e;Tl) 406 L M. Kopelovich et al j Regulatory Toxicology and Pharmacology 68 (2014) 402-411 CAUTION: CONTAINS ASBESTOS FIBERS. ~VOID CREATING DUST. BREATHING ASBESTOS IDUST MAY CAUSE SERIOUS BODILY HARM. Fig. 3. Warning text from a 1973 Bendlx brake box (Hcndlx. 1')73). CHLOROFORM WARNINGI VAPOR HARMFUL Use only with adequate "entilolian. Avoid breathing vapor. Avoid prolonged or repeated contact wilh skin. 00 not tClke ;nternoUy. Fig. 4. Example chloroform warmng label (MU\' J 9G 1). extremely irntating, 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 (C()~se1ill et tit, 19H4; MeA. 19(1). Similar to the Bendix brake box label (Fig. '$), these labels were brief and concise, with appropriate signal words. statements of hazard, and precautionary measures. With regards to warning-related 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 (Bord v. Flhreboard Paper Prod. Corp. 49'5 l'.2d 1()7fi, 197'5). 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 asbestos-containing product manufacturers were held liable for warning end product users about the potential dangers of their products (Borel v. Fihrc[)o,ml Paper Prod. Corp. 4~n F.2d 1076, 19T); !ohnsl\Ilanvliie. Undated). Although none of these defendants were automobile or friction product manufacturers, the case likely had an Impact on the future of labeling development and use for all asbestos-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 BOIilal and Lob (FlT)), prior to 1975 there were no epidemiological studies conducted characterizing asbestos-related 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 roepeoted broecthing of vcpor. Avoid prolonged or repeated contad with skin. Do nOllokoe jnlernCllly. Fig. 5. Example tnchloroethylene warnmg label (MCA. 19GI). conducted to better understand this possible risk (lorimer et aI., 197G). 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" (Lonmer el Jl.. 1976, p. 217). The researchers also concluded that asbestos disease "will be present" among brake repair workers, and thus "appropnate control measures should be urgently instituted" (l.onn'e( et ;t!., 197(i, 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 (ClB) to all US industrial hygienists by William ]. Lloyd. the director of Office of Occupational Heath Surveillance and Biometrlcs (Uoyd. 1975). In aJuly meeting, he alerted those active in ocwpational medicine. as well as NlOSH 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 conducted 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 NlOSH to minimize dust exposures dunng 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 asbestoSIS (Fig. (i). The letter also contained information on removing brake dust, as well as which cleaning methods should be avoided, such as compressed 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 (l.loyd, 1975). Simultaneously, the automotive Industry began developmg and including warnings in Its technical bulletins and service manuals consistent with the NlOSH ClB recommendations for premises warnings.. For example, in 1975, a warning cautioning against using compressed air during brake work appeared in the Ford Technical Service Bulletin (Ford Motor Comp,lllY, 1975). The label advised that brake assemblies should be cleaned only with a vacuum 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. il) published by Delco Moraine DiviSIOn of General Motors, contamed language that was more extensive than what had been used previously, although the overall content remamed the same. The added language presented clearer instructIOns to avoid creatmg Asbestos Dust Hazal:d Avoid Bl:eathing Dust Weal: Assigned Protective Equip.ent Do Not Remain in Al:ea Unless YOUl: Work Requil:es It Bl:eathing Asbestos Dust May Cause Asbestosis snd Cancel: Fig. 6. Asbestos warmng sign that appeared In the NIOSH Current Intelhgence Bulletin 5, Issued on August 8. 1975, to alert auto mechamcs of the pOSSIble hazard of working With brakes. The bulletm was titled "Asbestos Asbestos exposure dunng servlcmg of motor vehicle brake and clutch assemblies" (Uoyd. 1'17') L M KopelovlCh et ai/Regulatory Toxicology and Pharmacology 68 (2014) 402-411 407 CAUTION: Oust and din condition! present on wheel brake asumblies and rotors and drums. may contain asbastos fibers that can represent a potBntlal health haiard 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 ti'lrough t!1e Rotunda Dealer Equipment Catalog, Dust and dirt from t,e 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 eQulpmel"lt Fig. 7. Warning text from the 1975 Ford Techmcal Service Bulletm. Number 99 (}\)Id ivhHH (omp<-lny, U)/')). iWAIINlN<;, Wllt;:II SJtlWICINtl WHEEL BRAKE PARTS, 00 N<Yr CltEATt! Ol1ST 111' "RI:o;oING OR 5A.NDlNG BRAKE LININGS OR B CU~NIN(l WilE!';!, IIRAKE I'ARliI ~~T~ :lIV::B~\~~~J;~:~~~~:~~A:: ~~~~~'::i;~ ~ IPAR'I'S CONTAIN Ali8E!>'TGS FIBERS WHICfl CA." 6 ..0014& "IIIOOkNIl I" l)l.'ST IS rnEA'l1:lI f>l)J!I!I.'(; SERVICING. BREATHING m}~l" CONTAINING ASlIE81'OS nllEII" MAY CA\;lili SERlut'!' IlOtlILY HARM. Fig. 8. Warnmg text from the 1976 Small Car Brake Service Manual published by General Motors Delco Moraine DIVISIOn (Ddco. El7Ii). dust during wheel servicing. and also suggested alternative cleaning methods (Dl'ico. I ~r;()). 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, 197G). Another example similar to previously discussed warning labels. and in line with contemporary recommendations, is the 1977 Chevrolet manual (Fig. <l) that encouraged using proper cleaning techniques. Specifically, this manual emphasized that brake lining grinding, sanding. or cleaning using a dry bru~h or compressed air should be avoided. Furthermore, the warning stated that a wet. rather than dry, cleanIng technique should be used (Clwvrolet, 1~)77). 3.2.3. 1980s-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 flcc for airborne asbestos. According to the Federal Register. OSHA derived a dose-response relatIOnship and estimated that an ETS of 0.5 flcc would reduce the mortality caused by occupational exposure to asbestos (OSIlA, 1983). Some of the studies used by OSHA to support this change included Finkelstein et al. (1983). IJemem el al. (191';:)). and liel1dClSOll dnd Enlt'rline : 1~)79;. USing data collected from workers at an asbestos-cement factory. Finkelstein and others were able to analyze Warning: When servicing wheel brake parts do not create dust by g~"nding or sanding brake linings or by cleaning wheel ~rl!lkO IIArt.. with A dry broth or with MmllrA!:9d air. lA wator ~lImp\ln\ld cloth should be u&ed.) Many wheel brake pArts contain asbestos fiOOrs which can become airborne if dust is created during servicing. Breathing dust containing asbestos fibers may cause serious bodilV harm, Fig. 9. Warmng text from a 1977 Chevrolet Service Manual. The mformatlOn was prInted on the first pages of both the hydraulic and air brakes sectIOns (ClWv[,)iN. 1(177). individual exposure history and generate an exposure-response relationshIp for asbestos-associated malignancies (Fmkelstelll, EIS3). Dcmcnt et al. (1983) performed a retrospective mortalIty study among chrysotile asbestos workers that estimated worker exposure 'associated with textile processes. Lastly. llendl'rson and Lllterlmc (1 (79) proposed a dose-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 flee ETS. the limit was not promulgated as a final rule. Most ofthe comments submitted by industry. as well as by senators and congressmen. argued that the PH of 0.5 flcc was not feasible from an economic or engineering standpoint. Furthermore. representatives of the mantime and construction industries asked that a ruling more suitable to their unique workplace be established (fvl;;rtonik pr al.. 2(01). 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 f/cc. not to the proposed ETS of 0.5 flcc, but to 0.2 flee instead, According to OSHA, work published by Dement. Henderson and Enterline, Finkelstein and Seidman. and Nicholson and Sehkoff showed that the current PH of the time (2 f/cc). was "inadequate" for protecting workers against the risk from lung cancer and mesothelioma. as was the previously proposed 0.5 flcc (OSHA. 193(;, p. 22619,22644). They further noted that. according to their risk assessment, a PEL to 0.2 flee was "reasonably necessary to reduce the cancer mortality fisk from exposure to asbestos" (OSHA, 19Sb, p. 22647). SpeCIfi- cally, OSHA's risk assessment showed that lowering the PEL from 2 flcc to 0.2 flcc "reduce[ d] the asbestos related cancer mortality risk 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 flee would only reduce the number of deaths to 17 in 1000 (OSHA. 19H(i, 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 flcc was "the lowest level that [could] feasibly be attained in operations in workplaces In both general industry and construction" (OSllA, FlHh. 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. 198(;, 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 reasonably 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% (OSllA. 19BG, 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 en~apsu lated asbestos. Even though OSHA continued to exempt encapsulated products from asbestos labeling reqmrements. warnings were still proVided in autom'obile service manuals as a precaution. For example. according to the language in the 1985 Buick Service Manual. (fin' 10), it was recolTIlTIended that brake lininc; c;rindins or sand- ing 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 (BUll k. ] ~J8:). In 1994. the asbestos PEL was lowered to the current (as of 2013) value of 0.1 flcc as an 8-h TWA (OSHA. FJlJ4). Again. even 408 L M. Kopelovlch et ai/Regulatory ToxICology and Pharmacology 68 (2014) 402-411 . CAUTION: When servicing wheel brake parts. do not create dust by grinding. sanding brake linings. or by cleaning wheel brake parts with a dry brush or with ~ompressed 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 weter based solution should be used to remove any dust on brake parts. Equipment is commercially available to perform thi8 w88hing function. These wet methods will prevent asbestos fibers from becoming airborne. Fig. 10. Warning text from a 1985 BUlck ChaSSIS ServIce Manual, Volume I. The informatIOn was prInted on the first page of the General Brakes SectIon (Butrk, I%S). 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 m brakes was converted to forsterite or a similar breakdown products during the braking process (Anderson et aL, 1ST3; Jacko et al., ; 973; Lynch and Ayer, 1')68), Exposures to asbestos dunng 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 supported by various industrial hygiene surveys conducted between 1975 and 2002 (P"uorenb",h et aI., ?OO"l). Later, Weir et at (2001) concluded that grinding and drilling asbestos-containing brake pads "do not pose an important source of exposure to respirable asbestos fibers" (Weil and MCldL, 2001, p. ! 1490), 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 flcc, the OSHA PEL at that time (7.ey and l<!E'I1HllP, 19i12). 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 onginal equipment manufacturers), but the one shown in Fig. 11 was fairly typical of the era. Interestingly. this particular warning recommended that non-asbestos replacement parts should be used whenever possible (Ford 'Vlotor Company, :C)cn). 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 E~ARNING: 00 NOTINHALE DUST FROM BRAKES, CtES OR ASSOCIATED COMPONENTS. :rIONOF DUSTCONTA1NlNG ASBESTOS CAN BE INJURIOUS TO YOUR HEALTH ~COUlDCAUSE CANCER OR ASBESTOSIS. COMPRESSED AIR OR BRUSHES MUST NOT BE USED TO.CLEAN BRAKES, BRAKE DRUMS, CU1FCHESAND ASSOCIATED COUPONEHTs. A ~~ClEAHEREOOPPEO FOR THIS """",,SE SHOULD BE CAREfUIJ.VUSEO TO JIEMOVE Atf'( DUST. AOHERENTOUST SHOll.D BE REMOVED WITH ADAMP RAG. AI OUST SHOUlD BE CONTAINED IN ASEAlED AND UBElEO BAG FOR DISPOSAL. WEAR AN APPROYEOHIGH EFFICtENCV CARTRIDGE OR AIR LINE RESPIRATOR AND USE EXTRA CAUTION TO AVOIDSREATHlNG THIS OUST. USE NOM-ASBESTOSREPLACEMENT PARTS WHENEVER POSSIBLE. Fig. 11. WarnIng text from a February 20, 1993 Ford Techmcal Service Bulletin. The InformatIOn was prInted In the Light Truck Shop Manual SectIOn, speCifically under the 4-Wheel Anti-lock Brake SectIOn (F,,,d :v1ot,,' COll\P,lIlV, 1(9)). 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 warmngs was, based on our research, due to increased sOCletal expectatIOns regarding labehng of many different consumer products, as well as the increase in asbestos-related 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 PSHA), Throughout the pamphlet, the US EPA makes statements regarding mesothelioma and brake mechanICS (USErA, E1S6). However, the document utilized out-dated case reports, and disregarded the relevant epidemiological literature. For example, the US EPA neglected to include three case-control studies that were published in the 1980s (Mc.Oonald and McOonald. Flon; '>pJrtdS et al., F)85; -l<:'la cl al.. 1903), and these studies uniformly concluded that brake mechanics were not at an increased fisk of developing an asbestos-related dIsease (Wong. 2(01). The Gold Book also failed to note at least six different studies published between the late 19605 and early 1970s that found virtually no asbestos fibers in brake dust (Andcl son et at, 1973: Hlck;sl1 and Kmght, 19'!O; ldcko et al.. 1')73; Lynch dod Aye!, 1968). Several studies published in the last decade have shown that asbestos exposures aSSOCIated with automotive work are low (Rldkt: et al.. LO(n, 20011; BOflrer ,md Spenct:r, L003; Boelter l't aI., 2007, Cnhen and Van Ordt'n, 200R; Fmley d al.. 2007; Jiang et aI., 200g; 1\11.1dl et al., 200K 2009' Pamtenl)Jrh Pt AI, 200'i, Rlcilter et aI., 2009; RJ Lee Group Inc., 200,1). In addItion, numerous epidemiological studies have been conducted examining the InCIdence of asbestos-related health effects in vehicle mechanics between 1975 and the present (Agm!o et dL. 2000: llutnor er dL, 2002; Goo(\maIl et aI., 2004; l-tmsen dnd Meer,olm, 200s: Hes,,,: et rtl., 2004: iV1cDol1ald and MrDonald, "] 9ilO: MdbJIn and OSSldl1del', :l.OO!: NIOSH, 2002; Olspn and JeD'>el1, ] '1117; [{akf H al. 2009; Roi\"nd et ill., 2010; Splrtas et ai, 1904, Spirtas pc aI., 1985; Tcschke et aI., 1l)97: Teta et a!, 1983; Welch et al.. 2()05; WoitOWlfZ ,1mi Ixodelspcrgel, ] 994; Wong. 2(01). These studies have consistently found no increased risk of any asbestos-related disease in auto mechanics. Beyond these, NIOSH currently mamtams the NatIOnal Occupational Mortality Surveillance (NOMS) database on its website, which tracks associations between cause-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, 20ll). As a result of several discrepancies identified m the origmal 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, :1.0(7). 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, LM Kopelovlch et all 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/or excursion limit will be released" (OSIIA. 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. 201'1). 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 clothmg and respirators are required, signage should include the text "WEAR RESPIRATORS AND PROTECfIVE 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 pre-1990s were Insufficient (Fgdman and H(JlNl', 2007: Fgilm<lll <Inn BI!llI1g<,. 7(05). However, based on our research, such broad claims are unfounded based on what was, and is, known regardmg 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 mtended purpose, if too much information were to be mcluded, 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 er 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 warnmg 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 (FlJlltL C'l .11., j 999). 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 (SaL, et ilL, 2(11). 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-related disease in auto mechanics. the language on these warning labels proVided end users with mformatlOn 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 mountmg scientific evidence that did not support the association between such exposures and an increased nsk of developing mesothelioma, lung cancer, or other asbestos-related disease among auto mechanics. Conflict of interest All of the work associated with wntmg this manuscnpt was conducted without outside financial support from any automotive or truc~ manufacturer or any group assoCiated with brakes. automobiles 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 mvolved in litigation involving asbestos. At least one of the authors has served as an expert witness on asbestos in the courtroom who was retamed by automobile. truck or bus manufacturers. Acknowledgment The authors would lil<e to specially thanl< Ms. Claressa Mazzetti for her assistance with this review. References ACGIH (Amencan Conference of Governmental Industnal Hyglel1lsts). 19461n' ProceedIngs of the Eighth Annual MeetIng of the Amencan CounCil of Governmentallndustnal Hyglemsts. ChICago. illInOIS. ACGIH (Amencan Conference of Governmental Industrial Hyglemsts), 1968 In TI ansactlons of the 30th Annual MeetIng of the Amencan Conference of Governmental Industnal Hyglemsts. St. LOUIS. MO Agllliv :\. CfJlIl.iicz C.'I. Bkda. MJ. Ramll ez. J HCI nant,cz ) .. Lop. l. 1 CaliCla. /\ PanaJe;. H. 'lHugut't. D. L'lOLu. 1\, BcitlJJl M (.0n2.11~2-MoY,l, j,E' lCuD Uc\..upaunn J.H{! llsk (It mJl!gl~dllt p!(,lH~ll mcsotlldtcnlJ t\ :::J.')e-(f)ntj(~l ~:Jd,./ 111 ';Pdlll Am J lnd. ~vlpd 37, 1')D-HJ8 I\ll Hygwnl.' FOllWidllOJI 1'141 Dlgc\! Ul 1,\([U;:I1<' HY~lcJl, 1\11 l1n;l1><lt Fonnd,)tlt l !), Pli!shl'!gJl P.A.. Anderson, A.E., Gealer. R.L.. McCune, R.c., Sprys. JW .. 1973. Asbestos EmiSSIOns From Brake Dynamometer Tests. SAE Techmcal Paper 730549. Society of Automotive Engineers. Warrendale. PA. ANSI (Amencan National Standards Institute). 1976. Amencan NatIOnal Standard for the PrecautlonalY Labehng of Hazardous Industnal ChemICals ANSI Z129.1- 1976. Amencan NatIOnal Standards Institute. New York. ANSI (American NatIOnal Standards InstItute). 1991. Amencan NatIOnal Standard for Product Safety SIgns And Labels. ANSI 2535.4-1991. Amencan NatIOnal Standards Institute. New York. NY. ANSI (Amencan National Standards Institute). 2006a. Amencan National Standard for Hazardous Industnal ChemIcals - PrecautIOnary Labeling ANSI Z129.1- 2006. Amencan NatIOnal Standards Institute Inc.. New York. ANSI (Amencan NatIOnal Standards InStltute). 2006b. Amencan NatIonal Standard for Hazardous Industnal ChemIcals - PrecautIOnary LlbelIng. ANSI Z129.1-2006 (ReVISIon of ANSI ZI29.1-2000). Amencan National Standards InstItute. New York. ANSI (Amencan NatIOnal Standards Institute). NEMA (NatIOnal Electrical Manufacturers ASSOCIatIOn). 2007. Amencan NatIOnal Standard for Product Safety Signs and Labels. ANSI Z535.4-2007. NatIOnal Electflcal Manufacturers AssoCla!Ion. Rosslyn. VA. AY1?, T.j, Wood, Cl. <;('11111.111. RA. "vlcClr>hy Rt.. 19%, RJ'h pelcepll0'1 ,101(\ 11\:.hdVlOl,ll ChOK(l lnt! J (Ogll h:~{)nOlll }!, 'i"i-SJ, Bt'ndl>' 19T-l Rf'H(fix Hldk(-"~ MdlHldi H'lm~yv\-'e!J, F1Ylld OH. BJc1kt~, \.~ L, L\plsoll, CS, ! {,H bhun KO., 20P8. EVdl~JallOn ot d)be,\lO:'I Wttillfl. thl:' rlUlnmotlVL~ rt'>p;w Indus-tr\!' A slwiv llWt' Vl!1g !NlInV,]l of LOm~~'n[n;:: body ~ed!Jnh dnd d! wc dutch ! CpLl(CrnCi)l Rcgul To)< ](01 Phd!!flJ.lOJ ~),:~, 324--331. BJalw Cl., V,m DI den, lJ H BanrlS1K "vI IIdl ill>on R D 20d 3 Al;-IJOrlw asilcs'os (ODcentlJllOl1 flOm btake ch.:mg!!lt'- does not exceed pelmlSslble l'XpOSUJ(A i'nm Hrgul l\)xlCoL Ph.lunacoL 'iX, S3-70. BO<.-'Hl..'t, F< ~p.. mpl.J, ~:orn CltPJPtll~1reLJlnpnll'nt \hld~ An ~~1:,11udlj11{l ot rllllh)ine J<>IH~,>to.:; !~X!)j)'>lUI.. {It!! ll'l,g rn,llnl ('tl..-ln(l' Llnd rep,HI of (atf'riH!!Jl eqlHpmC'JI! Penua !.l.. Bo{,tt([, !,VV ~pPlh.e!, J\V, :\[!11n,nn\ C.F, ~~f)07 Ikon'! eqt'!pPlt'nt tH,un!('j)(l,;{e expo:.,mt~ d::..')('~smt"nt \. ~tn;~ (1 tl!TII"-d(UV!lY !1wde; tL estmHte )Ull(JV~ll( \',llL{,::, fL)) It'''pL~k'l'JnCnt ot n11 <.,<.,1 ng: d~)l<' ! (It'CUP LnVIIL)f: HuJ!!rU, ]\1(\" Lob, :\,1,. 191) }{1~L vt asbe~tu,::!') In \1'vfJ.:-kel<J hnmg's )(hwev 'Vled. \:V~ChL 103, 13~1~] 3j9 Borel V FIbreboard Paper Prod. Corp. 493 F 2d 1076, 1973. BUlck.1985 Group 5. Brakes. m' BUlck. (Ed.). ChaSSIS ServIce Manual: Vol.l. General Motors. DetroIt. MI. pp. 5 1-5C3 5. Rutnor, KJ ' S'h<lr!!],t, 1\, SpOl 11, I A, Noggl!, \/ T ,200;' 'Vl~ 11~.ndt1f Ilh',>othe!J,,)ll1.' "lId tlC<..Up<ltH'O,l! t'}'P{'S1!{('to .1('IH",tO" An ,aH,11ysIS ,\l !...t4S (t\\P,:: A'ln Ol..tHl) :"l\~, 4t}, ISO j:J L 410 L.M Kopelovlch et ai/Regulatory Toxicology and Pharmacology 68 (2014) 402-411 Chevrolet. 1977. SectIOn 5: Brakes. Vega & Monza Shop Manual. Chevrolet. Detroit. pp 51-530. C!Hy',k!, 1<")Ti nu y\ler <}t'IVICP \,1anu.Jl rlHy"j('f ;'vlotnt (pi POfdttOn, ClhH lotlE', N( (pi1cn, H.j, \liill Olden. D.R, 20(18. A~\b(~)tl\) expo::.un"~l of fnt'ChdfH(:, p~~l.rormm~~ l'lutch ,,'I VI( P on motor vetuJc,. I (iUP LnVlnlll !-Iyg. 5. 148-1 Sii. (JHll, ,\':1 > ft18G A<,!Je\l"}') .:1:1(1 dlC,(:<bf- /\ll mdu(,~flJ! bV~,lem~,t\ PCI-;pr-ltl\:P Am, lot) llyg !\ss:x. J' 4/, :d~-:))3 CPSC (Consumer Products Safety Commission). 2008 POIson PreventIOn Packagmg Act (Codified at 15 U S.e. pp 1471-1477) October 14.2008. Umted States Consumer Products Safety Commission. Bethesda. MD. ';"llal! CII Rral'I~' Se-rvH(> MdHl!dL !7i) 1,j' Udf;..'d, !97(, (Jeneral fvktors, D('tHJlt, ML Dfllwnt.J M, HdW, 11. RI. 'iymcll, kt!. \liy. C 1\:1 l'lWJ l:xpo',lH!'. ,1110 nlOlIdlilj -lllltlPP 0:. hrv"-otllf' <l"-bp\H.l~ WOlk(}I<: J\l)! J: fxp:)stHo;' e~lmMk" Am J InCl,IVkd 4, ~()9 419. Drf'('<"~d), '0J C, DdlldVdik, I Tvl, fdw<H(j), T I, rvlIHf!, J \,y" Sd'y(')"::, RR, Fasom, H F, ~'r L~, 1V 1" 1c)3R /> or A.sb(')ttlSi,\ m rhe i\:;:iwstos !\::.>t11(-, lndH)trv U \ Go\,< p, n1t fl'~ nHH'e, DC [~l~l'ndF;, (), }IO\/vc ~" 200/ Af,diHS: a!lLI i1eaLh CptdCHnoiogy COl(HJfdlC ol}stru-::Ucn 01 PldJIlC he,11tl~ VIa !llJmpuIJtlop of epidelTHOlo2;V Int J UC[UP, I'nvtwn He.11th i;, 118-124 r;l:~:!~d, D ~, Bdhng" M A, lOO:>, /\iH.JM:' <.JI (.'pld"!!H()lo::sy ,1utomobJJ\' llldllULH,tuE(,l:" llldout<H,nnc d dvlf'HSC to ,h )I.")W'> Jl<lblllty F:{!v~rpn. Ht'dltll ' !, '360 ~71 ' lnt. J O(lUP F:nkt"/')u"m, M :\'1" [98'i ~j!'{)!l..-dILV 'HHnng li>!l!~ let!H empJl)vet'> nj (1H Ontdlio d',b('\t():', (('men! tdtlory BI ,Iud. .l\1(--'tl 40, 1')0 144. rmlev, H! . RH htt"l I{ 0 MOWdl, f 5" \'1JJlqdlt~k, ~, Patl~tenbdch, f) J, \lV,llJncldarll J 1\t1, 'Sh':'chdH, f'J, rwo! LtlHUtidtlVe d~besLOs e>p('~ute tOt 115 dlliomoblle mo::l.. h<1 !l! cc' mv~)lvl'd tn blr1kc lepd!r (td"(,l 1(3'1(i::,- lOUU). I LxqYJ ".:,(~ fnvHon lpl\,krmol 17, (JlI;}-o5S. l-rJ!d !\10tOl Company 1~)75. '} cchmca! SCl VJ(C Bul;cUn' lord Paris and ~('rvicc Dl vlSlOn g,Ii!~'ll 1NurniJl'{ q() UdolJi'f 24 I w;S, rUH~ \1UtOl CUillp<1r~y, hVfJnl,1 ;\111 ~f~!,j f\if,AOI CU!llFtlny EFn vr'dmH~l, :)dV!ll..' Bulk-till Bulh !Ill ~~{), 93~4A, rl'ilrhlIl, !O, 1')9'L hlld Mo'orColltjl,my. LVOIlH ML .lIlTi'., JP., Rhoadcs, TP, 'y{IU!l~':;' S;, S\huH'!, J,/\, l!)qf) POt!'11t!,.11 pl{)blcll}~ ~l<.,s{)c!,ued wi!h ov;;,{usmg 'NcHIH!lg''), Pw('(;','d Hll',jfHl Fact f:lgilll, \o! Ann c.c. fvj,'lI 43, g lIi 970. C'H)<im,lf} \11. TCOld, M!, Hi'ssel. 1'.'\, Clrdbl.lnl. [) H. Ct,Well, V A. SCl.lltord, f(-"lsh, M f\, 2E)04 Mt:'snUwlwHl<l <wc! lung LLHlle! ,~m()nF mOLOr \,t.'"hl( \e meclldl1lc) 1\ metd-anaiY5ls Ann Ucn!!] lly)..: "18, ]!J9-,)2h Gosselln. R.E.. SmIth. R.P.. Hodge. !-I.c.. 1984. SectIon 11. Ingredients Index. In: Gosselin. RE. et al (Eds.). Clinical Toxicology of Commerctal Products WIllIams & Wllklns. Baltimore. pp. II.1-II.460. H,l!l\('l1, J. lVkel :..ohn, A" LOtr3 (,111<.(>! !iH>1 Ullty dll1(Hig D.:!n!~h emploYF<.'" : I f)70 J99T V>" mdu:;tlY l..!J.\\!ftc;:lu:m [f(l,kfr.,yg('llg!wl! bLmdt dd J~kE) lr)II{\1{)dLl~_WI\ (1l)70 97~ fOld;,>!! P<) Adh !(l:.u!<;ynel ~ 4f) bid!\{ 1lt."gl!!ppeJ 1 In\(llut !d! f.p!delJllO!oghi{ Kradl1m~knlng, i<r,Wfl('h\ nd,clClnpl'l'>l', Kobcn1uvll. Ht'Il<iPI'.Oll VI.. ["I('.illlP pr" 1979 A,h",1O'_")<I'''''II(' f,llIO" ,h\oOdl(,d Wllil ex(e~::, Cdnter <mod res;::nrdtOl j dl~t~a)t' 1nOl tahLY Arm N Y A( ,3d So .3 30, 11 ~I l"li rH'<;;:;e!. P /\ 1eta, :v1;, (,:.wdman. M, L~-:;u, L, 200~ Mc~othdIOma Jf[lonr; bidkc me,,'hd!1!C-S /\n expandcc: anJlysis ot cl G,(:"C'-C< ,nn l)l ':.tudy Rl<;;f !\ll~11 21,547-'):)2. l lCksh. D L !\n:~ht K L, 1~}70 lxposur(~ to asb\'stos ctunrlg brake mam[CnJflCC' ,\111' OcrUF Hyg D. 17 21 Hosey. A.D.. 1970. Development of cntena for standards. In. Amencan Conference of Governmental Industrial Hygiemsts (Ed.). TransactIOns of the 32nd Annual Meetmg of the Amencan Conference of Governmental Industnal Hyglemsts. DetrOIt. Michigan. May 10-12. 1970. American Conference of Governmental Industrial Hyglemsts. Cmcmnatl. OH. pp. 58-62. Jacko. M.G. DuCharme. R.T.. Somers. J.H.. 1973. Brake and Clutch Emissions Generated Dunng VehIcle OperatIOn. SAE Techmcal Paper 730548. SocIety of Automotive Engineers. Warrendale. PA. Il'w;:; (, L Madl. A k, In;,mlmd',,)I1. j{! ' MUl hdck j) lJ,,1.. l'el1illl)' K A. 1'.1Ustcnbd( 11, l); .. l'mlcy, B L 20uH 1\ ':ltudy cof dlrhc'nJc cl!lV'htdc ((mCentlath~ns d'l'loGatcd \I\-It11 l1all(nql~, unpacking dnd iepZtChlJ1g hoxcs of llUj"Oll10blk c1l,lrt! UISCS R,guJ '{OX!C{l\ Pha{m~1tdl. SI 8/"::)7. Johns-Manvllle. Undated. LISt of All Worker's Compensation Claims or Civil ActIOns FIled Pnor to 1970 Agamst Johns-Manvllle CorporatIOn: Response to Interrogatory. Titled ISTCLAlM.STD. L,q,?,t'!, A r'v~ .!.Uri R('dllCllClI ot th\" lHl'lo~,!( <11 1}1,trHtlfl1 of dllY"l)t!lP ,hht'::.tu.;.. <Ublllg f!om (OndnlOns ill \I',V1U" cm Inake pd':~ R(,~~HL ruxH.cl I'hdIIll>1I-OI, 'iH 11- if. Lloyd. J.W.. 1975 Asbestos: Asbestos Exposure Durmg ServlCmg of Motor Vehicle Brake and Clutch Assembhes. Current Intelligence Bulletm 5. August 8. 1975. Department of Health. EducatIOn and Welfare. Pubhc Health ServICe. Centers for Disease Control. National Institute for OccupatIOnal Safety and Health. Cmcmnatl. OH U;llHWl, 'vV.\'" RI1Ll, AN, fVllJe. i\, :-\bhoholl, \/'1J, (;('hkoH, LJ, 1!)76 expo')ul!' \!f LHdkl' {('U,lll WUI J,.(>{ '; III rh( lJlllted 's't,H('~ Mt Sllla! J, rvkd 218. Lvnch j H, AY'>'l,!! E. I Qt"};;<' :Vle<hUldnenl 01 ,bllt'>st{)\ expo'.uft'" ! O(ftl!) i\,b(,~IO'" -*~, 207- r"h'd 10, 21 24. Madl A K Cafrnev. \ 11 Balzet. It., l'Ju,tenbach D" 2009 AJrbortlt a',bcosl", Clillcntrattons ,1S)ollateci "itl1 i1edVV eqUipment hake Icml'hll A111 I CClU)) H\tg S3, g'Y)~85'/. ~klctL /\K, "[II!t, 1..1> \iur!),xh, D\1, Feliitng, 1(,4" f!'J;{~y gr, PJ.lhlt'llb,H!l, Dj, }OOR f'\po',l.lIt" to I-.hrv"oufp (hbE,qq~ d,<.,o({(itrd V/ltlll!PPddwli! ,H1d It'";)rl:t<ln~ bo}"p', of cmjornnhdf' br~lkt'" Pd,j-: ~ul(l ;hol;;'''' AI!!"> O,-Otp Hyy ;7, 4G'~ 47CJ Mcutoruk, I I" N,,~dl, L. Cru':"~lnMl, E., 2001 I ht"' hl\u,f\' of OSHA\ a<.,bc:::'loS !Ul('mdjdll~~ dnd $pl1W dl')Un(tiVe apPloadws: thdt tht~y !l1tft)dm.L"d tnt !egutJ!lJ'lg 0 updllon(11 expos-ure lO WA!L' )Hb~td!l(C<" /m I!:d H}fg A,(,~OC 1 (;2, :luB-21 J. MCA (Manufactunng Chemists' ASSOCIatIOn). 1961. GUide to PrecautIOnary Labehng of Hazardous ChemICals. Manual L-1. Sixth ed Manufactunng Chemists' Association. Washmgton. D.e. McDonald. A.D.. McDonald. J.C.. 1980 Mahgnant mesothelioma m North Amenca. Cancer. 46. !V\(C,lath. LM. 2011 Th(' IOiL' ot ecjlll[lII1"I~t Wdll1lljp; i;'\)"Io m tllP rnjlhlll.l1 \VOdq1L1' Int! j Ou'up S<ttelY [rgon 17,40 GO r.,:ie!(~weltwl, E R.f\, PI Ice, (,\V" !930, Rt"t)()l t IlP F1lce t<., o~ ,A,~bbiO~ Dl!~L ~1'1 ll: __ Lungs drld Dust SIlPPI('W{ll1l1llth' A:.be\lo) JI1:imtfV Pait Jand II it' \'H-'''y, \t.-'lt!ntK'IV OWn::., L()'l(l~)n Mdhdm, ~ \ O')'>tdnder, l , 2001 OCCUPdUGlld.; \1oltall~Y In \:Va<..hd!~Lon ~td.t(' It):)U1~j99 V'/,1shJJ1~1L)n St."ttr D('paltmCni 1.,1! Hcal~h, !.Jt;Kf' er t~plcle'l)}Qln~\', Olympta WIi. Ml,lphy \-A./j 19J'i,fdltofLJl Ia!wl:',~At!Olllh~'ofpn.'v(':)t~{n ~ f\glit. }ood(J}",{t I, J'i'J- JS'J. NEMA (NatIonal Electncal Manufacturers ASSOCIatIon). ANSl (Amencan NatIOnal Standards InstItute). 2011 American NatIOnal Standard: Product Safety SIgns and Labels. ANSI Z535.4-2011. NatIOnal Electncal Manufacturers ASSOCiatIOn. Rosslyn. VA. N!OS!i (\Jdt!lJI1.l1 in~tJlUle 101 C)(CUPdtH)l1J.! ~~lfdV apt' Hc.;.lth), 191j ;\.:lmult"} 01 (}(lHp.{tlOnal txpu':.UlC<., lO A(.bf'~{(J'" Du':.t from BI<!ke linIngs fVlL'etm'~ ,1Lly)' j()75 ~"JtJ0n..1[ In:5uwtC' tor Occupational )J.fctY JPd dedlth t\tlanta, (lA. NI()SII '\JIIl)I1:li Imu! Ule 101 ()c,-upJ! IOl1al ,alct v Jlld ilcJlri') 2002. >H(j~Jj lie/Md Ri.'Vh':/\! Ht'dLl1 Eff,'ds of OU_Up,ltU)!h1! I:xpOSl!!f.' to l\l::"puJble Cly':>nHll~,' ')tll( ,t" :~002 Dl-11 tnwnt of Hi,;'-Jlth ,lnd !'-hlll1dlf ')('[ vtlt'--, (ente '> !o: 01'>'-'.:--" (ono!!] rmd P!I-.V,ntltlP, :..idtlOllal fnsfltu!(' tOl C)(CUP,Ht',l1al ~aft>{y and HCdllh Cllldlmdll, OH. NlOSH (NatIOnal Institute for Occupational Safety and Health). 2011. NIOSH Safety and Health Topic: National OccupatIOnal Mortality Surveillance (NOMS). <hUp :/v/WIN ut( gov/JlIO~h/tol)j(::'/~U!vt'1I!dn(e/'\00.:1S!1~ ethod hun!> National Institute for OccupatIOnal Safety and Health. Cincrnnatl. OH (Updated 1.02.2011.) Olsen. J.H. Jensen. O.M.. 1987 Occupation and fISk of cancer In Denmark. An analYSIS of93.810 cancer cases. 1970-1979. Scand J. Work. Envlron Health. 13 Suppl 1. 1-91. O')BH ~Oll'gon '1rdk BOcHd ot Health !~}4S Ruk" ano R\'gulawdl> fo! (l,e PH'vl.'nllflU iUHi t flllt! uj f,j Ol..( upatlon,i.! Dhe.h~)S 0[\ gon Stil!(' R~"1.1d 0;:' nSfL-\ \O({Ullflt!{)n~!l S,}k!y (wd Hhll!h !\:hHl!!!~OfH{{;n:, 19~'1 ~<lt!Olhl: COll\d)',C-, SI.llld,\t(1\ .lnci Fsrdhl"'II'd Ft'deldl St.ln(\,lI(h re,l Rc". Hi 1041ili 10,(1) ()SHA IOlIpJllOllcli ~diL'lV ,lnd Heallh Adllllll1:.tl.}llOn. 1,,;, Sr-llldc"d (01 t:)'p()~ute to A:-be)LO~ Du':.! led Rf;~. 31 11313-! 1322. OSI U\ ({ )ccUpd:tll..lll~11 ~Jk:tv and Health l\dmIHlstrat!(Jo', ~ 98 J OCCllpatJOr::.dl t Xp{)1:.UI(, to Jsb('stn<..' r.nwrgPI1t.'y lempOld!V ')~~lnd(uc fed R('~ lW, :')]036- 5 J 110. O~H!\ :On'up~11j(lnd! ')illety and f!f>Jlth Actmlt1l5t!,HIOr', 1986 ~)C({q),ltlOr:Jl Lxpo<,un- 1G /\s!}pstos 11 rnl011te, l\ntlwphyJlIt(', (:nct l\\~tUIO:t~(', llC'31 Ht!!'-'"s red lkt :;1, "2()12 :!'I7S!O OSHA ~(kt, HVdtW!ldl ')fltety ~lrHl HPdHh Admtnt"tJ -It!o:'l, 1t)'-14 {)(( !'PdtlO!U I f:xpo~un" t/, A;;lIP ,to'>, r~nrll Rnl\"" Fed Reg, )q 4()qG4 4! I G2. OSHA (Occupational Safety and Health Admlmstratlon). 2013 Califorma Codg of RegulatIOns. Title 8. SectIOn 5208 Asbestos. <hllp. www d" d )'cv:[r:I"S, ~)2U8 iltml>(Accessed 11.06.2013). I'Jllstl'nbd( h j) I hnlcy, B L, cu. L I. \)fOl by, C f', SheI'h,l.l ? I, 2001 f nVllf)nmentd! <Inn ol\'updtlmh11 llC'dlth h.tldrd') J,),){'>d<lt<:.'cl v./lth th.: of as,l)(-qo') 1J1 bldkc hIHflg'> Jnd pdds (1(}()O (() plL".'-onr;'!\ !CVI('W Jf 1'oXJl-.ol fny,ron, HCil1tn U lilt, Hc\, 7, 2:)~KO, PdUq"lIiJ,lC It Il J' RlciIlpl. R 0, hllll'Y. g,1 . Shpdull. P J,20(") fill ev,llu.lt}<)l1 of (h' ht'hH:(cl! t'XIHI"ut~'<" of llw(h,m;;,c, to <l'b('~!u<., in ~)L)k\ dU':lt t'\ppJ O~(l!!~ FnvlI on Hyg !g, 73t, 804. PC{ kl1,nn, {~, :lOne}, ,,'n O'.:f!VI('\iV of Ill(' f\NS! 7,")'),) Qrll1ddl::!" lm \dH>I)' d!ld t.(~g'" in \A/f:gJll(~L ~vI \ (Ed I, Iidlll:hooL III \.v.HnlIH~<" flun!<U! ;dh!'" lOt:, fmd ll,~onoHll<:'::', L1VIlf'IlU' [tlh~Hl!ll A~::-()(I,He~, Mdllwdll N, pp 4{7 441. t{aj"l" C, Cllham, C, liJl(h, I , Darntun, :-,\" Hudgson, 1, Pl'tc, J ,200~1 OUPdtIOlldL dO!l1e<.,n( and t:'nvlrl:-l1JHclltal IYH.'s.:ori1eh('lllld nsks In tr12 D!JtISh popul~H!()!-: A c<1<;e-(olltiol ~tudv Br f lLHh'l'r luU. 11';:' 11B3 RKhtct, R 0 l'lnlev, B L. 1)aush:nb~1(!1. [) I, \Vtlilams, PR, <;hechan, PJ 200~~ An I.. vdluauon 01 ')hOl t-tCI m ,'3<..POSUI cs of buke nH"d~an{cs to dsbcc;tos dUfh1g dtlH.Hll{IIJVf' ~1nd tlHck brak\' rk~dnJl)g and 1Y!<KhH1ll1g ,lCtlvltlC'\; J r-.."pu ')() EnVllnn j-pl(k nl!~)l 19, iSR~ 47 t RJ Lee Group Inc.. 2004 ObservatIOns durmg mspectlOn of manual transmIssIons. Project LSH307891. Roll<met, P CI<llHond, C, L,1(OUll. A /\<';lcul p, Ch,H11.Jllll{:' S, Dllcdmp, S FWlkt), ( ,(,<1Idu',1;.t :-'dllt\ r, n,~, A.c', Imlw-li10Il, 1 , I e ~~,lns~, ~~, Pdlrnn, ! l, C()-l<.ilw:~;, M, UlCH.. halcl, P, 2UIO Occupatlon5 dnd mdu5tllc) m hanc(' Jt hl~h fisk tor pktn~lt rne"othL'hoIThl' ~l populdtlOn'based C.))l'- uJntloI :tudv J~!93-2CtJ:: Am I Ind \1cd S3, 120/-121') LM. Kopelovich et al./Regulatory Toxicology am! Pharmacology 68 (2014) 402-411 411 HUl!""eau, l..J\, VVogdllel, vi s., lOnG, R{~"e,H\ h I'll watnmg s!f!.n., i!1 vVog<lth'c:Vl S ~rd,~, H,H"l.dh{Jo\( 01 \Nclllll!lS'" Hum,m F,l(tol', <lnd F1soncnlJ('" Ldv\'I('nn' f:dh<1lltn A"rj{IAlt',. \1.1 I1W.1 11 , N J,PI' 147 1'i~. Sa;a, I B, NlChols, EA, :Vluilammad, R, Lakhlam, S [), l(.ldSdIPnD('ii"'" R, Wood Cl, 2011 Covelnm.ent. wa.nllllb~ ar:d )dfc[,! mtorm~tll)l1' A cnmp.::n')on 01 lflrc'I-agen\.'v rc~ulan0n$ Jnd gUldanu:, III K.uw0w!'lo, \V) ~alv(,~ldV, (; J.ch,), AdVJl1Cf.":; !P lhHnan F~l(~OrS, F{g0n0n1IC\, and (),J.tcry m VldnuLlC(Uim~ ~lnti ()f'T\'I( e !ndu'::tl !C"S Td\dcl fZ: 11,111(1,), Bf!C.1 i\dicn pp llH7 -1tYiG. S( It!>.!, r. r, ICJhl, rIle t{,l.k~>l! h,\.,..(~,d\!lt\ \l,~~htdJl(' iJbf'llllY, dC! Tlw BH\nW"~ L,lWVE'1 17, !'~7 1<)b. SpjJl\nH LJ, (jl(!! g J. Hdn1Pl{r!id, f C, i 9(14 Aslw- to~, ~:'XPtl~U! (~ dnrl ncOpld"lrl. JI\fVl/\ 19x )2 -:L/") Spq~d'., l~ Hetn~'n1,-1f, t r . B(,Il)')~cm, L r,p,... b(', {s \''\/ , J(u'iln, i~ I, ~t<lr;z, A, II.n jl'W, H L, HCf1lclwu, I, 1~J~~4 \idllgndll[ me'JothcllOn1J Att! !buu.bIZ' 1lSk of dsbt',tos CX!Jfj$U!c Occup tnVlf(l" Mej 51, HO 1-1\ 11. SPlrr-lS, I{ Kc,'hn, l{ VV1H;hr, W, SL1ik, A, HeeiJr (" D!ckson, l., 1<)8'), v}('.;;;othf'11l 1f11.1 !lsk rpj<lh.'D hl orcup?twnai O! oth!...'l dsbestos <,'X:POSUil' T'tt'lttHifl,lry [('~t!I!<J hem r' {d')('-(onnol""lUdV. !\I!L J, i:pHkmlOL 122, SIR. St,lt? 01 Clilf"im,l, [l\'(1dllrrw:'1 of In(\u,,:!ldl Rd,lIlO11S, 1945 Duqs, f\llfl~', Vdl"'!) {~C(j C<~.,(~" Safftv On:1-',[\ lhvl"lOn qi llHln,\!rI<ll S,-ttf!Y nf !h.;-' SL1!E' at C,11tfplnH, ;J)) /\Ii~,d('). Te,cllke, K.. MOl!:dll, Ho.. (!'>cdmwdV ! I., "'dnkim, (" )jJn;eih ).1, v,m Belie, C, Vv'e!ss, ~ S j{;~;/ :V1esot!~..?lioma surVelllJ.~ce ~o iO(Jre s:ml:CL'$ of CXPO,)UlC hJ ~~sl;C'c;to,:>" \..-J.n J PUb!H Hcalth S3, 1(13- J GB. T~ til, !\1,J, 1cvv;:hclm H C, f.1r g:--, J "IV, Vld~II~r. RI\., "v10VVdd, L/, !:-L.ll1Jw(v, j.l , P);'B :Vh.'':l(Hhe1wmJ m C:mnC't.llcul !9J:J- 1f}]7 O<.cupdIlOn,)! ,1nd gC'Ogldph!( J ~S~{)(!<ll 1011':>" O(('IlP, vl!'d ? J, 749 7"16. J(, , Tho' lj">ot1, f<d~1 llulrl, Roe, Md( fh)llcHd, R R 1Qt)'1, A",b<'\! (j) d'). d modt'i II III b.-l!l hUilnl S Atr "v11'd I 37, 77-81. US Congress - 74th, 1936. The Statutes at Large of the Umted States of Amenca from January 1935 to June 1936; Concurrent Resolutions Recent Treaties and ConventIOns, Executlve ProclamatIons and Agreements. Vol. XLIX In Two Parts; Part 1 - Public Acts and ResolutIOns; Part 2- Pnvate Acts and ResolutIons, Concurrent ResolutIOns. Treaties and Conventions. Executive ProclamatIOns and Agreements US Govt Pnnting Office, Washmgton. D.e. US Congress - 89th, 1966, Public Law 89-756 Child ProtectIOn Act of 1966. US, Govt Pnntmg Office, Washmgton, D,C U.s. Congress - 92nd, 1972a. Consumer Product Safety Act. (Codified at 15 USe. pp. 2051-2089), U.s. Govt Pnntmg Office, Washmgton, DC U~ longref)f) - (J2nd, FJ/2h Feeler.:-!! Ll1VllOIHllCnrJl Pc~tJlldc (onnol Act of 1{J12 f\!~l('r.dr;:';.cnls t"'-j rE'c!~'lJl I nVlrOn!nenttll le.'~cctlnde, l-wHpocl..\ apd RoccntlC!ck Au, U" C i' U, Wasl1lllp,n. !J.C, dn!\!lnv,m, 1()4~) A GUide t01 tllf' rIl~p(1{d'WJJ 01 WdlnJn~ L-lbt.~j.., rO! Hd/d dOll":; Ch(',llJ~dh Ch('!!l f-n~, N(-'w,,> l\rcll (), qtl: qq6 USDL (United States. Department of Labor), 1951 Part 1 - Safety Programs Pay DIvidends Safety and Health Standards for Contractors Performmg Federal Supply Contracts Under the Walsh-Healey Public Contracts Act. U.s, Govt Pnntlng Office. Washmgton, Dc.. pp, 1-23, \.J:::'l:h\ ~Cn!lcd )tJ.tC'':l I'nvHonmenl,11 PlOtcctlon t'\gen.:vi, :qg~) CWda,lC( fh P!('\/cn1mg- t'\':;lh.,q\l$ f)[,>c.)')t' /\mong Auto f\'1cchamC''' LP/\-5GO-OPfS RC) 002 ! (}gb Olllu:' cl f\~"tj( u\p,> (~nd TOAlt ~llthl,mu~},,> ,~\bp\lO~ :1.,{ ;ton P!O:=';' (~ n \Vd':llUG~)OIl, D.C. USEPA (United States Environmental ProtectIOn Agency), 2007, Current Best Practices for Preventmg Asbestos Exposure Among Brake and Clutch Repair Workers, EPA-747-F-04-004. March 2007, U,S Environmental Protection Agency, 'Washmgton, DC VISUlSI, 'vV K, PJ!)(j Indnndlkl.i ratlOnalttv, hdlard Vdlnn-'~'5. "H1d t!1C toundt1tlo:-:'} ~!f ldlt Liw Rulgl'rs L J(,'v, 48, b2'i-fill x \NC'!!, f\'\!, ;\,1,~[a.(" LB, 2001 ;"v1orpholo lfcli chal<l>..'tr--!stlC';;; of asbe\;!O\; hhl'F, ld('c1'cd dwmg f:I!nILng dud dllJJlHg or !O((il.Hl pwd!'; r'? J\ppl (1;.,tUP Fnvllo,) fiy~, Hi, ,147 J 149, V\f(.lkh L2> AchPflllrm, Y.l, lldIie, L, ')Ok,h, R K, SlWdlb"i(Pl :"l H ,2()O~) t\\be-Sto) dlld P(~f)tow::dl m('~otllehomd <-1!l10!l~, L(JnL>~t> edu( Heel men :.It J (kt-up [nv,! Oil IIcc1illl 11, 2~1- 2"~, \VOsJ!r(,L ;"/1), lOl1?(Jla, V C )mHh-i~lCkson ! L .2()02 h:seJ!cl1~bJsed ~ll!{jehlk>~ fOl Wdtnllh~ d,'slgn <Hid f'V<1.ludtlO'l :'\p;Jl Frgon. 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