Document q04EjX0XqgkONdGoZdpJQRXj

DRAFT CARCINOGENS IN THE WORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established (faring the 4th quarter, 1979 by joint action of the E&R and MicS Subcommittees. The Tac Force Charter was to coordinate plans and efforts among Company activities, to identify carcinogens in use, and eliminate or control them in future products and manufacturing operations. Task Force findings and recommendations are summarized in the following pages. Detailed determinations and other relevant data are presented in the ExzobiSand Appendices. ** Background . Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that ocmnational related cancer is a serious concern. It has been estimated that in coming deeads i^> to 20% and perhaps as much as 40% of cancer in the U.S. might be associated witt. occupational factors. Accordingly, Personnel and Organization Staff, Employe Health Services, has exerted a continuing effort to provide employe protection, as knowledge of torie/hazardous materials hBsbeen introduced. - Public concerns relating to the control of toxic/hazardous ctateriils; are shared by Ford, due to the Company's regard for public health and the protesmon of toe environment and potential impact of legislation on our products and manufacorrng operations. Also, the right to examine the Hazardous Materials Catalog from, the Connany's computer file of hazardous materials, and on-line access to the Materials and Tasieulogy System (MATS) has been Attended to (the UAW by contract. Resolution of workplace exposure concerns relating to the msnagsneat of toxic/hazardous substances, materials,, and wastes, involves a consideration of toe relationship between the internal and external environments. Emphasis on wastewater pretratment standards, toxic pollutant effluent standards, nonregulated/hazardous air poEmtarr emissions control and solid/hazardous waste management has been increased by gui'q.n'uentnl authority. These factors reinforce the desirability of reducing the amount of residuals generated by Company manufacturing processes and operations, through more efficient manufacturing techniques as well as by materials substitution. During the past decade, the Company was subjected to a gi-uwiug camber of laws which regulate material use, transport, handling, and disposai (Fig. 1). Under certain of these Acts, & "knowing/willful" criminal violation can expose indmdzals, axciading officers of the Company, to five years imprisonment. Civil and criminal penalties include maximum fines up to $25.000 per day, and a citation normally consists of multiple related violations. Litigation is also a growing concern. At present the Office of Prera! Counsel has three suits pending, involving deaths allegedly due to the inhalation: of carcinogenic substances. Some Workman's Compensation expense has also been incurred. The greatest potential for major expense, however, lies in the possibility of punitive action by toe court. Internal and external pressures regarding hazardous substance eoiu.ul and compliance have increased substantially since March, 1977, when Directive 3-UZ ms issued to assign responsibilities within the Company (Fig. 2). Since that tizne tew standards have been issued, additional standards ore anticipated, and the level of eesoomc risk has increased. a Federal Register 45(15): 5031, January 22, 1330. -i Mav 2. 1930 006387 o 105550 PRODUCED BY FORD DR ATT FIGURE 3 PAST COMPANY ACTIONS Production - . Removal of lead and chromium from paints. * . Removal of "Tris" flame retardant . Controls instituted far asbestos m new designs. ' Nonproduction . Removal of asbestos from, t, - - Structural fireproofing - Thermal insulation * - Molding compounds . Substitution of vacuum for air blowing in brake and clutch maintenance . Personnel protection against benzene in light oil tanker loading operations . Substitution of lead-containing maintenance oils . Substitution of benzene-containing adhesives at San Jose . Reduction of lead-chromates in vinyl operations 006388 "V -2f May 2, 1980 PRODUCED BY FORD 0AAf PAST COMPANY ACTIONS Production Materials . In response to OSHA regulations in 1978, the Company removed lead chromates apd lead molybdates from paint used for topcoats on exterior and interior surfaces, effective with Job #1, 1980. School bus yellow and fleet vehicles were excepted. Also, "Tris" flame retardant treatment far fabrics, was removed during 1977, in response to an inquiry by NHTSA. In response to initial OSHA regulations in 1972, the Company determined plant areas m which employe exposure to asbestos exceeded regulated limits. All domestic line operations were apprised of the OSHA standards and the requirements for employe protection and medical examination. Car Engineering released a practice banning new designs containing asbestos unless documented rationale for its use is provided and it is encapsulated. Nonproduction Materials l ^ In 1969, sprayed-on structural steel fireproofing containing asbestos fibers was eliminated in all new and reworked construction. In 1970, Corporate mechanical construction standards were revised to prohibit asbestos in thermal insulation. Maintenance Bulletin No. 137 was published, prohibiting the use of air blow-off in all brake/clutch maintenance and substituted vacuum fiber/dust pick-up. In 1974, Steel Division light oil by-product tanker loading operations were reviewed and personnel exposures were pinpointed and appropriate protective equipment supplied. In 1977, the Company replaced M-2C60 Series of maintenance lubricants with the lead naphthenate free M-2C142 materials, and deleted the use of asbestos bearing molding compound at Sheldon Road. In 1978, an adhesive used at San Jose was reformulated to eliminate benzene exposure. During 1979, analytic chemistry procedures at Central Laboratories was revised to eliminate benzene, the volume of lead-chromate employed in vinyl plant 'operations was reduced and ventuation/protective measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used in painting. (The substitution of non-hazardaus paints is targeted for Romeo for late 1980.) - 006389 -2 May 2, 1980 PRODUCED BY FORD