Document jgN8Jkz1j2ovjjYRYOrGra1J5

ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FORCE REPORT Engineering Staff Manufacturing Staff May 27,1980 nnoi lf?f> pprvrvr topt'i tjv -nvMSTA SCF-ALLF-08131 I, '' .EXEGL'TivE SUMMARY '-yr ' , "CAUCINOnF.NS IN THH- WORKPLACE 1 '< t- -1' c inutcriul.s andjlprocesses. In this regard, e TaskiForce Wascstublishedbythc Subcommittees to: identify jten/tWjpciarci!r>ogenstoijdj.flujahiilies:'in:;j,use.^'seitftjir(5eli'|l^or;4eUm'iatt.iio,ii,v`of' sueft'-'-; substances if possiblc ohebd of rcpulBtion. take stcps to find subsUtutes. deveibp o clireetive and workplan.and orgunize to identify and control potcntiallyicurcinogonic substances;; : Since iOctobcr. bsHA has released UsPolicy which .establishes criterio bnd procedufes for thej'ideniiJjicat'ion,1 'Cioss(ficnti^.riiriS^`regulation; ofil^oj'entie) corcinogensi;in;;;the workpiae'e;; / The Poiicv defines Category J potential carcinogens as substances known.to be carcinogenic in fttimeiwj;ori;w)tich';;jM!yo^ Bnirnalj:::isiu^]E^}!>J;i^BVeg:wy<:'--H:;;.^p^i3ne^;rfare^^Hejfe'j;pdW^f:,'krel4;suE^siiye of governingi;.use|'pffva.ipariicuior.'substBne.e-i;;j:;.i(!6i;'spdcifie:'.isuo|tahees'fwc^e;|'C:n'ieBoriM.d,' .. :'stah'dar'ds,;;prdmuiMVed;vwith^the''issiiancei;ofAW!-''Pfeii'eyv't;:!lN`ofmbi)y;f'bnce;th!e,':h'ce<S:-for a' on-stringont'VulesI ^the':curcinogcnieity(oT.a;Su!5s:ohcei:cnd!;onj;lackTof;e-cost?behe'fit>HcHte1ie!lini;the!iPo'iicyi`;'':.iThe drf.ifiii^f|cpr^i.^ite^sii&tati^(i|ii^ped;^yiiOSUAUv0'ryeo1;Bgo,!is4otl>eiT*vt8ed^y>.My, JSBO followed by a prioritized extract in September. j! Theijirosk':For,ce:hW';cdncentrated on'deyeiopingitlie' capability forimnnagingiithee'iecHlimmiinnaetilon o^^'ccm^oi:fi^^l;leg^^^(io,t^iieVfj^^np|ens^in'i!the^:vorkpliB.cei"t.A'^$tart.:haslibeen..a..|.i.e.. in i`Hilflt!ltfitirS;:enoi/Ii'.';iftwHf*tniftnC>7.fn**!'1tC(iKconilont " timin0tiOn' ;:0t control'' cf asbestos'. hexavalent chromium compounds and benzene. '' ' , ; Accomplishments ' 1 ' 11 Based; onanMVMA report, the Task, Force has identified thirtyrsix (36> substances'assocr ieted with Butomotive production includcd in the draft: OSHA eandidate list. Elevon (111 are ' , t.eurKenttlyf'resuiatedlifiy.PQSHA ns potential Carcinogens; tlie bulance hove'potcniial tor new-!' regulation; Tlte^iisrof substanceswesrcviewed by the Task Force consideririg impnct on the :' Companyand. potential for further' ,regulation' res:iiiing ;in; definition ;of ';ciglu priority '^iscuoisVan6<es^-^;frhe`ililscHest:-^iribrijty iiRj^tu^ees^:A*Mijm^iwxiay)enV,ie)wc^iun^'.eo.mfHwirtdB'-.and|f ; bcnzene. were examined by-'identifying; application to-materials and ports ahd assessing ; - .- r^ojuldiltty-.o^.j^tt^t'ltutioA.;; /A..-'ll5t^o/c[iiiso^t<^p(<bd^tietn>flria'ijerIiilitti^?t6ech- deveJ-1"^. r :b-dpcd::-.;dnd,;TwvrBr>ded:itd;-'fmrchdsing--:fd'r::;supp'lieriyer;ificdtidn!jof';!cidnVcntT8nd;%ypilability;' of ;h:p6ssidleltsubstitutesi:`-' Jjic'i- benzene. '' y \ analyzed by tho-product offices ond Manufaciuring Stoff lodcfinespecincpartsusoge. J , . i Slratettv and Workplan ', ` ^i fisbest5*'^BShyalent'chromium:i,compounds;;nnd benzene'defined 0; > : ipreiimi^iiry/^tnetcombictc c^^p^^Linjhd:ma:usr,laitf;eontai^fn^'tH^disubstaii%(;as';lliste.<l:'-' ` : were judjierncnt!iijly; catcgdfizdd intoi three, groups: ! ! known'substitute! material' without1-' major redesign.' known stidstitufe ImatcrialV wiih. major :: , 'r^|e^jgni;w^'cm')iu^wn;%ubst:itutc'Wii'ij,^tWenecd'ibi^inb^ ? )~y-,C- y . y J*: rS'uchs;iialutionC*sa'_tego~ rv nR.rAodiiction AMt.n. tcrlnls/Piirts^ !? :LN1 ohni^btltifttioh iMt .niitAe.r.:lntls/nP..arts AsIlCStOS ; Chromium ilenzene Asncsio1. Chromium. 'Ilenzene , A - Known wilhout `redesign : /yrz 8- Known Witii;!rcdosign;[^ , /i'-Vit-'/!.--- d. 2fi " 22 - >8 ' 8-1 ^V'-! - 26-;-.: K. `;.r s - ' 4 : v-l-;!' , -aoivv' MN 5 8 ll<-;'.-'::r>x ;; 8D03 1623 PRODUCED BY FORD' l-.fhii ; ' , 2 - 'I yI7>e rollowins strBtcRj'jand timeloblc ore recommended for asbestos, hcxavalent chromium; ? compounds undbcnisenc: pv v'"/ ;r .; for' eppticiitioriS iW'lth, known'jut>siiiute 'maierifli$ <not .requiring major redesign, ,' /; - eliminate if appropriate try Jod gl,198&. ji. : XXK .il'-Jr'v-.~; -.V ' J ' For; appifeations ^ with knownsubstllute materiBls but requiring major redcsign. j : eliminatcif appropriate consistent with cycle plahs andiBCility projects. /. i;,':;. ;'-X For applications K-ithoutSdcfined sutsstilutcsi advahccd engineering will be required - before oTstrategy and timetable can beidevelbped. ! j!;-'1.' Ifelimtnationisnotappropriateor,possible^provideBdcquatecontrolsoncxpbsure. 'i 'll' Strategies and timetables remain .to;, be developed. for the balanee or'the eight priority potential carcinogens. j Aigenftralizcdj wbrkpiaft has been prepared on the basis of thal eyaluatioh ipf ithh substances - referred to above. The workplan requires central program :mana|e.mpnt?;%thShetjIph;: implerneniationbyNAAO/DPOProductEnginecringOffiees.PurchasingBctivitiss.Product Planning,! Vehicle activities,': Manufacturing activities, and^ thl^MaftuYa'eCurii^.:|a,ii^ffSupi>fsr^ Staffs. The workplan timing requires one year to define -the : uses' of o ^potentially , carcinogenic isuDstonce with elimination requiring nwo rbddiUonBl ' years ifor e suostance;: `ibavlngjiai known subsiitutesWith mosi major Bredesign.irequiredv':^^:For"fmAteriBl` :eppiieaiiohs.:; : requiring major "redesign. the timingiia, .consistent with new product phase ;V timing' of 33 >roonltis.for vehicle ond'45 months for; powertrain programs. , 11 ' ' ' I i 1% > l1 i* , ', ' , ' | '"^1 ' .Although; a strategy and workplanare proposed in.this; paper and'efforts havebeemstaried; in' these';;areas, there;are'.consiaercble'iitimingjiandifeasibility'issues; in esch of the idenufied applications. -Without funding. or directed 'prioritization over; other 'engineering effort,* the work;on' the; identified,:asbestos^!hexavalent ahromium fcbmpodhd or'iibehiiieh'Cjiappiications;, : cannot^proceedo under.' present economic ''conditions,; Never.thelessi ifalmeasured;iGbmihy',;:;; reaetiorilsnecessarytoinitiaieorderlysubsiitutionpripg.-emswith sufficient!: flexibilityatom: adapt to engineering and economic'limitations: ; ' Materials and Toxicology System tMATSl J,-** ^i ( y 5> ' f A new. computer data base is being developed which links,health, product,and'menutBCtunng : datav bases to facilitate;;rapid identification 'of potential carcinogens and: otner f toxic e substsnces. The ilinks; between'thesesystems will provide a method'for generating a list.of production andnbnprbducllon materisfl specificatipns which contain Gategory l substances. To date, of the four major MATS subsystems, two huve been completed and the others are . being!monually opcrated. |n:oddilion, l>EP S-18S which spccifies/procedures for the review : "-.of hew;materia^jis'beihg;heytsed;.;tb|ihqlu'(fej;the;necessary abUpns':for;ehteringjdotaqn;to):ici:. ; and ha28rdous;Substances;iint6 thei;data base. The .work to date in development of the Materials & Toxicology System (MATS) has emphosized the need; for mutcrinl definition on at! part releases. To this end the total engineering release file has been audited end the responsible PEO's are preparing material definition for all pp*t releases. 1: V Recommendations > :- Achievement of: the elimination or/eontrol of. potential -carcinogens .requires a corporate commitment to foslcr an integrated and sustained effort throughout the Company ,over a . number of years. To accomplish ' this. lhc tollowing pctions end responsibiliticsere v recommended; ' ' X'* .XiX:K "y"!:' 5<iv ' .iF: I; Assign hazardous substance control program - management ; responsibility i to :; Environmental nnd Safety EngineeringStef(.(Responsibility: Enyironmental ik Safety 'F'r;; EngineeringStaff -ESliSl,, j: > F`;i F\ 'jr,'F |-;',;FFFF'-,,..'-WF 2. Establish; ;o! Hazardous Substance Control- Committee .choired by Envlronmcntali'end Safety Engineering Staff. The Task Force would be discontinued. ' (Responsibility; ' -'iESESj^'Ini-vVrl1-;;' , '* .j',: 'F'Fr-jFFvF'FhF: ' ,3.' Revise iiDir.ectfye (,Br,l 01 (Occupational; Safety:nnd Hcollh and Control of; Hazardous!' J Materials) to reflect adjusted responsibilities for line and staff. No new Policy; is required, the mattcr is covered undcr Policy CrS, Standtrds of Corportte Conduet. ; (Responsibility: ESES Progrom Manager) i.'Vi,. V `X -!C--/-' 'I lif'v SO63 U2 PRODUCED BY FORD -3- 4. Adopt os the Company potential carcinogen listing, the 36 current OSIIA-regulntcd nnd proposed Category I substances used in automotive production. Establish the lop eight priorities proposed by the Task Force as Company priorities. Direct that the listing be updated semiannuully. (Responsibility: P&O Staff) f 5. Complete strategies and timetublcs for the eight .prioritized potential carcinogens for review and approval by the subcommittees. (Responsibility: ESES Program Manager) 6. Continue the development of MATS by Environmental & Safety Engineering Staff. A budget and headcount transfer from Engineering Staff has been agreed to. (Responsibility: ESES Program Manager) The Company has demonstrated a commitment to protect workers while seeking to eliminate specific substances. Directions on the use of and protection for numerous substances have been issued. Workers ore protected by restricting exposure and by special clothing and engineered safeguards designed to keep exposure within known permissible limits. Specific recommendations for eliminating asbestos, hcxavalent chromium compounds and benzene follow: 7. Proceed with the elimination of Croup A (known substitutes without major redesign) not later than Job HI, 1985 where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: PEO's, BMD's, Purchasing) 8. Include Croup B (known substitutes with major redesign) elimination actions in Phase V of vehicle and powertrain programs and in new plant and renovation projects where appropriate as determined by the Hazardous Substance Control Committee. . (Responsibility: ESES Program Manager, Product Planning, Vehicle Engineering, Manufacturing Staff) 9. Recommend advonccd program funding to develop designs and/or substitutes for new production and nonproduction parts and materials to identify feasibility, reliability, cost and weight implications of alternative materials/dcsigns for Croup C applications (no known substitute, advanced engineering required). (Responsibility: PEO's, BMD's, Technical Planning, Scientific Research Staff) " '/ The implementation of the obove actions and responsibilities should be reviewed periodically by the Engineering and Research and Manufacturing nnd Supply Subcommittees to provide a forum for discussion, Corporate overview and endorsement of oppropriate funding end prioritization of efforts. Engineering Staff Manufacturing Staff May 27, 1980 Vertical line indicates revision at subcommittee direction. 8006 130S ' PRODUCED BY FORD I l i '' t CARCINOGENS IN THE WORKPLACE INTRODUCTION At the October 1979 joint meeting of the Engineering end Research and Manufacturing and Supply Subcommittees, a report on the Occupational Safety and Health Administration (OSHA) Policy for Regulating Workplace Carcinogens was presented by Personnel and Organization Staff. This report noted that final regulations for carcinogens in the workplace were anticipated by the end of 1979. It was agreed thot efforts to eliminate the use of potential carcinogens where possible should be preceded by analysis of the affected materials and processes. In this regard, a Task Force was established by the Subcommittees to identify carcinogens and quantities in use, set targets for elimination ahead of regulation, take steps to find substitutes, develop a directive and workplan and organize to identify and control potentially carcinogenic substances. . Since October, OSHA has released its Policy which establishes criteria and procedures for the identification, classification and regulation of potential carcinogens in the workplace. The Policy further defines Category I potential carcinogens as substances known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category R substances are those where data are suggestive of carcinogenicity in humans and test animals. The Policy also outlines criteria for classifying a substance into Categories 1 or n and establishes the mechanism for issuance of standards governing use of a particular substance. No specific substances were categorized, or standards promulgated, with the issuance of the Policy. Normally, once the , need for a standard is determined by OSHA, it could take one to two years before the standard is issued. If an "Emergency Standard" is set, the ruling is issued and immediate compliance is required. A number of court challenges of the new Policy are expected to center primarily on stringent rules virtually precluding use of negative evidence studies when defining the carcinogenicity of a substance and cost/benefit criteria. A draft list of candidate substances governed by the Policy was issued by OSHA two years ago. A revised list is expected to be released in July, 1980 followed by a prioritized extract in September. The Task Force has concentrated on developing the capability for managing the eliminaation or control of Category I potential carcinogens in the workplace. A start has been made in identifying specific applications for subsequent elimination or control of asbestos, hexavalcnt chromium compounds and benzene. t at)0l !<>?r -1- May 27, 1980 PPr>r\TTr,pn DV rv^nr-. FEDERAL ACTS REGULATING T0X1C/I1AZARD0US MATERIALS HAVING IMPACT ON THE COMPANY figure i Workplace Related Occupational Safety and Health Act 1970 D.O.L. (OSI1A) Hazardous Materials Transportation Act - 1975 D.O.T. (HTMA) Toxic Substances Control Act - 1976 E.P.A. (TSCA) Resource Conservation and Recovery Act * 1976 E.P.A. (RCRA) Clean Air Act and Clean Water Act Amendments (CAA) 1977/78 E.P.A. Packaging A Stacking Federal Hazardous Substances Act - 1970 Poison Prevention Packaging Act -1970 Consumer Product Safety Act > 1972 Waste Management Resource Conservation and Recovery Act -- 1976 E.P.A. (RCRA) FIGURE 2 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) Staff ESES Responsible Activity - SSECO P&O - Employe Health Services MFG. STAFF - Safety Engrg. - Plant Engrg. Office . Mfg. Engrg. & Systems - Plants EARS - Prog. Anal. 6c Metis. Engrg. Research Staff SUPPLY - Trans. 6c Traffic OSHA Compliance Reporting Identification of Controls Monitoring Enforce Controls Facility Controls Development Process Controls Development . Process Controls Implementation Facility Control Implementation Develop new metis., mfg. processes, 6c meosurcmenl devices. REGULATORY ACT TSCA Compliance Reporting Material Inclusion in EPA Inventory . Interpretations . Eval. working conditions . Audit HMTA DOT label in Data Base Non-Prod. 6c Prod. Matls. Review Non-Prod. Matls. Review Non-Prod. Matls. review Packaging Storage Material Characteri zation Production Mails. Review Compliance Reporting 2f- Moy 27, 1980 PRODUCED BY FORD BACKGROUND Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated by the U.S. Department of Health, Education and Welfare that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.&. might be associated with occupational factors.-' Accordingly, Personnel and Organization Staff, Employe Health Services, has been involved in a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. ' Public concerns relating to the control of toxic/hazardous materials, are shared by the Company and the UAW. The right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has been extended to the UAW by contract. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques and by materials substitution. During the past decade, the Company was subjected to a growing number of laws which regulate material use, transport, handling, and disposal (Fig. l). Under certain of these Acts, a ''knowing/willful" criminal violation can expose individuals, including officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines of $25,000 per day; a citation normally consists of multiple related violations. Litigation is also a growing concern. For example at present the Office of the General Counsel has three suits pending, involving deaths allegedly due to the inhalation of asbestos. Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been issued, additional standards are anticipated, and the level of economic risk has increased. 1/ Federal Register 45(15): 5031, January 22, 1980. 0ul 167* -2 V May 27, 1980 pprvrvr rrpn nv crPT>> FIGURE 3 REPRESENTATIVE past company actions Production . Removal of lead and chromium from topcoat paints for passenger vehicles. . Removal of "Tris" flame retardant ' . Controls instituted for asbestos in new designs. . ** Nonproduction . - . Removal of asbestos from, . - Structural fireproofing - Thermal insulation - Molding compounds ' . . Substitution of vacuum for air blowing in brake and clutch maintenance . Protection of personnel potentially exposed to benzene in light oil tanker loading operations . . Substitution for lead-containing maintenance oils . Substitution for benzene-containing adhesives . Reduction of lead-chromates in vinyl operations - 3f - May 27, 1980 8006 1310 PRODUCED BY FORD I t REPRESENTATIVE PAST COMPANY ACTIONS <Fig. 3) r4 The Company has issued Directive B-l 01 which assigns responsibilities for Toxic/Hazardous . material control. Product Engineering Procedure PEP 3-189 and Manufacturing Procedure Il.d.1. provide for systematic review and clearance of new production and nonproduction materials. Production Materials ' In response to OSHA regulations issued in 1978, the Company removed lead chromates and lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment for fabrics, was removed during 1977. In response to initial OSHA regulations in 1972, the Company determined plant areas in which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. In 1979, Car Engineering released a practice banning new designs containing asbestos unless a documented rationale for its use is provided and it is encapsulated. Nonproduction Materials In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction stand ards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in b11 brake/clutch maintenance and substituted vacuum fiber/dust pick-up. Since 1973 new suppliers have been required to furnish complete compositional data to obtain clearances prior to use in the plants. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with lead naph- thenate free M-2C142 materials, and deleted the use of asbestos containing molding com pound for heater housings at Sheldon Road. In 1978, an adhesive used at San Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories were revised to eliminate benzene, where possible. The volume of lead-chromate employed in vinyl plant operations was reduced and vcntilation/protective measures were identified at the Romeo Tractor Plant to minimize potential hazards from chromium compounds used in painting. - apOl l ^ 71* May 27, 1980 PPOTvTTPTin nv ervor', FIGURE 4 task force charter Tho Task Force wits chartered t>y Fill and MAS Subcommittees (Meeting of 10/24/79) for coordinating plaits and efforts to: 1. Identify substances in use (OSIIA Categories I and II). 2. Determine quantities used (for materials regulated by Michigan Department of Natural ' Resources). - ' 3. Set targets for elimination of as many Category I substances as possible. 4. Take aggressive steps to find substitutes for as many Category I substances as possible in anticipation of government regulations. . ' 5. Develop a policy and action plan for eliminating potential carcinogens where possible. 6. Organise to identify substances systematically. ' FIGURE 5 1979 USAGE OF MICHIGAN CRITICAL MATERIALS as nnponTEP to mats* (adjusted by rmrplants in their mdnr reports) Motcrial Acrylic Acid Acrylonitrile Aniline Antimony Arsenic Benzene Cadmium Chromium Cloroprene ' Cobalt ' Copper Cyanides Dichlorobenzenes Formaldehyde Hydrazcne Hydroqulnone Hypochlorite Lead Lithium Nickel Phenol Selenium Silver Silicon-Dioxide Coated Lead Chromate Styrene Tetraclorocthylenc Thiourea Triaryl Phosphate Esters Trichloroethylene . Yinyl Chloride Zinc Lbs. of Usage 251,707 641,133 90 830,571 11,157 ' 385,028 ' 3.311 81,377 24,676 210 321,704 923,069. 2,542 488,965 130 1 15,841,758 626,027 123 126,624 5,839 127 25 2,317 1,413,986 1,095 18 160,022 91,849 118 1,085,724 Principal Users PPV - Paint ' PPV - Paint MCC, Dbn. Glass, TAC Sterling PPV - Vinyl TAC Vandyke. PPV - Vinyl AAD - Dearborn Assy., Gen. Service PPV - Vinyl PPV - Paint. EED - Ypsl. AAD - Utica PPV - Saline AAD * Dearborn, PPV - Saline, MSD - Monroe MSD - Monroe FTO - Highland Park MCC, PPV - Paint PPV PPV - Vinyl MSD - Monroe AAD - Wayne/Dearborn, PPV - Paint ED - Northville, TAC Sterling MSD - Monroe, TAC Sterling Mich. Cast. Cntr. TAC Sterling TAC Sterling PPV PPV - Milan, PPV - Vinyl AADGO, Mich. Prov. Grnd. PPV - Vinyl Steel, TAC Sterling EED > Rawsonville PPV - Vinyl PPV - Point, AAD. FPSD, FTO Michigan locations reported to the State of Michigan but not to MATS: Detroit Industrial Engine Research A Engineering Center Research - Glendale Troy - Tractor Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixom Assembly * Category I Potential Carcinogens - 4f - Moy 27. 1980 8006 1312 ' PRODUCED BY FORD TASK FORCE CHARTER The complete Task Force Charter assigned,by the Engineering and Research and Manufacturing and Supply Subcommittees is shown in Figure 4. To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate, where possible', the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. ^ - A listing of SB Category I substances or groups of substances in use in the automotive industry has been prepared. (Exhibit I), based on a 1978 MVMA Information Bulletin on substances associated with automotive production. - For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used 81,877 pounds of chromium compounds, and 385,028 pounds of benzene (primarily in gasoline). Asbestos is not one of the currently designated critical materials. The largest use, 641,000 pounds of acrylonitrile principally at the PPV paint plant, is planned to be removed from topcoats by Job fl, 1981 and from DSO and fleet colors by year end, 1980. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category 1 substances were examined in detail. -4- May 27, 1980 9001 1680 pprvrrnrcr'i ov FIGURE 6 POTENTIALLY CARCINOGENIC SUBSTANCES Prioritized Substance______________ Occurrence within Company Asbestos Friction materials, gaskets, sealers Hexavalent Chromium Compounds Benzene - / Paint pigments . Product of coking operations, foundry operations, petroleum products, paints, thinners Cadmium Oxides and inorganic salts Fastener plating, solders, foundry effluent, valve alloy Coke Oven Emissions/ Coal Tar Pitch Volatiles Coke oven and foundry emissions Vinyl Chloride Vinyl Manufacturing Beryllium Oxide and inorganic salts Aluminum foundry operations Trichloroethylene Degreaser Current Exposure Limits 2 fibers/cc 52 yg/m3 (as Cr)* 10 ppm * 0.1 mg/m, (fumes) 0.2 mg/nr (dust)* 3 0.2 mg/m 1 ppm 2 yg/m3* 100 ppm* Exposure limit not based on carcinogenicity. 8006 1314 - 5f - May 27, 1980 ' PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES The highest priority of Category I substances contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6, along with exposure limits and typical usage. The complete listing is provided in Exhibit L The substances are presented in order of priority as established by Task Force consensus. The development of a capability for managing the elimination/control of Category I potential carcinogens was determined by evaluating the scope of usage of asbestos, hexavalent chromium compounds and benzene (priority ranks 1, 2 and 3, respectively) as test eases. May 27, 1980 AOol 1681 PPOTV mm r>v >:-riAta&&k' POTENTIALLY CARCINOGENIC SUBSTANCES Asbestos FIGURE 7 j>/r Potential Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer ~. . FIGURE 8 Exposure Limits Time Weighted Average Time Weighted Average Ceiling OSHA ____________________NIOSH Proposed Regulation for Regulation Recommended (Fibers/cc) (Fibers/cc) (Fibers/cc)- -2.0 0.5 10 5 0.1 - FIGURE 9 Summary of Asbestos Usage Production Nonproduction Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Brake Linings . Millboard Asbestos Reinforced Paper Core 6c Mold Making Sealers Safety Apparel Clutch Plates ' oo * w - 6f - May 27,1980 1 PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES Asbestos During the past several years, OSHA has reported evidence of a link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer (Fig. 7). These Include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. . The permissible exposure limit by OSHA is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group in The Department of Health and Human Ser vices (formerly HE1V) has recommended to OSHA that limits be tightened to as low as 0.1 f/cc in 1980, (Fig. 8). Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban, under the Toxic Substances Control Act, on all non-critical uses may occur as early as 1985. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of vehicles, manufacturing equipment and plants. 6- May 27, 1980 8001 1662 ppomtrpr* pv pnon POTENTIALLY CARCINOGENIC SUBSTANCES Chromium Compounds FIGURE 10 Potential Health Effects on Humans Hexavalent Chromium Compounds Other Chromium Compounds Respiratory Tract Irritation/Perforation of Mucous Membranes, Bronchitis X X Liver damage / . X X Skin dermatitis, Ulcers . X X Kidney damage Lung cancer X X-ft/ X. - a/ except in combination with hydrogen, alkali metals, ammonia, oxygen FIGURE 11 Exposure Limits Ceiling Time Weighted Average OSHA____________________ NIOSH Regulation Proposed Regulation -Recomm* endatio-n 52 pg/m - - 1 pg/m b/ 3~ 50 pg/m /15 min c/ 3" - 25 pg/m c/ b/ Potentially carcinogenic hexavalent chromium c/ Noncarcinogenic hexavalent chromium FIGURE 12 Classes of Materials Containing Hexavalent Chromium Compounds Production Nonproduction Topcoat Paints Primer Paints Chromate Coatings Maintenance Paints' Point Strippers Marking Inks - 7f - May 27, 1980 8006 1318 PRODUCED BY FORD potentially carcinogenic substances Chromium Compounds Some trlvalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (Figure 10). Chromium in hexavalent combination with hydrogen, the alkali metals (e.g., sodium), ammonia and oxygen are considered noncarclnogenic. All other hexavalent combinations of chromium (e.g., leatTand zinc chromates) are considered potentially carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of handling them primarily in paint making and application. Pro tective measures are employed so that regulated limits are not exceeded. The current statutory limits for all chromium compounds is 52 wg/nr although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 ere of current concern since the most critical sources of exposure are in paint manufacture and application. -7- May 27, 1980 B901 16B3 ppnnTTppn pv popt> POTENTIALLY CARCINOGENIC SUBSTANCES Benzene FIGURE 13 POTENTIAL HEALTH EFFECTS ON HUMANS Contact Dermatitis Eye Irritation Narcotic and Central Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyscrasias (disorders) FIGURE 14 EXPOSURE LIMITS OSHA , Regulation Proposed - NIOSH ' Recommended Time Weighted Avg. Ceiling 10 ppm/15 min. .- 1 ppm/8 hr. 1 ppm/2 hr. - a/ Promulgated as a standard but not upheld by Court of Appeals, and is now before ~ the Supreme Court. FIGURE 15 CATEGORIES OF MATERIALS CONTAINING BENZENE Adhesives and Sealers Rust Preventives Thinners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases Lubricating, Hydraulic dc Multiple Purpose Oils Liquid Fuels - 8f- May 27,1980 8006 1320 * PRODUCED BY FORD POTENTIALLY CARCINOGENIC SUBSTANCES Benzene ' Benzene is a potential leukemia producing agent. Excessive exposure may result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. *' At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, but employe protective measures are in effect. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The proposed standard was not upheld by the Court of Appeals because OSHA did not determine whether the benefits expected from the standard bear a reasonable relationship to the cost imposed. The case is now before the Supreme Court, which is expected to rule on it shortly. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption was necessary since there is no known way of controlling benzene exposure among service station personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. May 27, 198D 3001 16A* Tjprvrvr Tr>r?r% t>v crYmn. SEARCH FOR POTENTIAL CARCINOGENS FIGURE 16 . Potential Carcinogen Identification - Reviewed likely material specifications and manufacturing standards. - Reviewed the IH&T CATALOG of Hazardous Materials. . - Reviewed North American Engineering Product Information System (NAEPIS) to identify Industry Standard Materials - Reviewed the Michigan Critical Materials data - Surveyed previous assessment of production materials. - Communicated with material suppliers. ' - Analyzed the production material list (PEO). ' . Potential Carcinogen Usage - Reviewed the NAEPIS cross-reference for production material/part usage. - Reviewed processes/uses involving the substances in nonproduction materials. . - Confirmed the NAEPIS usage list for completeness/verification. MATERIALS AND TOXICOLOGY SYSTEM (MATS) Chemical Compound FIGURE 17 8006 1322 - 9f - May 27,1980 PRODUCED BY FORD t I i ? SEARCH FOR POTENTIAL CARCINOr.F,NS Three Category I substances were examined to identify material specifica tions, ports and nonproduction uses. Existing data bases containing Product, Manufacturing and Purchasing information were found to be inadequate for complete identification of all uses of these substances. In the absence of one reliable system, the detailed steps in Figure 16 were undertaken. For production materials, each design responsible PEO reviewed the * . matcrial/usage list for completeness and established a list of. parts and bulk materials thought to contain the subject substances. These lists were, returned to Engineering Staff. E&RS is consolidating the lists to provide them, along with the approved source and material identifications, to Purchasing and Supply Staff for supplier contact to determine usage and substitutability. Nonproduction materials were identified by similar methods. The production asbestos list is with buyers; benzene and hexavalent chromium compounds are under PEO review. MATERIALS AND TOXICOLOGY SYSTEM (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four systems: The CATALOG of Hazardous Materials (PicO Staff); the Engineering Materia) Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); end the Environ mental & Process Engineering Review System (.Mfg. Staff). These Systems can be linked with some manual effort to search for uses of potential carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing Category 1 chemical compounds can be identi fied in the CATALOG. 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specifica tion. ' 4. With the parts list, Purchasing can determine quantity used and Manufacturing Engineering can determine processing methods. Other functions of MATS include Approved Source Lists for production and nonproduetion materials, Michigan DNR Critical Mntcrials usage reporting, ' CATALOG of Hazardous Materials for plant physicinns and Hazardous Material Information Center, verification that a substance is on the Toxic Substaftccs Control Act (TSCA) inventory, and listing of hazardous rqotcrial usage und precautions for each plant. ` -8- May 27, 1980 BfiOl 1<*5 PRODUCED FORD FIGURE 18 POTENTIAL CARCINOGEN SEARCH RESULTS Substitutes for .. Production Materials/Parts-' Asbestos22'/ Chromium ,, Compounds- A. Known w/o redesign 56 - B. Known with redesign 21 - C. Not known; adv. engrg. reqd. Sub Total 26 103 . 22 22 Benzene 5 5 Substitutes for ' .. NonproductionMaterials/Parts- A. Known w/o redesign B. Known with redesign C. Not known; adv. engrg. reqd. Sub Total .8 8 Total 111 84 26 4 114 126 1 1 2 7 1/ Data are directional estimates only and refer to materials known " to contain the particular substance. . 2/ Primary source - Car Engineering. 3/ Only certain hexavalent chromium compounds considered. - lOf - May 27, 1980 8006 1324 ' PRODUCED BY FORD I riSi'k*'!/.- l I 3,.. F -- I % ` *> . *. .. POTENTIAL CARCINOGEN SEARCH RESULTS 1 ............................. .................. .. Partial listings of 111 asbestos, 126 chromium compounds and 7 benzene production and nonproduction applications (Appendices I, II and ID, respec tively) were examined. * These applications were classified as: . A - Known substitute material available for application without ' major redesign; * # B - Known substitute materia) available for application with major redesign; C - No known substitute. Advanced Engineering Project required; The number of applications in each group are shown in Figure 18. Even in Group A, (known substitute without major redesign) extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required and experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then establish sources for production as well as nonproduction requirements. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this pBper for the three materials examined in detail. -10- May 27, 1980 B001 1686 ppont trpn pv popta FIGURE 19 ALTERNATIVE STRATEGIES FOR ELIMINATION/CONTROL OF POTENTIAL CARCINOGENS Continue OSHA Category I potential carcinogen exposure control by design or process. Eliminate category 1 substances where substitutes are known when required by regulation or good business practice, a/ Wait for government rulemaking to eliminate or control OSHA Category I potential car cinogens. / - Proposed Strategy: .. ' - Proceed to eliminate Group A (known substitute without major redesign) asbestos, hexavalent chromium compounds and benzene by Job #1, 1985 where appropriate. Where elimination is not appropriate control exposure by design or process. - Establish Group B (known substitute with major redesign) timetables for these three substances consistent with cycle plans and new plant construction or renovation plans. - Initiate advanced engineering projects for these three Group C (substitute unknown, advanced engineering required) substances. a/ Current Car Engineering practice for asbestos (Dec. 19, 1979): Newly designed components should not contain asbestos. In documented cases pre cluding alternate materials, asbestos must be reduced to the lowest level and encap sulated or resin coated to avoid worker exposure to airborne fibers. CD o o c* w IM - Ilf - May 27, 1980 * PRODUCED by ford i? ALTERNATIVE STRATEGIES FOR ELIMINATION/CONTROL OF POTENTIAL CARCINOGENS Strategy alternatives were considered for the elimination and control of asbestos, hexavalent chromium compounds and benzene. The Task Force agreed that the Company should proceed now to eliminate Group A (known substitute without major redesign) by Job #1, 1965 where appropriate. Where-elimination is not appropriate control exposure by design or process for specific applications. (Fig. 19) For those applications requiring major redesign (Group B), the elimination timetable must reflect Company cycle plans on new plant construction or renovation plans. Finally, where no known feasible substitutes exist (Group C), advanced engineering will have to be completed before elimination strategies or timetables can be established. Individual timetables remain to be established for the balance of the eight prioritized substances. 100b -11 - rfoy 27,1980 pp/'>TvrT/~|Trr< dv FIGURE 20 GENERATED WQRKPLAN (For Each Category I Potential Carcinogen) Action Responsibility Production Nonproduction Block Timing Targets 1. Manage Program SSECO SSECO Ongoing 2. Propose prioritized list of Category 1 potential carcinogens P&O P8cO Semiannual Update 3. Propose list of specifications containing Category I substance. P&O P&O 1 Month 4. Verify proposed list Engrg. Staff & PEO's Mfg. Staff 1 5. Identify part numbers contain ing Category I substances PEO's Mfg. Staff 1 6. Request supplier verification of Cat. I containing specifications and parts NAAO/DPO Purchasing Supply Staff 3' 7. Request supplier verification of substitution feasibility NAAO/DPO Purchasing Supply Staff 6 8. Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) PEO's (NAAO/DPOPurcMsing) Mfg. Staff (Supply Staff) 6 9. Implement Group A actions Veh. Engrg. PEO's NAAO/DPOPurchasing Mfg. Staff <5c BMD NAAO/DPOPurchasing Supply Staff 12-24 10. Implement Group B actions 11. Implement Group C actions 12. Audit effectiveness Veh. Engrg. Mfg. Staff . Prod. Planning PEO's SSECO P&O Engrg. Staff Res. Staff BMD SSECO P&O Mfg. Staff 33-45 Ongoing Ongoing a/ estimated implementation from decision date. b/ will be output by MATS effective 2nd quarter 1981. -12f- May 27,1980 8006 1328 PRODUCED BY FORD I i GENERALIZED WORKPLAN * The foregoing strategy, even though having been tested only for asbestos, * chromium compounds and benzene, are judged to be appropriate in concept for other carcinogens with timing adjusted to adapt to the realities associated with elimination. ' A generalized workplan has been prepared on the basis of the evaluation of the substances referred to above. The workplan requires central program management, with action implementation by NAAO/DPO Product Engineering Offices,*Purchasing activities. Vehicle activities, Manufacturing activities, and the Manufacturing and Supply Staffs. The workplan timing requires one year to define the uses of a potentially carcinogenic substance with elimination requiring two additional years for a substance having a known substitute with no major redesign required. For material substitutions requiring major redesign, the timing is consistent with new product phase V timing of 33 months for vehicle and 45 months for powertrain programs. Four of the first five actions of the workplan (items 2 -- 5) have been completed for asbestos, hexavalent chromium compounds, ond benzene. The sixth and seventh actions have been initiated for production materials and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1961. (Fig. 20) Completing the actions by these dates requires Corporate direction that the elimination/control of these substances in vehicle, component, plant renovation and new construction programs is a mandatory priority effort. Overall program management is essential to this effort. 88*1 100b -12 May 27, 1980 ppr*TYM/~,T7r t>v crinr> FIGURE 21 PROPOSED CHEMICAL SUBSTANCES CONTROL Chemical ! Substances Control I Manager { Proposed 6 h/c (On hold) i 1 MEMBERSHIP FIGURE 22 HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control Office . Environmental and Safety Engineering Staff . Purchasing and Supply Staff . Personnel and Organization Staff | . Labor Relations Staff 1 . Scientific Research Staff . Engineering Staff . Manufacturing Staff . Car Engineering , . Body and Assembly Operations-' . . Ford Parts and Service Division . Ford Tractor Operations . Powertrain and Chassis Operations . Basic Products Operations- . Electrical and Electronics Division . Climate Control Division . Truck Operations . European Automotive Operations . Office of the General Counsel . a/ Divisional participation as required. | Vertical line indicates revision at subcommittee direction. -13f- May 27, 1980 PRODUCED BY FORD 8006 1330 Although a strategy and workplan arc proposed in this paper end efforts have been started in these areas, there ere considerable timing and feasibility issues in each of the identified applications. Without funding or directed prioritization over other engineering effort the work on the identified asbestos, hcxavalcnt chromium compounds or benzeno applications cannot proceed under present economic conditions. Nevertheless, a measured Company reaction is necessary to initiate orderly substitution programs with sufficient flexibility to adapt to engineering end economic limitations. '* Achievement of the elimination or control of potentio! carcinogens requires a corporate commitment to foster an integrated and sustained effort throughout the Company over a number of years. To accomplish this, the following actions and responsibilities ore recommended: (Fig. 23): 1. Assign hazardous substance control program management responsibility to Environmental und Safety Engineering Staff. (Responsibility: Environmental tc Safety Engineering Staff - ESES) 2. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. (Responsibility: ESES) 3. Revise Directive B-101 (Occupational Safety and Health and Control of Hazardous Materials) to reflect adjusted responsibilities for line and staff. No new Policy is required, the matter is covered under Policy C-3, Standards of Corporate Conduct. (Responsibility: ESES Program Manager) . 4. Adopt as the Company potential carcinogen listing, the 36 current OSHA-rcgulated and proposed Category 1 substances used in automotive production. Establish the top eight priorities proposed by the Task Force as Company priorities. Direct that the listing be updated semiannually. (Responsibility: P&O Staff) 5. Complete strategies and timetables for the eight prioritized potential carcinogens for review end approval by the subcommittees. (Responsibility: ESES Program Manager) 6. Continue the devclopment.of MATS by Environmental & Safety Engineering Staff. A budget and headcount transfer from Engineering Staff has been agreed to. (Responsibility: ESES Program Manager) The Company has demonstrated a commitment to protect workers while seeking to eliminate specific substances. Directions on the use of and protection for numerous substances have been issued. Workers arc protected by restricting exposure and by special clothing and engineered safeguards designed to keep exposure within known permissible limits. Specific recommendations for eliminating asbestos, hcxavolent chromium compounds and benzene follow:" 7. Proceed with the elimination of Group A (known substitutes without major redesign) no later than Job #1, 1985 where appropriate os determined by the Hazardous Substance Control Committee. (Responsibility: PEO's, BMD's, Purchasing) 8. ' Include Group B (known substitutes with major redesign) elimination actions in Phase V of vehicle and powertrain programs and in new plant and renovation projects where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: ESES Program Manager, Product Planning, Vehicle Engineering, Manufacturing Staff) ' 9. Recommend advanced program funding to develop designs ond/or substitutes for new i production and nonproduction parts and materials to identify feasibility, reliability, ; cost and weight implications of alternative materials/designs for Group C ; applications (no known substitute, advanced engineering required). (Responsibility: : PEO's, BMD's, Teclmicnl Planning, Scientific Research Stoff) The implementation of the above actions ond responsibilities should be reviewed periodically by the Engineering and ljteseoreh and Manufacturing ond Supply Subcommittees to provide a forum for discussion, Corporate overview ond endorsement of appropriate funding and prioritizotion of efforts. . | Vertieol line indicates revision at subcommittee direction. 8006 1331 *- Mnv 27. 1980 ' PRODUCED BY FORD FIGURE 23 PROPOSED PRIORITY ACTIONS 1. Program Manager 2. Hazardous Substances Control Committee 3. Revise Directive B-101 .. 4. Adopt Category I potential carcinogen listing . 5. Complete strategies and elimination timetables 6. Continue development of MATS 7. Eliminate Group A asbestos, hexavalent chromium and benzene 8. Include Group B asbestos, hexavalent chromium and benzene in programs 9. Recommend advanced program funding for Group C 8006 1332 -14 f - May 27, 1980 ' PRODUCED BY FORD , PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the requirements for chemical substances control. ' It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issues. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an EfcSES location was recommended. (Fig. 21) In view of budget Constraints, it has been agreed that the existing Com pliance and Liaison Department would perform the program management function. The Department Manager should be responsible for implementing control strategies and coordinating Company response to potential and promulgated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities and expand operations1 role, assuring that Operating Components and Staffs issue facing documents to B101, establishing a financial measurement of the compliance effort, assuming development direction and control for the computer information system and implementing the workplan as directed. Although additional budget is not now requested, the transfer of a currently budgeted MR employe from Engineering Staff to ESES with the MATS computer development budget component has been mutually arranged. The ongoing responsibilities of the Compliance and Liaison Department Manager will be to coordinate the product/facility/manufaeturing/health/ environment response of the Company to changing regulations. This will include comments to government agencies regarding proposed regulation, forecasting/ regulatory impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Research and the Manufacturing and Supply Subcommittees name os a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page (Fig. 22). It is further recommended that the Committee be chaired by the E&SES representative. -13 - May 27, 1980 proposed priority actions Although a atratcgy and workplan are proposed in this pnpcr and efforts have been started in these areas, there are considerable timing and feasibility issues in each of tlie identified applications. Without funding or directed priorittuition over other engineering effort the work on the identified asbestos, hcxavalcnt chromium compounds or benzene applications cannot proceed tinder present economic conditions. Nevertheless, a measured Company reaction is necessary to initiate orderly substitution programs with sufficient flexibility to adapt to engineering and economic limitations. * ^ Achievement of the elimination or control of potential carcinogens requires'a corporate commitment to foster an Integrated and sustained effort throughout the Company over a number of years. To accomplish this, the following actions and responsibilities are recommended: (Fig. 23): '. . 1. Assign hazardous substance control program management responsibility to Environmental and Safety Engineering taff. (Responsibility: Environmental & Safety Engineering Staff ESES) 2. Establish a Hazardous Substance Control Committee ehalred by Environmental and Safety Engineering Staff. The Task Force would be discontinued. (Responsibility: ESES) 3. Revise Directive B-J01 (Occupational Safety and Health ond Control of Hazardous Materials) to reflect adjusted responsibilities for line ond staff. No new Policy is required, the matter is covered under Policy C-3, Standards of Corporate Conduct. (Responsibility: ESES Program Manager) .' 4. Adopt os the Company potential carcinogen listing, the 36 current OSlIA-regulated and proposed Category 1 substances used in automotive production. Establish the top eight priorities proposed by the Task Force os Company priorities. Direct that the listing be updated semiannually. (Responsibility: P&O Staff) 5. Complete strategies and timetables for the eight prioritized potential carcinogens for review and approval by the subcommittees. (Responsibility: ESES Program Menoger) ' 6. Continue the development of MATS by Environmental & Safety Engineering Staff. A budget ond headcount transfer from Engineering Staff has been agreed to. (Responsibility: ESES Program Manager) The Company has demonstrated a commitment to protect workers while seeking to eliminate specific substances. Directions on the use of and protection for numerous substances have been issued. Workers ore protected by restricting exposure ond by special clothing and engineered safeguards designed to keep exposure within known permissible limits. Specific recommendations for eliminating asbestos, bcxevalent chromium compounds and benzene' follow:" 7. Proceed with the elimination of Group A (known substitutes without major redesign) no later than Job II, 1986 where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: PECs, BMD'a, Purchasing) 8. Include Croup B (known substitutes with major redesign) elimination actions in Phase V of vehicle and powertrain programs and in new plant and renovation projects where appropriate as determined by the Hazardous Substance Control Committee. (Responsibility: ESES Program Manager, Product Planning, Vehicle Engineering, Manufacturing Stuff) - 9. Recommend advanced program funding to develop designs and/or substitutes for new production and nonproduclion peris and materials to identify feasibility, reliability, ' cost end weight implications of alternative molcrinls/dcsigns for Group C applications (no known substitute, advonecd engineering required). (Responsibility: " PEG'S, BMD's, Technical Planning, Seientific Research Staff) The Implementation of the above actions and responsibilities should be reviewed periodically by the Engineering and Research and Manufacturing end Supply Subcommittees to provide a forum for discussion, Corporate overview and endorsement of appropriate funding and prioritization of efforts. .' Vertical line Indicates revision ot subcommittee direction. -14 - ` May 27, 1980 B00I 1^90 ` i pr nrvr topo p v pop r *- EXHIBIT I . OSHA CATEGORY I SUBSTANCES WITH AUTOMOTIVE IMPACT*^ Regulated as Carcinogens Potential for Regulations as Carcinogens Acrylonitrile Acetamide Arsenic (inorganic) Benzidine Sulfate (1) Asbestos, including: (7) Beryllium oxides Ic inorganic salts Amoslte (4) Cadmium oxides & inorganic salts Anthophylite Carbon tetrachloride Chrysotile Chloroform . Crocidolite (2) Chromium, hexavalent Serpentine Diethylamine, N-Nitroso (8) Benzene . ' p-Dixoane Benzidine Ethane, 1,2-Dibromo- (5) Coke Oven emissions, including: Ethane, 1,1, l-Triehloro-2, 2-bis (p-chorophenyl) Benz (e) acephenanthrylene (8) Ethylene, Trichloro- Benz (a) anthracene Hematite . Benz (a) anthracene, 7,12-Dimethyl* Hydrazine Benz (a) anthracene, 7-Methyl- Hydrazine Sulfate Benz (a) anthracene, Lead Acetate 7, 8,12-Trimethyl-' Lead Naphthanate Benzo (rst) pcntaphene Nickel oxides k salts Benzo (c) phenanthrene, 8-Methyl . Polychlorinated biphenyls V Benzo (a) pyrene Polyethylene glycol monostearate Dibenz (a, h) acridine Sulfuric acid, Dimethyl ester Dibenz (a, j) acridine Tannic acid Dibenz (a, h) anthracene Tannin Dibenzo (b, def) chrysene o-Toluidine Dichlorobcnzidine Urea, Thio- Dimethyla mine, N-Nitroso- 1-Naphthylamine 2-Naphtylamine (6) Vinyl Chloride 1/ MVMA InformationBulletin, September 28, 1978 2/ Parenthetical numbers refer to Task Force priorities. Note: Candidate substance list is expected to issue from OSHA July, 1980. * . Prioritized candidate substance list is expected to issue from OSHA Sept., 1980 'Wj May 27, 1980 8001 lf91 pt>rvrvnrrpr* nr\r>r CAS Humber CARCINOGEN SEARCH Materials and Toxicology System EXHIBIT II May 27, 1980 8006 1335 PRODUCED BY FORD Ii EXHIBIT U CARCINOGEN SRAHCII Materials and Toxicology System (MATS) To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common duta base. The four systems are: the CATALOG of Hazardous Materials (PicO Staff) containing Company materials, their toxicological evaluation for worker/ consumer protection and the chemical composition, the Engineering Material Approved Source' List (E&RS) containing the material specification title nnd the materials approved to that specification; the Konproduction Materia) Approved Source List (Manufacturing Staff) contain ing the- nonproduction material standard and the approved materials; and the Environmental & Process Review System (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. * Carcinogen Search Strategy . Developing the links between the above systems will, in the future, provide a method for loco- ting Category I potential carcinogens in nonproduclion materials and production parts and bulk materials. The search methodology is numbered on the feeing page to correspond to the following search steps: ' 1. The Chemical Abstracts Service numbers of the Category I substance and their com pounds are identified bylHicT. The system will then generate a list of materials which ' contain those chemicals. 2. Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other Category 1 containing materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEP1S) which contains the engineering notices from bU of the product engineering offices. The NAEP1S system will then produce a cross reference list of all parts which use that materials. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in AAD. . Functions A function of MATS is to maintain and produce the Approve Source List for nonproduction and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the CATALOG of Hazardous Materials as cither a full componywide print or as a plant specific print. The CATALOG is used by Hazardous Material Information Center and plant physicians for verification that the substances are on the TSCA inventory and is required to be furnished to the UAtV under the current contract. The system is also available to the plants Hazardous Material Information Center to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. The system also produces the Michigan DNR Critical Materials report for the consumption of materials which contain a Michigan defined "critical component" c.g., chromium. Affected Activities : All Corporate Staffs concerned with mnterials/toxieological/environmcnt controls are currently involved in using/dcvcloping the system. All NAAO/DPO plants are planned to hove access to the system by third quurter 1980. ' May 27, 1980 001 1*9? PRODTTPFD RV FORD MATERIALS CONTAINING ASBESTOS * -1- * Group A -- Known Substitute Material Available Without Major Redesign Production Materials Specification Light Truck ESF-M8G55-A ESW-M8G$D9*B -- -- --' Body ESB-M2G58-C ESB-M2G171-AB ' ESB-M2G188-A ESB-M3G95 ESB-M4G1-B ESB-M4G31-A ESB-M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A ESB-M4G174-A ESB-M4G175-A ESB-M4G177-A/8 Material Gasket Gasket Deadener Sealers -- Adhesive Adhesive ** Adhesive Tape Sealer Sealer Sealer Sealer Sealer - Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Basle Part No. ' Part * 7086 ' 4035 850038 350038 9800000 Trans. Ext. Gasket . Carrier Gasket Econ. PDV Box Assy. Eeon. PDV Box Assy. Courier Box Assy. . mm -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- '-- Primer for Adhesive -- -- -- -- -- -- -- .-- -- -- -- -- -- -- -- -- -- . . .-- -- -- -- : --_ .-- . .' -- -- APPENDIX I 5/27/80-- pool lt>93 w PRonnrFn nv fopfi -2- Group A -- Known Substitute Material Available Without Meior Redesign (cont'd.) Production Materials Specification Material Basic Part No. Part ESB-M4G188-A ESB-M4G197-A ESB-M4G198-C ESB-M5G8-A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A -- Trans ESE-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A Ford Division ESB-M4G32-A ESH-M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A ESF-M3D113-A ESA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A -- CCD ESF-M8G55-A Chassis ` ESB-M4G109-A Sealer Sealer Sealer Deadener Deadener Deadener Rust Prevent / .-- -- -- -- -- -- -- 9004650 Gasket Gasket Seal Gasket 7D026 7A136 4035 7052 7A247 15520 Sealer Sealer Sealer Coating 19560 19560 19554 19515 Phenolic 18B374 8K621 . 17B616 18B374 Phenolic 11015 Polypropylene 13711 Gasket 10914 12A696 Gasket 12A676 Gasket Gasket 17C430 . 14A427 Gasket . 13817 Gasket Sealer 19D970 2A792 -- -- -- -- .-- -- Sprayable Wax Type Rust Preventative Cigar Lighter Spacer . Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Caulking Cord Rope Sealer Perfect Seal Undercoating A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator I/C Lamp Socket . Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window Reg. Yoke Gasket Horn Gasket ' *' J. : ; ) , A/C Comp. Gasket . P/B Cable Opening Cover 8006 1338 PRODUCED BY FORD  ' . MATERIALS CONTAINING ASDESTOS ~ At'ff.NIJIA I 5727/8TI-- Group A -- Known Substitute Material Available Without Major Redesign (contVL) Nonproduction Materials .' . Specification M-10G11 M-10G12 M-10G15 r M-10G16 M-99G59A M-99GB2A M-99G84A M-4R29A Material Asphalt Saturated Asbestos Roofing Felts -15 lb. Asphalt Saturated Asbestos Roofing Felts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper Mold Sealer 90P1 !***<* PPOT^Tirpn dv mon -4- Group B-- Known Substitute Material Available With Major Redesign Production Materials Specification Material Basic Part No. _____________ Part Light Truck ESE-M8G10G-B ESE-M8G140-A Gasket Gasket 5B266 5B266 Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor vendor Vendor Vendor Vendor Vendor Vendor Vendor Vendor Phenolic Phenolic -- -- -- -- -- -- --. -- -- -- -- -- -- 7934 7937 7F314 7D034 7D095 7F196. 7E311 7E313 7F219 7E312 7F239 7E312 7B614 4797 4A435 7550 ' Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Ini. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy. TYans. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Rear Axle Diff. Clutch Plate Assy. Man. Trans. Clutch Disc Assy. Chassis ESB-M8G106-A ESA-M8G140-A -- Gasket Gasket -- 5B266 5B266 2022 2021 Resonator Gasket Assy. Resonator Gasket Assy. Front Disc Brakes 8006 1340 PRODUCED BY FORD I APPENDIX 1 M**A**TERI1A11 LS CONTAINING 1 ASB1 ESTOS' 'TM " " ......... ... 5/27/60 ( -5- Group C -- No Known Substitute. Advanced Engineering Project Required. Production Materials Specification Material . Basic Part No. Part Light Truck * ES-C8AV2B282-A f ES-D20A-2B072-BB 2021 Lining Pront Wheel Brake Outer ES-C8AA-2B282-A -- ES-D20A-2BD72-BB \>\'* Vendor Print -- 2022 2019 Lining Front Wheel Brake Inner Shoe and Lining Inner Vendor Print -- 2018 Shoe and Lining Outer ES-EOTA-2B120-AA -- 2018 Shoe and Lining Outer ES-D6TA-2B118-AA ES-C8TA-2B282-A 2022 . Lining Front Wheel Brake Inner ES-C8TA-2210-D -- 2209 RR Brake Shoe Lining ES-C8TA-2010-C -- 2284/5 RR Brake Shoe Lining ES-D8TA-755D-A -- 7550 Driven Member Clutch T -- 4797 Clutch Plate -- -- 4A325 Clutch Plate -- -- 2598 Parking Brake Lining Heavy Truck -- -- .-- -- -- 2010/11 Hydraulic Brakes - Front -- 2209/10 Hydraulic Brakes - Rear -- 2598 Parking Brake -- 2010/11 Air Brake Assy. - Front (Wedge) -- -- 2010/11 Air Brake Assy. - Front (S-Cam) -- -- 2209/10 Air Brake Assy. - Rear (S-Cam) --' -- 2875 Air Brake Compressor '-- _ -- 8A616 Fan Clutch Assy.* -- -- 8A627 Clutch and Bracket Assy. --* -- 5230 Muffler Assy. * --. -- 7A596 Clutch Disc Assy. 7550 -- 7E434 Torque Limiting Brake Assy. Chassis ESE-M8G149-A Gasket -- 5F263 2284 2285 Exhaust Manifold Goskct Rear Broke Shoes ' B601 1*95 dprwr ircn pv cwr APPENDIX n " 5/27/80 MATERIALS CONTAINING HEXAVALENT CHROMIUM COMPOUNDS^ -1- ' Group A-- Known Substitute Material Available Without Major Redesign Nonproduction Materials Specification No. Title M5B40 M-5B165A M-5B220A(F) M-5J30 M5J68A M5J75 M-5J79A M-5J84 M5J99N M-5J105A. M-314 M-325 M-332 M-400A Metal Gleaner for M-99J26 Fingerprint Remover Paint Stripping - Organic Additive Yellow Marking Point for Crfeosoted Floors Enamel, Semigloss, Yellow Corridor Accent Maintenance Paint - Zinc Chromate Primer .Medium Green (Maintenance Paint) -' Yellow Road Marking Paint Coatings, Administration Offices and Employe Facilities Diamond Phosphorescent Pink Enamel Alert Orange (Maintenance Paint) Target Yellow (Maintenance Paint) Seal Brown (Maintenance Paint) Primer, Red Oxide . Air Paint NR-73 Also Kote ZSD-NA Alert Orange Enamel Alkyd M332 85-Y-95 Alkyd M472 B5-R-122 APS93 Paint and Resin Remover Brown Air Dry Primer Cl 68 Corrosion Inhibitor C2041 Celite 535 Chrome Yellow Medium Cooling Water TRT Chem. CR 401 Copper NAD Acrylic Enamel CWT 204 CWT 404 D-Smut ` Dearborn 517 1/ Hcxavalent chromium combinations with hydrogen, alkali metals, ammonia and oxygen excluded. * P001 1696 ppnnr ircn pv enpn -2- Group A. -- Known Substitute Material Avoilnblc Without Mnjor Redesign (cont'd.) Nonproduction Materials Specification No. Title . ' Dk. Green NAD Acrylic Enamel Entec 304 FM-150 Marking Ink, Forest Green FM-150 Marking Ink, Green FM-150 Marking Ink, Lt. Green FM-150 Marking Ink, Orange Granodine 65 Green Marking Lacq. 640500181 ' Grinding Coolant Hagatreat 168 . Halox CW 111 HP 12301 X5901S1E Hercules Water Treatment Chem. CR414 Inertol Rustinhibitive Primer Ivy Green Urethane #433 Krolor Orange R KO 789 D Krolor Yellow Lt. KY-781-D Krolor Yellow Med. KY-795-D L9110 Yellow Traf. Marking Lacq. SI 586 Medium Green Enamel Metal Conditioner VM-5717 Metal Rust Inhibitor Activator MM300 M Marking Ink Orange Molybdate Orange YE 637 D Molybdate Orange YE 698 D Nalco 360 Ball Oakite Stripper 157 Orange, 1-Part Epoxy Orange Marking Lacq. 640500183 Ornsol Orange RLN 1/ Hexavalent chromium combinations with hydrogen, alkali metals, ammonia and oxygen excluded. 8006 1343 PRODUCED BY FORD * , APPENDIX II MATERIAL CONTAINING HEXAVALENT CHROMIUM COMPOUNDS*-' ~ 5/27/80 '5' . . Group A -- Known Substitute Material Available Without Major Redesign (cont'd.) Nonproduelion Materials Specification No. Title . . ` " PI. Color Conc/Pinc Green - MMCA PL Color Conc/Lt. Sand Quick Dry Yellow Traf. Marking Paint Red Enamel Safety Orange Aquapon 902176H Safetylite 75 Traffic YeUow Seal Brown Enamel Strontium Chromate - Pig Yell 32 Tangerine NAD Enamel 44-3108 Target Yellow Enamel Tractor Enamel 83132AM Traffic Paint for Creosoted Floor Valencia Orange Valencia Orange Red 104 Vulcan Cooling Water Treatment W and B Grinding Coolant Er55 X-2777 Regal YeUow Light X2552 Rex Orange . X2865 Strontium Yellow YeUow K831-742 YeUow Iron Oxide Ylo 1789 YeUow NAD Acrylic Enamel Yellow Rond Marking Paint TP702 YeUow Safety Enamel STP YeUow Truck Enamel * m 1/ Hexavalent chromium combinations with hydrogen, alkali metals, ammonia and oxygen " excluded. B001 1697 ppnrvr irr?n t>v -4- Croup B -- Known Substitute Material Available With Major Redesign Nonproduction Materials Specification No. Title M-99B113A(H) M-99B114A(H) M-1178C M-5241C Chemical Dcburr Buffer Salt Chemical Deburr Make-up Concentrate Phosphate Coating Replenish Alodine 1200S Alodine 1500 Alodine 407 Alodine 47 ' Black Color Concentrate Chemburr 3F-1 Concentrate Chemseal 174 . HCR 840 Iridite 67 Lead Chromate Liquid Ferric Chloride M&T Fumetrol 103 Macro Polish 5F Macu Stop 9505 70/30 Macu Stop 9506 Yellow Macuplex Etchant L55 19355 Macuplex L56 Acid Cleaner 19356 Met. HCR 841 Chromium Plating Compound Metal Bond 47 A B Parcolene75A Tractor, Primer Udylite Cromylite K352 Zinc Chromate - Pigment Yellow 36 . . 1/ Hexavalcnt chromium combinations with hydrogen, alkali metals, ammonia and oxygen " excluded. . 8006 1345 PRODUCED BY FORD `* . . ,, .MATERIAL CONTAINING IIEXAVALP.NT CHROMIUM COMPOUNDS-' ~ ' . -s- APPENDIX II 5727760-- Group C -- No Known Substitute. Advanced Engineering Project Required Production Materials t Specification No. Title ,, ESF-M1F10-A Leather, Chrome Tan - Vegetable Reton _ ESB-M99Q109-A Ceramic Conting, Glass Decorative ESA-M2J52-A ESN-M2J114-A ESB-M2J214-A Enamel, Air Dry Asphaltum, Chassis Black Enamel, Standard and Low Bake, Tractor Quality Enamel, Baking, Clear, Unanodized Aluminum - Interior ESN-M6J96-A ESN-M6J96-B ESB-M6J119-B ESB-M6J120-C ESB-M32J104-A-^ ESB-M32J104-B ESB-M32J105-Cl-^ ESB-M50J100-A--^ ESB-M50J1DD-B ESB-M50J1D5-a|( ESB-M50J106-AESW>M62J12-A-/ ESA-M62J16-A Primer, Air Dry or Baking, For Export Primer, Air Dry or Baking, For Export Primer Surfacer, Taupe, Epoxy, Low Bake Primer Surfacer, Low Bake Epoxy, Exempt Solvent Taupe (ft)96 Reactive Solvents) Baking Enamel, .Reflow Acrylic - Exterior Quality - Enamel, Baking Exempt Solvent (1096 Reactive Solvents) Reflow Acrylic Exterior Quality Paint, Enamel, Acrylic Basecoat for Basecoat/Cleareoat Wet-on-Wet (1096 Reactive Solvents) Paint, Enamel, Acrylic Baking (NAD), Exterior Passenger Car Quality Enamel, Acrylic Baking - Non-Aqueous Dispersion (NAD), Exterior Body Quality - Paint, Enamel, Acrylic Baking, Non-Aqueous Dispersion (NAD) Paint, Enamel, Acrylic Baking, Non-Aqueous Dispersion (NAD), Exterior Paint, Water Dispersible, Black Water Dispersible Black Paint ESB-M64J12-B ESB-M64J13-B ESB-M64J13-C Primer, Waterborne Electrocoat - Black - Low Solids Type Primer, Waterborne Electrocoat - Black - Medium Solids Type Primer, Waterborne Electrocoat - Black - High Solids Type ESB-M99J248-A Paint, Color Coat for Acrylonitrile - Butadiene - Styrene - First Surface Exterior Nonproduction Materials Chromium Acetylacetonate SSK102 WS 164 WS 64 V Hexnvalcnt chromium combinations with hydrogen, alkali inctals, ammonia and oxygen . excluded. . ` : " . ` . 6001 1698 PprvnT rren cv cro>r> MATERIALS CONTAINING BENZENE^ APPENDIX in 5727755 Nonproduction Materials t Specification No. * Title * Croup A -- Known Substitute Materials Available Without Major Redesign . Sno-Sol 184C Group B -- Knov/n Substitute Materials Available With Major Redesign . lsol 2429, 2429 Naphtha Production Materials Group C -- No Known Substitute.'Advanced Engineering Project Required Z0000329D ESF-M1DC1-A ESE-M99C21-A X3512 ESR-M99P4-B 10SOL2429 2429 Naphtha GP1140 Carburetor Fluid Hydraulic Tappets Oil Sunfleet Super C 10W Oil Underbody Coating/Daubert AC690B MEMO: The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as 8 portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. The following fuels are so identified: M-4C20A ESE-M4C50-B ESE-M4C51-A ESE-M4C56-B XMSOB Z00002232 ESE-M4C45-A ESE-M4C89-A ESE-M4C91-A $2 Fuel Oil, Arco Heating Oil Indolene High Octane 01 Gasoline Indolene Motor Fuel No. 5 Indolene High Octane Motor Fuel 30 Certified MS-08 Amoco Premium Pb-Free Gasoline Regular Gasoline Lead Free Gasoline Cetron Gasoline 1/ Materials known to contain benzene at levels ^ 0.1% 16^ pponTtrpn pv mon SAE 831036 1 TECHNICAL INFORMATION SECTION Ford Motor Company Scientific Research Laboratories LIBRARY LOAN COPY Do not transfer to another person. If you wish someone else to see this, send in name with document and the Library will arrange a loan. 8006 1348 PRODUCED BY FORD