Document vXv03akgqVDrnazB9Kr2E139

FILE NAME: Allied Signal Bendix (ASB) DATE: 1975 Oct 24 DOC#: ASB010 DOCUMENT DESCRIPTION: Meeting Minutes - Asbestos Study Committee crio: HERIAIS STAca:o institute E-2I0 route (., ?A.v:r::, s . . eres: '~r nv T!!E <~ZZZ'.'C of the ASBESTOS STUDY COITIITTEE Friday, October 24, 19 75,. at 9:30 All Institute Office, E-210 Route 4, Paranus, N.J. PLAINTIFF'S EXHIBIT H. Varner, Chairman Z . S. Feicrabond D. E. Stone I. H. Veaver j . Tunderdale OTHERS PRESEVI Carlisle Corporation Abex Corporation Eendix Corporation Raybestos-Vanhattan, Royal Industries Inc. IIV ?.. Cole E. V. Drislane Vr.3E?.S TOT PRES Clapp L Eisenberg *. Friction Materials Standards Trmitute M. Jacko E. P. Scefl Bendix Corporation H. K. Porter Co. The r.eeting vas called to order by llr. Wagner, Chairaan, at 9:30 A.X. mimutes of previous meztiug The Minutes of the Meeting held April 28, 1975 had been distributed. cinutcs were reviewed and a notion for their acceptance was nade. These Upon notion duly made, seconded and unaninously passed, it was ' RESOLVED: To accept the ninutes of the April 28, 1975 aeeting as written. - AS3ESTOS ISFORMATI01! ASSOCIATION CCUFET.ZUCE The Asbestos Information Association (AIA) held their annual Government- Industry Conference in Washington on September 10-11, 1975. Hon-menbers of ALA were invited to attend this conference. Several individuals representing friction caterials attended. . One of Che itens of interest was the proposed OSHA regulation which whs due near the end of September. It had been indicated that the OSHA standards would be oriented more cowards work practices than to a numerical standard, Hr. Weaver indicated that the OSHA individual who indicated this did so believing that the new standard would not have a net; numerical Unit. Apparently there was slot of movement within OSHA by ocher groups-- possibly labor unions and 1II0SH-- and that the proposed lower nunerical standard came in at the verv end of the write-uo as it was inutes o che Meeting Asbestos Study Committee -2- Octcber 2, 1575 prepared for publicacin. The standard, which .ill be discussed la:ec, proposed a tur.erical standard o 3.5 fibers/cc (TVA). Several attendees stated that this conference vac nest worthwhile. It gave a good overview on asbestos. P.ie only 'criticise! r.ade was* that the speakers did not have sufficient tine to be questioned after their presenta tions. The Institute will continue to monitor this conference' and expresses its support of the work of the ALA. peaks for ikstitvti similar ok asbestos %.lz . Keener and Mr. Drislane had taken the initial steps to organize this seminar. At the April 28, 1975 meeting of the Asbestos Study Co-- ittee a resolution was passed recommending that the Institute sponsor a workshop on the asbestos problem in the fall of 1975. This resolution was reviewed with the President of the Institute, Mr. Simon, and it was decided to proceed with such a seminar. Mr. Vagner contacted Mr. 'Joel Hendry of Johns-Manvilie relative to his putting on a session similar to that which J-M presented two years ago. (For reference: ilr. Koel Hendry, Denver, Colorado, telephone 303-770-1000, Extension 2142). It -was suggested that the Johns-Manville presentation would have to be * the corner-stone of any seminar and that this would have to be arranged^" first before arranging other presentations. Mr. 3. K. KTron of OSHA had been invited by Mr. Wagner to address this seminar. Mr. Xvon had indicated that he should be able to attend. It was suggested that the seminar would be a good time for a synopsis of the major points of the new OSHA standard. Also it would be well for Mr. Kvon to talk with people from our industry. A comment was made to the effect that OSHA had misled those attending the conference in Washington indicating that the proposed standard would be work practices oriented. (The standard cane out' with a lower numerical limit.) It was stated that Mr. Kwon was knowledgeable in the incint,xiJ hygiene area out he was not a policy maker, lie was not responsible for the addition of numerical standard in the proposed amendments to the OSHA regulations. - Mr. Drislane `indicated that he had talked with Mr. Bob Mereness of the Asbestos Information Association, and Mr. Mereness indicated that he would be pleased to attend. Also fir. Drislane contacted Mr. R. Magdelain of Hilfisk of America Inc. Mr. Magdelain would be most pleased to put on a presentation relative to that type of vacuum cleaner for the work . place. Mr. Kagner also talked tilth Mr. W. Engeleightener of Ferro-Tech - relative to their pelletizing equipment. Mr. Engeleightener will also . make a presentation. At the meeting fir. Kagner called Mr.. Uoel H^pdry to firm up Che J-M participation. In summary, it was indicated that Mr. Bill Riitze would discuss the medical aspects of the regulations. Mr. Ed Fenner would review OSHA and EPa regulations. Mr. Hoel Hendry would discuss fiber handling. The J-M presentation will require-a 35 tan projector, a 60 x 60 screen, along with * podium and a PA system. Mr. Drislane indicated that arrangements for these would be made. Asb es ccs Ccudy Cam 4 tee -3- Occeber 1U , 1975 The seminar will be sc:;-.fule i fcr '.'ecr.csday, December 3, and Thursday, December t>. The opening sjm.sien will be a presentation by Johns-Manvilie for the full afternoon on December 3. Other topics will be scheduled on Thursday rorsinj., rich !tr. Kcissess (or sor.cone else iron AlA) talking at the luncheon on_Thursday. There would be a registration fee of $19 for the seminar. Mr. Drislane will try to make arrangements at either the Jlarriott at Saddle Brook, the Damada Inn in F.ochelle Park, or the Sheraton Heights in Hasbrouck Heights. Mr. Drislane will write Mr. Magdelain and Mr. Mereness to officially invite then. Mr. Vlagner will write to Mr. Kv:or., Mr. Enceleighcer.er, and Mr. Hendry to firm up the arrangements. The committee recommends that. Messrs. Uagr.er and Drislane plan and schedule the seminar. It was suggested that the type of person to be invited should be someone involved with plant problems, but it should also be the foreman or other individual who could get across the message to not use an air hose or a broom. The possibility of a movie being shovr. was discussed. It was suggested that the controversial interview of Dr. Selikoff and Dr. Lewir.sohn of Turner Srcthers would not be the right presentation. Perhaps a movie that emphasized controls in the work place might be worthwhile. Mo decision was cade as regards a movie. ^mother suggestion was to have a presentation by those who have used foam to'envelope the work station so that no dust is raised during mixing. <, Mr. reaver felt that this was an interesting technique. !!r. Stone had discussed this at ar. earlier meeting but had made no further progress on this since that time. It ves decided that this would sot be added to the agenda. As regards the Hilfisk equipment, it was noted that this is good equipment for local pick-up of cust and debris in the work place. However, this subject should be expanded to include a central system such as a Hoffman unit. . It was fait that this session should be called "housekeeping in the work place" rather than "Wilfisk". However, the '.iilfisk representative would discuss his unique equipment. The idea was to sell the concept of cleaning the work area (not to sell the vacuuc cleaner). Mr." Drislane will indicate this oarticular point to Mr. Tlagdelain in his- invitation. AlA SCT.-HT "AS3ESTCS AZTD SHAKE LIKINGS' Mr. Mereness reoaested Mr. Drislane to have this booklet reviewed for update and corrections. The first question raised was "Who Is this booklet aimed at ? :. Also, "yhat is the purpose of this booklet?" It was stated that this write-up was not a complete presentation of any particular aspect of the asbestos problem, and while interesting insofar as it vent, was not particularly convincing. It is not the type of message that would ordinarily be given to . customers of friction material manufacturers. The nessage for re-builders nd the garage people is to not create dust in the work place. There should be more emphasis, if this was the direction of the booklet, on such things as labelling, possible use of instruction sheets, the handling'of lining, and the proper use of exhaust systems. One of the problems ln*the field is that these customers will often groove, chamfer or provide extra drilling. It is during these subsequent operations that asbestos concentrations may be raised to levels above chat allowable. It was pointed out the Asbestos Study Committee could not re-write a draft unless it knew what the booklet was aiming at. It was stated that the title is wrong. Perhaps there should Jr.uts of che Leering Asbestos Scudy Cnmircee -4- October 24, 1575 be two eoperate ^stiphlets, one for the garage end the rs-buiider type operation (for these who are doir.3 brake service), and another for the gar.aral public." It was stated that the audience for this booklet, as written, r.ust have beer, the eavironr.er.tally concerned customer. . Mr. "eaver suggested alternatives as regards this write-up: (1)1 Drop it-- do not use it. (2) Rewrite it for those servicing and installing friction materials. (3) Mrite a cor.plete new article. The write-up r.ade has little inpact. One advantage nay be the listing of reference naterial at the end of the booklet. If the AIA believes that the booklet should gat to the user (the cuctomer of the friction n3terials manufacturer) it is suggested that information be given to the user as indicated in the proposed regulations under ''DAMC-ER" labels. This concerns the requirement during :'any reasonably forseeable use', handling, storage, disposal, processing, or transportation'' that no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed be released. The items that folia..* this section cn housekeeping and waste disposal are particularly pertinent to the users of friction materials prior to installa tion on a vehicle. Mr. Drislsne was advised that the Asbestos Study Committee will not re-writ# the article. The Comittee recommends emphasis on recommendations for + garages and the re-builders. The Committee vould be happy to review a r.sv write-up prepared by AIA which was aimed for this user, with emphasis on the these who actually do subsequent work on friction materials such as grooving, cutting, grinding, chamfering, etc. . RZC^rZMDID PP.DCTDbT.D FOR 3RAMI AIM) CLITCH SIRVICIMG This write-up had been preparedJy..the Raybestcs-?Ianha:tan, Inc. hr. Meaver distributed copies to Committee members. Raybestos would welcome comments on this write-up along with any recomandations for changes. Ccmnicree members wishing to comment should send their recommendations to the Institute office. THI OSHA STANDARD AI7D THE 0.5 TI3ER/CC LIMIT Prior to discussing detail on the proposed OSEA standards, several members stated that they had been inspected by OSHA. tJhile in a few cases citations were cade for higher concentrations of asbestos than permitted, there had been many instances where counts were made without a citation. While the values on the concentration are revealed when a citation is cade, OSHA does not provide information on the counts when a citation is not Issued. Several members indicated that they believed that OSUA will not provide written results on their test in the work place unless it is necessary to support a citation. In other words, where a citation is not involved they will not reveal the data. Legal Counsel will check on the availability of this information and whether OSHA can be requested to provide* this data when a citation is not involved, and will report in writing to the Institute or. thl3 . 7he proposed OSHA standard is far reaching. The main problem is ehe new more difficult numerical standard (0.5 fiber/ce). OSHA has put out a list of rather specific items for public participation with the main item beine that the comments must be postmarked on or before December 8. I07*- Minutes of the "eecing .Asbestos Study Cor.rd.ttee -6- Occober 26, 1975 any work that tjiey night do which could bring their concentration above 0.5 fiber/cc would now be a problem. These people would now be covered by the requirements of the QSHA standard. Many smaller operators have to drill materials to adapt them to unique shoes in the field. Additional drilling would probably ctove concentration levels well above the;maxinun ceiling concentration of 5 fiber/cc. A point to be mentioned Is not to adopt the tactic of "You can't do it." The point is that at the present tine technology is not available in the factory to get down to these levels. The industry does not know what the costs are. How can comments be made on cost inpact, ccr.peticior., employment, energy, etc. when the technology to get there is not known? Still further, is such a limit necessary? It is suggested that unless a member has specific nedical information suitable to refute the proposals in the standard that he not attempt to resist the 0.5 fiber/cc limit based on non professional observations of workers made in the past. In other words, if it was not good nedical information don't use it. The Asbestos Information Association will try co assemble some realistic medical information for consideration by the Department of Labor. . * As regards the problem with cost impact on the consumers, it may be that clean rooms for the elimination of asbestos nay be required. Without knowing figures perhaps costs will more than double with poorer performance at a time when the National Highway Traffic-Safety Administration is calling for even higher performance. Members have mace extensive plans for equipment, exhaust systems and procedures to jet to the 2 fibcrs/cc limit on July 1, 1976. Since this equipment will not get them to the 0.5 fiber/cc level, this huge capital investment should perhaps be stopped until such tine as a new standard is decided. Should a manufacturer discontinue his heavy commitment to equip ment for the 2 fibers/cc limit when this equipment will not meet the 0.5 fibers/cc limit? Could there be more emphasis on protective clothing with cover-alls', smocks, boots and gloves as well as a respirators. With reduction to the two fibers/cc level on July 1, 1976 and better work practices, the clothing night do the job as well as the new difficult-to-measure 0.5 fiber/cc liait. The embers don't know hov? low they can get in fiber counts until this new collection equipment is actually installed and in operation. Suggestions mace for cleaning the work area are all vail and good but the only proof that one has reached an arbitrary fiber liait is when the installation is.completed. ^ As regards energy who can say that if double the horsepower vas added to collection systens chat they would get down to the new limit? How . can the energy cost be estimated until this same equipment has actually reduced the concentrations down to the new levels? Where regulated areas are established where allowable concentrations may be exceeded, it is difficult to gee employees to wear the proper clothing. If one were trying to operate a clean room along with proper protective clothing, employees would want air-eonditioninc in the work place for the ur.cor.fore able clothing. To require air-conditioning ir. the work piaffe vhiia also maintaining the extensive exhaust svsters would be prohibitively expensive-- if it can be dene at all-- because one is at cross purposes with the other. Costs also will be increased because of the new monitoring requirements. t . As retards the effect on competition it was pointed out that this nay very veil be the trigger vhich would close do1/ some marginal operations vith a resulting transfer of jobs outside of the U.S. Even in Great Britain where much medical information has been gathered they have not gone to the C.5 fibcrs/cc limit. It does not appear that Great Britain has sufficient medical evidence to support such a lir.it. Countries on the continent do not have this 0.5 fiber/cc limit. The Latin .American countries have no limits. As regards the effect or. employment and competition, the hupe capital expenditures required for the U.S. plants may very veil export additional jobs. Ur.iie sone of the procedures recocnended for handling asbestos and removing the worker from contact with the product may show labor saving results, the actual level of exposure to the remaining workmen from these changes still will be quite high. ' z * There would be considerable costs for members ir. the friction materials industry sc requalify brake blocks and heavy duty segments for the recuire- nents of the :"HTSA Standard 121 which, vent into effect during 19 75. There has been a considerable expenditure of funds for Standard 105-75 (hydraulic brake systems standard) by many members. Amy changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard would add additional costs for manufacturers in recualifvine their materials. The friction materials industry in particular is caught between the forces of improved performance of braking materials along with restric tions or. ho*.' to manufacture and distribute their materials. There may be considerable testing tc racualify materials if there should be a change in processing or compounding. As regards the costs to consumers and society in general the industry does not knot: what can be done if it is necessary to remove asbestos from brake lining. The industry could be subject to 5 - 10 years of serious dislocation. Ir. addition to the problems with the OSEA standard that appear evident, costs can not be quantified at this time. Industry needs more tina to respond tc these far reaching regulations. Gne of the requirements for record keeping stated that the records must be maintained for ferry years, or for an employment interval plus 20 years, which ever is longer. This is a considerable record keeping requirement. However it was stated that perhaps this is necessary in order for subsequent s'tudy of the epidemilogy of asbestos. It was suggested that perhaps this is one of the new proposals that can be lived with. In prior meetings and at prior workshops the problem of correlation of fiber count has been discussed. In general there seems to be some agreement chat different experienced counters may total up results showing as much as a 307 variation in counts from the sane sample. This is already a problem. However these counts where the 30* variation is evidenced are In the 2 fibers per cc to 5 fibers/cc area. A 307 difference with a 5 fiber/cc count is 1.5 fiber/cc Here, CSKA is asking for a concentration licit of 0.5 fibers/cc when with current observations there can be variations of as much as 1.5 fibers/cc. As concentrations move towards 0.5 fibers/cc not onlv does teehnolotrv *et iiinuces of the Meeting ' Asbestos Study Committee -8- Oetobcr 24, 1975 Industry conditions in 1975 (under the current 5 fibers/cc lir.it) are much improved over industry conditions which were in effect through most of the 1960's. Each additional step approaching zero fibers/cc is a lot core difficult than the steps that were taker, to get industry down to; the 5 flbers/cc licit, '.vhile it will be burdensome to move the concentrations to the 2 fibers/cc licit, the steps necessary to geu down to 0.5 fibers/cc are not known There are requirements in the proposed standard for worker re-assignment. If cany employees are moved to lesser and lesser duties maintaining the same premium pay that they had received for working with the asbestos products, there will be a negative productivity result. It has been industry practice in the past for night shifts and more difficult tasks to command higher pay preiums. This rotation to another Job with no loss in pay will be another penalty to productivity. The recommendations that will be made by the FMSI or the AIA are not kno'-r. at this time. It is believed that the AIA stand will include background on medical information. However, it is most important that the individual companies make a response. They should not expect that someone else will write it for them. The Secretary will prepare a bulletin to be sent to tide membership suggesting that they comment to OSKA on these requirements. ItTwill be pointed out that the comments must be those of the individual member and they should not echo the suggested outline of problems which the Institute will prepare. It was also pointed out that there are a lot of new items in the proposed regulations including items on loading, unloading and storing of asbestos cargo. The carrier-- be it a railcar, ship or other-- must make a visual inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed. Who does this? Does the carrier do this? Are the carriers aware of this problem? A close reading of the proposed OSHA standards revealed many problems of this nature which will have to be pointed out to others who may not feel that they are affected by the asbestos rerulations. .* THE E?A aATIOMAL EMISSIONS STANDARDS FOR ASSISTAS The Environmental Protection Agency published the amended standards for the .rational Emissions Standards for Asbestos. This appeared in the Tederal Register October 14, 1975. Ordinarily the EPA amendments would be an iten of prime concern to the manufacturers. However the proposed OSHA standards are so extensive and so far reaching they must take priority over these new EPA Standards. It was pointed out that the SPA notice is the adoption of the . amendments to the standards. These are not proposed amendments. In particular the'waste disposal requirements are of interest to friction materials manufacturers. The friction materials manufacturer is-responsible to see that land-fill operators and trucks carrying vaste comply-with the requirements of EPA on disposal of asbestos bearing materials. The manufacturer is responsible for supervision to see chat these requirements are carried out. Members reviewed the section 61.25 on waste disposal. There was some difficulty with interpretation. Mr. leaver pointed out chat the requirements for covering the asbestos containing material were applicable only if there were visible emissions to the outside ** ----- ' -'** *' 'kir.utes of the Meeting Asbestos Study Committee -9- October 24, 1975 of 61.25 do not.cor.e into ploy, no-.'ever these requirements for cover do take effect tf there are any visible emissions. The most difficult areas of the new E?A*standard are in the waste disposal area. There was no other business called to the attention of the committee. Upon notion duly made, seconded and unanimously passed it was P.ES0LVED: To adjourn. Acicurned: 2:15 P'A E. W. Drislane Secretary / A