Document qmvnNaaJvvjbnxgJV03xeE0EK

Intar Ottica ' FordParta and Sarvlea Division M&rohrli, l?8l Ms. V. Jones Subject: Product Litigation Information Request Enclosed is our response to your request for information regarding asbestos vacuums and brake washers. Answers to your individual questions are under the appropriate tabs. If there is any further information I can provide, do not hesitate to eontaot me. attachments B. C. Merrill 8008 1370 SCF-FORD-3063 PRODUCED BY FORD PRODUCED BY FORD 1. Asbestos use, regulation and proposed policy 2. Memo to file-asbestos 3. Automotive related exposure studies 4. Asbestos Information Association-News and Notes 5. VMD&P involvement with asbestos *002 *372 PRODUCED BY FORD ASSESSMENT OF ASBESTOS USE AND IMPENDING REGULATIONS Vehicle Materials Development and Planning August, 1979 8002 1373 PRODUCED BY FORD ASBESTOS-IMPACT Purpose . ' 'o review and update the engineering asbestos plan. Background The 1975 OSHA proposed standard remains dormeint. If promulgated it will lower the permissible occupational exposure limit for asbestos from the current 2 fibers per cubic centimeter to 0.5 fiber/cc. Formal hearings that normally precede issuance of a final standard have been delayed for several reasons* . A standard for the construction industry has not been prepared. . An economio impact study has not been released, although it has been in draft form for six months. . Continued attack on the proposed standard by asbestos and mining interests sb being too restrictive. Contrary to this apparent inactivity, NIOSH has recommended documentation of the "life cycle" of asbestos from mining to disposal and elimination of all non-essential uses. A working group in EPA's Office of Toxic Substance is currently performing a "life cycle" analysis of asbestos. First priorities for regulation are paper products (gaskets) and friction materials (brakes). Assessment ' study of the current regulatory situation indicates a high probability that tighter environmental restrictions on asbestos will be promulgated within the next two years. The fact no firm evidence exists that the current standard is inadequate only means there will be no emergency standard of a disruptive nature. Evaluation of the current standard could take 30 or 40 years and still not surface concrete evidence supporting either the government or industry position. The burden is clearly on industry to "prove" the current standard is adequate. Since this is not possible and the government agencies were created to regulate the use of materials, we must proceed on the assumption there will be further regulation of asbestos. The previous scenario for a staged tightening remains a possibility. This would mean a reduction of the current standard to 1 fiber/cc by mid-1980 and 0.5 fiber/cc by early 1983* However, this timing is unlikely because most industry currently meets 1 fiber/cc and the proposed standard has been "on-the-books" for nearly four years with no action. If, as expected, during the next two years the proposed OSHA standard is promulgated, and/01 regulation by EPA of asbestos emissions from brake wear occurs, then the following results can be expected! A. A drastic reduction in the use of asbestos containing friction materials over the next 3 to 5 yews. Comments: Court challenges will delay implementation of standards for at least 1 year. Transmission and Axle programs will be accelerated for non-asbestos sub stitution. (Attachment I) . Costly "crash programs" for brake drum substitutions. * . Attachment II shows the company usage of asbestos containing friction materials. * General list being compiled, by VMD&R- additional innut. reouired >r\ PRODUCED BY FORD 2. E. The use of asbestos containing gasket, insulating and sealer materials will remain cost-effective for most applications* Comments: . Raw asbestos comes from Canada. . Process areas meet 0.5 fiber/cc by encapsulation. . No emission problem because of encapsulation (with the possible exception of disposal). *. Attachment III shows the company usage of asbestos containing gasket, insulating and sealer materials. It is less likely that we will see a standard of 0.1 fiber/cc. Streets in major cities have been measured at levels higher than 0.1 fiber/cc and citing this level as dangerous could result in "public panic". Competition Several years ago, GM reportedly considered a policy to get asbestos out of the brake linings because of the toxic concerns. They decided that the effort to find a substitute for asbestos would be better spent to improve the performance and durability of the lining material and opted for a development program with semi-mets by '8l-'82 and all linings (disc and drum) by *o5. The asbestOB issue has helped keep the semi-met programs going over the years. There is no "official" GM company policy to remove asbestos from other component areas. However, because of toxic concerns and company awareness of asbestos, gaskets and heat insulators are slowly being replaced with asbestos free materials. Asbestos insulation reportedly has been removed from manufacturing plants and the facilities that manufacture brake linings meet the present standard of 2 fiber/cc. It appears obvious, regardless of company policy, that GM intends to eliminate the use of asbestos. Their approach of "no formal policy" is a result f uncertainties associated with cost and timing for substitutions, and a general awareness that issues must be dealt with before they become problems. Chrysler also has no formal program for asbestos removal. However, in the case of sealers and gaskets, they attempt to use non-asbestos materials wherever possible and in most cases, are now introducing the substitute materials. In the area of brakes, front wheel discs are being converted to semi-mets aB new programs permit, but no plan exists for rear brake drum substitution. Summary It is unlikely that crash programs on some friction materials can be avoided when tighter standards are promulgated for the following reasons: . Reportedly there are no asbestos free substitute materials for drum brake linings available for evaluation at this time. . Despite the lead body solder fiasco, the engineering attitude (with the exception of Transmission and Axle) remains "wait until the standard is promulgated". (Questions have been raised by various PEO's regarding a policy or position for the use of asbestos. In the absence of other direction, VMD&P makes recommendations later in this paper for a specific asbestos policy.) . The automotive industry has not shown sufficient interest in non-asbestos materials to warrant accelerated R&D efforts by suppliers. General list being compiled by VMD&P - additional input required from PEO's for completion ! [THE ABOVE COMPETITIVE INFORMATION Tfi RA.^Rfl OH ARNESm.V I IAVATT-ARTJg TWDUqTPY DATA. VRT.74RW*- f'St npuriw-"w ,1 a e r r : 7 non PRODUCED BY FORD 3 Summary (continued) "sbeatoB containing gasket, insulating and sealer materials will remain cost-effective this *ime around* However, the ultimate goal of NIOSH is to ban the use of asbestos, which means regulatory pressures will continue for many years to come. If we do not begin a serious effort to develop non-asbestos substitutes, additional "crash programs" can be expected. Recommendations The above assessments raise questions about company response to impending government regula tions for environmental exposure to asbestos. In order to minimise the economio and timing impacts of these regulations, the Company must inorease response in the following areas: 1. Initiate Advanced Engineering projects in the PEO's to develop alternate materials for friction, gasket, insulating and sealer components that contain asbestos. The October 7 1978 Transmission and Axle Engineering Non asbestos Material Program (Attachment I) is an excellent example. The suppliers must be made aware that we are seriously interested in alternate materials so that they will expend the necessary R&D efforts. Additional manpower will be necessary to assist the already over burdened PEO's. Responsibility: PEO's (Advanced Engineering) 2. It will be necessary to increase the capability of the Friction Materials Study Group within Research Staff to provide parallel support for engineering projects. Responsibility: E&RS ' 3. A firm company policy must be adopted for asbestos usage. Attached is a Car Engineering Practice Letter signed by the Vice President, Car Engineering (Attachment IV). - Responsibility: VMD&P 4. Because of the lack of a formal meohanism to follow progress in this area, periodic reports must be made to management via the Engineering and Re search Subcommittee. Responsibility: PEO's (Advanced Engineering) Vehicle Materials Development and Planning August, 1979 8002 1376 PRODUCED BY FORD tra?sm:ssic:: a::d axl r.:zT.:iz?.r.'j KCM-A555ST0S MATT?. .1 .-.-.aorjiM To develop non-asbestos saterial components to rerlece those iters currently released which contain asbestos. Manufacturing controls necessitated by anticipated 03HA standards to control carcinogenic materials will virtually eliminate asbestos usage in the autoaotive industry. For autcaatic transmissions, the initial development effort to evaluate non-asbestos frictica materials is being conducted with the C6 transmission; initial production inecrporaticr. is scheduled for fob 1, 1950. As final material selections are nade for individual fric tion elements, the other automatic transmission groups will determine their requirements based on the Co experience. The asbestos reinforced phenolic reactors will commence phasing out in lc0 and be ccapletely phased out by Job 1, 1931. Tue to limited prod W A yj * rm rir.ual zrzr.szissizz. * g --o chase the &*" cianate i sucs-icr '.rcc sed cu^ T.Z ZTJZZ." R002 1177 PRODUCED BY FORD ' 8002 t378 PRODUCED BY FORD