Document nNBjeXYKzYaVVRJRbJ1Orq3rG

FILE NAME: Friction Materials Standards Institute (FMS) DATE: 1975 Apr 28 DOC#: FMS037 DOCUMENT DESCRIPTION: Meeting Excerpts - Asbestos Study Committee - OSHA Regulations & Membrane Method for Measurement i EXCERPTS FROM APRIL 28. 1975 MEETING OF ASBESTOS STUDV COMMITTEE The OSHA R e g u l a t i o n s and the Membrane F i l t e r Method for Measurement O rigin ally t h is subject was to be two items on th is agenda: ( l) The Membrane F ilte r Method Tor measuring airborne asbestos concentrations, (2) The OSHA standards with emphasis on .the July 1, 1976 two fib e r s /c c lim it. In discussing th e se su b je c ts it v/asrfound d i f f i c u l t to s e p a r ta e the membrane f i l t e r technique from the OSHA stand ards'. ..They are being combined for purposes of these minutes. It was suggested that with the current economic clim ate that perhaps there might be some de-emphasis in OSHA r e g u latio n s. There has been de-emphasis on sea t b e l t s , and bumpers, emissions co n tro l and it was suggested that perhaps OSHA might ease o f f on th eir regu lations. One Committee member said that it was most u n -lik e ly that there would be backtracking on the OSHA regu lations. If anything they might be s tiffe n e d . One member s t a t e d that there were fiv e d ifferen t ty p es o f a sb e s to s and that some were more harmful tnan others, it was suggested that while t h i s might tz so, a l l asbestos i s apparen tly linked with lung cancer and a s b e s t o s i s . It would be d i f f i c u l t to ' win an argument that there are some types of a s b e s t o s that a r e not harmful to the r e sp ir a to r y t r a c t . ,__At t h i s point the method for counting fib e r s was d iscussed. It was sta te d by one member that o r ig in a lly a f i b e r woulcj/gl'coonted i f i t was not t o t a l l y within the f i e l d . This was from Jbhns-<Vanville course on the use of the membrane f i l t e r technique. It was s ta te d now that anything that i s in the top or the l e f t hand borders o f the sample, even i f only p a rtly in the f i e l d , are to be counted. Another member indicated that when he took the NIOSH course a t Cincinnati that t h is was the way that he was t c ld to count: any fiber on the l e f t hand or top border, even if not f u lly within the f i e l d being counted, would be counted in th a t f i e l d . It v/as stated that the c r y s t a l 1ization of the solvent used 3n the s l i d e could some times make it appear to be an asbestos fib e r. There i s a method c f preparing the s l i d e s so that the formation of c r y s t a ls v/i 11 not appear similar to a sb e sto s fib ers for counting purposes. T h is method is apparently used by most companies doing t h e i r 1 own counting o f the f i b e r s . , It was pointed out a lso that s l id e s should not be re used. r.e-used s l i d e s may a c c e le r a t e , c r y s t a l li z a t io n of the solven t. It was stated the people making rea Bible. It v.-as si; indicated that he co rrela tion with different reading higher counts wer minus 50% ir. the r-s.-rsar stated tha e i s a s much variation in readings of fiber count a s there are ings. One member suggested that he used the NICSH manual a s a ted that t h i s manual was subject to wide in te rp retatio n . A member exchanged samples with NIOSH in Cincinnati anc has had decent heir counts. It was stated that on the lower counts that three would come out plus or minus 105 on the count. However, when read, the three different readings would come out with p l u s or ount. Over now long a oeriod were these samples colle cted? One OSHA ta kes S-hcur samples. Another s t a t e s the*, they took samples for a mini mum 3- b. ur p er i o d with a 30-minute cycling. Another had oner-hour periods for colie ting samples using one f i l t e r . As regards d iff e r e n c e s, i t was stated by two me" ers that the OSHA inspectors have ac tually picked up lower counts than some or* the embers. It v.-es stated that there were d iff e r e n c e s in r e s u l t s depend i n; uoon wr. ther the counts were done in house, by outside organizations or by government pec le. V/ith these differences in fi ber count, a question was raised - 1- 6  i to hew can on solve a p. ublem when they don't know how _jver the problem l s . In response to question a s to what th is Committee could recommend it was suggested that members should a t l e a s t t e s t each operation every six months. In attempting to get counts down to the 5 fiber lim it and even tually down to two f ib e r s a*member.stated that good housekeeping i s required. Several members mentioned the Milfiak vacuum cleaner . This p a rtic u la r vacuum cleaner can be used "or gettin g into p la c e s that a central unit cannot reach. It has a p l a s t i c bag lin e r and runs on a 15 anp c i r c u i t . Of the movable type vacuum cleaner the members seen to prefer t h i s h lilfisk . This is a Swedish make vacuum c le a n e r.' More information will be gathered on t h i s vacuum cleaner for d istr ib u tio n to the members. In addition it was suggested that one must have a good central c o lle c tio n system. Cr.e that was mentioned was the JM modified central vacuum system, which u t i l i z e s the main duct system a s a cen tral vacuum system. Several memebrs sta te d that goodhousekeeping was one o f the main things that must be taken c a r e o f in order to bring the fiber count down. It was suggested that there are three points for good housekeeping: ( l) Good shrouding and good dust co llectio n ; (2) There should be a cen tral cleaning system for the work area; (3) The N ilfisk vacuum cleaner should be usee for general housekeeping in the work area. ' In ad d itio n i t was sta te d that there should be no dry sweeping in the work area. It was suggested that the f r i c t i o n m aterials business i s d if f e r e n t from regu lar a sb e sto s manufacturing. In ad d itio n to asbesto s, we have other m aterials in the product such as r e sin s, carbon blacks, fr i c t io n dust and v ario u s minerals. It i s p o s s ib le that some o f these may be picked up during the sample gathering before the count. In seme cases these w ill be counted by operators a s being a sb e sto s f i b e r s . In essence it is more d i f f i c u l t to count asbestos in a f r i c t i o n m aterial environment than it i s in a t e x t i l e environment. It i s f e l t that there may be greater d i f f i c u lty in getting co n sisten t readings on fiber counts in the f r i c t i o n m a te ria ls b u sin ess, for that reason f r i c t i o n material manufacturers would prefer a work practices oriented standard. It v/as sta te d that the membrane f i l t e r method should not be abandoned as i t i s the cnly tool for measurement. However, reliance on t h i s tool for enforcement may be almost unbearable in f r i c t i o n m aterials fa c to r ie s. It was suggested that OSHA be ad visee o f our ind u str y's concern with the wide v aria tion in f i b e r counts. Based on the fa c t that' rater i a l s other than asbestos might be involved, it i s necessary th a t the counts be interpreted r e a l i s t i c a l l y . In other words, while the membrane f i l t e r r.sthcc may be the only method that i s av ailab le currently for measureng airborne e s b s s t c s . and it is not f e l t that there i s another method th a t can take i t s p l a c e , it i s a tot 1 that should be usee by manufacturers only in tr y in g to clean up t h e i r a r e a s . it i s net f e l t that t h i s tool is accurate enough to be used for enforcement cur coses. It is suggested that OSH.A inspectors must real ize thi s before f a c t o r i e s are c l : s a c : : r and f i n e s are levied when there i s doubt as to hov; accurate the reas-re~ant is. Because of the wide variation in r e s u l t s there is concern among .-ember s as tc the m illio n s o f d o ll a r s now being put into control methods. Even with these ex;erdicures, there is no way of knowing p o s i t i v e l y whether in d u str ie s are j e t t i n g their counts down to required lev els. Various words were used to . describe the r e l i a b i l i t y of the membrane f i l t e r method for enforcement: One ire: c a t s : that it was " u n r e l i a b l e , " and another indicated th a t it v/as " inadequate". " he s" chasis was that it is the only tool now availab le but i t is not the proper e~ tcrcen er. i ic ar cs. cult .r cul . it had been suggested by some government people in the past that the a t e r ia l 'c'ustry woul d be the f i r s t to comply with the 03'rlA standards. that the f r i c t i o n mat erials business could most r e a d il y meet these standthis meet ins, industry members are indicating that it may be more ,d ffih. friction m ateria ls business to meet the levels because of the d i f f i cu_t i rg fiber samples. It v/2 s suggested that i f we're having d i f f i c u l t y - 2 - 63 - me^tf1ng- i he 5 fib e r s /c c l i e . . . cu rrently, it would be near i. ^ m j o i o ..w 2 tib e r $ /c c limit due ctely 1, 1976. It was suggested that the Industry should oppose t h i s change. t was s ta te d that real is t ic a ll y it i s unlikely that CSHA w ill not go to the i f ib e r /c c limit, on vXily 1 , ,197c. The only question i s w ill they go lower than the 2 fib er limit? ur. S e lik o ff has spoken of a 1 fib e r /c c lim it end has even said no f i b e r s . It was s ta te d that the Asbestos Information A sso ciatio n had circulated in fo rratio n concerning the MIC3H suggestion that the f r ic tio n m a t e r ia l s business would come under the standard now. Such lit e r a t u r e was never re c e iv e d by the I n stit u t e . .Vest members on the Committee were unfamilar with t h i s NIOSH suggestion. As had been suggested e a r l i e r , it i s necessary to make the counts a s accurate a s p o ssib le . For th is reason suggestions on counting procedures, p o s s i b l e c r y s t a lliz a tion of solvents, and a prohibition on the re-use o f slid e s e r a important. Ur. Heaver pointed put th at in a recent pu blication he noted that a p l a s t i c shroud is placed about the entrance to the pump being worn at the work p l a c e , in order to keep large p a r t i c l e s of a sb e s to s from g e ttin g pulled in to the f i l t e r . This shroud would prevent material from being taken fren a worker's clo th es a s well a s from some large p ieces that would o rd in arily f a l l to the floor without bein g inhaled. He sta te d that Turner brothers has been using such a shroud. The u n it i s completely open on the front and it i s f e l t that th is technique g e ts r i d o f some sporadic high counts. f.ir. IVeaver w ill get a copy o f t h i s and d istr ib u te i t to th e members. This could be another p o s s ib le improvement in the sampling technique which might make the membrane f i l t e r method more p a la ta b le . It was suggested 'hat t h i s be considered and perhaps a proposal be made to 05HA for i t s use. The problem i s tw ofold: ( l) Im proving the r e l i a b i l i t y o f the membrane f i l t e r technique, and (2) The use o f the membrane f i l t e r as a to o l for enforcement with i t s lack o f r e l i a b i l i t y . 4 This subject has been f a i r l y well covered. There was some agreement about-the problems in using t h i s technique a s a tool for enforcement o f th e OSHA regulations. The question was what should be done about i t ? One member s t a t e d that the Committee would be rem iss i f it did r.ot advise the members o f t h e s e d i f f i c u l t i e s . It was suggested that the Board o f D irectors be advised that th e re i s a problem and that there is going to be more o f a problem when the 2 fib e r lim it is put into e f f e c t . To repeat the problem: while we need the membrane f i l t e r method a s a tool for measurement, t h i s tool i s not su ita b le for enforcement pu rpo ses. It is sug gested that when the 2 " ib s r s /c c lim it takes e ffe c t that t h i s will-become a most serio u s problem. Fiecorr.mendstions should be put into e f f e c t on instructions to employees, the use of vacuum cie arers, the use c f dust c o l le c t in g systems, d is p o s a l, e t c . When these work p r a c t ic e s are cut into e f f e c t the area w ill be cleaner. It was suggested that the I n stitute contact the Asbestos Information Association concerning the use of the membrane f i l t e r tech-.ieje for enforcement. (See later section o f these minutes concerning Asbestos Information Assoicat ion). The Industry must concentrate on c o l le c t in g , clesr;->; and housekeecing, using the membrane f i l t e r a s a tool to see hew the levels are being reduced. with c a t es croj ecte c 1 i a r c e . ' The air. i s Var i c u s cr i t i cal a r e a r e a . It was surges a inly hell in crcvin c r ; a work sheet with target cates for completion of various i r"reet i r- the CorA standards. This i s e s s e n t i a l l y a schedule "cr each stec which will move their fa cto ry nearer to comp- c have the factory at the 2 fiber l imi t by J u l y 1, 1976, 5 are covered with detailed- steps projected to clean up each od i 'rai t hi s was almost necessary for control and would cert intent to comply with the regulations. - 3C