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3* Inter Olhce To: * J. P. Bernard L. T. Dixon R. L. Ervin . E. P. Francis cc D. D. Baker ( D. L. Block . B. P. Cromwell J. H. Douma A. V. Duff ~ P. D. Fadow K. U. Gillis J. B. Huebner G. T. Luzosski E. J. Marks H. P. Frears S. M. Prey D. F. Hagan _ M. H. Hamburg ' A. B. M. Houston Z. T. Mablsy C<f Eftfinaerlfig Juno 16, 1900 c. A. KcKenney E. R. Price G. A. Schley L. L. Smith U. H. Tribu H. A. Nickel H. A. Potoczak J. G. Rivard V. H. Sue emon E. B. Teraoat J. D. Volte Subject: Toxic and Hazardous Substances - Product Engineering Substitution Actions Recommendations from a task fares on Carcinogens in the 1/erkplace presented May 27, i960 to the Engineering and Research and the Manufacturing and Supply Subcommittees have oeaa accepted. A copy of the Executive Summary and recommendations (Attachment 1) shows the assignments to the Product Engineering Offices as: - Eliminate Group A (known substitutes without major reassign) asbestos, hexavalent chromium consonants and benzene for Job #1, 1985( where possible. - Assist in defining redesign/development required to eliminate Group 5 (known substitutes with major redesigns). - Recommend advanced programs that will define the Job of eliminating Group C 'substitutes unknown). -- Vehicle Materials Development and Planning proposes to coordinate these assignments "and take ovqyall responsibility for assuring they are done with the least additional workload os each PEO. Ve hope to do this by staying in touch and assisting at the working engineer level. Bab Husan, lW*13k, will be the VMD&P engineer in charge. Please contact him or me with your thoughts on any aspect ef what we are planning (Attachment 2). ' RAH:vc attachments Jr 9 G. 7. Bolling f 003204 PRODUCED BY FORD SCF-FORD-2031 t lL EXECUTIVE SUMMARY CARCINOGENS IN THE WORKPLACE irtlCHHEHT 1 Introduction Al the Oeieeer 1979 joint mooting of me Engineering and Rasanrcn and tha Manufacturing and Supply Subcommittees, a reoort on me Occupational Satetv and IteiUh Administration (OSI)A) Policy Cor RejulMmg Workplace Carcinogens *u* presented bv Ptrxonnel and Organization Sluff Tina raport noted thui imal regulations Cor carcinogens in tha worKpIsee were amicipulad oy (he and at 1979 U >o agreed Iliac eCCerts to eliminate me use of potential carcinogen!, whore possible, should be preceded bv analvita at me affected materials and procusas. In Utu> regard, a Tail. Force *u established bv me Subcommittees la identify potential carcinogens end quantities ut use. set targets Cor elnmnetion of such substances it possible ahead of rvgum'jqn. ipke steps to Find substitutes, develoo a directive and wbrkplen and organize to identify und control potentially eurcinogunic substances. Since October, OSIIA has released its Poliev which establishes criteria and procedures for tho identification, classification, end regulation of potential carcinogens in the workplace. The Policy defines Category I potential carcinogens oj substances known to Be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category II substances are those where data are suggestive of carcinogenicity in humens end test animals. The Policy also outlines criteria for classifying a substance into Categories I or n and establishes the mechanism for issuance of standards governing use of a particular substance. No specific Substances ware categorized or standards promulgated with the issuance af the Poliev. Normally, once the need lor e standard is dalorminad by OSH A, it could take one to two years before the standard is issued. If an "Emergency Standard" is set. me ruling is istuad and immediate compliance is required. A number of court challenges of me new Policy ure exoacted to center primarily on stringent rules whien virtually oraclude use of negative evidence studies when defining the carcinogenicity of e substance and on lack of a cast/bcnefit criteria in me Policy Tho draft bsl of candidate substances issued by OSIIA two yoars ago is. ta be revised by July. 1990 followed by a prioritized extract in September The Task Force has concentrated on dcvolooing me capability tor managing me elimination or eonlrol of Category I potential carcinogens in the workplace A start has been made in Identifying specific _ soplications fpr subsequent elimination or control of asbestos, hexavalent chromium`compounds and benzene. Accomplishments Based on on MVM \ report the Task Force has identified thirty-six f]SI substances assoc iated with automotive production included in the draft OS1K candidate lot. Eleven (ill are currently regulnled bv OS 11 \ es potential carcinogens, (tie balance have potential for new regulation. The list of substances was reviewed by the TdSk Farce considering impact on the Company and potential for funner regulition resulting in definition of eight priority substances. The highest priority substances, asbestos, hexuv/tlent chromium compounds end bonzene. were examined by identifying application to materials and parts and uncasing possibility of substitution, 'i list of nsbestos production materials and parts has been devel oped and forwarded Co purchusmg for supplier verification of contan end nvuilnbili tv af possible substitutes. The benrone and haxavalcnt chromium compound lists are being analyzed by the product offices and ilanufacturing Staff to define specific purls usage. Strategy and Workplan The initial search for usoostas hexavalent chromium compounds and Convene defined e preliminary but not complete list of purls and materials contenting these suoxumtes as listed in the table below The npnticalions acre judgamcntally categorized uno tliruu g-auns known substitute material without major redesign, known auhatiluie material with major redesign and no known substitute with advanced engineering required Substitution Category Produrlinn Matprinlsfrarti Asbestos Chromium Uun/ono A - Known without redesign B - Known with redesign C - Not known, adv. engrg rcq'd SS 11 193 * 99 91 1 S Nonoroductinn 'tHtcnala/Parta Ashexiox Cnromium H^n/cn* 1 14 99 -< i i - B 111 9 003205 PRODUCED BY FORD / l L i- Tho following itrutcgy md timetable are recommended for esocstos. hexsvjlent chromium earn pounds and acnxane Far aoolicetions vith St"own substitute materials not 'equiring major redesign, eliminate f apcropriate sy Joo U, 1913. For abdications with known substitute nate",alj juj -ecutring motor taci.gn. eliminate it appropriate consistent *111 eve!* plans nno . jctiil/ projects. For applioationj witloul Se'ntd K.Dtt"JtM. idvoneod enjinee-nj will e* -qqui'ed ore 1 i.raiejy and 'tmetaole can oo sevetooeo. If elimination is not aporoor'ate or possible, provide adequate controls on exposure Strategies and time'JDles remain 'o 30 oevo'ooed .'or ,,he Saline* ot "1* eight pr-onty potential pere.nogens A generalized workblan has Soon prcon'sC on t.no Pasts of ..he evaluation of u-e supsuness referred to aoove The workplan requt'e* central prag'a-i management him pcfon implemenut'on Pv SAAO/DPO Frocuct E.ig'neermg Ot.iees. "urenosing ect.vities, a*oduct Planning, Vediele activities. Menuteetu'ing eci'vities end .no `lunufactur ng and Supolv Staffs. The workplan timing requires one year to detina in* uses of a potentially carcinogenic luostcncs itn eltmini' an requiring t.a additional years for a substance hiving icnown suostitute with no ms,or *tdestgn required, for .notorial sooticauons requir-ng major -edesign the timing is cone latent with new oroouet phase V timing ct 91 months tor vonicle end 43 months `or powertrain prog'vms Although a st'o'egy and workplan era oroooied n this ovoe* end efforts hove Peon startod in these areas, ,ne*e are conaidt'ecle .lining ind fcasimlit) sues in teen pf the 'cent . ed applications, iv'ithoul `und ? or ii*ee*ed or'or tization ov-* other engineering at,or:, 'no work on the idem,rod aioostos, nevavelent cnrontiur compound or penxeno ioplicti.ons cannot proceed under present economic conditions. Veve-thc'ess. a meuuree Comoanv reaction is neeesssry to initiate orderly suoaututien proyams with sutficient .Tetibmcy to adapt to engineering end economic limitations. Materials and Toxicology Svstem (MATS) A new computer data oaae J oeing develooee wnich links health, product, and manuuet.rng data bole* to facilitate reptd idcntincation of potential carcinogens and other tone suostinees. The ar..s between io evstomi will provide a mothod tor jen**vng 1 list of production snd -an production mate- jJ asectica'iona mich contain Ca'tgor/ luostJ'Ce* To date, of the four major MATS suosvstems. two nave been ccmplauc end .-e et*e*e are being manual!: oce'S'ed. In addi' on, 1-139 vine" soeei.ies preeedursa fo* ihe review of nev idiar ala a pong *evi<ed .3 inc'ude tr.e ecoosurv ectioru rjr ente-mg data on oxie end naxarsous auPsteneea i.vo the data poae The work to date ui devaloomem 01 he Meter.ala It Toneologv System (MATS) raa emphasized t"e neea ler mete-.Jl cetinit on on all per: .levies To .his end ihe ,otal engmee-ing re'eoae tile has teen audited and me reaponaiole PEO's ore preparing maternal denni.ion .or ell perl releases. Recommendations Achievement of me elimination or eontral ot potential carcinogens -equ'-cs 4 corpora.* commitment to foster in 'n.eg'nicd and sustained effort througnout the Cemeanv pve* a numbe* at years To accomplish .his, Ji# .ollowing actions and ressons.ml ties ere recommended. 1 Assign hazardous substance eonfol orng**m monugcnent rtsoonsihil.tv te environments' end Sefetv Eng'iiee'tng Siaif (Responsiptluv environmental ft Seiety Eng,nee*-ng Stafr ESaS} 1. Estsoluh 0 Hazardous Susstence Confol Committee chaired by Enviranmc-tel and Safety Engineering Steif. The Toau Faroe would oe discont.nged. (Resoona.pili.y ESCSJ . 3. Revise Oirectivc |1--101 (Occupat'onal Safctv 9hd Health and Confol of 'larArcaus \Uterislsl to railed' adjusted osoons.oili'.rs tor mo and stof'. ko new Pnlic 1 is required, uha matter is covered untie* Policy C*3, Standards ot Corporate Csnduc. IRuspanubility ESF5 Program Manager) 003206 PRODUCED BY FORD ATTACHMENT 1 J- 4. Adapt os the Company potential carcinogen Iminc, the 38 current OSIt wepiloted end proposed Category I substances uned in automotive production. Ealubliah (he lop eignt priorities proposed 8y the 1vaK Torce os Company priorities Direct mat the listing be updated semiannually (Responsibility PkO Stuff} 5. Complete strategies and timelahlct far the eight prioritised potential carcinogens (or review end approval by lha suoeoinmitiees (Kesponaibilily tSCS Program Munuger) S. Continue the development of MATS by Environmental A Safety engineering Staff. A budgot nnd headcount trunafor from Engineering Staff has been agreed to (Responsibility ESL5 Program Manager) The Companj has demonstrated a commitment te protect workers while seeking ta eliminate specific subatuneee. Directions on the use of and prntection for numerous lub-tnnccs have been issued. Worker* aha protected by restricting exposure nnd bv special clothing and engineered Sdieguards designed te keep exposure within known permissible limits Specific reeommandatians for eliminating asbestos, hexavalant chromium compounds and benzene follow 7, 1 Proceed with tho elimination of Croup A (known substitutes without major redosignl not leter than Job II. 198$ where appropriate os determined bv the Hazardous Substance Control Commitlca. (Responsibility PEO's. 3MD's, PurehastngJ 8 Inehide Croup B (known substitutes with major redesign) elimination actions m phase V of vehicle and poserirein programs and <n new plant and renovation orojeeia where aporopmle es detsrmined by the Hazardous Substance Control Committee (Responsibility ESCS Program .Manager, Product Planning. Vehicle Diginee'ing, Manufacturing Slarf) 8 Recommend advanced program funding to devtlop designs and/or suostitutes for new production and nonproductien parts and materials te identify feasibility, reliability, cost and weight implications of alternative materialsvdesigns far Croup C rpoheations (no known substitute, advanced engineering required). (Responsibility PEO's, OMD's. Technical Planning, Scientific Research Staff) The implementation of the above actions and responsibilities should be reviewed oenodicellv by the Engmee*ing and Research end Monufaeturing and Supply Subcommittees to provide a forum far discussion, Corporate overview and endorsement of appropriate funding and prioritization of efforts Engineering Staff Manufacturing Staff May 97, 1930 I Vertical line indicates revision at suoeommittee direction. 003207 I ATTACHMEUT 2 COORDTOATING PRODQCT OFFICE TOXIC MATERIAL SPBSTITnTICK ACTIONS ]0l]j ~ CRAFT STATUS REPORT As discussed la the meeting vnth materials rss pons ibis personnel in G. 7. Balling's office on Key 7, I960, it was concluded that remote "management-by-assignment" vill not do tbs job required for control of toxic end hazardous materials. Even the simols compiling of a full list of asbestos, baxavalant chromium sad benzene anplic&tions, for example, requires experienced research vhieh today'9 austerity budgets cannot aosorb. Therefore, as agreed in principle at tne meeting, 7KD&? proposes to do the foLlovug: 1. Assist in refining the initial listing and classification of the top three hazardous material applications. 2. Coordinate substitution development among the PEO's to avoid duplication of effort. 3. Report both FSO and Corporate status of actual elimination and'status of development to the ESES program manager. VKD&F reports vould be against a product family group. Status by part number detail, if necessary, vould remain a P50 responsibility. . Furthermore, simplification of ES-M's in NAAO is a part of the VMDb? charter, and a broaa review of materials such as this ought to turn up many like ES-M's in like apnlications. VMD&? vill therefore highlight and include m the substitution recommendations every possibility for commomzing. The job is large enough to require that it be taken a bite at a time. The bite size should bo established by a carefully considered classification of like materials and function. For example, bite size might bet asbestos m friction materials, asoestos in gaskets for high temperature; etc. Draft Status Report A draft status reoort (Exhibit 1) has been prepared cy 7WD&? for asoestos removal from product families with general classification of friction materials. The recort is incomplete, out sr.ould serve as a thought starter for content, organization ana format. As written, the raport is in tvo parts. . Raeap of each FEO's position and a spread sheet removal action/issues . Summary of the key aspects.of the design development Job feeing Ford product engineering! government regulation, scope of Ford use, survey of substitute availability performance, oibliography, and miscellaneous information of a general nature. (This is the basio technical reference information (the * glue) that vill keep the program on course end avoid duplication.) Development and the continuing update of this report would oe the responsieility of Vehicle Materials Development and Planning based on input by the responsible FSO materials end design engineers, suppliers and staffs. Periodically, a brief general meeting of the materials engineers might oe necessary to adjust our course. Vehicle Materials Development and Planning June, I960 003208 PRODUCED BY FORD P.-rh-iV.'* J, Page 1 of 7 I PAST 1 - mCTIOK MATERIALS I STATUS REPORT HO. 1~| i Vehacla Materials Development and Planning June, i960 ` 003209 PRODUCED BY FORD n 6 z J d 1 1 o u 2 c. I 3 0 r 2 J s 5 Exhibit 1 Page 2 of 7 y a n P0 07 r \r 1 o U /i 1 s0 *2 / Pa 3!? d i\ /* J o' *1 mJ Mi 3j $3 o u o uJ -3. VUf J P J2 ?> 1 at sY* rd v3i di .< 0 -1 -j v> 9 r J 'K ai tt p "J iu -4. \ii<0 (5 h /v 2 r3 litf <1 uJ y r*. u- 4 u Q> 5 ^1 f 003210 PRODUCED BY FORD I Exhibit 1 Page 3 of 7 'ASBESTOS ELIMKATTON - FRICTION MATERIALS CATEOOfff SECTION 2 - PRODUCT EHOIHEZRIMG REPORTS | Activities Rev-iev - BraJceF] . Passenger Car Chassis - Asbestos free semi-set front disc brake pads were first used la the 1979 Hustang turbo option and Fairmont police package. Usage spread in 1930 nodels to all Mustang, VS Fairmont and T-Bird, 1981 usage will increase again to all Fox vehicles and Granada.' Bendue is the sola supplier. Sem-eets have proven the least expensive way to improve capacity. The trade off Is generally greater rotSr wear. All rear brakes are drum vxth asbestos containing lining. . A general asbestos-free lining development baa been initiated by Car Chassis Braks Department with a letter to all the leading lining manufacturers. The letter invites manufacturers to demonstrate feasibility of asbestos free linings by comparing per formance to current release over a single set of vehicle test parameters. Light Truck - All I960 model light trw^rupuize semi-met front disc brake supplied by Beodix. Boars are all drum tyns^vipiyasbeatos containing shoes. Ho non-asbestos suostitutas are being investigates./ Heavy Truck - The and rear, of ccnventioi pound capacity front no plans to evaluate heavy trucks are equipped with drum brakes, front os material. The very heavy class 16,000 to 20,000 utilize disc brakes vrth semi-mat pads. There are non-asbestos brake materials. I Statistics I - 6/80 Humber of End Item Brakes PEO Front Car Chassis Rear Lt. Truck Front Rear Front Hvy. Truck Rear Actual 1981 Model ! Total , SNon-Abs* 1' | 1st. Sst. 1982 Model i 1985 rfoael . Total SNon-Abs 1 Total . SNon-Aos 1 1 1 l 1 : i: l l 0032 n PRODUCED BY FORD Exhibit 1 Page 4 of 7 ASBESTOS EUMCTATIOK - FRICTION MATERIALS CATESORT SECTION 5 - PRODUCT ENGINEERING REPORTS ' Activities Review - Clutchaal k<? Transmission Axis -- T&A incentives ^svslop asbestos substitutions baa beau largely policy. All vet operatimg*untejpaA transmission clutch plates and bands and locking differential dutch {3etks/have been converted to noa-aaceatos facing as of ( ). y/ A non-asbestos (fiberglass) compound, developed for manual transmission clutches by Hayhestoa, was used in production of 1980 200 CHI Fairmonts. The soma material is currently released aa an option to all conventional asbestos containing facings. Production of nan-asbestos clutches hovever, will be limited by Raybestos product ion facilities until other sources are approved (Thermoid in process). Higher cost might also inhibit early release. . Heavy Truck - clutch facings ore being converted to ceramic materials as performance and costa become blown. Conventional organics are not adequate. . Lignt Truck - No non-asbestos substitutes have shown equivalent performance to date. Possible development for luma with Ashai (Japan1. Current 90S supplier, * Thermoid, assures be can meat EPA proposed exposure limit. All facings beginning 81 are seal coated far assembly safety. , Statistics I Number of 3nd 'Product Clutches Actual 1st, Est. 1981 Model , 1983 Model 1985 'dedal PEO Total SNon-Abe I Total SNon-Abs j Total SNoo-Ads| T&A Light Truck Heavy Truck 003212 PRODUCED BY FORD Exhibit 1 Paw 5 of 7 Brake a and Heavy Duty Friction Aoclieatlons Asbestos has unique physical and chemical propertvejr which are very difficult to reproduce in a substitute. These properties include a consistant natural lubricity, high temperature function, good permiability to heat generated gases, low cost. Furthermore, braking performance is Judged against a highly developed (on asbestos) envelope of GPAS and FK7SS tests. Three categories of non-asbestos compounds are currently being investigated. 1) Semi-metallics (Gem-met) - essentially spoilage iron and steel wool plus graphite and bonus sulfate held togetner in an organic matrix. The graphite is_reqiuxed to_prevent_welding to the drum or rotor, but has a very . low coefficient of fnetisn when vet - it effectively restricts passenger car use to power disc brakes; although they have been applied to heavy tracks. . Semi-met disc broke pads supplied by Bendix today for ear and light track are e oompoaite sandwich of semi-met surface bonded to a reinforced organic back ing in turn riveted to a conventional steel pad. The sandvich construction is used primarily because the semi-met material does not have the compressive strength for riveting. 2) Sintered metallies - mixtures of iron and copper, some in variable density, used in clutch discs, aircraft brakes. Hot likely to become feasiole for automotive brakes. 3) Non-asbestos organic (N.A.O.) - essentially the same as the current asbestos shoes/pads but vxth other fibers such ss glass. These would seem the best prospect as s substitute involving leaet product development but N.A.O. materials are not strong structurally & delaminate in the high speed manufacturing process used for passenger car drum brakes. They are compatible with less automated ' process used in some large truck drum brakes. Consensus among passenger ear product engineers and suppliers is that an N.A.O. material would require a three to five year combined development of drams, snoes, and linings Before release. Regulation and General Cartorate Policy (T3D ) tons of asoestos are released to the environment annually as a result of wear of friction material containing asbestos.- There is s strong difference in pro fessional opinion as to the hazard from wear debris. High temperatures and pulverizing during wear change asbestos into a different form. The disagreement is to the toxicity of the deans. 003213 PRODUCED BY FORD ( ( Section 3 Page 2 Exhibit 1 Page 6 of 7 Regulation and General -Coroorate Policy (continued) There is no doubt, however, that asbestos mining and manufacture of asbestos contain ing products will be increasingly regulated. Regulations in11 be- in the form of airborn exposure limits, and banning of more products containing ascestoa in a free con dition (as vs. a filler m gaskets and plastics), A bon on the use of asbestos con taining fnotion material is net expected in thf /near future but regulation will nake them more costly and reduce their availability.^ More information about regulations and the intentions of private sector leadership will be exposed at an E?A sponsored conference July lb, 19oG in Washington D.C. Mr. A. Anderson of the Scientific Lab will attend. NAAO Car and,Truck Policy on product usage of asbestos is defined in CEPD-IO: - with certain exceptions, "Rawly designed components should not contain asbestos". 1/ Bibliography item reference Vehicle Materials Development and Planning June, 1980 003214 PRODUCED BYFORD | APPEHDIX A5BE3T03 ELIHIHATIOH PROGRAM, PART 1F ric tio n M aterial Suppllere 8. b Z 9U tOn3 Mg e I6h"TJ 1? fc 8 3U u ao eo Ps J3 1 B 3 +0aai uba 1s A Ufl t5 3 cM t,, hC ab & S> w a *a 2 * ca xg ot3 sa I o H S i 55 \ % \ AB I hO o 5B 5 B d eO 5 A9 .M0A He HA B OX4HgSJ 5aAAB 3 3 JAd E 03 *g Mab Exhibit 1 Page 7 of 7 18 r-I i IA Si BAg I3 a Si C2Io9T H &35 IS! I m S3 8 a 3. 8I Smr IrHA Xe fab. 5 s aA e5 *asaJ; *hHa u UA HoA' bO O 00321S V e h ic le H a te ria la Development and P la n n in g June, 1980 I PRODUCED BY FORD J (* Responses from PEO's - Asbestos 1. Climate Control Division 2. Body and Electrical 3. Engine Engineering 4. Ford Parts k Service Division . 5. Transmission k Axle Engineering ` 6. Electrical k Electronics Division 7. Truck and Recreation 8. Truck Operations 9. Chassis Engineering Supplier Survey Request and Purchasing Activity Responses - Asbestos 10. Climate Control Division 11. Casting Division 12. Electrical A Electronics Division 13. Glass Division Responses from PEO's - Chromium and Benzene ' I June 6, 1980 00321B PRODUCED BY FORD