Document npwe0bzp9Mz1V2DB0BmZ1D6dX

FILE NAME Allied Signal Bendix ASB DATE 1975 Apr 26 DOC ASBO09 DOCUMENT DESCRIPTION Meeting Minutes - Asbestos Study Committee 33 a, a en ee ee a es 7+ me cs ey mmesw 6 twee ~~ wes ee Sete OF THE THE ron ary ewer aot UNCONFIRMED UNCONFIRMED UNCONFIRMUEDNCONFIRMED UNCONFIRMED MINUTES MINUTES of the ASBESTOS STUDY COCHITTEE : ; am Monday April 26 1975 at 9:30 ALI : Institute Office 210 Route 4 Paramus N.J. [2 N. PLAINTIFF'S EXHIBIT EXHIBIT BDX 45 M ME EMMBBEERRSSMEMBERS PRESENT PRESENT PRESENT 1. d Teaver Chairman H. Wagner 1. Stjohn For 3. E. Stone J. Dunderdale I. A. Feierabend . FOR THE THE INSTITUTE INSTITUTE INSTITUTE Manhattan Inc. . Carlisle Corporation Bendix Corporation Royal Industries Abex Corporation . . Brislane MOT PRESENT Friction Materials Standards Institute 4 + E. F. Stefl M. Jacko H. K. Porter Co. Bendix Corporation The The meeting was called to order by Mr. Weaver Chairman at 9:30 .. MINUTES OF PREVIOUS MEETING The Secretary These rinutes obtained read a summary of had been released the and Minutes of the Meeting held June 14 1974 a motion for their acceptance had been . Upon motion duly made seconded and unanimously unanimously unanimously passed it was RESOLVED To accept the minutes of meeting as distributed the June 14 1974 SUGGESTED WORK PRACTICES FOR OSHA STAITDARD In late 1974 the Asbestos Information Association submitted some recommended 1 work practices for manufacturers and fabricators using asbestos friction materials These were to be sent to OSHA for their consideration OSHA has been considering a new or revised standard in which work practices might be emphasized Mr. Drislane reviewed the MA suggested work practices before they were submitted and made some suggestions for change A draft the suggested work practices was circulated to the membership of this committee Manhattan had done work on the subject entitled Asbestos Dust Control in Brake Service Centers It was suggested that these procedures mighbte applicable for fabricators There were several suggestions on how Com tere . ne me ee e e ne . . cae eo toe wet Asbestos Minutes Study CoCommmimtteiCeomite tCommitttee ee -2- April 28 1975 to handle the suggested Paybestos procedures One susgested that these be recommended the forwarded to work Asbestos Information practices for OSHA Association to be included Another suggestion was for in their this to be distributed to our members for their distribution to their customers It is considered likely that when the revised OSHA standards come but that the work suggested be any action practices will that this Committee be included There does can take at this time as not appear to regards work practices except for the suggested practices in the Brake service centers The OSHA Regulations and the Membrane Filter Method for Measurement Originally this subject was to be two items on this agenda 1 The Membrane measuring Filter Filter Method for airborne asbestos concentrations 2 standards with emphasis on the July 1 1976 two fibers limit The OSHA In discuss- ing these subjects it was found difficult to separate the membrane filter technique from the QSHA standards They are being combined for purposes of these minutes It was suggested that with the current economic climate that perhaps there > might be some emphasis in OSHA regulations There has been emphasis emphasis on seat belts and bumpers emissions control and it was suggested that perhaps OSHA might ease off on their regulations One Committee member said that it was most likely that there would be any backtracking on the OSHA regulations If anything they might be stiffened One member stated that there were five different types of asbestos and that some were fore would harmful than others It was suggested that while this might be asbestos is apparently linked with lung cancer and asbestosis so It all be difficult to win an argument that there are some types of asbestos that are not harmful to the respiratory tract At this point the method for counting fibers as discussed It was stated by one member that originally a fiber would not be counted if it was not totally within the field This was from a Manville course on the use of the membrane filter technique It was stated now that anything that is in the top or the left hand borders of the sample even if only partly in the field are to be counted Another member indicated that when.he when.he tock the NIISH course at Cincinatti that this was the way that he was told to count any fiber on the left hand or top border even if not fully within the field being counted would be counted in that field It was stated that the crystallization of the solvent used on the slide could sometimes make it appear to be an asbestos fiber There is a method of preparing the slides so that the formation of crystals will not appear similar to asbestos fibers for counting purposes This method is apparently . used by most companies doing their out also that slides should not be own counting of the fibers It was pointed used Re used slides may accelerate crystallization of the solvent It was stated there is as much variation in readings of fiber count as their are people making readings One member suggested that he used the ICSE manual as a Bible It was stated that this manual was subject to wide interpretation A member indicated that he exchanged samples with NIOSH in Cincinnati and has had decent correlation with their counts It was stated that the lower counts that three different readings would come out plus or minus 10 on the count However when higher counts were read the Asbestos Study Study ^'ntes Committee -3- April 23 1975 three different would come out with plus or these Over how long period were samples that OSHA takes hour samples collected Another stated that minus 50 in the count One member stated they took samples for a minimum hour period with a minute cycling Another had three hour periods for collecting samples using one filter As regards differences it was stated by two members that the OSHA inspectors have actually picked up lower counts than some of the members It was stated that therewere differences in results depending upon whether the counts were done in house by outside organizations or by government people With these differences in fiber count a question was raised as to how can one solve a problem when they don't know how severe the problem is In response to a question as to what this Committee could recommend it was suggested that members should at least test each operation every six months get In attempting to counts down to the 5 fiber limit and eventually down to two fibers a member stated that good housekeeping is required Several members mentioned the Nilfisk vacuum cleaner This particular vacuum cleaner can be used for getting into places plastic has a plastic bag liner and runs on vacuum cleaners the members seem to that a central unit cannot reach : a 15 amp circuit Of prefer this Nilfisk the movable type This is a Swedish make vacuum cleaner More information will be gathered on this vacuum clegner for distribution to the members In addition it was suggested that one must have a good central collection system One that was mentioned was the I modified central vacuum system which utilizes the main duct system as a central vacuum system Several members stated that good housekeeping was one of the main fiber counts down things It was bring that must suggested be taken care of in order to that there are three points for the good housekeeping 1 Good shrouding and good dust collection 2 There should be a central cleaning system for the work area 3 The Nilfisk vacuum cleaner should be used for general housekeeping in the work area In addition it was stated that there should be no dry sweeping in the work area It was sugrested regular asbestos materials in the that the friction materials business is different manufacturing product such as In addition to resins carbon from asbestos we have other dust and blacks friction various minerals It is possible that some of these may be picked up during the sample gathering before the count by operators as being asbestos fibers In some cases these will be counted In essence it is more difficult to count asbestos in a friction material environment than it is in a textile environment It is felt that there may be greater difficulty in getting consistent readings on fiber counts in the friction materials business For that reason friction material manufacturers would prefer a work practices oriented standard It was stated that the membrane filter method should not be abandoned as it is the only tool for measurement However reliance on this tool for enforcement may be almost unbearable in friction materials factories It was suggested that OSHA be advised of our industry's concern with the wide variation in fiber counts Based on the fact that materials other than asbestos might be involved it is necessary that the counts be interpreted realistically In other words while the membrane filter method may be the only method that is available currently for measuring airborne asbestos tae. and it is not felt that there is another method that can take its place it is a tool that should be used by manufacturers only in trying to clean up their areas It is not felt that this tool is accurate enough to be used for enforcement purposes It is suggested that OSHA inspectors must realize . Asbestos Minutes Study Committee -4- _ 29 April 1975 this before factories are closed our and fines are levied when there is doubt as to how accurate the mausurement is Because of the wide variation in results there is concern among members as to the millions of dollars now being put into control methods Even with these expenditures there is no way of knowing positively whether industries are getting their counts down to the required levels Various words were used to describe the reliability of the membrane filter method for enforcement One indicated that it was unreliable and another indicated that it was inadequate The emphasis was that it is the only tool now available but it is not the proper tool for enforcement Ironically it had been suggested by some government people in the past that the friction material industry would be the first to comply with the OSHA standards NIOSH felt that the friction materials business could most readily that it meet these standards may be more difficult At for this meeting industry the friction materials rembers are business to indicating meet the levels because of the difficulty in counting the fiber samples It was suggested that if we're having difficulty meeting the 5 fibers limit currently it would be near impossible to meet the 2 fibers limit due July 1 1976. It was suggested that the Industry should oppose this change It was stated that realistically it is unlikely that OSHA will not go * the 2 fibers limit on July 1 1976. The only question is will they go lower than the 2 fiber limit Dr. Selikoff has spoken of a 1 fiber limit and has even said no fibers It was stated that the Asbestos Information Association had circulated information concerning the NIOSH suggestion that the friction materials business would come under the standard now Such literature was never received by the Institute lost members on the Committee were unfamiliar with this KIOSK suggestion As had been suggested earlier it is necessary to make the counts as accurate as possible For this reason suggestions on counting procedures possible crystallization of solvents and a prohibition on the use of slides are important Mr. Weaver pointed out that in a recent publication he noted that a plastic shroud is placed about the entrance to the pump being wora at the work place in order to keep large particles of asbestos from getting pulled in to the filter This shroud would prevent material from being taken from a worker's clothes as well as from some large pieces that would ordinarily fall to the floor without being inhaled He stated that Turner Brothers has been using such a shroud The unit is completely open on the front and it is felt that this technique gets rid of some sporadic high counts Mr. Heaver will get a copy of this and distribute it to the members This could be another possible improvement in the sampling technique which might make the membrane filter method more palatable It was suggested that this be considered and perhaps a proposal be made to OSHA for its use The problem is twofold 1 Improving the reliability of the membrane filter technique and 2 The use of the membrane filter as tool for enforcement with its lack of reliability This subject had been fairly well covered There was some agreement about the problems in using this technique as a tool for enforcement of OSHA regulations The question was what should be done about it One member stated that the Committee would be remiss if it did not advise the members of these difficulties It was suggested that the Board of Directors be advised problem that when there the 2 is a problem and that there is going to be fiber limit is put into effect To repeat more of a the problem Asbestos Minutes . Study Committee -5- while we need the membrane filter method as a is not suitable for enforcement purposes It 2 fibers limi takes effect that this will tool for measurement this tool is suggested that when the become a most serious problez Recommendations should be put into effect on instructions to employees the use of vacuum cleaners the use of dust collecting systems dis psal etc. When these work practices are put into effect the area will be cleaner I was suggested that the Institute contact the Asbestos Information Association concerning the use of the nembrane filter technique for enforcement See later section of these minutes concerning Asbestos Information Association The Industry must concentrate on collecting cleaning and housekeeping using the membrane filter as a tool to see how the levels are being reduced One member brought along a work sheet target dates for completion of various items that will help in meeting the OSHA standards This is essentially a schedule with dates projected for each step which will move their factory nearer to compliance The aim is to have the factory at the 2 fiber limit by July 1 1976. Various critical areas are covered with detailed steps projected to clean up each area It was suggested that this was alomost necessary for control and would certainly help in proving intent to comply with the regulations , 7? In another area a question arose as to what were the Canadian standards Ac the present time there is no national standard in Canada However it is likely with the recent furor over asbestos in Toronto that Canada will be moving to a 2 fiber limit Upon motion duly made seconded and unanimously passed it was RESOLVED That the Committee requests guidance from the Board of Directors concerning the problem of the 2 fiber limit and the lack of reliability of the membrane filter method for measurement of fiber counts ASBESTOS FIBERS SHORTER THAN 5 MICRONS Those promoting standards for the work place and the environment are now expressing concern about the asbestos fiber which is shorter than 5 microns Their feeling is that fibers shorter than 5 microns are medically significant There may be a problem with lower efficiency systems filtering out micron material It may be simpler for five micron particles to pass filters and any natural filtration in the human respiratory system and more readily get into the lungs It has been stated that in the EPA No Visible Emissions standard that there are probably many fibers less than 5 microns that are not visible In order to measure these fibers one would have to go to electron microscopy It was stated that a measuring device called the Nucleopocraen make measurements dom to 0.1 micron A problem is that industry is having so much difficulty with the standard for particles greater than 5 microns so what can they possibly do about those shorter than 5 microns There is no reliable means of gathering sub 5 mitron particles in wide usage today It was suggested that if work practices and control procedures now being put into effect are effective in reducing the 5 micron and larger particle counts down to acceptable levels that at the same time industry would radestos Minutes Jin- Conmievesa -5- . patricle be reducing the sub 5 micron patricle level April 25 1975 EFFLUENT EFFLUENT GUIDELINES - ASBESTOS INDUSTRY One of the must use that Deans requirements of the EPA effluent guidelines is that Canufacturers the best technology available in effluent control This essentially they must use the dry bag house Some members did not want to abandon wet dust collectors Regardless most have nos moved to the dry bag house There are problems with the dry bag house In particular one is when a bag is broken Another is the continual problem with fires It was suggested that there should be separator before the bag house Some As at an earlier meeting one member pointed out that when they enforced a smoking ban in the work place they stopped the fires in the bag house Another member indicated that he had tried this but that it did not work It was stated that one could use fire proof bags but they are expensive It was suggested that while this problem can be solved the solution is expensive also However as regards the effluent the way to compliance is by the guidelines use of dry bag house a -. v7 . NATIONAL EMISSIONS STANDARDS FOR ASBESTOS It was pointed out that the Friction Materials Standards Institute did comment to the EPA concerning the proposed amendments to the National Emissions Standards for Asbestos This comment was made on December 3 1974 The FSI pointed out that there were two problems 1 The inclusion of fabricators of friction products in the requirements and 2 The requirement for warning signs on inactive waste disposal sites The first problem is that the fabricators were not aware that they were coming under the National Emissions Standards and there was not sufficient time for them to comment to EPA One member took the proposed amendments and the letter to EPA and circulated these to his customers so that they would be aware of the problem and possibly comment to EPA . The other problem affected industry directly is that private contractoconrtracstors were hauling the material to public land fills The problem is the warning signs on inactive waste disposal sites and the fact that this could effectively remove the land area from future development Mr. Weaver advised that the Asbestos Textile Institute had commented concerning the difficulties with the various EPA solid waste requirements In particular they commented concerning sludge removal that might have to be transported to a land fill and the requirements for covering a land fill ATI indicated that some of the regulations were moving at cross purposes For example OSHA prefers wet methods to control dust whereas EPA wants dry methods to prevent water pollution This land fill problem is going to be a major problem if implemented as indicated in the proposed amendments to the National Emissions Standards ASBESTOS INFORMATION ASSOCIATION AIA One member stated that he was disappointed that the Institute did not take steps to have closer liaison with the Asbestos Information Association 2 et ahs ccm ee etme oe oh Bees af Ri wgneanen we ee eee eee ee em eee + FEO te tee eee Qe ee Asbestos . Mnutes Study Committee -7- April 28 1975 agenda at the June Neeting The Institute has always tried to maintain an independent course and has not affiliated with other organizations We have however tried to cooperate with the Asbestos Information Association The general feeling is that the Asbestos Information Association is doing a good job for the Asbestos Industry including friction manufacturers We have maintained our contacts and links with the Asbestos Information Association The Secretary advised that at a March meeting of the Board of Directors a resolution was passed that we would contact the Asbestos Information Association offering financial support Whether this support would be a direct contribution by the Institute or a recommendation of support by individual members has not been decided The Secretary contacted Mr. Mr. Mereness of the Asbestos Information Association concerning this possible support At this point it was stated that we had considerable discussion earlier in the meeting about the difficulty friction materials manufacturers are having in meeting the existing 5 fibers standard and will have in meeting the 2 fibers limit The question is Are other manufacturing groups having this same difficulty It was suggested that the Secretary contact the of asbestos is the only Asbestos Information Association to find out whether other users are having this difficulty While the membrane filter method m method available the members are questioning its inherent inaccuracy and the difficulty in training people Have other industry accepted the 2 fiber limit Perhaps the friction material industry is having more problems with the membrane filter technique than other industry groups This question will be asked of the AIA To summarize Have other industry groups questioned the existing 5 fiber limit and the 2 fibers limi that goes into effect July 1 1976 Upon motion duly made seconded and unanimously passed it was RESOLVED The Asbestos Study Committee wishes to go on record in favor of support of the Asbestos Information Association As a comment the words financial support were not used as the Committee suggests that the Institute either give direct financial support or as an alternative recommend direct support of the Asbestos Information Association to the members of the Institute POSSIBLE WORK ASBESTOS PROBLEMS It was stated that perhaps the Committee members were not the best qualified to handle the asbestos problem Perhaps some members are environmental people Others may be factory people Others might not be directly involved with the problems of asbestos Perhaps it would be well to call on others who might be able to give specific expertise It was pointed out that Bendix had two members on the Committee with different expertise It would be completely reasonable for the members of this Committee to bring along to future meetings people skilled in different areas in the asbestos problem Such attendees would be welcome at any meeting At this point two years ago seablers only it was suggested that the proposed seminar that had been suggested might be worthwhile A more formal program dealing with asbestos could be scheduled For example most people who attended the cee 8 ~ woe we te ee Asbestos Study Committ Minutes -8- April 28 1975 Manville seminar were quite pleased with it Perhaps they have dated some of their work This is a half day session that was put on in various parts of the country and to which several members of the Institute were invited Perhaps Manville would be willing to put on such a seminar again and it was suggested that Mr. Bill Reitze of Manville be contacted Methods on air sampling could be discussed at a M seminar Mr. Weaver suggested that he would contact Manville concerning this subject It was suggested that if the Institute were interested in sponsoring a work shop the Manville program would be ideal for the first half period To strengthen our ties with the Asbestos Information Association it would be well to have someone from the AIA address those attending In this way we could indicate some of the problems the friction materials industry has that the AIA might not be aware of Also it might be possible for the Asbestos Information Association to solicit support of the Institute and Institute members at such a session Upon motion duly made seconded and unanimously passed it was RESOLVED That the Committee recommends that the Institute sponsor a one day work shop on the asbestos ca problem in the early Pall of 1975 - OTHER BUSINESS It was suggested that the Asbestos Study Committee might enlarge their activities beyond the field of asbestos There was a recent article in one of the newspapers concerning the health hazards of nickel Nickel is a substance found in asbestos and it apparently is found in cigarettes as well Nickel does not get into the cigarettes from the plant but apparently is picked up during processing It was suggested that perhaps this was a cause of the lung cancers that have been associated with asbestos It was also stated that this might be grasping at straws A real problem in the workplace may be encountered by those using lead or lead oxides in the workplace OSHA is talking of lead concentrations in the .15 cubic meter It may be worthwhile to bring lead into this committee's activities It was suggested that the committee be named the Hazardous Materials Study Committee No action was taken in this area It was also stated that because of the heavier lung cancer risk for those who smoke as against those who do not smoke that smoking campaigns should be promoted Even Dr. Selikoff has indicated that a smoker working in an asbestos work place may be no more likely to be effected by lung cancer than a person in the general population However cigarette smoking coupled with exposure to asbestos in the work place multiplies the problem * e sh & & There being no other business brought to the attention of the Committee upon motion duly made seconded and unanimously passed it was , . RESOLVED To adjourn ines aFiaes 2.00 Dw E. W. Drislane - -- ey