Document pmoQbKe4xB5Oz5MJ6Re5Zrbr7

trttuMuau E. J. du Pont de Nemours S Company HC8MOMTCP Wilmington, Delaware employee relations department CC: H. G. Smyth/C. ue Martino - ERD Occupational t Environmental Health Mgri ERD Division Directors PSERD HEADS The attached letter was sent to Mr. Jefferson with a brochure containing the remarks of Mr. Thomas 0. Mathues, Vice President, Manufacturing Staff, General Motors Corporation. Mr. Mathues* remarks were made at the Asbestos Information Association Conference, September 17-18, 1980, in Washington, DC. The letter and attachment were also sent to Ken Stueber, Plant Manager of the Martinsville Plant, and may have been sent to many additional plant sites. If any of your plant sites have received this request to provide information regarding asbestos, ask that they not respond, but refer the letters to my attention for handling. MEDICAL DIVISION BWKiceb Attachment Karrh, M.D. Director ''1 DUP 0906860 J 00666 SC-DP-07395 Johns-Manville Corporation Ken-Caryl Ranch Post Office Box 5106 Denver Cotoreoo 60217 John A. MtKInney Chairman ol the Board and Chief Executive Officer . tblO --2> Mr. E. G. Jefferson, Chb. Du Pont E. I. De Nemours & Co. 1007 Market St. Wilmington, DE 19898 Dear Mr. Jefferson: General Motors is a large user of asbestos fibre and asbestos-containing products. In addition to millions of sets of brake linings and clutch facings, asbestos is used in gaskets, sound deadeners, adhesives and electrical components in GM vehicles. Also, they use many construction products such as asbestos-cement pipe and sheets, rolled roofing and floor tile for their plants. General Motors has a long-standing commitment to protect the health and well-being of its employees, the general public and the environment. We applaud that commitment, and the conscientious manner with which it is applied. General Itotors' policy toward asbestos was presented in a paper by T. 0. Mathues, Vice President Manufacturing Staff, to the ALA Govern ment Industry Conference. It is attached for your review. We believe it is in the best Interest of society that Industry take responsible positions similar to that of General Motors on issues such as this, where emotionalism has tended to skew rational direction. If your company has taken a position similar to General Motors regarding asbestos, or plans to, we would appreciate hearing from you. A Sutnoi<v e> Uni town*n AUG J (. ^ CliADOlAjN'i u: TICE DUP 0906862 J 00 667 DUP 0906864 J 00 668 The proper and safe use of asbestos is obviously an area of vital interest, and I know from experience that programs of this type can be extremely helpful in all our thinking. , General Motors is a large user of asbestos fiber and asbestos-containing products. We use these materials in many of our products, including passsenger cars and trucks, buses, off-road vehicles, diesel-electric locomotives, and powerplants for stationary applications. They also are incorporated in some plant-maintenance items and other non-production materials. Both applications are used in General Motors operations around the world But. in order to address the specific interests of this group. I would like to confine my comments today to our North American operations. Asbestos is just one of hundreds of toxic materials which are constantly under study at GM. And. before we go further, let me make a distinction between "hazardous" and "toxic" materials. AJ1 chemical materials are. to some extent, inher ently toxic Ordinary tap water, for instance, is toxic --though, obviously, to a very low degree. With improper use. however, toxic materials can become hazardous. If this room were filled with water right now, we would be faced with a rather hazardous situation DUP 0906865 JO0669 General Motors Corporation has. for years, been before the federal government published its committed to protecting our employees by recog asbestos rules. nizing, evaluating, and controlling exposure to toxic materials. To a large extent, these programs are only now being required by various regulations. Jt is our continuing practice to evaluate all materials prior to their use. The evaluation considers impact on the environment, health, product performance, and cost, including the cost of government control. Thus, if a material we ' ` ' One phase of our evaluation of asbestos considered availability and cost of control. We do not foresee an imminent supply problem with grades currently in use at General Motors. But the legislative and regulatory dimale is uncertain, and the cost of the continuing use of asbestos may be dependent upon the existence of stringent compliance requirements. might be considering requires environmental For example, if the exposure limit is reduced to assessment, or the administration of medical that which NIOSH has proposed, our compliance examinations to employees, those costs are costs will certainly increase. However, if the also included. limit is not as stringent as presently proposed by NIOSH. we feel that with some added processing We are p-epared to change present practices, and tooling expense we could meet the standard when there is need to do so For example, when in most of our operations. rt became accepted by the medical community that excessive airborne exposure to asbestos fiber was Based on current information, however, we do not more hazardous than previously thought, we see an urgent need to curtail all asbestos usage. re-evaluared our use of the mineral Workplace But we do believe alternate materials must be and ambient air quality were monitored. Employees examined, should the need arise, for economic or were given medical examinations designed to health reasons, to replace asbestos-containing determine the presence of typical abnormalities materials. Thus, we agree that non-essential caused by asbestos. New processes are continually uses of asbestos should be controlled whenever being investigated and substitute materials are adequate substitutes are readily available... being sought. providing those substitutes are economical];, feasible, and providing they will not result ir. The use of asbestos fiber and asbestos-containing anv new health risks products was reviewed by local GM plant hazard * ' ous materials control committees. The committees . At Genera! Motors, our largest use of asbestos are composed of people knowledgeable about is in friction materials such as the 5-6 million production processes, chemistry, and health and * sets of brake linings and about 44 million clutch environmental effects. They evaluate all present or facings we produce each year. Other uses include potential materials and recommend safe methods various gaskets, sound deadeners for metal fillers for storage, handling, use and disposal. in mastics and adhesives, and some electrical component parts. We also use construction materi As a result of all this review and testing--which als containing asbestos--cement, asbestos pipe, is continuing today --we revamped our asbestos- roofing felt, and floor tile, for example.1 related operations at many GM plants. The changes required a significant investment... but resulted in improvements in the environment and in the protection and preservation of employee health and safety. Sinrr this paper was written in September J980. Cent'a] Motors has madt a limited number of additional product changes which substitute non-asbestos ingredients fee Let me emphasize that we did this in response to new medical findings. Much of our work occurred asbestos whtre functional tests have indicated the octquan. of non-asbestos containing compounds DUP 0906866 We believe there is a basic distinction between processes using raw asbestos fibers and those using asbestos-containing materials. Whenever loose fiber is used, we exercise greai caution to minimize the potential release of fibers to the workplace or the ambient environment. The same care is used whenever asbestos materials are handled in such a way that loose fibers could be generated --for example, in cutting asbestos paper or grinding a brake lining. For many asbestos-containing materials, such as adhesives, brake linings, mastics, and floor tiles, the asbestos is bound in a matrix. This matrix is either flexible --as in tar-based sound deadeners --or highly durable, as in cemeni asbestos products. In these kinds of materials, asbestos fiber generally >s not released during our manufacturing processes unless the material is misused In our view, this is an important distinction In considering risk analyses, or in considering regulations and standards, we think it is important to differentiate between applications involving loose fibers and those irv.olving non-friable materials or encapsulated fibers. Such differentia tion is not the case today --and it should be m our opinion The techniques and devices used by Genera Motors are designed to control the release o: asbestos fiber Recently, fhere has been considerable discussion about the use of substitute materials for automo tive friction products. While asbestos substitutes are being used in some light duty brake systems, we have not found effective substitutes for many other applications. Various substitutes for asbestos in clutch plates have been investigated, but no suitable alternatives have been found. Certain products, therefore, will probably continue to contain or use asbestos. So we should avoid any ban on use and distribution of either original equipment or replacement parts for which there are no substitutes.- ln most cases, for example, non-asbestos brake linings, if installed as replace ment parts, will not provide suitable performance in older brake systems designed for asbestos linings. In such cases, the configuration of the entire braking system has to be changed. Changes of this magnitude would require extensive and cosily modifications and testing. Since we cannc: recommend substitution of non-asbesios linings :n brake systems designed for asbestos, an adequate supply of replacement asbestos linings should continue to be available. This same situation wiL' hold for friction materials used as clutch facings in both manual and automatic transmissions. General Motors does not use body fillers containing asbestos. However, sound deadeners today contain asbestos as an inert filler. The matrix doesn't dn to the point of becoming brittle, nor is it sar.ded or ground during vehicle production. Thus, asbestos fibers used in sound deadeners and other types of undercoatings really do not constitute, ii our opinion, a ready source of airbone asbestos fiber. However, we are encouraging development of substitutes for most asbestos-containing mastics. . sound deadeners. and the like. For example. mineral wools, and glass fibers max' be effectively substituted in some applications. Perhaps some products can be reformulated to eliminate the need for fiber fillers. But we recognize that the substi tute fillers may be more cosily. DUP 0906867 L DUP 0906868