Document rBbrwx2m4D0pNwONGNpqM9VR7

FILE NAME: Ford (FD) DATE: 1980 DOC#: FD031 DOCUMENT DESCRIPTION: Internal Report with Cover Memo - Carcinogen Task Force Report A . Anderson, Exhibit 4 5/4/98 Block V Maremont inter Office Engineering ana Research Staff May l , 1980 Messrs. D. D. Baker D. L. Block, M.D. J . H. Douma P. D. Fadow W. H. Fike S. M. Frey S. Gratch D. F. Hagen M. H. Hamburg G . C . Hedges C . D. Lauer E. T. Mabley J . H. Ogden J . A. Pflug H. W. Potoczak P. E. Prill J . G . Rivard V. H. Sussman J . D. Veite cc H. P. Freers G. 0 . Keutgen H. A. Nickol Subject: Carcinogens Task Force Report to EA R and MAS Subcommittees The Task Force on Carcinogens in the Workplace was established by joint action of the EAR and MAS Subcommittees, with representation from affected line and sta ff activities. The Task Force was chartered to coordinate plans and efforts to identify and quantify carcinogenic substances in use; to develop action plans, take aggressive steps and set targets or elimination of as many carcinogens as possible; and to organize to identify substances systematically. The Task Force will present its report to the Subcommittees on May 27, 1980. Attached is a draft of the report. Your comments are requested by May 9, 1980, so that we may meet the timing of the several pre-reviews scheduled. ' Attachment J . W. Duratine PROP ERTY OF FCP3 PCTOR COPPANY CARCINOGEN" ,v' THE W ORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established by the Engineering and Rescarcn and Manufacturing and Supply Subcommittees to identify carcinogens ano quan tities in use. set target* for elimination ancud of regulation, take steps to find substitutes, develop a directive und workplan and organize to identify substances systematically. Th Task Force assignment responded to evidence that cancer may be a serious occupotional concern and to the Company's and public concern with regard to protection of the environ ment and public health. Additionally, the Company hos been subjected to a growing number of lows which regulate material use, transport, handling and disposal. In summary, internal and external pressures regarding hazardous substance control and compliance have increased substantially since Marcn, 1977, when Directive B-101 assigned responsibilities within the Company. Past Company Actions ' Since 1977, the Company has removed lead chromates and molybdates from paint (except special order), "Tris" flame retardant from fabrics and instituted controls on asbestos, including a Vehicle Engineering directive that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). Sprayed-on fireproofing has been asbestos-free since 1969 for new and reworked construc tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazards from paint-related chromium compounds. Carcinogenic Substances The Task Force has identified sixty-seven (67) carcinogens in-use in the automotive industry. Twenty-six (26) of those are currently regulated byOSHA; the balance have been proposed for new regulation. More restrictive standards have been proposed for some of those sub stances currently regulated. Thirty-one (31) substances are reported to the Michigan Department of Natural Resources for computation of water surveillance fees. Michigan plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur rently required to be reported in the other states. The list of carcinogens was prioritized by the Task Force according to impact on the Company to identify the top eight (8). The top three of the eight priority substances, asbestos, chromium compounds and benzene, were examined in detail. ' - Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets and for nonproduetion roofing, millboard and core/mold-making materials. Medical evidence links inhulation of asbestos dust to lung cancer, mesothelioma and other diseases. The present OSHA limit is 2 iibers per cc of air (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/cc as early as this year. - Chromium compounds are used primarily in paints and inks for production and nonproduction use. Medical evidence links hexavalent chromium compounds to lung cancer, liyer and kidney damage and other diseases. The present OSHA limit is 52 mg per m of air which is proposed to be reduced to 1 mg/m . - Benzene occurs primarily in coke oven operations as a by-product. It is a residual constituent of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has proposed a limit of 1 ppm in air time weighted average in 8 hours. Specific lists of bulk materials and parts for production and nonproduetion use hove been developed. A new computer data base is being developed. Materials and Toxicology System (MATS), which links health, engineering, and manufacturing data bases to facilitate rapid identification of carcinogen ooplications (2nd quarter 1981). The engineering release system has been audited and is being updoted to extend materials identificotion to all parts. Product Engineering Procedure PEP 3-189 hus been rewritten to require systematic review of suspect carcinogens and input to the data base. PROPERTY CF F t R D KCTCR C0P P 4NY lUonwnucai Strategy and Workplan The soarrt; for asbestos chromium compounds and benzene defined the numocr of ports and materials containing these substances ns listed in the tonic below. Where possible, the opplieottons were divittcd into three groups: A * Known substitute material without major redesign, B - Known substitute material with major redesign nnd C - So known substitute or advanced engineering required. The duU is directional only. There remain many suspect applications w hich require tune-consuming annlyscs for identification. ________Bulk Materials nnd Ports Production________ A B Total Nonoroduction A B Total Asbestos Chromium Compounds Benzene 34 49 22 105 " - 25 25 - - 15 15 8 8 98 81 34 213 3 - 5 8 Strategies have been formulated to eliminate or control these substances. The recommended strategy is to proceed now to eliminate these three carcinogens by Job 1. 1985, in light of competitive and regulatory pressures, and Company experience. Where elimination cannot be contained, institute controls on design, process anc exposure. It is judged that the elimination timetable is practical for Groun A asbestos, chromium compounds and bcnzcnc-contaimng parts and materials. For those applications requiring major redesign (Group B, e.g.. drum broke linings) the elimination timetable would have to be adjusted to reflect Company cycle plans although G.M . has stated an intent to eliminate asbestos by 1985. Finally, where no known substitute exists (Group C), advunced engineering will have to be completed before a elimination timetable can be established. A generalized workplan has been prepared on the basis of the evaluation of the carcinogens already referred to. The workplan requires cerumi progrum management, with action imple mentation by NAAO/DPO Product Engineering O ffices, Purchasing activities. Vehicle acti vities and the Manufacturing and Supply Staffs. It is judged thnt approximately a year is required to complete the sorting of the three carcinogens into the known substitute, major redesign and advanced project groups. It is judged that one additional year would be required to implement the most feasible product actions not requiring major redesign. Substitution requiring redesign would take 33 months for vehicle or major powertrain pro grams. Recommendations Achievement of the recommended strategy requires an integrated approach throughout the Company and a sustained effort over a number of years. The Task Force recommends: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2. Assign Carcinogen Program manager control responsibility to Environmental and Safety Engineering Staff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by the subcommittees. (The Task Force has requested General Managers and Chief Engineers to recommend directional timetables.) 4. Direct all affected organizations to proceed with the elimination of Group A asbestos, chromium compounds and benzene for Job I I , 1985. 5. Request that NAAO Product Engineering O ffices and Manufacturing Staff present to the subcommittee specific action plans and timing for the Group A applications identified. 6. Provide advance program funding to develoo designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). 7. Adopt as the Company carcinogen list ' g the 67 current OSHA-regulatcd and proposed Category I substances. Establish the t.-p eight priorities proposed by the Task Force as Company priorities. r n w r t H i t OF FORD MOTOR COPPANY Engineering Staff - E&RS Manufacturing Staff May 2, 1980 OUTLINE ENGINEERING AND RESEARCH SUBCOMMITTEE MANUFACTURING AND SUPPLY SUBCOMMITTEE CARCINOGENS IN THE WORKPLACE TASK FO RCE REPORT - MAY 27, 1980 Introduction Background . Past Company Actions - Production - Nonproduction . Task Force Charter Carcinogenic Substances . Prioritized by consensus . Asbestos, chromium, benzene . Asbestos Summary . Chromium Summary . Benzene Summary " . Carcinogen Search ' - List specs, and parts - Identify items having no substitutes - Identify substitutable items .. Eliminate when redesigned or reordered - Develop substitutes for others (advance engrg. funding) . MATS . Carcinogen Search Results . Carcinogen strategies . Generalized Workplan . Proposed Chemical Substances Control . Proposed Priority Actions Exhibits . List of "67" Carcinogens . MATS Appendices Asbestos-containing parts and materials Chromium-containing parts and materials Benzene-containing parts and materials PROPERTY CF FCRD PCTOR CCfPANY DRAFT FEDERAL AND MICHIGAN ACTS RTCULATIVG TOXIC'll A7.ARD0US MATERIALS MAVINC IM PACT ON THE COMPANY flCUKE 1 Refulatory Acts Occupational Safety ano Health Aet - 1970 D.O.L. (OSHA)* Hazardous Materiali Trsnsportation Act I97S D.O.T. (HTMA) Toiie Substances Control Act 1971 E.P.A. (TSCA) Resource Cornarvition and Raeovcry Aet - 197* E.P.A. IRCRA) Clean Air Aet and Clean Water Act Amendments - (CAA) 1*77/7* E.P.A. Mietiican Aet 793. P.A. - 1*77 Miehi(an D.N.R. (MDNR) Flettacinc 4 Staekm* Federal Hazardous Sudatane Aet - 1970 Foiaon Prevention Paekacinf Aet - 1970 Coiaumer Product Safety Aet - 1977 Waste Manafcment Hasardws Waste Manarement Aet * 1*7 Mich., P.A. (4 Solid Waste Manacement Aet - 1971 Mieh.. P.A. (41 p r o p e r t y of FORD MOTOR COMPANY * t tricc r*V,le<S 0Ur,nf l " 0, *6 low,r Permisnole espoaure limit from present 7.0 fibert/ee te 0. or 0.1 rtCURE 7 CORPORATE STAFFS RESPONSIBILITY FOR TOXIC/HAZARDOUS MATERIALS (DIRECTIVE B-101) Staff ESES Responsible Activity SSECO P40 IH4T MFC. STAFF SAFETY Plant Enere. Office Mf*. Enfre- 4 Systems Plants E4R5 Prof. Anal. 4 Metis. Enere- Xesearen Staff SUPPLY Trans. 4 Traffic OSHA TSCA Compliance Reportme REGULATORY ACT RCRA ft S u t* Solid/ Has. Wastes Compliance Reportme HMTA Compliance Riportine Identification of Controls Monitorine Enforce Controls Material Inclusion in EPA Inventory Facility Controls Development Process Controls Development Process Controls Implementation Non-Prod. 4 Prod. Metis. Review Non-Prod. Metis. Review Non-Prod. Metis. Review Facility Control Impit mentation Develop new mails., mfe. processes. 4 meisuremcnt devices. Production Mails. Review Chemistry in Data Base DOT Lapel in Deu Base Disposal Math. 4 Fae. Dev. Waste Charac terisation Peeksf i x (torace Material Character t- aation Compliance R ip o rtin e CLEAN AIR 4 WATER Compliance Riportine Mormorine MICH DNR Compliance Riportine Chemistry in Data Base Fecilitles Roue* Consol Development idation Process Centr. Development Permit Riportine Usaci Riportine If May 2, 1980 u n. t\ r PROPERTY CF FORD MOTOR COMPANY .troduction CARCINOGENS IN THE W ORKPLACE The Task Force on Carcinogens in the Workplace was established during the 4th quarter 1979 by joint action of the EdcR and MdcS Subcommittees. The Task 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 Exhibits and Appendices. Background Scientific investigations into the occupational factors involved in the development of cancer, conducted in recent years, have provided evidence that occupational related cancer is a serious concern. It has been estimated that in coming decades up to 20% and perhaps as much as 40% of cancer in the U.S. might be associated with occupational factors. Accordingly, Personnel and Organization S taff, Employe Health Services, has exerted a continuing effort to provide employe protection, as knowledge of toxic/hazardous materials has been introduced. Public concerns relating to the control of toxic/hazardous materials, are shared by Ford, due to the Company's regard for public health and the protection of the environment and potential impact of legislation on our products and manufacturing operations. Also, the right to examine the Hazardous Materials Catalog from the Company's computer file of hazardous materials, and on-line access to the Materials and Toxicology System (MATS) has 'een extended to the UAW by contract. " resolution of workplace exposure concerns relating to the management of toxic/hazardous substances, materials, and wastes, involves a consideration of the relationship between the internal and external environments. Emphasis on wastewater pretreatment standards, toxic pollutant effluent standards, nonregulated/hazardous air pollutant emissions control and solid/hazardous waste management has been increased by governmental 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 growing number of laws which regulate material use, transport, handling, and disposal (Fig. 1). Under certain of these Acts, a "knowing/willful" criminal violation can expose individuals, including 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 O ffice of General 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 the court. Internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 was issued to assign responsibilities within the Company (Fig. 2). Since that time new standards have been ^sued, additional standards are anticipated, and the level of economic risk has increased. Federal Register 45(15): 5031, January 22, 1980. - 1- May 2,1980 DRAFT FIGURE 2 PAST COMPANY ACTIONS Production . Removal of lead and chromium from paints. . Removal of "Tris" flame retardant . Controls instituted for asbestos in new designs. Nonp reduction . Removal of asbestos from, . - 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 P R OP E R T Y OF FORD MOTOR COPPANY - 2f - May 2,1980 u rs. a r PAST COMPANY ACTIONS Production Materials In response to OSHA regulations in 1978, the Company removed lead chromates and 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 for 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 in which employe exposure to asbestos exceeded regulated limits. A ll 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 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 ventilation/proteetive measures were identified at the Romeo Tractor Plant to minimize hazards from chromium compounds used in painting. (The substitution of non-hazardous paints is targeted for. Romeo for late 1980.) -2 - May 2,1980 PPCPFTY CF FCRO F C T C R COMPANY DRAFT FICURL A TASK FORTE CHARTER Tlio Task rorcc ms cnsrterec By P.iK ana M i S Subcommittees (Meeting of 10/24/79) for coordinating plans ana efforts to: ! . Identify substances m use (OSHA Categories I and 11). 2. Determine quantities usca (for mutcrials regulated by Michigan Department of Natural Resources). 3. Set targets for elimination of as meny Category I substances as possible. 4. Take aggressive steps to find substitutes for as many Category I substances as possible in anticipation of government regulations. 5. Develop a policy and action plan for eliminating potential carcinogens where possible. 6. Organize to identify substances systematically. FIGURE 5 USAGE o r MICHIGAN CR ITICA L MATERIALS AS REPORTED T O M A T S * ( A D J U S T E D HV T H U PI A M S I S T H E IU MDNR REPORTS) P R O P E R T Y OF FORD PCTOR COMPANY Material Acrylic Acid Acrylonitrile Lbs. of Usure 251.707 641.133 PPV - Paint PPV - Paint Princioal Users Aniline 90 M C C , Dbn. Class, T&C Sterling Antimony 630,571 PPV - Vinyl Arsenic 11.157 T& C Vandyke, PPV - Vinyl Asbestos (not reported as a material - present in articles only) Benzene Cadmium 385,028 3,311 AAD - Dearborn Assy., Gen. Service PPV - Vinyl Chromium Cloroprene Cobalt Copper Cyanides Dichlorobenzcnes Formaldehyde Hydrozene 81,377 24,676 210 321,704 923,069 2,542 488,905 130 PPV - Paint, EED - Ypsi. AAD - Utica PPV - Saline AAD - Dearborn, PPV - Saline, MSD - Monroe MSD - Monroe FTO - Highland Park MCC. PPV - Paint ' PPV liydroqumone Hypochlorite 1 15,841,758 PPV - Vinyl MSD - Monroe Lead 626,027 AAD - Wayne/Dearborn, PPV - Paint Lithium Nickel Phenol Selenium 123 126,624 5,839 127 ED - Northville, T4C Sterling MSD Monroe, T4C Sterling Mich. Cast. Cntr. T4C Sterling Silver Silicon-Dioxide Coated Lead Chromate 25 2,317 T4C Sterling PPV Styrene 1,413,986 PPV - Milan. PPV - Vinyl Tetracloroethylcne Thiourea 1,095 II AADGO, Mich. Prov. Gmd. PPV - Vinyl Triaryl Phosphate Esters Trichloroethylene Vinyl Chloride 160,022 91,849 118 Steel, T&C Sterling EED - Rawsonville PPV - Vinyl Zinc 1,085,724 PPV - Paint, AAD, FPSD, FTO * Michigan locations not reported to MATS: Detroit Industrial Engine Research 4 F.ngmeertng Center Research - Glendale Troy - Tractor Vulcan Forge Dearborn Glass Dearborn Specialty Foundry Wixon Assembly -3- May 2.1980 DRAFT TASK FORCE CHARTER To implement the charter, the Task Force has coordinated plans and efforts to identify usage of potentially carcinogenic substances, developed specific strategies to eliminate the use of these substances and initiated plans to find substitutes for substances ahead of government regulations. The complete Task Force Charter is shown in Figure 4. In 1977, OSHA issued a draft policy listing numerous chemicals that could be classified as "Category I" and "Category IT' carcinogens. According to OSHA's draft policy, Category I substances are known to be carcinogenic in humans or which have been demonstrated to be carcinogenic in two separate laboratory animal studies. Category n substances are so classified where data is suggestive or carcinogenicity in test animals and humans, or unreplicated tests indicate potential occupational carcinogen in a single mammalian test species. - - A listing of 67 Category I substances in use in the automotive indus try has been prepared. (Exhibit I). - For materials regulated by Michigan Department of Natural Resources, quantities have been determined, as shown in Figure 5. As reported to the State of Michigan, in 1979, the Company used asbestos only as articles, 81,377 pounds of chromium compounds, and 385,028 pounds of benzene. Action on the remaining items in the Task Force Charter will be discussed on the following pages. Category I substances were examined in detail. P ROP E RT Y OF FORD PCTOR COPPANY -3 - May 2, 1980 DRAFT FIGURE 5 TASK FORCE PRIORITIZED CATEGORY I SUBSTANCES Substance 1. Asbestos 2. Chromium Compounds 3. Benzene i. Cadmium/Cadmium Oxide 5. Coal Tar Volatiles Benzo (a) Pyrene . Benzo (a) Anthracene 5. Ethylene Chloropolymer 7. Beryllium 3. Trichloroethylene Occurence within Comoanv Friction materials, gaskets, sealers Chrome plating, paint pigments Product of coking operations, foundry operations, petroleum products, paints, thinners Fastener plating, solders, foundry effluent, valve alloy Coke oven and foundry emissions Coke oven and foundry emissions Coke oven and foundry emissions Vinyl Aluminum foundry operations Degreaser Current Exposure Limits 2 fibers/cc 3 0.1 mg/m 10 ppm 3 0.1 mg/m 0.2 mg/m3 3 0.2 mg/m 0.2 mg/m3 None established 2 ug/m 100 ppm FORD ROTOR COMPANY -4f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES A prioritized list of Category I substances that are contained in materials used by the Company or generated as a result of Company operations, is shown in Figure 6. The current exposure limit for these substances is also provided. It is important to note that this does not represent an exhaustive list. (The complete listing is provided in Exhibit I.) The substances and their typical uses listed are presented in order of priority as established by Task Force consensus. The ability to achieve the strategies designed to meet the objectives of the Task Force was measured by evaluating the scope of usage of asbestos, chromium and benzene (priority ranks 1, 2 and 3,- respectively) as test cases because they are considered by Operations and Staffs to have the greatest impact on the Company. NAAO/DPO material uses of asbestos, chromium and benzene were systematically identified. Strategies to eliminate/control these materials, in a practicable manner in anticipation of Government regulations, were formulated. A plan to extend the strategy formulated for asbestos, chromium and benzene, to as many Category I substances in Company materials as possible, was established. PROPERTY CF FCRD PCTOR COPPANY -4 - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES Asbestos Health Effects on Humans Asbestosis Lung Cancer Mesothelioma Laryngeal Cancer Digestive System Cancer Exposure Limits Time Weighted Average (NIOSH) Time Weighted Average (OSHA) Ceiling Regulation (Fibers/cc) 2.0 10 FIGURE 7 FIGURE 8 Proposed (Fibers/cc) 0.1 0.5 5 PROPERTY CF FORO ROTOR CORPANY Summary of Asbestos Usage FIGURE 9 Production Clutch Plates Brake Linings Gaskets Insulators Adhesives Sealers Sound Absorbers Nonproduction Roofing Materials Millboard Asbestos Reinforced Paper Core 6c. Mold Making Materials Safety Apparel - 5f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES ASBESTOS During the past several years, positive evidence has established the link between the inhalation of asbestos-containing dust and chronic respiratory disease (asbestosis), as well as several forms of cancer. These include lung cancer, mesothelioma (cancer of the membranes lining the chest and abdominal cavities), and gastro-intestinal cancer. Asbestos is found in a variety of automotive components, and thus many occupational exposures are possible. The most critical exposure occurs during brake and clutch repair. A small number of Ford employes are potentially exposed due to repair of Company owned vehicles. The permissible exposure limit currently regulated by OSHA, is 2.0 fibers per cubic centimeter of ambient air. The National Institute for Occupational Safety and Health (NIOSH), an advisory group, and OSHA have recommended that limits be tightened to as low as 0.1 in 1980. Industrial Hygiene and Toxicology has issued bulletins detailing controls. An EPA ban on all non-critical uses may occur as early as 1985. PROPERTY CF FORD KOTOR COMPANY - 5- May 2,1980 CARCINOGENIC SUBSTANCES PROPERTY CF FORD POTOR COMPANY CHROMIUM COMPOUNDS Health Hazards of Chromium Compounds E ffect on Body Systems Respiratory Tract - Irritation/Perforation of Mucous Membranes, Bronchitis Liver - Damage Skin - Dermatitis, Ulcers Kidneys - Damage Lungs - Cancer Hexavalent Chromium Compounds X X X X X I FIGURE 10 Other Chromium Compounds X X X X FIGURE 11 Exposure Limits Time-Weighted Average (NIOSH) Ceiling (OSHA) Ceiling (NIOSH) Exposure Limit (NIOSH) 52 ug/m^ a/ 1 u?/m3 " 1/2 of above 3 25 ug/m 10 Hr workday 3 50 ug/m /15 Minutes 1/2 of above a) Measured as chromium. No differentiation is made regarding valence or type of disease due to exposure. FIGURE 12 Classes of Materials Containing Carcinogenic Chromium Compounds Production Topcoat Paints Primer Paints Chromate Coatings Nonproduction Maintenance Paints Paint Strippers Marking Inks - 6f - May 2, 1980 DRAFT CARCINOGENIC SUBSTANCES CHROMIUM COMPOUNDS Some trivalent and hexavalent chromium compounds have demonstrated potential health hazards to human organs and systems (See Figure 10). Chromium in hexavalent combination with hydrogen, the alkali-metals (e.g.[ sodium), ammonia and oxygen are considered noncarcinogenic. All other hexavalent combinations of chromium (e.g., lead and zinc chromates) are considered carcinogenic. The primary concern for exposure is through inhalation, potentially causing lung cancer. A number of Ford employes have potential exposure to these compounds by virtue of their handling of materials, primarily in paint making and application. Protective measures are employed to assure regulated limits are not exceeded. The current statutory limit is 52 mg/m3 although NIOSH has recommended lower levels (Figure 11). The classes of materials included in Figure 12 are of current concern since the most critical sources of exposure are in paint manufacture and application. PROPERTY OF FORD PC TOR COMPANY 6 - May 2,1980 P ROP E RT Y OF FORD PCTOR COPPANY DRAFT CARCINOGENIC SUBSTANCES BENZENE FIGURE 13 ADVERSE HEALTH EFFECTS FROM EXCESSIVE EXPOSURE TO BENZENF Contact Dermatitis Eye Irritation Narcotic and Central Nervous System Effects Ventricular Fibrillation Malfunction of Liver and Kidney Chemical Pneumonitis and Pulmonary Edema Leukemia Blood Dyscrasias (disorders) Time-Weighted Avg. Ceiling FIGURE 14 EXPOSURE LIMITS' Reeulation 5 ppm/15 min. Prooosed 1 ppm/8 hr. 1 ppm/ 2hr. Sample collected at 1 liter/minute FIGURE 15 CATEGORIES OF MATERIALS IN WHICH BENZENE O CCU RS OR IS SUSPECTED Adhesives and Sealers Rust Preventives Thinners, Enamels and Lacquers Primers, Paints and Coatings Cleaning Solvents and Compounds Misc. Organic Compounds Coke Oven By-products Marking Fluids and Wood Preservatives Finishing/Polishing Compounds Lubricating Greases and Oils Lubricating, Hydraulic * Multiple Purpose Oils Liquid Fuels and Hydraulic Fluids Hydraulic Fluids - 7f - May 2,1980 DRAFT CARCINOGENIC SUBSTANCES BENZENE Benzene is a leukemia producing agent. Excessive exposure can result in a number of other adverse health effects (Figure 13). Benzene may enter the body by inhalation and/or skin absorption. At present, a small number of Company employes are potentially exposed to benzene in excess of one part of benzene per million parts of air and no employe is exposed in excess of 10 parts of benzene per million parts of air. These potential exposures result from the coke oven steel making processes, and employe protective measures are in e ffe c t. Permissible exposure limits allowed by regulatory agencies are summarized in Figure 14. The OSHA standard exempts employers who store, transport, distribute, disperse, sell, or use benzene as a portion of gasoline or other motor fuel after it has been discharged from a bulk terminal. This exemption vas necessary since there is no possible way of controlling benzene exposure among service ation personnel, mechanics, or tank truck drivers. Employe Health Services has reported that no indication of excessive exposure exists for Ford employes as a result of handling gasoline. Benzene occurs as an unintentional constituent in many materials used throughout the Company (Figure 15). Petroleum-related materials are of primary concern as they most likely contain benzene at levels that require consideration. (See Exhibit III) PROPERTY CF FCPD PO TOR COPPANY -7 - May 2,1980 DRAFT CARCINOGEN SEARCH FIGURE IS Carcinogen Identification - Reviewed all likely material specifications and manufacturing standards. - Reviewed the IH&T CA TA LO G of Hazardous Materials. - Reviewed NAEPIS to identify Industry Standard Materials . - Reviewed the Michigan Critical Materials data - Surveyed previous assessment of production materials. - Communicated with material suppliers. - Analyzed the production material list (PEO). Carcinogen Usage - - Reviewed the NAEPIS cross-reference for production material/part usage. - Reviewed processes/uses involving the substances in nonproduction materials. - Confirmed the NAEPIS usage list for completeness/verification. Chemical ComDound MATERIALS AND T O XICO LO G Y SYSTEM FIGURE 17 property cf FCRD POTOR COPPANY - 8f - May 2, 1980 PROPERTY CF FORO PGTOR COMPANY DRAFT CARCINOGEN SEARCH Three Category I carcinogens were examined to determine material specifications, parts and nonproduction uses, was tedious and inexact. Existing data bases containing Engineering, Manufacturing and Purchasing information were found to be incomplete and not readily accessible. In the absence of one reliable system, the detailed steps in Figure 16 were under taken. For production materials, each PEO reviewed the material/usage list for completeness and established a list of parts and bulk materials of their design responsibility suspected of con taining the subject substances. These lists were returned to Engineering S ta ff. EicRS con solidated the lists (See Appendices) and provided them, along with the approved source and material identifications to Purchasing and Supply Staff for supplier contact to determine substance usage and to find out if there is a known substitute. Nonproduction materials were identified by similar methods, except for the PEO review. MATERIALS AND T O X IC O L O G Y SYSTEM (MATS) overcome the deficiencies of manual and semi-computerized search methods, the Materials bu.j Toxicology System (MATS), under development, will consolidate four systems: The CA T A LO G of Hazardous Materials (P<5cO Staff); the Engineering Material Approved Source List (E&R Staff); the Nonproduction Material Approved Source List (Mfg. Staff); the Environmental <5c Process Engineering Review System (Mfg. Staff). These Systems can be linked together with some manual effort to search for uses of suspect carcinogens in Company products as follows and diagrammed in Figure 17: 1. Materials containing suspect chemical compounds can be identified in the C A T A LO G . 2. Similar materials and the specifications to which they are approved can be found in the Approved Source Lists. 3. For Production materials, parts lists can be obtained from the engineering release system via the Engineering Material Specification. 4. With the parts list, Purchasing can determine quantity used and Manufacturing En gineering can determine processing methods. Other functions of MATS include Approved Source Lists for production and nonproduction, materials, Michigan DNR Critical Materials usage reporting, CA TA LO G of Hazardous Materials for plant doctors and Rouge Poison Control Center, UAW contract agreement to provide non confidential list of hazardous material usage and precautions for each plant. -8 - May 2, 1980 PROPERTY CF FORD POTOR COMPANY Asbestos -'Ll Cr Compounds-^ Benzene CARCINOGEN SEARCH RESULTS FIGURE 13 Production Materials/Parts A B 34 49 - - - - C Total 22 105 25 25 15 15 Nonproduction Materials/Parts Asbestos Cr Compounds4- / Benzene A B C Total 8 - - _ 8 98 81 34 213 3 - 5 8 A - Known substitute material available without major redesign. B = Known substitute material available with major redesign. C = NA= No known substitute. Advanced Engineering Project required. Not available 1/ Data are directional estimates only and refer to materials known to contain the particular carcinogen. " %! Primary source - Car Engineering. V Only certain hexavalent chromium compounds considered. 4/ All chromium and chromium compounds considered. - 9f - May 2,1980 DR A F CARCINOGEN SEARCH RESULTS From our examination of asbestos, chromium, benzene, a partial list of production and nonproduction material applications has been assembled. These were classified as: Known substitute material available for application without maior redesign; Known substitute material available for application with major redesign; - No known substitute. Advanced Engineering Project required; Even in group A, extensive product or manufacturing engineering effort is required to implement a substitute material. A new material specification may be required, experimental parts must be fabricated and tested to arrive at a successful application. Purchasing must then renegotiate contracts for production or nonproduction applications. Realistic timetables and budget provisions must be established by the responsible manufacturing and product engineering organizations. Broad block timing is proposed later in this paper for the three materials examined in detail. PROPERTY CF FORO MOTOR COMPANY -9 - May 2, 1980 DRAF i FIGURE 19 CARCINOGEN STRATEGIES - Continue OSHA Category I carcinogen control by design, process and exposure limits. Eliminate carcinogens where substitutes are known when required by regulation or business pressure, a/ - Proceed now to eliminate OSHA Category I carcinogens by Job #1, 1985. Where elimination cannot be contained, control the design, process and exposure, b/ - Wait for government rulemaking to eliminate or control OSHA Category I carcinogens. - PROPERTY of ford potor coppany a/Current Car Engineering practice for asbestos (Dec. 19, 1979).: Newly designed components should not contain asbestos. In documented cases precluding alternate materials, asbestos must be reduced to thelowest level and encapsulated or resin coated to avoid worker exposure to airborne fibers. b/Advanced funding would have to be provided where elimination cannot be contained in the 1985 timeframe. - lOf - May 2,1980 DRAFT CARCINOGEN STRATEGIES Three major strategic alternatives were considered for the elimination and control of carcinogenic substances. Twenty-six (26) OSHA Category I substances and Forty-one (41) substances that affect the auto industry and are proposed for regulation (MVMA analysis) provide the basis for these alternatives. NIOSH advised substance controls were deemed to be of lower priority. It was agreed by the Task Force and PEO chief engineers that the Company should proceed now to eliminate asbestos, selected chromium compounds and benzene by Job #1, 1985. Where elimination cannot be contained, design, process and exposure controls would continue for specific applications. Implementation of the recommended alternative can only proceed by specific effort on each of the unique applications identified to date. It is judged that elimination can be completed for applications where a substitute material is known and major redesign is not required. (Group A) Elimination for applications requiring major redesign (Group B) or advanced engineering (Group C) can be initiated now but cannot with confidence be expected to be fully implemented in the 1585 time frame. Implementation decisions will have to be made for each application in the context of the vehicle cycle plan, component redesign, plans facility renovation/replacement and the practicality of the substitute. PROPERTY OF FCRD PCTOP COMPANY - 10 - May 2,1980 DRAFT FIGURE 20 GENERALIZED WORKPLAN (for eacn Category i Carcinogen) Action Manage Program A / Propose list of known and suspectspecifications Verify proposed l i s t -ft/ Identify known and suspect partft/ numbers Request supplier verification of suspect specifications and parts Request supplier verification of substitution feasibility Sort into Class A (known substitute) Class B (major redesign), Class C (Advanced project) Implement Group A actions Implement Group B actions Implement Group C Actions Audit effectiveness Responsibility Production Nonoroduetion SSECO SSECO SSECO SSECO Block Timing Prod. (NonDrod Ongoing 1 Month (A) PEO's PEO's Mfg. Staff 1 (A) Mfg. Staff b/ 1 (A) NAAO/DPO Supply Staff 2 Purchasing _ NAAO/DPO - Supply Staff 3 Purchasing PEO's Mfg. Staff 6 (NAAO Pch.) (Supply Staff) Veh. Engrg. PEO's Veh. Mgr. PEO's Tech. Ping. PEO's SSECO Mfg. Staff Mfg. Staff Tech. Ping. Research Staff BMD SSECO 12 33 (TBD) 45 c/ Ongoing Ongoing PROPERTY CF FORD PCTOfi COMPANY a/ Will be output by MATS effective 2nd quarter 1981. b/ Powertrain program. c/ Complete for asbestos, chromium compounds and benzene. -Ilf- May 2,1980 DRAFT GENERALIZED WORKPLAN The foregoing strategies, even though having been tested only for asbestos, chromium compounds and benzene, are judged to be appropriate for other carcinogens with timing adjusted to adapt to the realities associated with elimination. The first three actions of the workplan have been completed for asbestos, chromium compounds, and benzene. The fourth and fifth actions have been initiated and are expected to be completed by the end of July (asbestos), August (chromium compounds) and September (benzene). Classifying the substances should be completed in the first quarter of 1981. Completing the actions by these dates requires -Corporate direction that the elimination/control of these substances is a mandatory priority effort. Without such direction, vehicle, component, plant renovation and new construction programs will continue with insufficient emphasis on the elimination/control of carcinogens. essential to this effort. Overall program management is PROPERTY OF FCRD POTOfl COMPANY - 11 - May 2, 1980 DRAFT FIGURE MEMBERSHIP HAZARDOUS SUBSTANCES CONTROL COMMITTEE Chairman - Director Environmental Control O ffice Environmental and Safety Engineering Purchasing and Supply Staff Personnel and Organization Staff Scientific Research Staff Manufacturing Staff Car Engineering Body and Assembly Operations Ford Parts and Service Division Ford Tractor Operations Powertrain and Chassis Operations Basic Products Operations Electrical and Electronics Division Climate Control Division Truck Operations European Automotive Operations O ffice of the General Counsel Staff FIGURE 22 CHEMICAL SUBSTANCE CONTROL MANAGER PROPERTY CF FCRO PCTOR COPPANY - 12f - May 2, 1980 DRAFT PROPOSED CHEMICAL SUBSTANCES CONTROL Personnel and Organization Staff has completed an analysis of the requirements for chemical substances control. It was concluded that designation of a Program Manager would be the least costly and disruptive means for improving coordination among involved activities and would help to surface crucial issued. The Program Manager would have a small staff to assist in collection of data, preparation of reports, bulletins, liaison and other assigned functions (computer systems). Organizationally, an E&SES location was recommended. In view of budget constraints, it has been agreed that *he existing Commpliance and Liaison Department would perform the Program Manager function. The Manager should be responsible for implementing carcinogen control strategies coordinating Company response to potential and promul gated toxic substance regulation. Initial assignments include revising Directive B-101 to clarify responsibilities, assuring that Operating Compon ents and Staffs issue facing documents to B-r01, establishing a financial measurement of the compliance effort, and assuming development direction and control for the computer information system and implementing the workplan as directed. The ongoing responsibilities of the Chem ical Substances Control Manager will be to coordinate the product/facility/manufacturing response of the Company to changing regulations. This will include governmental agency comments to proposed regulation, forecasting/regulatory impact, direction and control of the information systems required, and compliance assurance. It is recommended that the Carcinogen in the Workplace Task Force be discontinued and that the Engineering and Researcn ana the Manufacturing and Supply Subcommittees name as a joint working group a Hazardous Substances Control Committee. This Committee should be composed of responsible executives from the areas shown on the facing page. It is further recommended that the Committee be chaired by the E&SES repre sentative. Presently assigned responsibilities of Staffs and Operations should remain essentially unchanged, except where supplemented or clarified to overcome present inadequacies. PROPERTY CF FORD KOTOR COMPANY - 12 - May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS FIGURE 23 1. Hazardous Substances Control Committee 2. Program Manager 3. Direct elimination of Asbestos, Chromium Compounds, Benzene 4. Request Operations Workplans 5. Adopt the priority carcinogen listing 6. Request the establishment of overall elimination timetables. PROPERTY CF FORD KOTOR COKPANY - 13f - May 2, 1980 DRAFT PROPOSED PRIORITY ACTIONS Achievement of the recommended strategy to proceed now to eliminate OSHA Category I carcinogens Dy Job #1, 1985, with control of design, process and exposure where elimination cannot be contained, requires an integrated approach throughout the Company and a sustained et hffflotrt over a number of years. The Task Force on Carcinogens in the Workplace recommends 1. Establish a Hazardous Substances Control Committee chaired by the Director Environmental Control O ffice. The Task Force would be discontinued. 2. Assign Carcinogen Program Manager control responsibilities to the Compliance and Liaison Department, Environmental and Safety Engineering S ta ff. 3. Request Environmental and Safety Staff to establish carcinogen elimination timetables for the 67 known carcinogens for review and approval by this Subcommittee. 4. Request that NAAO/DPO Product Engineering O ffices and Manufacturing Staff present to the Subcommittee specific action plans and timing for the Group A applications identified. 5. Adopt as the Company carcinogen listing, current OSHA regulated Category 1 sub stances (26) and proposed for regulation substances (41). Establish the top eight prior ities proposed by the Task Force as Company priorities. 6. Direct all affected organizations to proceed with the elimination of Group A asbestos chromium compounds and benzene by Job #1, 1985, as outlined in the workplan. ' PROPER T V CF FORO MOTOR COMPANY - 13 - May 2,1980 P ROP E RT Y OF FCRO P C TOR COP. PA NY DRAFT EXHIBIT I OSHA CATEGORY I CARCINOGENS Regulated Acrylonitrile Amosite Anthophylite Arsenic Asbestos Benz (e) acephenanthryiene Benz (a) anthracene Benz (a) anthracene, 7, 12-Dimethyl- Benz (a) anthracene, 7-Methyl- Benz (a) anthracene, 7, 8, 12-Trimethyl- Benzene ' Benzidine Benzo (rst) pentaphene Benzo (c) phenanthrene, 5-Methyl Benzo (a) pyrene Chrysotile Crocidolite Dibenz (a, h) acridine Oibenz (a, j) acridine Jibenz (a, h) anthracene Dibenzo (b, def) chrysene Dimethylamine, N-Nitroso- 1- Naphthylamine 2-Naphthylamine Serpentine Vinyl Chloride Proposed for Regulation Acetamide Acetic acid, Lead (2+) Salt Benzidine Sulfate Beryllium Beryllium oxide Beryllium sulfate (1:1) Cadmium Cadmium oxide Cadmium sulfate (1:1) Carbon tetrachloride Chloroform Chromic Acid, Calcium salt (1:1) Chromic Acid, Calcium salt (1:1), dihydrate Chromic Acid, Chromium (3+) salt (3:2) Chromic Acid, Dipotassium salt Chromic Acid, Disodium salt Chromic Acid, Lead (2+) salt (1:1) Chromite Chromium Chromium (HI) oxide (2:3) Chromium (VI) oxide (1:3) Dichromic Acid, Disodium salt Diethylamine, N-Nitrosop-Dioxane Ethane, 1, 2-Dibromo- Ethane, 1, 1, l-Trichloro-2, 2-bis (p-chlorophenyl) Ethylene, chloro-, monomer Ethylene, TrichloroHematite Hydrazine Sulfate Lead Chromate (VI) oxide Lead naphthenate Nickel Nickel (n) oxide Polychlorinated biphenyls (Kanechlor 500) Polyethylene glycol monostearate Sulfuric acid, Dimethyl ester Tannic Acid Tannin o-Toluidine Urea, Thio- May 2, 1980 DRAFT CARCINOGEN SEARCH Materials and Toxicology Svstem (MATS) .Ahini ~ II PROPERTY CF FORD MOTOR COMPANY To overcome the deficiencies of manual and semi-computerized search methods, the Materials and Toxicology System (MATS), under development, will consolidate four materials approval systems into one common data base. The four systems are: the CATALO G of Hazardous Materials (PdcO Staff) containing materials, their toxicological evaluation lor worker/consumer protection and the chemical composition, the Engineering Material Approved Source List (E<5cRS) containing the material specification title ana the materials approved to that specification; the Nonproduction Material Approved Source List (Manufacturing Staff) containing the nonproduction material standard and the approved materials; and the Environmental & Process Review Svstem (Manufacturing Staff) containing the waste disposal, treatability, and facility engineering cautions on all materials approved to Engineering Specifications and Manufacturing Standards. Carcinogen Search Strategy Developing the links between the above systems will, in the future, provide a method for locat ing suspect carcinogens in nonproduction materials and production parts and bulk materials. The search methodology is numbered on the facing page to correspond to the following search steps: 1. The Chemical Abstracts Service numbers of the suspect carcinogens and its compounds are identified by IHdcT. The system will then generate a list of materials which contain that chemical. - 2. Utilizing the NAAO supplier code, the specification number and the product name, the system will then identify other suspect materials and specifications. 3. The Engineering Specification can then be passed to the North American Engineering Product Information System (NAEPIS) which contains the engineering notices from all of the product engineering offices. The NAEPIS system will then produce a cross reference list of all parts which use that m aterial. 4. The list of production parts can then be matched to Purchasing's Procurement system to determine current sources to be queried for control and elimination of carcinogens. The same list can be matched to the AAD Process Sheet system to determine where and how the part or material is handled in A A D . Functions The primary function of MATS is to maintain and produce the Approved Source List for non production and production materials including the toxicology and environmental clearances for use by Purchasing. The system also produces the C A T A L O G of Hazardous Materials as either a full companywide print or as a plant specific print. The C A T A LO G is used by health and safety and plant doctors, and is required to be furnished to the UAW under the current contract. The system is also available to the plants and the Poison Control Center at the Rouge to be searched by supplier or specification for complete medical, handling, shipping, waste treatment and disposal instructions on a material. The system also produces the Michigan DNR C ritical Materials report for the consumption of materials which contain a Michigan defined "critical component" e.g ., chromium. *ffected Activities Corporate Staffs concerned with materials/toxicological/environment controls are currently involved in using/developing the system. All NAAO/DPO plants are planned to have access to the system by third quarter 1980. All NAAO/DPO Engineering activities v e also participating Squired6byXp 1^3 189^ ^ hassis wtlic^ currently does not participate in material control as May 2, 1980 - 2- EXECUTIVE SUMMARY lontinueai Strategy nd Wortolan The search for asbestos. chromium compounds end benzene defined the number of perts end m eterais co n tain in g these substances as listed in the tab le b elow . Where possible the pplicitions were divided into three groups: A - Known substitute material without mator redesign. B - Known substitute material with major redesign and C - No knownl bstitute or advanced engineering required. The dau it mreetionai only. There remain many susocct applications which require time-consuming analyses for identification. ^ Bulk Materials and Parts Production X - - Total Nonoroduetion J -- T -----_Z Total Asbestos Chromium Compounds Benzene 34 49 22 103 - 23 23 IS IS 1 - I 91 ti 34 213 3 3 S Strategies have been formulated to eliminate or eontrol these substances. The i . . . V . 1 . ; v cumuiaie u n c uira carcinogens by Job #1. Ills , in light of competitive and regulatory pressures, and Company experience Where elimination cannot be contained, institute controls on design, process and exposure It is Judged that the elimination timetable is practical for Group A asbestos, chromium compounds and benzene-containing parts and materials. For those applications requiring major redesign (Group B. e.g., drum brake linings) the elimination timetable would have to be adjusted to reflect Company cycle plans althougn G.M. has stated an intent to eliminate asbestos by 19SS. Finally, where no known substitute exists (Group C), advanced engineering will have to be completed before t elimination timetable can be established. * * A generalized workplan has been prepared on the basis of the evaluation of the carcinogens already referred to. The workplan requires central program management, with action imple mentation by NAAO/DPO Product Engineering Offices, Purchasing activities. Vehicle acti vities and the Manufacturing and Supply Staffs. It is Judged that approximately a year is required to complete the sorting of the three carcinogens into the known substitute meior redesign and advanced project groups. It is Judged that one additional year w^uid be required to implement the most feasible product actions not requiring major redesign grams!Utl n reqU'rin* would u "* 33 months for vehicle or major powertrain p! Recommandations Achievement of the recommended strategy requires en integrated approach throughout Company and a sustained effort over a number of years. The Task Foree reeommenos: 1. Establish a Hazardous Substance Control Committee chaired by Environmental and Safety Engineering Staff. The Task Force would be discontinued. 2. Engineering'sufi" Pr0fT,m m,nt*er eonU'01 re^onUbility to Environmental and Safety ? r .ir . , EnJ ^ nmenUl Ut t Xy Suif t0 * *" *> carcinogen elimination timetables ^ ^ r c in o g tn s for review and approval by the subcommittees. (The Task Um StabuLr^ Chief Engineer to recommand directional 4. Dlreet all affected organizations to proceed with the elimination of Grata: A ehromhim compounds and benzene for Job I I , i n s . ' Request that NAAO Pro&ict Engineering Offices and Manufacture Staff present to t^wbeommitte. ^ c ific action pi and timing for t * ^ a ap35o prop" funding to develop designs and/or materials for new parts to identify reliability, cost and weight implications of alternative designs (Group C). 7. " the Company carcinogen listing the 67 current OSHA-regulated and proposed Company priorities6" ' E*Ubh*h th* top " * ht Pfl0fltiM proposed by the Task Pore as Engineering SUff - EARS Manufacturing Staff May 2.1910 PROPERTY CF FCRD P.CTOR COMPANY EXECVTT.'E SUMMARv CA R C IN O G EN S IN THE W ORKPLACE Introduction The Task Force on Carcinogens in the Workplace was established by the Engineering and Researcn and Manufacturing and Supply Subcommittees to identify carcinogens and quan tities in use. set targets for elimination ahetd of regulation, take nape to find institutes, develop a directive and workplan and organize to identify substances systematically. The Task Force assignment responded to evidence that cancer may be a serious occupational concern and to the Company* and public concern with regard to protection of the environ ment and public health. Additionally, the Company has been subjected to a growing number of laws which regulate material use. transport, handling and disposal. In summary, internal and external pressures regarding hazardous substance control and compliance have increased substantially since March, 1977, when Directive B-101 assigned responsibilities within the Company. Past Company Actions Since 1977, the Company has removed lead chromates and molybdates from paint (exeept special order). "Tris" flame retardant from fabrics and Instituted controls on asbestos, ineluding a Vehicle Engineering directive that newly designed components should not contain asbestos (documented exceptions must be encapsulated or resin coated). Sprayed-on fireproofing has been asbestos-free sinee 1969 for new and reworked construc tion. Several manufacturing standards prohibit asbestos as a constituent. Benzene exposure has been reduced or eliminated at San Jose and Central Laboratories since 1978. Ventilation was increased at Romeo to minimize hazards from paint-related chromium compounds. Carcinogenic Substances The Task Force has identified sixty-seven (67) carcinogens in toe in the automotive industry. Twenty-six (26) of those are currently regulated byOSHA; the balance have been proposed for new regulation. More restrictive standards have been proposed for some of those sub stances currently regulated. Thirty-one (31) substances are reported to the Michigan Department of Natural Resources for computation of water surveillance fees. Michigan plants used 1.3 million pounds of the twelve (12) carcinogens on the MDNR list. The largest use was 641 thousand pounds of acrylonitrile at the PPV Paint Plant. Similar data is not cur rently required to be reported in the other sutes. The list of carcinogens was prioritized by the Task Force according to impact on the Company to identify the top eight (6). The top three of the eight priority substances, asbestos, chromium compounds and benzene, were examined in detail. - Asbestos is used by the Company primarily in vehicle brakes, clutches, gaskets and for nonproduetion roofing, millboard and core/mold-making materials. Medical evidence links inhalation of asbestos dust to lung cancer, mesothelioma and other diseases. The present OSHA limit is 2 fibers per cc of air (2 million fibers per cubic meter) which is proposed to be reduced to 0.1 f/ec as early as this year. Chromium compounds arc used primarily in paints and inks for production and nonproduction use. Medical evidence links hexavalent ehromium compounds to lung cancer, liver and kidney damage and other diseases. The peasant OSHA limit is 52 mg per m of air whieh is proposed to be reduced to 1 mg/m . - Benzene occurs primarily in coke oven operations as a by-product. It is a residual constituent of solvents, primers, adhesives, lubricating oils, fuels and hydraulic fluids. Medical evidence links Inhalation and contact with benzene to leukemia, blood disorders and other diseases. OSHA has proposed a limit of 1 ppm in air time weighted average in hours. Specific lists of bulk materials and parts for production and nonproduction ias have been developed. A new computer data base is being developed. Materials and Toxicology System (MATS), whieh links health, engineering, end manufacturing data frattf to facilitate rapid identification of carcinogen applications (2nd quarter 1911). The engineering release system has been audited and is being updated to extend materials identification to all parts. Product Engineering Proceoure PEP 3-189 has been rewritten to require systematic review of suspect carcinogens and input to the data base. p r o p e r t y OF FORO KCT0R C O F F E Y PRODUCTION MATERIALS CONTAINING ASBESTOS appen dix I DRAFT 5/2/80 Group A -- Known Substitute Material Available Without Major Redesign Specification Material Basic Part N o . ___________ Part Light Truck ESF-M8G55-A ESW-M8G109-B -- -- -- Bodv ESB-M2G58-C ESB-M2G171-AB ESB-M2G188-A ESB-M3G95 ESB-M4G1-B ' T-M4G31-A r-- M4G32-A ESB-M4G40-A ESB-M4G58-B ESB-M4G101-A ESB-M4G108-A ESB-M4G109-A ESB-M4G110-A ESB-M4G126-A ESB-M4G137-A/B ESB-M4G139-B ESB-M4G141-A ESB-M4G145-A/C ESB-M4G147-B ESB-M4G161-A/C ESB-M4G162-A ESB-M4G172-A " '-M4G174-A u . 44G175-A ESB-M4G177-A/B Gasket Gasket Deadener Sealers -- Adhesive Adhesive Adhesive Tape Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Sealer Scaler Sealer Sealer Sealer Sealer Sealer Sealer Sealer 7086 4035 350038 350038 9900000 -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- -- Trans. Ext. Gasket Carrier Gasket Econ. PDV Box Assy. Econ. PDV Box Assy. Courier Box Assy. Primer for Adhesive * -- -- - - m^ _ _ PROPERTY CF FCRD * CTOfi COPPANY 'ecification L. -M4G188-A ESB-M4G197-A ESB-M4G198-C ESB-M5G8-A/C ESB-M5G22-A ESB-M5G25-A ESB-M7C53-A Trans ESE-M8G62-A ESW-M8G109-B ESW-M2D166-A ESF-M8G55-A -- Ford Division '-M4G32-A hi. M4G32-B ESR-M18P2-A ESR-M99P4-B EED ESF-M3D76-A Material Sealer Sealer Sealer Deadener Deadener Deadener Rust Prevent Gasket Gasket Seal Gasket -- Sealer Sealer Sealer Coating Phenolic ESF-M3D113-A ESA-M4D140-A ESF-M8G55-A ESF-M8G96-A ESW-M8G109-A ESF-M8G126-A CCD * -M8G55-A Chassis ESB-M4G109-A Phenolic Polypropylene Gasket Gasket Gasket Gasket Gasket Gasket Sealer - 2 - Basic Part No. -- -- -- -- -- -- -- 7D026 7A136 4035 7052 7A247 15520 9004650 19560 19560 19554 19515 18B374 8K621 17B616 18B374 11015 13711 10914 12A696 12A676 17C430 14A427 13817 19D970 2A792 Part MB -- a ppen d ix : 5/2/80 -- _ -- Sprayable Wax Type Rust Preventative Trans. Int. Band Servo Gasket Trans. Front Pump Gasket Rear Axle Housing to Pan Gasket Trans. Extension Oil Seal Trans. Gear Shift Neutral Switch Assy. Trans. Back-Up Lamp Switch Assy. Cigar Lighter Spacer Caulking Cord Rope Sealer Perfect Seal Undercoating ' A/C Motor Commutator Cooling Fan Motor Comm. W/S Washer Motor Comm. W/S Wiper Motor Comm. Starter Commutator I/C Lamp Socket Water Temp. Sender Gasket EEC Seal Air Temp. Sender Gasket W/S Wiper Gasket Window* Reg. Yoke Gasket Horn Gasket PROPERTY CF FORO POTOR COMPANY -o * - ^ n^ O * > i A/C Comp. Gasket P/B Cable Opening Cover . - . - 3" NONPRODUCTION MATERIALS CONTAINING ASBESTOS APPENDIX I DRAFT 5/2/80 Group A -- Known Substitute Material Available Without Major Redesign Specification M-10G11 M-10G12 M-10G15 M-10G16 M-99G59A M-99G82A M-99G84A Material Asphalt Saturated Asbestos Roofing Felts - 15 lb. Asphalt Saturated Asbestos Roofing Felts - 30 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 20 lb. Asphalt Saturated and Coated Asbestos Roofing Felts - 50 lb. Asbestos Powder Hard Asbestos Millboard Asbestos Filament Reinforced Paper PROPERTY CF FCRD POTOR COMPANY APPENDIX I draft 5/2/80 PRODUCTION MATERIALS CONTAINING ASBESTOS Group B - Known Substitute Material Available With Major Redesign Specification Light Truck ESE-M8G106-B ESE-M8G140-A Trans ESW-M3D117-A ESW-M3D97-A Vendor Vendor Vendor Vendor Vendor Vendor 'or Vendor Vendor Vendor Vendor Chassis ESB-M8G106-A ESA-M8G140-A * Material Gasket Gasket Phenolic Phenolic -- -- -- -- -- -- -- -- -- -- -- Gasket Gasket -- Basi Part 1 SB266 5B266 7934 7937 7F314 7D034 7D095 7F196 7E311 7E313 7F219 7E312 7F239 7E312 7B614 5B266 5B266 2022 2021 Part Res. Inlet Pipe Gasket Res. Inlet Pipe Gasket Conv. Reactor Conv. Reactor Thrust Washer Conv. Damper Reactor Hub Assy. Trans. Int. Band Assy. Trans. Reverse Band Assy. Trans. Overdrive Band Assy. Trans. Clutch Forward Plate Assy. -Trans. Direct Clutch Plate Assy. Trans. Int. Clutch Plate Assy. Trans. Rev. Clutch Plate Assy. Trans. Oil Clutch Plate Assy. Trans. Int. Spline - Rev. Plate Assy. Trans. Clutch Plate Assy. Resonator Gasket Assy. Tesonator Gasket Assy. Front Disc Brakes PROPERTY CF FCRD PCTOR COMPANY - 5PRODUCTION MATERIALS CONTAINING ASBESTOS draft 5/2/80 up C No Known Substitute. Advanced Engineering Project Required. Specification Light Truck ES-C8AA-2B282-A ES-D20A-2B072-BB ES-C8AA-2B282-A ES-D20A-2B072-BB Vendor Print Vendor Print ES-EOTA-2B120-AA ES-D6TA-2B118-AA ES-C8TA-2B282-A ES-C8TA-2210-D ES-C8TA-2010-C ES-D8TA-7550-A Material - -- -- -- - -- - Trans Vendor Vendor Vendor Heaw Truck Basic Part No. 2021 2022 2019 2018 2018 2022 2209 2284/5 7550 4797 4A325 2598 4797 4A435 7550 Part Lining Front Wheel Brake Outer Lining Front Wheel Brake Inner Shoe and Lining Inner Shoe and Lining Outer Shoe and Lining Outer Lining Front Wheel Brake Inner RR Brake Shoe Lining RR Brake Shoe Lining Driven Member Clutch /Clutch Plate * Clutch Plate Parking Brake Lining Rear Axle D iff. Clutch Plate Assy Rear Axle D iff. Clutch Plate Assy, Man. Trans. Clutch Disc Assy. 2010/11 2209/10 2598 2010/11 2010/11 2209/10 2875 8A616 8A627 5230 7A596 7550 7E434 Hydraulic Brakes - Front Hydraulic Brakes - Rear Parking Brake Air Brake Assy. - Front (Wedge) Air Brake Assy. - Front (S-Cam) Air Brake Assy. - Rear (S-Cam) Air Brake Compressor Fan Clutch Assy. Clutch and Bracket Assy. Muffler Assy. Clutch Disc Assy. Torque Limiting Brake Assy. PROPERTY CF FORD PCTOR C0PPANY ESE-M8G149-A Gasket - 6- 5F263 2284 2285 DR A F 5/2/80 Exhaust Manifold Gasket Rear Brake Shoes PROPERTY CF FCRD kCTOR COFPANY draft TASK FORCE CHARTER ' coordinating plans anaertoTu" :*^ 6411 ^ M* S Suftcomm,tt*** (Meeting of 10/24/79) for 1. Identify substances in u m {OSHA Categories 1and II). 2. Determine quantities used (for materials peculated bv n. Resources). r**uiaiec oy Michigan Department of Natural 3. Set tarfets for elimination of as many Category I substances as passible 4. Take aggressive steps to find substitutes for as many Cataeorv i anticipation of government refutations. y **ory 1 " Ateneas as possible in 5. !*" " p . m e ,, < m u . m Ut M u * 6. Orftntze to identify substances systematically. um um u mm ' FIGURE S P R C P t R T V OF F0RD MOTOR COPPANV Acrylic Acid Lbe. of Ui 251,707 Acrylonitrile Aniline Antimony 41.133 0 30.571 Arsenic 11.157 Asbestos (not reported as a material preM Benzene Cadmium Chromium 315.02 3,311 1,377 Cloroprene Cobalt Copper Cyanides 24,676 210 321,704 23,069 Dichlorobenzenes Formaldehyde Hydrazene HytAoquinone 2.542 461,965 130 1 Hypochlorite Leed Lithium Nickel Phenol Selenium Silver SHIcon-Dioxide Coated Lead Chromate 15.941.75 26,027 123 126,624 5,639 127 25 2.317 Styrene Tetraeioroethylene Thiourea 1.413,996 1,095 1| TOaryl Phosphate Esters Trichloroethylene Vinyl Chloride Zinc 160,022 01.049 HI 1.065.724 Detroit Industrial Engine Research A Engineering Center Research - Glendale Troy - Tractor - Jf - FFV - Paint FFV - Paint MCC. Dbn. Glass. TAC Starling PPV - Vinyl TAC Vandyke, PPV - Vinyl irtieles only) AAD - Dearborn Assy.. Gen. Service PPV - Vinyl PPV - Paint. EED - Ypei. AAD - Utica PPV -Saline AAD - Dearborn. PPV - Saline. MSD - Monroe MSD - Monroe FTO - Highland Park MCC, PPV Paint PPV PPV - Vinyl MSD - Monroe AAD - Wayne/Dearnorn. PPV - Paint ED - Northville. TAC Sterling MSD - Monroe, TAC Sterling Mich. ; at. Cntr. TAC Sterling TAC Sterling PPV PPV - Milan, ppv - vinyl AADGO. Mich. Prov. Omtf. . PPV - Vinyl Steel, TAC Sterling RE * Rawsonville PPV - Vinyl PPV-Paint, AAD.FPSD.PTO Vulcan Forge Dearborn Glass Dearborn Specialty Foun*y hisonAiMmbly . May 2.1910