Document pBkY9NBEOXqo46XLBeg4J7gJa

PLAINTIFF'S EXHIBIT TO: FROM: RE: DATE: memorandum File BLC Friction Materials Standards Institute 10/1/84 Pursuant to ongoing asbestos litigation, 1 spoke with Ed Drislane, Executive Director of the Friction Materials Standards Institute (FMSI) on September 26, 1984. We discussed the two areas of concern: ongoing research concerning brake lining dust; and warnings on brake lining products. 1. Research: Mr. Drislane is aware of no ongoing research concerning brake lining dust, its decomposition and health effects. His only knowledge concerning research in this area is what is available through published medical and technical literature. He recommends that we contact the Asbestos Information Association for more information in this area. 2. Warnings: The basic model for the warning label on ' asbestos containing friction products came from the 1972 OSHA standard. Brake Lining Manufacturers, as a group, did not begin labelling their products until 1974-75, because of disagreement within the industry whether the OSHA Standard applied to encap sulated friction products. The FMSI have published a one-page notice in their catalogs since 1977 entitled "Recommended Procedures for Reducing Asbestos Dust During Brake Servicing" {copy attached). In late 1978, the FMSI published 45,000 copies of the booklet "Friction Material Work Practices Guide" (copy attached) which was dis tributed to its members (brake lining manufacturers). "The purpose of this booket is to provide practical guidelines for brake and clutch service mechanics in the handling and pro cessing of asbestos containing friction materials and in the maintenance and repair of brake and clutch assemblies... cont'd 3009 0407 PRODUCED BY FORD SCF-ALLF-09330 Adherence to the recommended work practices will reduce employee exposure to airborne concentrations of asbestos dust and will assist employers in complying with govern ment regulations." Mr. Drislane cannot state to whom the FMS1 members distributed these booklets or how many found their way to independent garages and shops. -2- dOOd 04Dj PRODUCED BY FORD ion 848-0440 FRICTION MATERIALS STANDARDS INSTITUTE, INC. u BERGEN MALL OFFICE CENTER S E, 210 ROUTE 4 * PARAMUS. N J. 07032 i September 26, 1984 Ms. Barbara Ciaramitaro, Legal Asst. Dickinson, Wright, Moon et al SCO First National Building Detroit, Ml 48226 Dear Ms. Ciaramitaro: Enclosed are 1 copy of the one page notice "Recommended Procedures for Reducing Asbestos Dust During Brake Servicing" which first appeared in our catalogs in 1977, and the booklet "Friction Mater ials Work Practices Guide" which was published in late 1978. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE ' - .. E. W. Drislane Executive Director EWD/e 5003 0409 ' PRODUCED BY FORD RECOMMENDED PROCEDURES FOR REDUCING ASBESTOS DUST DURING BRAKE SERVICING Because studies have indicated that exposure to excessive amounts of asbestos dust may be a potential health hazard, OSHA has set maximum limits of levels of airborne asbestos dust to which workers may be exposed. Since most automotive friction materials normally contain a sizable amount of asbestos, it is important that people who handle brake linings and clutch facings understand the nature of the problem and know the precautions to be taken. V Areas where brake work is done should be set aside if possible, and entrances should be posted with an asbestos exposure sign as follows: Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Area Unless Your Work Requires It Breathing Asbestos Dust May Be Hazardous To Your Health 2. The amount of asbestos in the dust from brake lining wear is normally at an extremely low level because of chemical breakdown during use, and if machining of friction material does not take place, simple procedures will minimize exposure. Dur ing brake servicing, the mechanic should wear a respirator approved by NIOSH for asbestos dust. It should be worn during all procedures starting with the removal of wheels and including reas sembly. 3. When removing worn friction materials, remove the accumulated dust in the assemblies with an industrial vacuum cleaner equipped with a high efficiency filter system. If such equipment is not available, dust can be removed with a damp cloth. Do not use compressed air or dry brushing for cleaning unless the assembly is enclosed and properly exhausted. 4. Whenever possible, purchase friction materials preground and ready for installation. If machining is necessary, the precautions which must be taken are of extreme importance. This is the operation in brake service when exposure to asbestos dust may be at its highest. This increases the difficulty in complying with the OSHA standards. In addition to the approved respirator, there must be local exhaust ventilation such that worker expo sures are maintained below the OSHA asbestos standards. If there is any question as to the efficiency of asbestos dust removal by the machine, the manufacturer should be contacted. 5. Industrial vacuum cleaner bags containing as bestos dust and cloths used for wiping brake assemblies should be sealed in plastic bags and labeled with the following warning label printed in letters of sufficient size and contrast to be readily visible and legible. Caution Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm ' All asbestos waste should be disposed of in accordance with OSHA and EPA asbestos regula tions. During removal of vacuum bags, an approved respirator, as described in (2) above should be worn. 6. Good housekeeping is essential in a workplace where asbestos containing materials are handled. Industrial vacuum cleaners equipped with multi ple stage high efficiency filters should be used for removing accumulations of asbestos dust and waste. Never use compressed air or dry sweeping for cleaning. Water or other dust suppressants should be applied if brooms are used. 7. Good personal hygiene practices are important in minimizing asbestos dust exposure. Do not smoke. Wash before eating. Shower after work. Change to work clothes upon arrival at work and change from work clothes at conclusion of work. Work clothing should not be taken home. Laun dering of asbestos contaminated clothing shall be done so as to prevent release of airborne asbestos fibers in excess of the exposure limits. CAUTION: DO NOT BREATHE ASBESTOS DUST 8008 0410 ' PRODUCED BY FORD PRODUCED B Y FORD SOURCES OF ADDITIONAL INFORMATION "Standard for Ctpoture to Asbecto* Dnf (Code of Federal Regulations. Title ?9. 1910 IOOD-OSHA "National emission* Standard* for Hazardous Afr Pollutants--Atbvtfo* and Mercury" (Code ot Federal Regulations Title40.Chapter I. Subchapter C. Pari 61, Subparts A. 8)--CPA "PundamontaH Governing tht Design and Operation el Local CiHautt System*." ANSI 19 2 1971 (1700) and"Practice* lor ftetpiratery Protection." ANSI Z88.2 I969t*550)-AN$I "Industrie! VmMaUcm ManuaT (18 00)- ACGIH F or other information. a user may contact Ihe manufacturer supplying his friction materials, the Asbestos Information Associate or the friction Materials Stand ards institute. ACGTH CPA American Conference of Governmental environmental Protection Agency Industrial Hygienists Public Information Center Committee on Industrial Ventilation 401 M Street SW 1*0 Bov 16153 Washington. DC 20460 00 Causing. Ml 46901 O o 00 ANSI American National Standards Institute 14 30 Broadway FMSI Frrctinn Materials Standards Institute o New York NY 10018 r* Cast ? 10 Route 4 Paramos. NJ 07652 AtA Asbestos Information Association 174b Jefferson Oavis Highway Artmgfou. VA 22202 OSHA Occupationat Safety and Health Administration Office of Information Washington. DC 20210 Octubei 1978 October 1978 FRICTION MATERIALS WORK PRACTICES GUIDE PRODUCED B Y FORD on O O (JO .O r* N (0 USE DUST COLLECTION EQUIPMENT WHEN MACHINING INTRODUCTION The purpose of this booklet is to provide practical guidelines lor brake and clutch service mechanics in the handling and process ing ol asbestos containing friction materials and in the maintenance and repair of brake and clutch assemblies on which the materials are installed. Adherence to the recommended work practices will reduce employee exposure to airborne concentrations of asbestos dust and will assist employers in complying with government regulations. This area is regulated by federal, state and local authorities. We caution that you may not rely on strict adherence to the work practices recommended herein as assuring compliance with these regulations, because (a) they are subject toamendment; (b) there are on-going administrative interpretations of these regulations; and (c) particular field conditions may vary. You should direct all questions relating tocompliancewith regulations to the appropriate regulatory agencies. ASBESTOS AND FRICTION MATERIALS Most molded friction materials contain about 50% asbestos some woven materials over 90%. In molded materials, resin binders prevent the release of asbestos fibers during normal handling. Woven friction materials, normally used only in con struction and industrial applications,must be handled with care to avoid Creating dust as the asbestos fibers are less firmly bound into the product. Potentially hazardous airborne concentrations of asbestos dust Can be created by improper cleaning and handling of worn brake and clutch assemblies, uncontrolled machining operations and poor housekeeping. . Breathing excessive quantities of asbestos liber can cause respiratory disease and cancer. Smoking greatly increases the risk ol lung cancer among asbestos workers. Prevention ol asbestos dust exposure is the only known method ol eliminating asbestosrelated disease among those working with asbestos containing products. Proper woik practices oiler the best assurance ol providing exposure safeguards lor workers removing, installing and machin ing asbestos containing Irirtmn matproifx PRODUCED B Y FORD DO NOT USE AN AIR HOSE FOR CLEANING WHY? SUMMARY OF OSHA ASBESTOS STANDARD EFFECTIVE JULY 1,1976 Under the current standard, it is the employer's responsibility to assure that exposure ot employees does not exceed the following permissible exposure levels. a. Eight-hour time-weighted average: Two fibers, longer than live micrometers, per cubic centimeter. b. Ceiling (Peak) concentrations: Ten fibers, longer than live micrometers, per cubic centimeter. Engineering controls such as isolation, enclosure, exhaustventila tion and dust collection are thepreferred methods lor meeting Ihe prescribed exposure limits. All external surfaces must be main tained free of asbestos fiber accumulation. Respiratory protection is required whenever airborne fiber con centrations exceed either the permissible time weighted average level or the permissible ceiling concentration. Protective clothing is required whenever airborne fiber concentrations exceed the permissible ceiling level. Caution signs, change rooms and employee notification are required where asbestos fiber concen trations exceed permissible exposure limits. The standard re quires Itiat all workplaces where asbestos fibers may be released shall be monitored to determine exposure levels, and regular monitoring is required where exposure levels are expected to exceed permissible limits. Employers must maintain records of monitoring required by the standard. They must also provide or make available medical examinations for employees exposed to airborne concentrations of asbestos fibers. 5 PRODUCED B Y FORD $ USE VACUUM OR WET METHODS FOR CLEANING ' oo o o 00 .o 6 HANDLENG NEW FRICTION MATERIALS Handling new disc brake assemblies, lined brake shoes, clutch facings and brake blocks purchased in individual boxed sets is unlikely to create significant airborne concentrations of asbestos dust. If the parts are purchased in bulk quantities, abrasionduring shipment may result in the accumulation of dust in shipping containers. Dust should be removed by vacuuming or cleaning with a damp cloth. Whenever possible, purchase friction materials preground and ready lor installation. This may keep dust levels below OSHA maximums and eliminate the need for respiratory protection, restricted areas, regular monitoring, special clothing, change rooms and employee notification. REMOVING WORN FRICTION MATERIALS Asbestos fibers in disc brake linings, drum brake linings, blocks and dry clutch facings are locked into the product with resin binders which prevent the release of asbestos fiber during normal installation. Heat and abrasion during normal use may generate dust containing asbestos. Some dust will accumulate in brake and clutch assemblies. When removing worn friction materials, remove the accumulated dust m the assemblies with an industrial vacuum cleaner equipped with a high efficiency litter system. If such equipment is not available, dust can be removed with a damp cloth. Do not use compressed air or dry brushing for cleaning. Use a NIOSH approved respirator when removing worn friction materials, or cleaning brake or clutch assemblies. MACHINING FRICTION MATERIALS There is an increasing trend for manufacturers and rebuilders to provide brake lining and clutch facings pre-drilled and pre-ground in final assembly form. In the case ol truck brake blocks, various oversize thicknesses are available. However, there are some instances where field machining is necessary. This is particularly true lor construction and industrial equipment applicationswhich may require machining of blocks, slab stock or roll lining. Oust generation can be minimized or eliminated during arcing ol brake blocks by lathe turning at low speed rather than grinding. Whenever possible Iriction materials should becut to length with a Shear rather than a saw or abrasive cut-oil wheel. 1 % dust collection methods When asbestos-containing friction materials are machined, i e.. drilled, ground, grooved, cut or beveled, the dust created contains asbestos libers which may become airborne unless adequatedust controls are employed. The preferred method for minimwing airborne dust from machining operations is local exhaust ventila tion A local exhaust ventilation system consists of dust collection floods or enclosures connected by duct work or piping to a dust collection filter and a suction source. DO NOT The two operations that offer the greatest potential for generation ol excessive amounts of airborne asbestos fiber are arc grinding SWEEP IN and beveling ol lined brake shoes and linings or brake blocks. Grinding machines used (or these operations must be provided with exhaust ventilation to maintain worker exposures within iK'iiiussibte levels. WORK AREA - USE II a central exhaust system is not available. NIOSH (National Institute lor Occupational Safety and Health) has stated that, at a minimum, the dust bag of the arcing machine shall be removed VACUUM METHOD anil replaced with the hose from a high efficiency industrial vacuum. Tor large volume machining operations that operate on a con tinuous basis, tlte preferred dust collection device is a fabric filter oi baghouse. with a heavy-duty exhaust fan as Ihe suction source. The dust collector must meet the air-cleaning requirements of the Federal Environmental Protection Agency Emission Standard for Asbestos. Approval must beobtained from EPA for installation and 00 o operation of each system. o 00 O OTHER METHODS OF MINIMIZING DUST mJk EXPOSURE in Whenever possible machining and repair operations should be isolated from other work areas in a restricted area to prevent unnecessary exposure of other workers. Entrances to restricted areas shall be posted with asbestos exposure warning signs as follows: - Asbestos Oust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain In Area Unless Your Work Requires It Breathing Asbestos Dust May Be Hazardous To Your Health 89 PRODUCED BY FORD WEAR AN APPROVED RESPIRATOR IF UNABLE TO AVOID DUST 10 Good' housekeeping is essential in a workplace where asbestos containing materials are handled. Industrial vacuum cleaners equipped with multiple stage high efficiency filters should be used lor removing accumulations of asbestos dust and waste. Never use compressed air or dry sweeping for cleaning. Water or oilier dust suppressants should be applied if brooms are used. Good personal hygiene practices are important in minimizing asbestos dust exposure. Do not smoke. Wash before eating. Stiower alter work. Change to work clothes upon arrival at work and change Irom work clothes at conclusion ol work. Work clothing should not be taken home. Laundering of asbestos contaminated - clothing shall be done so as to prevent the release of airborne astreslos fibers in excess of the exposure limits. DISPOSAL OF FRICTION MATERIAL DUST AND WASTE Dispose ol vacuum cleaner waste and asbestos containing cleaning materials in plastic bags or other sealed containers, with the following warning label printed on the container: Caution Contains Asbestos Fibers Avoid Creating Dust Breathing Asbestos Dust May Cause Serious Bodily Harm Use a NIOSH approved respirator when servicing vacuum cleaners, dust collectors, or handling any asbestos-containing waste materials. Asbestos containing waste materials must be collected, processil. iiiii k.iged, transported and deposited in such fashion lhal no visible emissions ate generated lo the atmosphere All wastes must be disposed ol at sites operated in accordance with applicable laws and regulations. II