Document kDOpJ2zne5O7GJ7V0JwO8o01b
FRIC7I0H MATERIALS STANDARDS INSTITUTE, INC,, E. 210 ROUxE 4, PARAMUS.N.J.U76^2':
PLAINTIFFS EXHIBIT
- MINUTES OF THE MEETING-
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ASBESTOS STUDY COMMUTES
AB-278
Friday, February 16, 1973, at 9:30 A.M. at the
Institute Office, E. 210 Route 4, Paraaus, N.J,
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MEMBERS PRESENT
I. H. Weaver, C .airman J. C. Henning
H. Wagner '
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E. H. Felerabend
MEMBERS NOT PRESENT
Raybestos-Manhattan, Inc.
Firestone Tire & Rubber Co.,
World Bestos Division
. Carlisle Corporation
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Molded Materials Division
Abex Corporation
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American Brakeblok Division '
T. Bell W.`Spurgeon ;
OTHERS PRESENT
H. S. Porter Company Bendlx Corporation
R. C, Wyatt E. W. Orlslane'
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Mareaont Corporation Friction Materials Standards Institute
The meeting vas called to order by Mr. Weaver, Chairman, at 9:30 A.M.
: MINUTES OF PREVIOUS MEETING
The Secretary read a summary of the Minutes of the Meeting held August 17, 1972.
These minutes had been released and a motion for their acceptance had been
obtained. i
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Upcn motion duly made, seconded and unanimously passed, it was
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RESOLVED: To accept the minutes of the August 17, 1972 meeting . as distributed..
LABELING PRACTICES
The subject of labeling of finished friction materials was the first item on
the agenda. While Interpreting the OSHA requirements, it is noted that the
hazardous warning label must be used where subsequent working of the materials
would creatn airborne concentrations of asbestos fibers in excess of the exposure
limits of the OSHA Standard. In many drilling and grinding operations without
dust collectors, Committee Members indicated that the 10 fibers/cc celling
concentration has been exceeded.
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Minutes of Meeting of Asbestos Study Committee
-2- February 16, 1973
The Chairman mentioned a-survey made in the Metropolitan 'area* concerning the relining of .bakery trucks; The survey (conducted by an : individual .affiliated vlth Me. Sinai Hospital) Indicated that during radius grinding and drilling of brake linings that the airborne concentration of asbestos. fibers was in excess of the 10 fibers/cc ceiling value.
The results of our survey on Member practices for labeling was reviewed, . The
results had been updated showing that .15 Members had replied of .the. 25. Mesbers
questioned. The results indicate that the Membership is not now labeling la
accordance with the OSHA requirements, and while they interpret the OSHA
regulations to require labeling where subsequent machining is expected, they are
undecided^ as to exactly what they will do as regards labeling; In the survey,
2 Messers indicated that a "binder" treatment makes it unnecessary-for the
Member to label: He believes he is complying with the labeling requirement
"No label is required where asbestos fibers have been modified by a bonding
agent...so that during any reasonably foreseeable use...processing...no airborne
concentration of asbestos fibers in excess of the exposure limits.. ;vll be re- *
leased."
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It xs the view of want hembeis o2 the CotioLttee that Cht 5 fibers/rc '(TWA) in
exceeded In many areas such as Inspection, drilling, and grinding where, .there
is no.adequate dust collection machinery. This could happen in garages where
subsequent drilling and grinding is often required and where there Is no
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adequate dust collection equipment. ' While the Members with OEM accounts axe
dealing with manufacturers who should understand the OSHA regulations, the biggest
problem may be with the small shops that are exempt from the requirements of the
OSHA regulations. In an interpretation of the regulations, it is apparent,
that where subsequent working of the material can raise the airborne asbestos
concentrations above the limits that the manufacturer is required to label the
material. Would labeling of cartons suffice? The Committee felt that, yes,
this would be Labeling that would meet the spirit of the OSHA Regulations. Would
it be necessary to put the warning label on individual segments? A Mesber
mentioned that In many cases the carton, or wrapping, for the brake lining is
disposed of before the brake lining moves in to- the working area. It was -
felt that if the warning label were on the carton or skid when it was received
by the customer that the customer has some responsibility to pass the information
on, and it was not necessary to label the individual segments. In the discussion
concerning labeling requirements, the Members bad to distinguish between "where
subsequent working will be required" as against "where there is any possibility
chat subsequent working will be required." Again the point was made that with
undusted linings from a manufacturer it is likely that customer inspection, or
possibly opening of cartons, could show airborne fiber concentrations in excess
of the 5 fibers/cc (TWA).
In discussion of the reasons to support or oppose labeling requirements, the question was raised as to whether objections centered around the cost of the labeling. Members indicated that the direct cost of labeling could be minimal. Most labeling could be put on by the box manufacturer at little additional cost to the friction naterial manufacturer. The rejoinder to this was that the Members felt that it was not the direct cost that bothered them. Rather, it is the indirect cost c the customer reaction to the warning label. Will the customer be temptedi to purchase his linings from a manufacturer who does not put the warning label on the cartons, giving an advantage to the manufacturer who does not comply with the lav or to the foreign manufacturer who is not aware of and cannot be punished by the law?
Minutes of Meeting of Asbestos Study Committee
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February 16, 1973
Upon motion duly made, seconded, and unaninously passed, it was
RESOLVED:
That (1} where asbestos containing materials - not have the asbestos fiber completely locked in, or (2) where subsequent operations may be performed on asbestos containing materials, the hazardous labeling practice be adhered to in accordance with the Label Specifications in the OSHA Standards for Exposure to Asbestos Dust.
The Michigan requirements for labeling toxic and hazardous materials were
discussed. These had been sent to the Members of the Committee in December 1972.
The Ford Motor Company had called to the attention of manufacturers the labeling
requirements for hazardous substances pursuant to Act #282 of Michigan Public
Acts of 1967. In the Michigan Standards there are specific labeling requirements
concerned primarily with flammable and toxic materials. They do not specifically
include asbestos. There are certain label requirements such as "DANGER, WARNING,
CAUTION." The Federal OSHA requirements for asbestos specify CAUTION, which Is
the least sensational of the type headings used. Of course, the DANGER warning
in the Michigan regulations is for materials that would be almost Instantly
lethal. However, it is difficult to tie In asbestos to the specific label
required. It is felt by the Committee Members tuat adherence to
Federal
OSHA requirements should be the first step taken. While the Issue cannot be
specifically resolved, it is felt that compliance with the Federal OSHA regulations
for asbestos would Indicate compliance with the Michigan regulations. While It
is desirable that any label used by the Members should also cover the requirements
of-various state codes, the first step would be to get the Hembezs to label
according to the Federal OSHA regulations.
As regards the Committee's recommendation to the Membership, a decision cannot be
made as yet on the size of the label. The OSHA regulations state that the label
shall be "of sufficient size and contrast as to be readily visible and legible."
Mr. Weaver has received some data on typical caution labels now in use. Mr. Wyatt
will furnish the Secretary the label type that his firm is using. Based on the
labels now in use, the Secretary will distribute this information to the Members
of the Committee for their review. With this information, the Committee should
be in a position to propose label specifications to meet the Federal OSKA
requirements.
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HEW YORK TIMES MAGAZINE ARTICLE "ASBESTOS. THE SAVER OF LIVES, HAS A DEADLY SIDE**
Copies of this article had been distributed to Members of the Committee. In addition, based on requests from Members not associated with the Committee, there were additional copies of the article distributed. As the brake lining industry as such was not a specific target, it was felt that no reply to the Times article was called for by the Institute. Mr. Weaver brought to the meeting copies of another article in the Saturday Review of the Society entitled "An Asbestos Town Struggles With a Miller.*' This particular article concentrated on the .Tohns-Manville plant in Manville, New Jersey. This, of course, was not their brake lining, facility. Other than the specifics of the individuals from Manville, the article relied on much of the same background chat appears in the article in the New York Times.
No action is planned on these articles, but they are almost required reading.
Minutes of Meeting of Asbestos Study Committee
' -4- February 16, 1973
HEALTH EXAMINATION REQUIREMENTS OF OSHA .
All Members of the Committee are aware of the medical examination requirements In the OSHA regulations. All have taken steps to comply with these requirements. The basics of the OSHA requirements are a preplacement examination, an annual examination and a requirement as regards termination of employment. These requirements are for workers who are "exposed to airborne concentration of . asbestos fibers." Note that there are no specific limits which tell whether an * office employee who must make occasional trips into the factory area is exposed to airborne concentrations of asbestos fibers. The treatment of this Is possibly best carried out by meeting the spirit of the regulations in including chose employees in the examinations who are exposed to concentrations in excess of 1 fiber/cc (as used by one member).
The interesting service by International Cotapnineties was discussed. The *.
International Compumetlcs Corporation, located in Princeton, New Jersey, proposes
a series of mobile medical tests which would Include the full examination v.
requirement, computerized medical records, at a price that appeared interesting
to the Members. They will also provide a $500,000 "Errors and Omissions", insurance
poli_y to the ccupany for their program. Two of the Committee Members had
investigated International Compumetlcs and while they were not long on experience
as regards cedlcal background, they apparently did have some computer capabilities.
Also, it was felt that they may have the talent to accomplish what they propose
to do. One Member planned to use the ICM services In one of their factories.
Another Member considered using their services in a factory which later was
scheduled for closing.
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Another Committee Member suggested that while the International Compumetlcs proposals are interesting that it might be possible to do what they have done even nore_reasonably. They work with their local Tuberculosis Society In scheduling examinations in the mobile unit. The Tuberculosis Society does the X-Ray and pulmonary function examinations. The company doctor, in the meanwhile, does the balance of the medical examination. Where local tuberculosis units wish to cooperate, this might be advantageous to both the manufacturer and the worker. In a review of the proposal by International Compumetlcs Corporation It is indicated that they will do everything that 1s required by the OSHA regulations.
The Institute Office will let the Membership know of the availability of the
services of International Compumetlcs Corporation. We will not make a-specific
recommendation. The Chairman also mentioned that there was a New York group that
had proposed some similar services and chat we should also let the Membership
know about them.
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One Member who has already planned to use the International Compumetlcs Corporation proposal will let us know his evaluation of them after they have finished their tests. In direct answer to the question from Mr. Iverson, President of Interaation Compumetlcs Corporation, we will not give them our mailing list. Rather, we will advise cur Members of their services.
ASBESTOS BAG OPENING MACHINERY
The Institute had sent out to the Membership information on manufacturers of specialized bag opening machinery. The problem here is to keep the asbestos fiber concentrations minimized during bag opening and to properly dispose of any asbestos dust still left in the bags. The list of those manufacturing bag
Minutes of Meeting of Asbestos Study Committee
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February 16, 1973
cpenlng equipment should be expanded to Include the:
' Taunton Engineering Company 700 West Water Street Taunton, Massachusetts 02780
INSTITUTE SEMINAR ON SAFETY AND HEALTH REGULATIONS
A Member mentioned that the dissemination of information on the bag opening
machinery was interesting. Perhaps there is more information chat can be given
to the Members concerning disposal, collection, and other techniques used to
comply with the various-regulations. _ In response to a direct question, the
Secretary Indicated that as long as any proposed activity in the area stayed
within the guidelines of our Constitution there should be no reason why
activity could not be planned in this area. Ihese would be specifically covered
by a few objects in our Constitution such as maintaining and raising the standards
of all products, and the cooperation with the United States Government through
its various departments and bureaus, etc. The Members suggested a workshop or .a
seminar which concerned "Asbestos regulations as they affect the work place or
the environment." It was recjamundcl that the Conerittee'.* interest in such a semi
nar or workshop should be approved by the Institute before further action is-
planned.
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Upon motion duly made, seconded and unanimously passed, it was
RESOLVED:
That the Committee is Interested in a workshop on the
effect of Government safety and health regulations
and proposed solutions thereto.
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The Secretary is directed to have this Resolution reviewed so that the Committee
could draw up a formal agenda for such a workshop. It would be the Committee's
intention to have the Institute sponsor this workshop in some convenient location
as soon as it is reasonably possible.
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EPA EMISSIONS STANDARDS
The Environmental Protection Agency had advised the Secretary that they expected to have the new EPA Emissions Standards regulations published by the middle of February. The Committee Chairman advises that publication of the regulations has been delayed and it is now expected that these regulations will be Issued possibly by February 23, 1973.
In the regulations there will be source reporting requirements. These have been extended to 90 days rather than the 30 days that had been indicated earlier. Control practices are still the basic means of applying the standard. Control practices will be required where visible emissions exist. It is not known whether waste disposal will be Included in the regulations.
REPORT OF ADVISORY COMMITTEE ON ASBESTOS CANCERS
At the request of the Chairman, the Members of the Committee had been sent a copy of the report of the Advisory Committee on Asbestos Cancers. The meeting was held in Lyon, France, on October 5 and 6, 1972. This report had been reviewed by the Members of the Committee and there were no comments made thereon. The
Minutes of Meeting of Asbestos Study Committee-'
-6- February 16, 1973
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Chairman advises that this report was to have restricted circulation and that the International Agency -for Research on Cancer had not officially released the report. As ve nay have been premature in distributing the report, it is suggested that the Members restrict their circulation of any information contained in that report.
TEE EPA STUDY OF PARTICULATE EMISSIONS FROM BRAKE LININGS AND CLUTCH FACINGS
The 3endix Corporation has been running tests on vehicles and on dynamometers to
entrap the wear debris of brake linings and clutch facings. This study is under
contract to the Environmental Protection Agency. Originally, the report vas to
have been made in 1972.
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Dr. Spurgeon, of the Bendix Research Laboratories, advises that a final report should be published on these particulate emissions sometime within the next six weeks. There is no indication as to what these results show, as the work (at this stage) is not for publication.
STATISTICAL EVALUATION CF THE M3QEAN5 FILTER MET3CD *
The Chairman distributed to the Committee the conclusions and recommendations in
a report made for the Asbestos Information Association on the precision and
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accuracy of the Membrane Filter Method for measuring concentrations of asbestos
fiber. This report vas done by the LFE Corporation under contract for the
Asbestos Information Association. The evaluation was not reviewed by the
Cormdttee Members at the meeting.
NIOSH RECOMMENDATIONS AS REGARDS HEAT STRESS
This particular area does not pertain specifically to asbestos. However, most of the brake lining and clutch facing manufacturers work with hot presses and various ovens. The recommendations as regards heat stress will affect most of the Members. A Member's work in the area of heat stress measurements was distributed for their review, along with a copy of the NIOSH recommendations. Again, as this information was new to some of the Committee Members the dara was distributed and not discussed.
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There being no further business brought before the Committee, upon motion duly cade, seconded and unanimously passed, it was
RESOLVED: To adjourn.
Adjourned at 1:00 p.m.
E. W. Drislane Secretary