Document mb9BMkek832kzzaQkG1pV1RNJ

No, bl ' January 31, I98O TEE Q5EA CANCER POLICY _r On Friday, January 19, I960, the Occupational Safety & Health. Administration (OSHA) issued the "OSHA Cancer Policy" entitled "Identification, Classification fie Peculation of Potantia Occupational Carcinogens". Although no specific chemicals are addressed in this statement, of regulatory policy, the policy establishes the criteria and procedures under which - specific substances will be regulated by OSHA. Incorporated as part of the Code of Fedora Regulations, the policy addresses the scientific evidence, subjective, and policy judgmant OSHA will use in determining which of several thousand potential carcinogens to regulate. The policy also establishes a Btap-hy-step process for writing specific regulations for ,, potential carcinogens. In the "Canosr Policy" OSHA combines a reiteration of authority granted to the Agency by ; the OSHA Act of 1970 (P.l. 91-56$) with specific statements as to "Classification, Priorit-. Setting, Initiation of Rulemaking, Model Standards, Scientific Rsviev, and other Bubissuea to be considered under the umbrella policy. i i< General The policy governs the identification, classification, and regulation of potential occu pational carcinogens to most adequately assure "to the extent feasible, on the basis of the best available evidence, that no employs will suffer material impairment of health or functional capacity even if such employe has regular exposure to the hazards dealt with by such standard for the period of his or her working life." " * The definition of a 'potential occupational carcinogen' (POC) is essentially that accepted by the Rational Cancer Institute and is described as any substance that directly causes,--r increases, or enhances a benign and/or malignant neoplasm in one or more manualspecies by appropriate route of entry. Chemicals metabolized by mammals to POC1 a ara included 1tt in this definition. The policy establishes two categories (rather than four as proposed) for classifying POC. A "Category I" substance is a POC as determined from human data, two separate mamma.1 studies, or one iMimml study with positive results from "short-tena" (in vitro) or "site of Injectlon/iapleuatation" tests. A "Category II" substance is a POC where data is from only one mammalian species or is "suggestive". Priorities ~ " Tentative classification, based on "brBf scientific review" may place a substance on a "candidate list" far Category I or II. From each candidate list a "priority list" of approximately 10 chemical materials will be determined (not necessarily by a scientific process). Some of the elements of decision-making will Include number of workers exposed, level of exposure, level of exposure reported to cause cancer, potential of regulation to decrease risk, and availability of substitutes. OSHA Btates that candidate and priority lists shall not be subject to legal review. Candidate lists n>mn be published at least annually and priority lists at least semi annually, - ' 085613 :ed by ford 105540 Although OSHA will "consider" negative scientific data, relatively marginally positive data will outweigh, all hut the most extensive negative teat results, IfalnrnaVHny Notification (within 30 days) of the study of economic and/or feasibility of specifio standards will be given by OSHA. Proposed rulemaking will be in accordance with authority granted to OSHA in the OSHA Act of 1970 and will include notices of proposed rulemaking, comment periods, and hearing dates. For Category I POCs, controls will provide for the "lowest feasible exposure level" or "aero" exposure if appropriate substitutes are available. Emergency temporary standards may be issued for Category I POC's where "grave danger" is determined as defined la the 1970 Act. For Category II FOC's, exposure shall be reduced "as appropriate". Exposure control shall be primarily by meaaB of engineering and/or work-practice controls, and standards for either Category I or II POC* a ahull follow appropriate detailed "model standards" addressed in the policy. Discussion Biring Ralsmn'Hng Discussion during rulemaking will be limited to certain issues including: . "Whether a substance meets a Category I or H POC definition. . Whether data are applicable for POC classification or applicable for exception ox amendment, . The environmental impact of proposed regulations. . DetsEnriaaiion of lowest feasible/appropriate exposure limit for Category 1/ Category H FCC's respectively. As more detailed information becomes available related to specific regulations of specific chemicals, the information nrt any action plans will be distributed as appropriate. For a full copy of tbs regulatory text (Title 29 CFR, Part 1990) see Federal Register. Volume 45, Humber 15, Tuesday, January 22, 1980, Bnles and Regulations, Book 2. Limited copies are available if necessary from the Industrial Hygiene St Toxicology Department (32-20210). ` 1II 005614 1 PRODUCED BY FORD APPENDIX V ET5HiSEEP.IG ASBESTOS PLAIT EPDATE r"'~ i Furcosa To provide a current evaluation on the asbestos regulation, usage and future trends to supplement the Vehicle Materials Engineering Asbestos Plan established August 26, 1977- Regulation I Although a .5 fiber/cc standard was proposed by OSHA on October 9, 1975, 20 measures have been taken to lover the present 2 fiber/cc permissible exposure limit. The following pressures are contributing to further regulation in 1979: , EgBrings have concluded after 44 days of testimony on OSHA's Generic Policy to regulate all carcinogens. B7 law, OSHA must act within 60 days of the close of the' record, but that deadline seldom has been met with past standards. Final rules to set guidelines for all carcinogens, e.g., asbestos, could easily be issued before the end of the year. . Concurrently, extensive media coverage will expedite the asbestos standard below the current 2 fiber/cc level. Medical authorities have taken the position that a safe level cannot be identified. . The completion of the Cotton Dust Standard set a precedent for protection of employes exposed to airborne carcinogens. . The British have adopted an approach aimed at reducing asbestos exposure to the lowest attainable level with a 2 fiber/cc ceiling, for excursions. Farther action is pending on the standard until reports are published by the Advisory Committee. Compliance is enforced under the Health and Safety at Work Act. Program Development j The Asbestos Plan, as delivered to the Advanced Review Committee, February 9. 1978, emphasized programs to prepare the Company for a staged tightening of the standard. Progress of these programs and recommendations are detailed below: Programs . VHDSP and IIAAQ Purchasing monitoring supplier com pliance and engineering programs. Status______________________Recommendations A-s of August 26, 1977 . Suppliers reaming compli ance to 2 fiber/cc level with active programs to meet lower levels. . Engineering programs in initial stage of develop ment of alternative materials. Raybestos-Msnhattan R&D Review, 9/27-28/78. __ VMDfiP and RAID Purchas ing to monitor suppliers progress of acmevmg efficient ennrormieital controls. VHD&? and Engineering to track E&D efforts and manufacturing feasibility of substi tutes. 005615 f FORD PrCSV *25 -2- Status APPENDIX '/ , * Hecoumeiidations , XAAO Purchasing mcniiorjag costa of asbestos containing components and engineering conduc ting comparisons vita alternative materials. . Advanced Engineering Programs funded for 1976 in Chassis and Transmission and Axle to assess substitutes. Transmission Chassis $114,000 Analysis limited to rav asbestos fiber. SAAO Purchasimg to svalu-j ate the cost of the finalV-J^ product on a directional basis on engineering determined substitutes. As of 8/78, $47,000 spent on Transmission to continue feasibility programs for non an active program on non asbestos clutch facings. asbestos replacements for The following non-asbestos production implementation. funds for 1979 will be incor porated into forward model allocations: $100,000 C-6 Auto-Job 1, '80 $300,000 JIQD-Auto-Job 1, 8l $100,000 Man. MTX-Job 1, * Si . * t. ri w *-- Funding cancelled _for_ calen dar year 1978. Lack of supplier submissions. ^ _ r-'*: -- n-_fl-nsr_ snj Budget for 1979 recommended at $40,000 for ^advanced projects on non-asbestos-. * Chassis to support tran sition to nan-asbestos friction materials by evaluating supplier 5&D anhai aslons.- . Besaarca support of Engineering in parallel projects. Tearly allowance for the Machining and Wear Depart ment, $312,CC0. The non asbestos project, not separately funded, does not incorporate the full time effort of one employe. E&H. Staff to reassess the flat budget planned for 1979 to susiain future supplier submissions, lawsuit inquiries and ICBA requests from Engineering. 005616 PRODUCED BYFORD 3- - appendix V I Usage j '''ha transition to non-asbestos products is keyed to the rapid escalating costs associated 1th the use of asbestos and reaches beyond the purchase price to include expenses such as... .regular medical check-ups, long term recordkeeping, fiber level monitoring and special work practices, as well as rapidly increasing insurance and legal costs. The basic factor in the overall strategy for asbestos elimination is the caution that must be exercised in introducing new materials to critical drivetrain and brake components. The unique properties of asbestos fiber have slowed efforts towards substitution in pro ducts with high asbestos content receiving heavy duty service, e.g. friction brake com ponents. Supplier submissions in these areas have been limited to evaluation by Scientific Research, with no level of success reported. Future Trends ] . Selective removal of asbestos as a product constituent appears to be the future trend where asbestos is not critical to product acceptance and performance. This is supported by the reduced demand for asbestos fiber imports, since 1973* The new approaches, materials and processes, required to achieve the transition to non-asbestos usage may provide improved levels of performance and reliability. . Products such as friction materials, where there is difficulty in duplicating the ^ attributes of asbestos and where there are no economically feasible alternatives, will continue to he produced, . Asbestos will be replaced by several materials - not by a single material for al!i product lines. This is not unexpected due to the present use of asbestos from very short filler fiber grades to textile grade fibers and yarns. Non-asbestoS fiber blends will be given expanded evaluation. . High costs of worker protection and environmental control in regulated, indus trialized nations like the United States will encourage hazardous and polluting industries to expopt their factories to non-regulating Third World Nations, e.g., Mexico, Taiwan, Brazil and South Korea. The U.S. Government will initiate moni toring of exporting hazards to other countries and will pressure world financial institutions to restrict funding to such concerns. Vehicle Materials Engineering October, 1978 005617 . PRODUCED BY FORD i5ES5>gr oT aej&tc I *; BCD'* APPENDIX VI BACXCRDnUD CSHA has pmiwO sated an airborne arsenic standard limiting exposure of -orkers to 10 ug/cj an in 3-ncur, tins-waigited av-rag* sample. This naw rtgulaticr will effect Ford's use of lead tody solder which contains arsenic is in essential ingredis-.t. Airborne arsenic levels say reaen 700 ug/n3 curing grinding of tie salner. tnplo/es nat wear respirators, baa under the new regulations, current anotices 'Jill not be adequate, The tiring for imolamentation ax' tne stanasrd is . Ford Prcvran. . August 1, 1978 - ELesoirator use ter employees exposed ebmm 500 Ug/m3. Presently complying , Ho later than Secrtenesr 15, 1978 - Completion oa s n< t.iel monitoring. Program Launches . October 1, 1978 - Caapleta establishment of regulated areas. - Respirator use for employees exposed above 50 ug/a3. - Completion of initial training. - notification of use to the government. lead grinding oootn designated as regulated area since Inten tion of lead control orogrtm. . December 1, 1973 - Respirator usa over ID Ug/sJ - Completion of initial magical - Completion of compliance plan All assembly plants have bean infermed. . July 1, 1979 - Completion of lunch rooms and byglena facilities. . December 31, 1979 - Completion of engineering controls. -- Respirator usa no longer acceptable. Ho formal plan out CGC contactea on advisability of recuasttng a variance. Compliance unlikely The uresence of arsenic in lead body solder is essential to its successful use. Tea tin arsenide posse promotes a fine grain sine necessary far good sureodabillty. Alternative alloys that miniaiie toe amount .of arsenic or eliminate arsenic entirely am a possibility, but research and development for such allays may be wasted if the expected lend standard praclines the use of lead body seiner. If alroome concentra tions of arsenic/lsad cannot be controlled to the standard, the most attractive alternative may be plastic body solder. Ford has considered this substitution in the past, but costs and facilities have prevented apolication. The most recent plastic body solder program was cancelled because of cost for implementation ana possible toxicity of_the .-itiea in the formlatlaa- "" 5ECOHHE3DATT0H . Zetablish a task force to determine if and bow Ford con meet the new airborne arsenic standard. Task force members shall be - - Automotive Assembly Division - Body and Zlectrical Product engineering - Industrial Hygiene and Technology , - Chemical Sciences Laboratory . - Manufacturing Processes Laboratory - Office of -the Ooaeril Counsel * - Vehicle Materials engineering . Begin design studies to eliminate need for body solder. , Reactivate the plastic body solder program to find accentabls replacement for the lead--arsenic solder. * 0GC Involvement will be required ta intsrnret the standard end to petition for relief from the standard if necessary. Vehicle Materials lagineerifig October, 1973 005618 PRODUCED BY FORD