Document o9o2nQngzJwbgLM8LOb4GM65R

FILE NAME: Friction Materials Standards Institute (FMS) DATE: 1972 Aug 17 DOC#: FMS021 DOCUMENT DESCRIPTION: Meeting Minutes & Attendee List Asbestos Committee Meeting FRICTION MATERIALS SI ARDS INSTITUTE, INC,, E. 210 IE 4, PARAMOS, N.J.07652 MINUTES OF THE MEETING of che C f e / f i- '^ 2~ ASBESTOS STUDY COMMITTEE Thursday, August 17, 1972, at 9:30 A.M. at the Institute Office, E* 210 Route 4, Paramus, N. J. MEMBERS PRESENT I. H. Weaver, Chairman J. C. Henning W. Spurgeon H. Wagner E. H. Feierabend Raybestos-Manhattan, Inc. Firestone Tire & Rubber Co., World Bestos Division Bendix Corporation Bendix Research Laboratories Carlisle Corporation Molded Materials Division Abex Corporation American Brakeblok Division MEMBERS HOT PRESENT W. B. Reltze* Johns-Manville Corporation OTHERS PRESENT D. E. Stone E. W. Drislane Bendix Corporation Friction Materials Division Friction Materials Standards Institute The meeting was 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 February 10, 1972. These minutes had been released and a motion for their acceptance had been obtained. Upon motion duly made, seconded and unanimously passed, it was RESOLVED: `To accept the minutes of the February 10, 1972 meeting as distributed. INTERPRETATION OF THE OSHA REGULATIONS The Asbestos Information Association (AIA) met with representatives from OSHA late in June. The purpose was to interpret various individual requirements in the 0S0A regulations. Letters from the AIA to their member companies, dated July 5, 1972 and July 12, 1972, were distributed to the Committee Members. In the first letter, they covered areas such as labeling, clothes lockers, Minutes of Meeting Asbestos Study Committee -2- August 17, 1972 -- respirators, monitoring and physical examinations, citations, OSHA inspections and employ notification. In the second letter, the AIA distinguishes be tween non-lockad-ia asbestos containing and clutch facings). There are certain labeling requirements tied in to the non-locked-in containing asbestos products, but this letter also discussed the problems of subsequent working of locked-ln asbestos containing products. The menbers discussed some of the items in the OSHA regulations. One member indicated that during an inspection, there were 3 OSHA people at their plant for 7 to 8 days. Interestingly, the 3 OSHA people came on site, the first day wearing respirators. Whether this was for effect or Is,a standard procedure for OSHA was .not known. One of the items pointed out by .-an OSHA lnspactor on the scene was the dry sweeping of loose asbestos-type compounds vs. tha wet sweeping or vacuum cleaning that OSHA calls for. Another member advised that they had'taken out all air hoses around briquette presses and.other machinery where loose asbestos is handled before it becomes locked in. Surprisingly to some members, asbestos sampling indicated that the inspection and drilling locations were problem areas. One member required that the respirators be worn at all drilling locations. . J In an inspection at one member's plant, the OSHA people set up 5 stations sad while 4 of them sampled below the 5 fiber per cc TWA, one station read 18 flbars per cc THA. This member was cited (in averaging the readings). When the federal Government was considering the necessity for asbestos regula tions, two of the companies represented by Members on the Committee were asked to cooperate in a survey by NIOSH. This study by NIOSH was to check over medical records and other such items to attempt to put the problem in prospective. NIOSH had indicated to the cooperating manufacturers that the Information they were providing would be kept confidential. However, as it turns out, the OSHA people have copies of the NIOSH studies which would indicate that the confidentiality has been violated. A member questioned what happens when the asbestos concentration in a work area exceeds 10 fibers per cc (the ceiling concentration in the OSHA regulations). The answer Is that the employer must notify the worker so exposed, in writing,, that he was exposed to such a concentration and the worker must wear a respirator in that area. The next question concerned what the proper means for notification of the workar would be. If an interpretation is officially asked of OSHA, they will indicate that a registered letter to the employee is the proper of notification. In other areas, OSHA has indicated that meeting the spirit of the law is what counts and it is felt that bulletin board notification would suffice. disposable The next question concerned respirators. It was indicated that there were 3 / respiratorPProveiy the Bureau of Mines, and these are.manufactured by the A. 0. Smith Company, Welsh, and Minnesota Mining and Manufacturing (MMM). Respirators furnished employees must have a proper fit and the employees must be instructed both as to the fit and the servicing of the respirator. Responsibility for testing and approval of respirators for protection against asbestos dust re cently was transferred from Bureau of Mines to NIOSH. Until NIOSH approvals are issued, it is recommended only respirators (reusable or disposable type) having Bureau of Mines approval specifically for use on asbestos dust be used in asbestos contaminated atmospheres. Minutes of Meeting Asbestos Study Cooalttee -3- Auguar 17, 1972 LABELING PRACTICES There are 3 areas for concern on labeling. One is the handling of the loose asbestos fiber from the point vhere It is received to the point where it is mixed and briquetted. The next la the handling of the products with supposedly locked-in asbestos during subsequent operations, such as drilling, grinding, inspection and boxing. The last concerns the handling of the brake lining or clutch facing by the customer where he may also do some drilling or grinding before the lined assembly is a-finished product. It was reported during this topic that there was a higher concentration of asbestos in the air In the Inspection Department than most; members had realised. One member indicated chat when pallets of brake H nt ng were shipped there apparently is additional dust created during transportation. The question of surface dust on the working surface of a brake lining or a clutch facing was discussed. Where members have taken action to reduce the dusty type surface, they have found that they have actually altered the frictional characteristics of the material during the early-miles on a vehicle. In other words, the brakes are not very responsive firing the early mileage after rellne. In thki AIL i-ecooT^adatlocs, it is cugcccted th?t vhere a m n f a c t u r e ? 1 shipping his brake linings or d u t c h facings (locked-in-asbestos products) he should notify the user of his product to the effect, "Power bench saws ,,without collectors should not be used In cutting this product. If this Is impractical, operators should be provided with e Bureau'.of Mines approved respirator.H It vae suggested that a notification bespat In boxes of brake linings or d u t c h facings being shipped to customers. A sample of the caution labels suggested is attached to these minutes. Mr. Feierabend indicated that this recommendation would not be accepted warmly by many manufacturers. Mr. Vagner objected to the recommendation that warning notices be put in the brake H r H w g * as he felt It j was another "red flag" that would bring more harm to the Industry than the / alleged good that would come from enclosing such notices. Several members have I had customers call in to their Sales Departments asking if the handling of locked-in-asbestos in brake linings and d u t c h facings is a hazardous condition. Another asked if this notifcation was a requirement of the OSHA regulations. It was indicated that this was not specifically required by the OSHA regulations. The concern is, do those customers doing additional grinding and drilling of the brake linings or clutch facings create working conditions where the con centration of asbestos would be a hazard. Since small manufacturers are exempted from the OSHA regulations, they will probably not be running tests. Larger customers will, of course, be covered under the OSHA regulations and it is expected that tests will be run in these manufacturers* work areas. Whether the Institute would recommend such labeling in finished products shipped to the customers was.not decided. It was felt that this subject should receive further consideration from the Members of the Committee before a recommendation is made. One member commented that there were instructions by some manufacturers advising that blowing out the wear debris from used brakes was not recommended. This subject of recommending that brake lining and clutch facing manufacturers include a warning sheet in their shipments appears to be somewhat controversial and it is suggested that this matter receive some serious discussion by the Members of the Committee with those responsible at their companies. This item will cost definitely be on an agenda for the next meeting of the Asbestos Study Committee. / ~ Minuses of Meeting Asbestos Study Committee August 17, 1972 SAMPLING FOR ASBESTOS FIBER COUNTING Hr. Stone questioned the possible movement of asbestos inside the filter sample when sent to the lab for examination. Mr. Weaver indicated that this possibility ves quite remote. Apparently the question arose after an OSHA visit to the camber's plant. In response to a question, one member indicated it takes about tvo months from the OSHA sampling until the OSHA report is received. Further, it vas Indicated that the company hears if it Is to be . cited and not if the conditions are satisfactory. The OSHA regulations -- n for an eight hour time weighted average (TWA) for the measurement of air borne concentration of asbestos fibers. One member indicated that he rune his sample test for a continuous four hours to compute the concentration. With a continuous four hour sampling, there are sometimes reactions from the shop people. Returning to the question on sampling for fiber counting, OSHA recommends a full straight eight hour sample. It was indicated they need 8 filters during this continuous sample. A member suggested using 90 minute sampling for most teas, or a complete job c/cle if it tctk longer then 90 sixortes. He recommended four hours of sampling for specials. A metier questioned as to what nrlniora time was necessary in sampling to determine the peak concentrations that cannot exceed 10 fibers per cc. No specific answer was given, but Hr. Weaver indicated some sampling procedures which he felt were optimum for counting fibers entrapped by the filter. The number of tests fot various conditions is suggested in this tabulation. One condition is where you ere measuring friction materials with asbestos in the compund, and the other is for areas where you are handling all asbestos. Optimized time for fiber collection - depending on TWA fiber per cc concentration expected in area. (Optimum for counting fibers on the filter) Friction Materials TWA Fibers per cc Optimum Number of Tests All Asbestos TWA Fibers per 0- 5 5-10 10-15 15-20 - 1-8 hr. test 2-4 hr. tests 3 tests, 3,3,2 4-2 hr. tests 8-1 hr. tests hrs. 0- 3 3- 6 6- 9 9-13 13-20 The question arose concerning the sample, where one is crying to pick up asbestos for counting. tThat about the otlf^^i^erials in brake lining that are n o ons^dered hazardous? Might these not be counted on the filter as well as asbestos? One answer that is indicated for the skilled laboratory man making the examination is that he should be able to distinguish between asbestos fibers and ocher materials. Further, one can go to 300X on the microscope and get a closer look at the materials picked up on the filter. Dr. Spurgeon indicated that one can use low temperature ashing to remove resins and other organic materials (primarily friction dust). Minute of Meeting Asbestos Study Committee -5- August 17, 1972 EPA AUTOMOTIVE MISSIONS Dr. Spurgeon Indicated that the Bendix Research Laboratories are working under contract for EPA on particulate emissions from brake linings and clutch facings and will not be finished until March 1973. Dr. Spurgeon felt it would not be proper to discuss results and progress to date on this study under contract to the government. THE STATUS OF EPA REGULATIONS Hr. Weaver Indicated that one of the reasons for scheduling this meeting in August was to go over the new EPA regulations. However, this agency has not finalized their regulations as yet and it is not expected to be published until sometime in September. Mr. Weaver indicated that the problem was not with the asbestos sections, but rather with some of the other materials and he expected that their regulations will not be very much different from the earlier temporary regulations on asbestos. Once again, those earlier regulations were more, concerned with control, practices (collectors and .disposal techniques) than with numerical emission values. No further action can be taken In this area until the EPA regulations are published. CONSIDERATION OF SUBSTITUTES FOR ASBESTOS At the Annual Meeting, in June, this Committee was directed to consider a recommendation that the Institute sponsor a research study to determine th*r\ possibilities of substitutes for asbestos. The purpose of this suggestion \ was that if an outside study were to show that certain materials might very \ well be acceptable substitutes for asbestos, the information would be made \ available to the members. If the outside study indicated that there were no \ satisfactory substitutes for asbestos in friction materials, this information \ could be used as a defense should we have a recurrence of action s im ilar to \ Illinois' banning of asbestos based brake linings. The Committee discussed this and as most of them are working on asbestos substitutes and some, in particular, have marketed materials without asbestos (primarily metalli.es), they felt this suggestion would not be warmly received by many members. One member indicated , chat it would be very difficult for them to sanction the Institute making any / such study considering the work they have done in the past Upon motion duly made, seconded, and unanimously passed, le was RESOLVED: That the Asbestos Study Committee does not recommend an Institute study in the area of substitutes for asbestos. WASTE DISPOSAL Someplace between the point where the asbestos product is finished and the waste materials are disposed of, the OSHA requirements will become EPA require ments. In ocher words, we are moving from the condition of standards in the work place to standards in the atmosphere or environment. The area of waste disposal is a major problem. All asbestos bearing wastes, according to the OSHA regulations, oust be collected and disposed of in sealed impermeable bags or other closed impermeable containers. Whether a closed steel truck body le considered "impermeable" is a question. If the OSHA people mean what they say Minutes of Meeting Asbestos Study Committee -6- August 17, 1972 when they suggest thet an employer who la attempting to meet the spirit of the lav will not have difficulty, it will be assumed that removal of the waste material in enclosed steel truck bodies would be an acceptable means of disposal. Moat members Indicated that they had great difficulty with polyethelene bags - they are too soft and they tear when they are stacked. The next area, which is a major problem, la the actual disposal of the dust. Usually, it is unloaded as land fill. One member uses a screw-type conveyor to fill a truck with a fixed container. The material is then dumped into land fill. The .material is vet down after dumping and, after a hole is filled, it is covered up. ' Mr. Stone mentioned a procedure he had seen where they turn the dust into pellets and dispose of the pellets. One member indicated a solution for the disposal of the paper bags that are used to package the asbestos. They unload the asbestos bag inside a hood where they cut the bag. The hood has an empty plastic bag which the aabestos bags are picked up in. The topic of proper disposal of the friction material waste products was discussed. The most desirable method of disposing of friction material waste products is to put it back Into the friction material. Where a manufacturer has a one-formula product line, this is reasonable. However, most of the larger manufacturers would find it very difficult to segregate the various mixes picked up In thuli collection devices and recycle if vack into the friction material without running into product problems. This is obviously the most desirable thing to do with the waste material, but for turning out a quality product It becomes.very difficult. The most common means of disposal are to wet the product down and dispose of it as land fill. In some areas the material is bagged and sent to the dump. The problem of economical means to dispose of the waste from friction materials has been a problem in the industry for many years. It is likely to become a much more perplexing problem considering the regulations by OSEA and EPA. Dr. Spurgeon brought up the question of the possibilities of the Institute sponsoring paid research on waste disposal. It was indicated that within the Constitution and By-Laws of the Institute we could very well sponsor such research but it would be ujp to the Committee to make recommendations in this area. Generally, there are areas other than asbestos that are Involved in this waste disposal problem. Among the items to be considered are: grinding dust, asbestos fibers and bags, phenollcs which are pcked up in vet scrubbers, lead and its compounds, and the solvents that are driven off during processing. The Committee will consider this possibility at a subsequent meeting. A member suggested a possible questionnaire to be sent out to the Membership concerning the problems of waste disposal to see whether the rest of the Membership could contribute some information in this area and to determine the extent of interest in the study of waste disposal by the Institute* The Members of the Committee should consider items to be Included in such a questionnaire for discussion at the next meeting of the Committee. MATERIALS OTHER THAN ASBESTOS Because the problem of waste disposal is not a problem of asbestos only, questions were raised about the possibilities of extending the scope of the Committee's work beyond that of asbestos alone. The Secretary indicated that it would be within the scope of the Committee to extend their activity to materials ocher than asbestos. Lead and lead compounds are among the hazardous materials being regulated by Federal agencies. As many manufacturers use lead and lead compounds Minutes of Meeting Asbestos Study Committee - 7' Augure 17, 1972 in their friction materials, this might be a material to be studied by the. Committee. On the other hand, because of the seriousness of the asbestos regulations, by taking on other materials, the efforts of this Committee might be dilated. Currently, there are regulations on solvents, silica, and other materials considered hazardous or noxious by the regulatory agencies. It is requested that the members consider the possibilities of expanding the activities of this Committee to cover other materials. METHODS FOR EXAMINATION OF FIBERS Dr. Spurgeon questioned whether there vers any other reliable techniques for the measurement of asbestos fibers other than the membrane liter method. The question vas also aimed at whether the regulatory agencies were considering other analytical methods. Mr. Weaver indicated that in conversation with AZA he had recently learned that the Department of Labor is considering a study an the possibilities of the gravimetric method, for sampling asbestos fibers. He indicated that the membrane filter met$& votud be in use for some years to come and possibly up to the July 1976 date when the atffar two fiber per ce requirement goes into effect. The Department of Labor Is considering a 15 man committee to study this possibility for sampling the asbestos. The make-up of such a committee veuli be cs follows: 4 from industry, 4 "experts," 1 from HZ OSH, 1 academic, 2 from labor, 1 medical, 1 from the American Industrial Health Association, and 1 consumer advocate. It is suggested that members of the Asbestos Study Committee consider whether their companies might wish to volunteer for service on such a Federal committee. OTHER BUSINESS Some of the Committee Members are operations oriented and others are environment oriented. It vas requested that those individuals responsible for corporate decisions in the hygiene environment area be listed. That list is as follows: Charles Borcherding Abex Corporation - Chicago, Illinois (Corporate Industrial Hygiene). James Armstrong Bendix Corporation - Southfield, Michigan (Safety Director) Ike Weaver Rayb es tos -Manhattan, Inc. - Manheim, Pa. (Director of Environmental Control) George Wilson Firestone Tire & Rubber Co. - Akron, Ohio * * * A h it h There being no further business brought before the Committee, upon motion duly made, seconded and unanimously passed, it vas RESOLVED: To adjourn Adjourned at 4:00 P.M. Distribution: Committee^Members J. Greenen L. Stickles British Council AIA/NA E. W. Drislane Executive Director