Document w1KL4N41188XRyzy2a4pm3kd

FMSI 03551 FMSI 03552 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, NEW JERSEY 07652 November 17, 1980 TO: HEALTH AND ENVIRONMENTAL AFFAIRS COMMITTEE SUBJECT: MEMBERSHIP ON COMMITTEE This is to advise Committee members on the make-up of the Health and Environmental Affairs Committee. I have attached a roster of those who will be serving on this Committee. Should there be information of importance to Committee members it will be sent to the names appearing on this roster. When a Committee meeting is called we will advise the members indicated. The foregoing is for your information. E. W. Drislane Executive Director Af- 1 ( 2\ FMSI 03553 2.7 - HEALTH & ENVIRONMENTAL AFFAIRS COMMITTEE James IV. Armstrong, Chairman Bendix Corporation Bendix Center Southfield, Ml 43076 313-827-6350 Charles H. Borcherding Abex Corporation Medical Department 4550 W 26th Street Chicago, IL 60623 312-521-3210 David E. Stone Bendix Corporation Friction Materials Division P. 0. Box 238 Troy, New York 12181 518-273-6550 William E. Milligan Larry J. Hatfield Carlisle Corporation Molded Materials Division P. 0. Box P Ridgway, PA 15853 814-773-3185 Nuturn Corporation 311 Plus Park Blvd. Nashville, TN 37217 615-367-9900 George J. Bohrer H. K. Porter Company, Inc. Thermoid Division 1849 East Sabine Street Huntington, IN 46750 219-356-2410 Paul I. Lee Richard Dean Raybestos-Manhattan, Inc. 75 East Main Street Stratford, CT 06497 203-375-3341 Thiokol Chemical Corporation Friction Division N. Enterprise Avenue Trenton, New Jersey 08604 609-396-6500 Cn Mai 1i List Only B. J. Pigg Asbestos Information Asso./NA - Arlington, Virginia James F. Reis Johns-Manville Sales Corporation - Denver, Colorado John H. Marsh Raybestos-Manhattan, Inc - Trumbull, Connecticut FMSI 03554 23 i NOV 1PP0S FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAilUS, H.J. 07652 BULLETIN N 0. 6 8 8 July 29, 1980 NATIONAL N0RKSH0P ON SUBSTITUTES FOR ASBESTOS On July 14-16, 1980 the Consumer Product Safety Commission (CPSC) and the Environmental Protection Agency (EPA) sponsored a national workshop on substitutes for asbestos. I attended the July 14, 1980 session at which a formal presentation was given on friction materials. This presentation was given by Mr. Charles Brunhofer of the Bendix Corpora tion, and emphasized the use of semi-metallic type linings on automotive disc brakes. This was a formal session with a prepared delivery and a slide program. In the afternoon there were sessions on various subjects which were called "round, table discussions." There was a round table discussion concerning friction products in the afternoon which I attended. I did not participate in sessions on gaskets, packings and other such material. But I did sit in on some programs such as the ones on textiles. I don't believe that there was any major new information developed at this workshop. Some speakers used their time to espouse substitutes that they were promoting. Others took the opportunity to take swipes at the use of asbestos to further their products. Some were state of the art type reports and I would characterize the Eendix presentation as such. Mr. Brunhofer's talk was well documented and illustrated and indicated the considerable work that Bendix has done on development of semi-metallic materials for disc brakes, lie reached back into the history of this development which started prior to the days when asbestos was a target of lit. Sinai and the environmentalists. The material was developed for use in a brake package to perform at higher levels of severity, which later tied in with reduced sizing of brakes from the vehicle manufacturers' down-sizing programs. This came with a move back towards solid rotors from the ventilated rotors which had been used on most United States passenger cars over the past 10-15 years. An abstract of Mr. Brunhofer's presentation follows: Friction materials for automotive brakes are complex composites containing three general types of ingredient materials: reinforcing fibers; modifiers that adjust or maintain friction level, wear rate, and noise properties: and organic resin binders. Historically, the foundation or major constituent of automotive friction materials has been asbestos fiber, so chosen because of thermal stability, friction level, reinforcing properties, availability, and relatively low cost. Numerous substitutes for asbestos in conventional organic materials have been evaluated, including both naturally occurring and synthetic materials. Direct substitution of these alternative materials in conventional formulations has resulted in poor friction levels, friction instability, roughness. FMSI 03555 BULLETIN NO. 688 2- - July 29, 1980 structural failure, increased noise, mating surface deterioration and/or front-to-rear vehicle brake imbalance. Complete reformulation, not simple substitution, is necessary to meet the numerous, complex performance requirements of consumers, manufacturers, and government standards, such as FMVSS 105-75 and FMVSS 121. In the 1960's, a new class of friction materials called semimetallics was developed to meet severe braking requirements, primarily in heavy-duty disc brake and extreme duty truck block applications. Semimetallics operate satisfactorily against the ventilated cast-iron rotors in the smaller brakes of downsized cars, as well as against the solid rotors found in the lighter brakes of new front wheel drive vehicles. Semimetallics rely on steel fiber and powder metallurgy techniques for reinforcement, and do not require asbestos. The improved performance of semimetallics compensates for their higher costs due to more expensive ingredients, higher specific gravity, and more costly processing requirements. Overall development took more than ten years from introduction to significant customer acceptance. The characteristics of semimetallics make them extremely difficult and costly to process as a drum lining segment. Consequently, an additional new class of friction materials is under development, specifically for drum lining applications. Additional development effort is necessary, not only to confirm the performance characteristics of these new substitute fiber formulations, but also to develop new processing techniques. These new-type friction materials will be more costly, however, due to the ingredients and new processing techniques. It will be noted that the talks and discussions at this workshop will be typed and made a part of the proceedings of the workshop. Conies of the proceedings will be available from EPA sometime after the next several weeks. I will attempt to get copies of the proceedings for distribution at that time. During questions following Mr. Brunhofer's presentation as well as at the round table discussion in the afternoon there were several comments. Statements were made to the effect that while semi-metallic type materials have been proven on disc brakes, drum brakes are a completely different problem. Drum brake semi-metallics are difficult process because of weak green strengths and the difficulty in bending the material, as well as the brittleness of the material. Lengthy lead times are involved. Where the changes were "evolutionary" they took from 3-4 years. This would be developing a new semi-metallic in an existing brake package for example. Mr. Brunhofer indicated that where the change was "revolutionary" this would take 5--1/2--8--1/2 years in development. This could be where the vehicles were being down-sized with a completely new brake caliper and solid rotor for example. In discussions participants indicated that there will be full semi-metallics on disc brakes by 1985. There also is develooment under way concerning organic drum brake linings using substitute materials for asbestos. The earliest that such non-asbestos drum brake materials may be in production was indicated as 1982-1983. Questions were raised about the replacement market, where a new vehicle takes a semi-metallic type lining. What would be used for replacement? Would the aftermarket install organics where a full semi-metallic was released as original equipment or would they install a like material? It was suggested that in practice the aftermarket may very well use conventional asbestos type materials to replace semi-metallics FMSI 03556 BULLETIH HO. 688 -3- July 29, 1980 but that it was recommended that replacement be on a like for like basis. That is, where semi-metallic is used as original equipment it was recommended that the replacement also be a semi-metallic type. A participant from Dupont recommended the use of Tevlar as a substitute for asbestos. He suggested that it not be used as a one for one substitute because it is quite expensive. He suggested that perhaps one might use 5% Tevlar, plus other lower cost inorganic fibers materials to replace the balance of the asbestos. One example of an inorganic material he indicated was wollastonite. It was indicated that materials of this type are used on clutch facings on Mercedes, Audi and Porsche. During the round table discussion Mr. Lee 3urgess of Wheeling Brake Block indicated that where substituting for asbestos may be possible for mass production disc brakes, there is an entirely different field where substitu tion is not going to be simple. He indicated the use of asbestos type materials on heavy equipment such as Manitowoc and other large off-highway equipment. He particularly mentioned submarines and/or defense equipment. Mr. Burgess indicated that these materials were almost custom made to the requirements of the customer. Where substitute materials are going to be higher in price, the costs to the end consumer will be staggeringly high. I'r. Burgess made several points as regards the fact that straight substitu tion for asbestos is not as simple as the regulators may assume. I am not sure whether the items discussed at the round table discussion will be in the proceedings, but if they are they will also be distributed when received. It was not our intention to distribute copies of the sessions other than those for friction materials. A brief write-up by EPA on asbestos and substitute materials for friction materials is attached. At the round table discussion, personnel from EPA (which included Mr. A1 Colli of the Office of Toxic Substances Control) asked generally the same questions that had been asked the Institute earlier concerning non-asbestos disc brake linings. Those answers had been given to the EPA people. A good deal of the session, and particularly that in the afternoon work session, was repetitive, as EPA was again asking questions asked earlier. EWD/lmc Enc. DistributionActive Members - List C Delegates & Alternates Regional Members (U.S. Dues) E. W. Drislane Executive Director FMSI 03557 SECTION 5 friction materials Asbestos Is well suited for use in friction materials because of its thermal, stability, reinforcing abilities, and relatively high ability to with stand friction. Asbestos-containing friction materials are used for brakes for light- and heavy-duty vehicles, aircraft, railcars, various types of heavy equipment and clutch facings. . Several manufacturers of friction materials have active research and testing programs to develop asbestos-free materials. Although industry s research and development activities are highly secretive, we know that among the materials proposed in the past as substitutes are: glass fiber, steel wool, mineral wool, carbon fiber, cermets (sintered metals), semimetallic materials, potassium tltanate fibers, aramid fibers, vermiculite, and silicon nitrides. Some firms may have ceased research on one or more of these materials but others may still be under consideration. Several manufacturers of friction materials have active research and testing programs to develop asbestos-free materials. Some of the materials proposed as substitutes are: glass fiber, steel wool, mineral wool, carbon fiber, cermets (sintered metals), semimetallic materials, potassium titanate fibers, aramid fibers, vermiculite, and silicon nitrides. As friction applications vary, so do the materials most appropriate for each use. Semimetallic and cermet materials may all be used in direct asbestos substitute applications, semimetallic in disc brakes (it is projected that in 5 years nearly all original equipment disc brakes in passenger cars and light trucks will use semimetallics) and cermets for aircraft brakes (95 percent of all new commercial aircraft use cermets). 23,24 Nonasbestos drum brake linings ' for passenger cars are currently unavailable commercially. 23 A cost comparison for various materials proposed as substitutes for asbestos in friction products is given in Table 7. TABLE 7. COSTS OF MATERIALS PROPOSED AS SUBSTITUTES FOR ASBESTOS IN FRICTION MATERIALS 25 Material Price per pound ($) * Asbestos Fibrous glass Mineral wool Potassium titanate fibers Graphite and carbon fibers Wollastonite Cotton linters Aramid fibers 0.05-0.15 0.05-0.75 0.15 1.00-1.25 10.00-12.00 0.15 0.15 6.00-8.00 Exacl costs for semimetallic friction materials are not available, but they are comparable to organic friction materials, times as much as asbestos friction materials. Cermets cost three to five 9 FMS1 03558 HEALTH A. ENVIRONMENTAL AFFAIRS CO'EIITTEE Committee - Reorganization . This Committee was formed by the Board of Directors in 1971 in _ response to the Occupational Safety and Health Act of 1970. The .Committee was originally formed to keep FMSI advised of OSHA activity on asbestos and thus thru 1979 was called the "Asbestos Study Committee." In 1979 the Board requested that the Committee expand its scope to monitor asbestos legislation activity in such areas as environ mental protection and workers compensation. As a result, the .i Committee developed a charter and a name change to the Health and Environmental Affairs Committee to more descriptively reflect this 'expanding role within the Institute. . The Committee has also been broadened to be more representative of ' the membership. Representatives now on the Committee are: : ; DOn Lee - .Jutum World Bestos Division . George Bohrer - H.K. Porter Co. - Therraoid Division . Richard Dean - Thiokol Corporation - Friction Division ./> G. Nicholson - Abex Corporation ' . D. E. Stone - Bendix Corporation ` . H: H. Wagner - Carlisle Corporation I, Hi Weaver - Raybestos Manhattan EPA Action . - "On October- 17, 1979, the Environmental Protection Agency and Consumer Product Safety Commission published an advance notice of proposed;rulemaking. The notice was a request for information 'V- regarding the use of asbestos in commercial products, an estimate of a persons risk and an estimate as to how many products could be produced asbestos free. The Institute replied to EPA's Advance Notice of Proposed Rulemaking on asbestos products. The comments took exception to the Agency's selection of friction materials for control based on allegations of heavy population exposure. . The EPA has indicated friction materials as being one of the prime products1 to be regulated. On ITovember 16, 1979, the EPA requested specific "Informational needs for friction products containing asbestos" (Eleven Questions for Friction Materials Manufacturers). The original list of questions was reviewed and found to be objec tionable to the FMSI. On January 3, 1980 a meeting was held with the EPA and major changes were agreed upon which made the questionsa little more palatable. FMSI 03559 In Hay 1980, the Institute responded to EPA on their questions concerning non-asbestos disc brake linings for passenger cars and light trucks. This included state-of-the-art information on types, advantages and disadvantages, costs and the lead times involved in conversion. It is very clear that the EPA is moving toward a ban on asbestos in at least disc brakes and is aggressively pushing that objective. . ;The EPA is also pushing for a greater awareness of the hazards of asbestos particularly relating to friction products. It has formulated agreements between OSHA and contractors^ Public Iledia Center, San Francisco, California, for the development of edu cational and informational materials for vocational and technical students being trained in brake^maintenance^ their teachers and mechanics. The Institute worked with the Asbestos Information Association r,ad [hoc Committee for Friction Materials in the preparation and circulating of questionnaries on friction materials industry labelling practices and training programs relating to asbestos. As part of this Committee's work, we have:updated a page in the Institute Catalogs on '`Recommended Procedures for Reducing Asbestos Dust-During Brake Servicing." Thusi are;in a good position to meet any request for training literature. \ . . On May 19, 1980 the EPA published regulations covering its "Hazardous Waste Management System" for the owners and operators of hazardous waste treatment, storage and disposal facilities. These regulations are included as part of the regulations under Resource Conservation and Recovery Act (RCRA) which was originally inacted In 1976. ` . The regulations are to be effective on November 19', 1980. ^ Asbestos.is listed as a regulated material but ther,p is an . exception. Generators of 1000 kilograms per month.or 2200 lbs. do not fall within the system. . ^ Those generators'of asbestos material waste in excess of this limit will be required to generate a manifest and assure that the waste disposal site has approval for the receipt of waste containing asbestos. " Asbestos Compensation . Legislative activity to develop a federal fund for the payment of - asbestos related diseases is still occurring. The Fenwick Bill, which was the first effort, is now considered dead. Senator Bart has Introduced legislation but it Is still to early to determine if it has support. -2- FMSJ 03560 OSHA . On January 1980, OSHA issued its Ions awaited Generic Cancer Policy. It was suspected that OSHA would attempt to place asbestos into the list of cancer agents and while still possible is becoming less likely. Latest input would indicate the OSHA direction to be of maintaining a single regulation on asbestos with the eventual lowering of the allowable level from 2.0 to somewhere in the .2 to .5 fiber range. This is not likely to occur until after the elections. In April 1980, a joint 1II0SH-0SHA Work Group recommended to OSHA _ a reduction in the maximum work place exposure level for asbestos from 2 fibers/cc to 0.1 fibers/cc. . On Hay 23, 1980 OSHA issued its final regulations on access to employee exposure and medical records. The regulation which goes into effect August 21, 1980 provides that employee exposure records required under the OSHA asbestos standard be provided to the employees, designated representatives (union included) and the Department of Labor upon request. This request includes air sampling results, and medical records and requires the employers to retain these records for the duration of employment plus thirty (30) years. Respectfully submitted. J. rT. Armstrong Chairman -3- FMSI 03561 Telephone (201) 849-0440 FRICTION MATERIALS STANDARDS BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS N J 07652 INSTITUTE, INC. WAR 2 5 1981 iis. Joni Repasch Document Control Officer Office of PeBticides and Toxic Substances Environmental Protection Agency Room E-447 401 M Street, S.W. Washington, DC 20460 (TS-793) Subject: Document Control Humber OPTS 84004 Environmental Protection Agency Proposal on Asbestos; Reporting aild Recordkeeping Requirements Dear Ms. Repasch: The Friction Materials Standards Institute is a trade association which includes most of the brake lining and clutch facing manufacturers in the United States. We have other Members worldwide. As friction materials manufacturers, most of our Members use asbestos as a major constitutent in their products. Our comments on these proposals represent the viewpoints of most of our asbestos-using Members. General Comments While we will address specific sections of the proposals on reporting and recordkeeping later in this letter, we question the timing and necessity of the proposed requirements. We are familiar with Section 8 of the Toxic Substances Control Act (Public Law 94-469). We understand that this section can require our Members to maintain records and submit reports in great detail, where that information is necessary to regulate substances that may present an unreasonable risk of injury to health or the environment. .The friction materials industry agrees that there are health hazards from asbestos in the workplace. These have been addressed by the Occupational Safety and Health Administration (OSHA) and we anticipate further regulation in that area. We do not believe it has been shown there is an unreasonable risk of injury to health or the environment from the sale or use of our products because of the following facts: 1. Asbestos fibers are locked-in to the product in its finished form. 2. There is less than 1% asbestos in the wear debris from used friction materials. 3. Small exposure levels in the general environment have not been established as presenting an un reasonable risk of injury to health and the environment. FMSI 03562 Ms. Joni Repasch Environmental Protection Agency 2- - We refer you to the enclosed paper '-'Asbestos & Health in the Friction Material Industry," prepared by the Asbestos International Association in London, England. It summarizes what is known concerning asbestos exposure in the friction material Industry, as well as what is known on exposure to friction material wear debris in the general environment. This position paper supports our contention that while asbestos does present a risk to those occupationally exposed, this exposure is now controlled, and that environmental exposure does not present an unreasonable risk--if it presents a risk at all--to the general public. The Institute suggests that before applying the reporting and recordkeeping requirements of Section 8 of the Act, that EPA demonstrate that asbestoscontaining friction materials may in fact present an unreasonable risk. We recommend that action of the type proposed by this notice be deferred until reasonable people can demonstrate the need for the costly and detailed records that in may cases go beyond the needs of the Agency. This proposed regulation would place one more burden on our Members, and particularly the United States manufacturers supplying brake linings, clutch facings and other friction articles to its already depressed automotive, construction, and industrial customers as well as to the energy related industry. The proposed requirements would not only be burdensome to our Members, but in most cases it is difficult to see how the information can be put to use by the EPA. It calls for a complete documentary on asbestos beyond the needs for purposeful regulation, if indeed that regulation is necessary. Our industry stands ready to help with information-gathering even where the need has not been adequately shown, if the EPA can sharply reduce the amount of information, the old information, information which is mostly confidential, and extraneous information apparently being requested for support of parties other than the Office of Toxic Substances. In fact we suggest that much of the information is available from other Government agencies and it may be of value to have Interdepartmental exchanges between the Government agencies concerned with the asbestos issue. Section 763.65 - Who must report In Paragraph (f) the proposals exempt "small manufacturers, processors, or importers as defined in Section 763.65(m)." Me agree with the exemption of small manufacturers or processors who employ no more than 10 full-time employees. There seems something inconsistent with the maintaining of jobs in the United States by the exempting of importers, who may be importing from factories with 1,000 employees outside of the United States, where a United States factory with more than 10 employees is not exempt. * One "small importer" could be responsible for more friction products, or other products for that matter, in the United States market than a mediumsize United States manufacturer, but the importer would be exempt where the United States manufacturer would not. This exemption would be more equitable if based on dollar value, tonnage, pieces or other like index. FMSI 03563 11s. Joni Ilepasch Environmental Protection Agency -3- Section 763.70(a) - Customer Lists Several llembers indicate that they will invoke claims of confidentiality on distribution of these lists outside their organizations. We question the need for telephone number and technical contact for each customer. In many cases this information is not available. In other cases, this can create an adversary relationship between a customer and a manufacturer. Claims of confidentiality for this type information are valid, as almost all of our llembers are interested in lists of his competitor's customers. We would suggest the EPA reconsider the confidentiality of this type information. We further believe the detail requested should not be required if provision of these lists is actually written into the final rules. Section 763.71 - Schedule for Reporting The schedule for reporting by our Members, who are all Primary Processors and Bulk Asbestos Importers, and in many cases are Secondary Processors, is unduly harsh. Rather than the 60 days required in sub-sections (a) and (c), and the 30 days required in sub-section (b), we recommend a standard 90 days schedule. Our Members have facilities at more than one location, and records are in many cases at a location other than the Factory. A 90 day requirement is more realistic when one considers the considerable detail asked by this proposal. Further, many of our Members do not have ready access to in-house Professionals to review and approve reports before submission. Our Members are entitled to have their reports reviewed by Outside Safety, Health and EPA Consultants, Legal Counsel, and other Professionals as to its adequacy and to assure that our Members are not harmed by their reporting. Form B(2) - Quantity of Bulk Asbestos Imported. The comments on Form B(2) apply to Form 3(3) - Quantity of Bulk Asbestos Obtained. Our major concern is with Form B(2), as almost all our Members use Canadian chrysotile. All Members of the Institute import asbestos, primarily from Canada. The EPA form asks for quantities of asbestos, by type, and chrysotile by grade. The form lists quantities for 10 years, from 1971 through 1980. In most cases, the older the records the more difficult the search. Some Members no longer have data from which to develop quantities before 1976. As the EPA is asking for information on asbestos emissions at the present time, we question the need for 10 years of data, and particularly that of more than two or three years ago. If the EPA were to have information on current consumption that should give sufficient information for estimating current exposures without the extra work involved in going back over ten years. We suggest, if the data is considered actually of value, that the EPA limit the request to that for 1930. The notice asks for details on types of asbestos and grades of chrysotile. We understand the EPA is searching for information on other types of asbestos, but question the need for grades of chrysotile. This involves considerable searching of records on the part of our Members, if in fact the information exists. We do not believe that anyone to this time has alleged or inferred that the hazards of asbestos are dependent on the grade of chrysotile. We FMSI 03564 Ms. Joni Repasch Environmental Protection Agency -4- suggest that the form be revised to ask only on quantities of chrysotile, and that reference to grades be removed. Form C - Primary Processor Production Our comments on Form C apply in most cases to Form D - Secondary Processor Production, ilany of our Members are Secondary Processors in attaching linings to steel shoes or where they perform other assembly operations. He again state that the older the information is, the more difficult it is to develop. He suggest that production figures for the last year only, 1980, be used. These are available. The manufacturer's efforts in compliance with the requirements of this form would be reduced in almost the proportion that the years are removed. Again, we believe the EPA is searching for current exposure information, and that while history is interesting, the requirement to gather it is not necessary to the task. Still further, in the instructions for this form, under ';End Product Shipped," the form calls for information listing the trade name under which the product is marketed, and calls for a listing of all "private brands" under which the product is sold. He fail to see where listing of trade names or "private brands" is pertinent to developing information on emissions or exposures to asbestos. This information is much more difficult to develop for posting to forms such as these. It would multiply the combinations which would have to be listed, when the only relevant information is a product.listing such as we suggest below: Drum Brake Lining (light-medium vehicle), etc. On Page 8225 of the Federal Register notice, "Typical Terms for Products Made From Bulk Asbestos" are listed. Ten different terras are listed under Friction Materials. Most of those are not relevant to exposures in the general environment. He suggest reducing the 10 terms to 7 as follows: Drum Brake Linings (light-medium vehicle) Disc Brake Pads (light-medium vehicle) Brake Blocks (heavy vehicle) Disc Brake Pads (heavy-vehicle) Clutch Facings (all applications) Automatic Transmission Friction Components (automotive)' Friction Materials (industrial and commercial) There are no woven disc or drum brake linings for light vehicle use. For other applications, we question whether information on molded verus woven is pertinent to the question of exposure to asbestos in the general environ ment 4' He feel there is but limited usage of asbestos-containing friction materials in consumer products. Still further, all units of measure should be "Pieces." We question particularly whether information on quantities sold under "Private Labels" will be available even in recent years, without painstaking one-by-one analysis of Individual invoices. In addition, there may be claims of confi dentiality in this area. FMSI 03565 i-ls. Joni Repasch Environmental Protection Agency -5- Form H - Summary of Current Worker Exposure This particular section of the reporting form would cause an undue burden for large facilities which have several hundred workers and a diversity of pro duction operations. Records on worker exposure levels are not maintained in a manner which would permit easy retrieval of the data requested. To simplify this section, it is recommended that Column 2 - Total Person Hours Per Year at TWA, and Column 3 - llumber of Measurements Used, be elim inated as this data serves no useful purpose and is extremely time intensive in its preparation. Form K - Pollution Control Equipment We question the need for the Month and Year under the "When Installed" column. Some installations go in over a long period--in some cases as long as 12 months from delivery to final usage. Do you wish the date ordered? The date delivered? The date installed? The date first used? The date put into use on a full-time basis? The year of installation should be sufficient. We believe a definition should be presented so as to clarify what is wanted or needed. Where there is more than one piece of pollution control equipment, even where there are two, three or more installed, the form calls for a separate listing. We suggest that the form be redesigned to permit listing of any quantity of a particular piece of equipment where that equipment is identical to another piece. The quantities could be listed per piece of equipment, with a total column for all equipment of that same type. The purpose of our recommendation is to reduce the paper work burden. ** * st We question the need for this proposed reporting from manufacturers of friction materials based on the reasons stated under our "General Comments." We suggest a deferral of the proposals on reporting and recordkeeping until reasonable people can demonstrate the need. We suggest that if the reporting and recordkeeping requirements in this proposal will not be deferred that the proposal be revised to simplify and reduce the paper work burden on our industry. This can be done in: three ways: 1. Cancel the study of history--ask for information for 1980 only. 2. Reduce the detail--such as grades of chrysotile, month and year of Instant iation, etc. FMSI 03566 Ms. Joni Repasch Environmental Protection Agency -o- 3. Eliminate or re-write the proposal on information requests where confiden tiality will likely be claimed Respectfully submitted, FRICTION MATERIALS STANDARDS INSTITUTE EWD/erc 2nc; Asbestos & Health in .the Friction Material Industry E. N. Drislane Executive Director FMSI 03567 ASBESTOS INTERNATIONAL ASSOCIATION (Limited by Guarantee) 68 GLOUCESTER PLACE, LOIS'DON WiH 3HL MEMORANDUM TO: Member Associations FROM: Director General AT A/7/3/PROI) 12 February 1981 '1 Asbestos & Health in the Friction Material Industry11 The attached position paper on Asbestos & Health in the Friction Material Industry is forwarded for information. It has been authorised by the Executive Committee who recommend that it should be used as a background reference paper to help members deal with questions in asbestos and health which may arise. FMSI 03568 AIA/7/3/PROD ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY The Problem Exposure to asbestos dust Is recognised as a potential occupational hazard. Among work people exposed to high concentrations of respirable asbestos dust, (such as is known to have occurred before present day dust control measures and work procedures were introduced) cases of cancer and asbestosis have been reported throughout the wotld. * ' The difficulty of reliably identifying the occupational history of those whose health has been affected many years after has resulted in any contact with asbestos being regarded with caution and all materials containing asbestos being attacked indiscriminately. Since friction material is widely recognised as one of the products for which asbestos is an important ingredient, it has attracted such attention. Indeed, the asbestos industry, in reminding everyone of the vital role played by asbestos in brake linings, has stimulated such attention. Nevertheless the occupational health record of the asbestos friction material industry is good and only a few cases of asbestos-related disease are on record. However, the widespread use of friction material in all types of vehicles has raised the question of potential pollution of the environment with $n assumed consequent danger to the health of the general public. The friction material industry, therefore, has two basic problems. The first, the occupational health problem, has in many areas been resolved. However, the industry must continue to ensure that those employed in the manufacture of these materials are not exposed to dust levels which are harmful. An extension of this problem is the need to ensure that workers employed in the subsequent use of friction materials, either in the fitting of the products or the maintenance of vehicles, are not exposed to harmful dust levels. (This page retyped at FMSI because of weakness of original copy) FMSI 03569 The other problem for the industry, that of possible environmental pollution, is more difficult to resolve, based as it iB on emotional anxieties (which are in no way Justified by the evidenoe). A olimate of concern for the effect on the environment of expanding towns and industries has led to the motor vehicle being included as a significant factor in thiB pollution. . This fact together with the publicity given to asbestos and its classification as a carcinogen,^ have all combined to lead people to question the use of asbestos-based components in motor vehicles. The automotive industry is also under attack for a number of other reasons, (e.g. pollution, waste of resources and congestion) and would gladly be without the asbestos problem although it must accept that for some years, current models of motor oars will heed asbestos-containing material for replacements. The friction material industry itself must therefore dispel anxieties about asbestos-containing products in motor vehicles by ensuring that the existing reassuring evidenoe is made manifest and is properly understood. .. Tackling the Problem , In order to tackle the problem most effectively, it is important that the origins, investigations and remedial measures involved should be well understood. This is especially necessary since the existence of the friction material environmental problem is to a large extent based on confusing two very different phenomena; on the one hand the occupational health - experience and dust exposure data related to manufacture (and the subsequent fitting and servicing operations sometimes called "para-occupational") . and on the other hand an assumed emission of similar dust into the general . ' , environment as a result of the daily, wearing down of brake linings and clutch facings* An example of this oonfusion may be seen in-the evidence given to the UK Asbestos Advisory Committee, where Claims that the general public are at risk are supported solely by reference to a survey of motor vehicle maintenance workers. 5 . It is therefore important to recapitulate the facta relating to health hazards and the conditions which axe believed to give rise to them. FMSI 03570 These facts will be reviewed under three headings, the first two covering the Occupational areas of Manufacturing.and Servicing, and the third heading covering that of the General Environment. Manufacture of Friction Materials t There is ample evidence to suggest that, in the manufacture of friction materials, the concentration of asbestos dust compares favourably with that found in most other modern asbestos operations. Within the last ten years efforts to observe a 2 f/ral** standard have led to further improvements in dust control and there are now many operations where levels well below this maximum allowable concentration are achieved^. Very few cases of asbestos-related disease arising from friction materials manufacture have been reported. In evidence presented to the UK. Advisory Committee,"* Ferodo Limited, who have been using asbestos in brake and clutch linings since 1910, reported 8 cases of mesothelioma and 5 cases of ashestosis. The mesothelioma cases had all been exposed in the manufacture of railway brake blocks between 1928 and 1933 or during the war years up to 1943, to crocidolite as well as to the chrysotile asbestos more generally used throughout the plant. The asbestosis cases were all involved in mixing processes where masks should have been worn. In the same volume of evidence, a report from the two Cape Industries'' factories manufacturing both textiles and friction material (one since 1901 and the other since 1923) cites 9 cases of asbestosis and no case of mesothelioma. * Ferodo report that "many millions of man hours have been worked on finishing operations of asbestos-based materials; though the dust concentrations associated with these were at one time very high, there * f/ml = (asbestos) fibres per millitre FMSI 03571 ha,s not "been a single diagnosis of asbestosis as a result of this exposure". In more recent years (1968 - 1976) hovever, average concentrations were well below 2 f/ral .following continuous improvements in dust extraction .methods, An investigation in 1975 by Eeidernanns, Kuhnen, Schutz and Prochaska9 into dust hazards which might be associated with the manufacture and use of asbestos-containing friction materials (updated in the Research 7" report of the German PeruPsgenossenschaften quotes concentrations of micro-dust in the range of 0.09 to 0.20 rag/ir^ during grinding, drilling, saving, turning and milling operations (the current Tritl* value is 0.10 mg/n^ or 2 f/nl: on this basis the current range is 1.8 f/ral to 4 f/ml), on average just below or just above 0.15 mg/ra^ or 5 f/ral. Ouch operations, unless subject to dust control, will emit duet containing asbestos. A number of surveys of such operations have been carried out in Germany 'UK 10,11,12, USA 13,14.15.16,17 elsewhere ana it is clear that, under some conditions of working and where such operations are carried out continuously, dust concentrations above 2 f/ral (or the TPK of 0.10 mg/my) can be reached. There is some evidence of effects on health . among men engaged for a long period on such work. Medical and epidemiological " '7 investigations by Professor Voitov}tz, Valentin snd others on workers who had been continuously exposed for at least 10 and up to 25 years to asbestos dust suggests a similar risk level for men employed on finishing operations (mewily grinding and drilling) in the automotive industry,to the risk ~ - 7 9- 's-vc-1 of workers in the r.pnnfacturing industry .+ . It wr~ noted that the automotive industry group studied had had long exposure from a very early age; ^ A group of men carrying out brake ' f CPE = Technical Control Limit -i Out'of 94 workers (including 43 women) in manufacturing, there were 3 probable cases of asbestosis and 11'^possible". Among 63 men employed in finishing operations on brake linings in the automotive industry, 2 probable asbrastosis cases were found and 10 "possible". ("Possible'1 means showing effects on the lung which might be fibrogenic.) FMSI 03572 -5- maintenance services with expo mire primarily during the cleaning and brushing out of brake drum dust gave little evidence of inhalation effects in spite of long years of exposure. Professor Selikoff's investigations 19 quoted indications of abnormalities ' in 32 out of 87 motor vehicle mechanics (6 out of 29 with five or more ' years intermittent exposure shoved signs on X-ray of changes consistent with asbestosis). Another report of the same investigation quoted 24% of 95 brake service mechanics showing chest abnormalities not necessarily asbestos-related and it is emphasised that there were no confirmed cases of asbestos-related disease. Dust levels quoted in connection with this AA A4 . investigation (in USA) * ' refer to mean concentrations for blow-out of brake tdrums, grinding of used linings and bevelling of new linings of I5.9, 3.8, and 37.3 f/ml respectively - much hi^ier than any found by any other researchers. Ho information is provided as to the duration of these samples - they are frequently referred to as peak concentrations or the mean of a number of such measurements. It is also clear that in the case of blowing out of brake drums, no asbestos fibres were visible by optical microscopy? some chrysotile was identified by X-ray diffraction. Fibres identified by electron microscopy were all below the minimum size specified in the definition of asbestos fibre (i.e. 5 }" in length) . It should be noted that the methods of sampling and the ^criteria for measurement of occupational environments did not conform to the methods used by , governmental agencies end by other investigators in Germany and UK. For Comparison, concentrations of asbestos dust during brake maintenance reported by Eickish and Knight ^ shoved an average daily exposure of 0.68 f/ml (range 0.21 to 1.12) during brake service of 11 cars. During . truck brake service, the average was 1.75 f/ml, with peak, during cleaning . . of the brake drum, of 7*09 f/ml. ' ' . ^, The German investigation in 1975 ^ (now incorporated in the Berufsgenossanschaften report ^) reoorded high concentrations* in the brake service department and * 0.03 to 0.79 mg/m^ and with background workshop atmosphere of 0.03 to 0.05 mg/a^. FMSI 03573 --V where machining w?s done without dust extraction. Although high concentrations of dust were observed during bloving out, no chrysotile asbestos could be detected by infra-red spectrometry, and the individual fibres which could be detected optically could not be identified as asbestos. The GeneralEnvironment During the application of drum brakes, disc pads or clutch facings, ' small ouantit es of the surface of the friction material are worn away. These materials contain between 305 to 6(^5 of asbestos, and it has been assumed by sons that thereby large quantities of dangerous asbestos dust are being regularly discharged into the atmosphere. This, it is argued, creates e dangerous atmosphere akin to that which has produced asbestos- related disease (especially cancer) in some working environments. Since the estimated consumption of asbestos in friction material is annually over 40,COO tons 2?" *for Europe and over 5^,000 tons in the _USA the amounts involved are substantial. An estimate carried out by the Pendix Corporation with the support of the US Environmental Protection Agency (IIPA) calculated that the amount of friction material worn sway in brakes end clutches annually in the USA is 8round-60,000 tons, J (of which 37,000 tons is the asbestos content i.e. >0;'. In Europe the content of brake linings is nearer 305"). However it is clear from measurements made at a number of locations with heavy road traffic that insignificant quantities 07 O J of respirable asbestos dust are so emitted. ' the c.-si important' factor in dispelling anxiety is that the asbestos content of the wear products of friction material is not emitted into the atmosphere in the form of respirable asbestos dust. Indeed, a number of ambient air investigations indicate that it,is difficult nowadays to find asbestos fibres in any significant quantity, regardless of size, in the A atmosphere - even in the vicinity of asbestos manufacturing plants.1^ . Measurements of the ambient air even in heavy traffic conditions do not show any significant level of asbestos. Again, in underground railway systems, where fierce application of asbestos-containing brakes in the FMSI 03574 -7- confined tunnel environment might be thought to create the worst conditions, no significant build-up of asbestos dust has been detected.' ' ' * The explanation is simple end is confirmed by a number of careful scientific investigations. The heat generated in the process of applying the brakes or the clutch (the reason in fact why asbestos is such a vital component) is sufficient to destroy the original' structure of the asbestos fibre. From-a temperature of 450C the chrysotile structure begins to convert to a non-crystalline amorphous phase, leading to a loss of stability.of the fibre structure. The mechanical strain applied during the braking process has a pulverising and grinding effect, leading to disintegration of the fibre structure. The German report calls it "a kind of micro-milling so that the dust no longer contains any fibres". From a temperature of 650C a new crystalline structure develops called Forsterite, which will be fully developed at temperatures of above 700 C. Generally, forsterite cannot be traced in brake lining dusts. This means that temperatures beyond 650C either do not occur or are only very short lived. The decrease of the chrysotile content, however, indicates that temperatures beyond 450C are reached because the amorphous phase of the chrysotile cannot be traced analytically (by either infra red-spectrometric or X-ray diffratcnatic methods). . Examination of the residue of wear products in brake drums confirms that the asbestos content is usually less than IJo of the resid-ue. 27 .It has been suggested that the dust escaping into ambient air may contain a higher proporticir of the fine respirable asbestos than dust left in the drums but ' --V 4' careful studies designed to entrap this .escaping portion of the wear _ product show that this is not sc. Various investigations into the amount of . asbestos remaining .in the residues from friction processes have been carried out which indicate how minute is the fraction of asbestos released in the application of friction. The latest report, 7 from Germany, confirms that technical investigations in recent years have repeatedly shown that the dust generated by friction of the linings in use - as opposed to dust created FMSI 03575 -a- during the finishing and handling of new linings - as a rule contains only traces of froe chrysotile fibre, i.e. of the order of 1?o. The working party was unable to provide clearer infra-red spectrographical evidence of chrysotile. Under phase-contrast and eloctron-nicroscopic scrutiny, the dust contained just a few isolated fibres which could not even be definitely identified as asbestos. This is consistent with the investigation by UK government and industry investigations in 1969 * which reported that the free asbestos content of wear products of drum brake linings rarely exceeded 1?o. (in disc brakes the content was oven lower.) . The Bendix'investigations for 1JI0SH in USA in 1973 gave a range from 1.655c to 0.0035a - only three tests were above 1Jo and the overall average was 0.235s. This study also determined that only 32?S of the asbestos content of all the wear products over the whole range of US motor vehicles became airborne - estimated at 5060 lbs* annually. 13J The Ford Motor Company carried out a study 28 based on dynamometer tests which shoved that during brake usage less than 0.025' of the lining wear was released in the form of free asbestos. The study estimated that concentrations of asbestos fibre in the urban atmosphere in the US due to brake usage was less than 0.07 x 10 ^ g/n? (.07 nanograms) (less than one millionth of the 2 f/ml occupational control standard). , Measurements carried out at points of heavy traffic concentrations in' the UK by the Asbestosis Research Council, under the observation of the TUC Centenary Institute of Occupational Health, also found Ho greater concentration. Even in the underground railway system, this survey found the asbestos content to be of the order 10 g/m^ to 10 ^ ngs - to 100 ngs/m3)2^ ' .' Finally, some observations made within the last three years by two eminent occupational health experts, on occupational risks and risks to the general public, are worth quoting. FMSI 03576 v- Hr. John Gilson, reviewing asbestos as an ocCupatiohal hazard in a general group in which he includes friction materials, says"Despite the thousands of products containing asbestos, evidence of ill effects from their use'is very snail". Ee adds the qualification that occupations <. involving brake shoe maintenance have been shovqa to be at- risk in the past. "Although nost of the asbestos in brake shoes is degraded, the dust in the broke drums still contains a small percentage of asbestos". "The magnitude of the 'risk (of aetestosis and mesothelioma in those working regularly in this employment) is not known but is likely to be 'small." Professor * 22 fi.vlhnis, ` in his report on public health'risks, concludes "There is evidence of no excess risk of nesotheliona from asbestos pollution which has existed in the neighbourhood of chrysotile and amosite mines. There is r.c .evidence of a risk to the general public at present". Later he repeats this view in hie. general conclusion "There is no established evidence that true ambient exposure, as prevalent in Vestem European countries, at this moment carries such a definite risk; however, there exist too many 'uncertainties to deny such-a risk, though if the r is': was substantial it is likely it would hrvr teen detected by now". aCi'r.LVSKWS rtnre , There can be an o<-c-"uat: onal heaxiv.. risk in the manufacture of esbestos- >t- se* friction materials. However, experience lu,- shown that this .is a very r i'.of hoclth r! ?k and that it can be effectively controlled by well tested equipment? and work procedures. ; , . * standards based on extensive experience in the industry have been established and equipment is available to maintain these standards so that the . occupational health risk can be controlled. In many countries these standards ere enforced by legislation,' but in -w case trade and industry have an c-.VHgaticn,. as with- any occupational safety problem, i.. ivryr,';euiv.nt the effective risk p-r-evention m<=o euros which have been developed by competent and experienced technicians. FMSI 03577 - 10 - Maintenance Work (Servicing) In certain conditions involving servicing, etc., there may be a paraoccuptional hazard. The Industry can provide information to ensure that users understand under what circumstances such risks can arise and how they can be avoided.3031*32*33* The General Environment The available data indicate that the general public is not at risk and means should be found to tell them so. ANNEX - Bibliography 14th January 1981 (Page 10 retyped at FMSI because of weakness of original copy)^ _ FMSI 03578 annex ASBESTOS AND HEALTH IN THE FRICTION MATERIAL INDUSTRY BIBLIOGRAPHY Walther, E., (formerly) Pneumoconiosis Research Unit, Penarth, Wales. "Dust Problems in the Use of Asbestos Products". Proceedings of the International Conference on Pneumoconiosis Johannesburg, S.Africa. 1969 Santorelli, Zedda, Aresini and Ghezzi; "Respiratory Physiotherapy of Asbestosis". La Medicine del Lavoro 63 (7 - 8) 269 - 281 July 1972 Rubino, G.F. : Institute Medicina del Lavoro, Torino, Italy. "Identification and Survey of Asbestos Occupationally Exposed Populations". September 1975. International Agency for Research on Cancer. I.A.R.C. Monographs on Evaluation of Carcinogenic Risk of Chemicals to Man. Vol.14 Asbestos. Lyoh, France. 1977. - "Selected written evidence submitted to the Advisory Committee on Asbestos 1976-77" Health and Safety Executive, UK. 1977. * Cross, A.A, former Director General, Asbestos International Association, London. "Progress in the Control of Asbestos Dust in the Workplace". International Conference on Pneumoconiosis, Caracas. November 1979. German Federation of Industrial Accident and Safety Insurance Corporations E.V. Berufsgenessenschaften (Bonn,W.Germany). Research Report - Asbestos. "Investigations into Health Hazards through Dusts by Brake-Linings containing Asbestos". (Analytical epidemiological and animal investigations) December 1978. "Hygiene Standards of Airborne Asbestos Dust Concentrations for use with the Asbestos Regulations 1969". U.K. Dept, of Employment H.M. Factory Inspectorate, Technical Data Note 13 (Rev) 1975. FMSI 03579 9. 10. 11. 12. 13. 2 Heidermann, Kuhnen and Schutz (Dust Research Institute of Federation of Industrial Trade Associations (Berufsgenosenschaften). Bonn, W. Germany), and Prochazka; (Bavarian State, Institute for Industrial Safety, Munich) "Investigations into the Hazards produced by dust of asbestos-containing friction linings". June 1975. Conference on Exposure to Asbestos during Brake and Clutch Maintenance, Brentwood, Essex, England, March 1969. a) Lee G.L: British Leyland, Longbridge, Birmingham. "Removing Dusts from Brake Assemblies during Servicing Alternative Cleaning Methods". b) Hatch,D., Ferodo, Chapel-en-le-Frith, Derbyshire, England "Possible Alternatives to Asbestos as a Friction Material". c) Knight, K.L. and Hickish, D.E., Medical Services, Ford of Britain, Brentwood, Essex. "Investigations into Alternative Forms of Control for Dust generated during the Cleaning of Brak Assemblies and Drums". d) Hickish, D.E., and Knight, K.L., (as above) "Exposure to Asbestos during Brake Maintenance". UK Annals of Occupational Hygiene. Vol.13 1970. Bentley, M.L.; Mintex, Cleckheaton, Yorkshire, England. Personal communication to A.A.Cross - Asbestos Dusts - test during drum brake maintenance. May 1974. Cross, A.A.; Chairman, Environmenta Controll Committee, ARC England. "Asbestos Dust in Friction Materials". September 1975. Jacko, DuCharme, Somers; Bendix Corpn. and Environmental Protection Agency, USA "Brake and Clutch Emission during Vehicle Operation". Automobile Engineering Meeting, Detroit, Michigan, USA May 14-18 1973* *Former Director General, AIA FMSI 03580 -3- 14. Rohl, Anderson, Nicholson, Langer; Mount Sinai School of Medicine, N.Y, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair." American Industrial Hygiene Conference, Miami, USA. (Abstract 223) May 1974. 15. Nicholson, W: Mount Sinai School of Medicine, N.Y. USA. "Asbestos Exposure during Brake Lining Maintenance and Repair" - June 1975 (Believed to be full version of abstract quoted above -14) 16. Rohl, Langer, Wolff and Weissman; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure during Brake Lining Maintenance and Repair". Environmental Research 12, 110 - 128 (1976). December 1975. 17. Rohl, Langer, Mlimentidis, Wolff, Selikoff; Mount Sinai School of Medicine, NY, USA "Asbestos Content of Dust Encountered in Brake Maintenance and Repair". Proc. Royal Soc. Med; 70:32-37 Jan. 1977. 18. Kogan, F.M.; Sverdlovsk Institute of Labour, Hygiene and Industrial Diseases, USSR. "Asbestos and Prevention Measures against Dust Harmful to the Health of Workers". (Chapter V). 1975. 19. Marsh, J.H.; Raybestos-Manhattan, Connecticut, USA. Personal * Communication. Reports of mesothelioma among brake service mechanics in Boston, Mass, and Santa Clara, California N.I.O.S.H. and Selikoff. August 1975. 20. Lorimer and Rohl; Mount Sinai School of Medicine, NY, USA. "Asbestos Exposure of Brake Repair Workers in the US". International Conference on Occupational Health, Brighton, England. September 1975. FMSI 03581 -4 - 21. Nicholson; Mount Sinai School of Medicine, NY, USA. "Comparative Mortality Experience of Three Cohorts of Asbestos Workers." International Conference on Occupational Health, See Item 20. 1 22. Zielhuis, Prof. R.L.; Coronel Laboratory, University of Amsterdam, Netherlands. "Public Health Risks of Exposure to Asbestos". Report of a Working Grouff o'f Experts prepared for the Commission of the European Communities. , Directorate General for Social Affairs, Health and Safety. 1977.. 23. Sebastien, Bignon and Bonnard; Centre de Perfectionnement Technique, Paris. "La Pollution Atmospherique Urbaine par l'Asbeste". Jourpeas d"Etude sur la Toxiicologie Industrielle, Paris. June 1975. . 24. Asbestosis Research Council, Rochdale, England. Personal communication to A.A.Cross* "Investigation into levels of airborne asbestos dust in the London Underground, etc.". 1978. 25. Johns-Manville; Denver, Colorado, USA. Boston Subway - Cobra Brake Lining Emission 1977. 26. Winton Laboratories, Surrey, England. "Asbestos in the'Underground - no cause for alarm". 't 27. Dufficy', B.L., Ferodo, Chapel-en-le-Frith, Derbyshire, gngland. Personal Communication - Asbestos Content of Wear Products from Friction Materials. June 1969. 28. Anderson, Gealer, McCune, Sprys; Ford Motor Company, USA. "Asbestos Emissions from Brake Dynamometer Tests". (Ref. as 13) 29. Gilson, J.C.; former Director of Medical Research Council Pneumoconiosis Unit, Penarth, UK. Personal communication to the AIA. * Former Director General of the AIA FMSI 03582 -530. "Asbestos Based Friction Materials etc. - Control and Safety Guide No.8". Asbestosis Research Council, Environmental Control Committee P.0. Box 18, Cleckheaton, Yorkshire, England. Dec. 1970 (Latest revision - March 1977). 31. "Safe Working with Asbestos - Friction and Anti-Friction Materials". ARC - See item 30. 32. "Recommended Work Practices - Fabrication and Use of Asbestos Friction Materials".AIA/NA- Asbestos Information Association of North America, Washington USA. 33. "Friction Materials Work Practices Guide". Friction Materials Standards Institute. Paramus, New Jersey, USA. October 1978. 14 January 1981 FMSI 03583 FRICTION MATERIALS STANDARDS INSTITUTE, INC., 3-210 ROUTE 4, PARAIIUS, N.J. 07652 BULLETIN N 0. 7 1 3 April 3, 1981 INSTITUTE COMMENTS ON SPA'S PROPOSALS FOR REPORTING AND RECORDKEEPING In January the Institute sent the Membership a copy of the Federal Register Notice of January 26, 1981, with its proposals for reporting and recordkeeping for asbestos products manufacturers. After this notice was mailed, we had two member inquiries asking if the Institute would be commenting on these proposals. We then asked the Membership for comments and subsequently prepared a letter of comments through the Institute's Health and Environmental Affairs Committee. The final draft was approved by Mr. Armstrong, the Committee Chairman, and copies were then circulated to the Board of Directors. The proposed comments circulated to the Board were then mailed to the Environmental Protection Agency on March 25, 1981. They requested comments by March 27, 1981. A copy of the Institute's comments to the EPA are enclosed. EWD/erc Enc: cc-Oelegates and Alternates Active Members - List C E. W. Drlslane Executive Director FMSI 03584 DRAFT INDUSTRIAL HYGIENE REPORT ASSESSMENT OF ASBESTOS EXPOSURE TO MECHANICS PERFORMING BRAKE SERVICE OPERATIONS INCLUDING RECOMMENDED PROCEDURE FOR ASBESTOS BRAKE AND CLUTCH SERVICING REPORT WRITTEN BY: Dennis R. Roberts Ralph D. Zumwalde DATE OF REPORT: April 27, 1981 REPORT #32.4 Industrial Hygiene Section Industrywide Studies Branch Division of Surveillance, Hazard Evaluations and Field Studies National Institute for Occupational Safety and Health Cincinnati, Ohio FMSI 03585 DISCLAIMER draft Mention of company names or products does not constitute endorsement by the National Institute for Occupational Safety and Health. 11 FMSI 03586 ABSTRACT draft NIOSH estimates that 151,000 U.S. mechanics and garage workers are poten tially exposed to asbestos brake friction materials. Therefore, NIOSH con ducted eleven industrial hygiene surveys to characterize dust exposures and work practices. Personal, general area, and bulk samples were taken and an alyzed for TWA and peak fiber concentrations by optical (opt.) and electron microscopy (TEM). Mechanics TWA and peak exposures varied depending on brake assembly cleaning methods and times. Eight of thirteen mechanics TWA's ex ceeded NIOSH recommended standards but all were within OSHA regulations. Peak exposures, during brake assembly cleaning, were higher (up to 15 fibers/cc) than respective TWA's (0.01 to 0.28 fibers/cc). Fiber levels for all cleaning methods except vacuuming were near the NIOSH ceiling and com pressed air cleaning often exceeded the OSHA ceiling. Background TWA's were similar for all facilities. TEM indicated lower fiber concentrations (>5 um) than opt. in most samples and revealed that 60% of the total fiber -population was <5 um long. TEM found 307. of the fibers were chrysotile, 20% forsterite, and 50% unknown; also, the geometric mean chrysotile fiber size aras 1.7 um length and 1.5 um diameter. The data suggest potential asbestos fiber exposures during brake servicing, principally brake assambly cleaning. Therefore, it is recommended that vacuum cleaning systems and NIOSH approved respiratory portection are used. ill FMSI 03587 CONTENTS Abstract....................................................................................................................Hi - .. Introduction......................................-.................................................... ................ 1 Brake Materials, Products, and Usage........................................................2 Historical Development of Friction Products............................ 2 Requirements for Brake Linings........................................................... 3 Types of Brake Linings and Manufacturing Processes............6 Brake Lining Repair and Maintenance Practices..............................8 Selection of Facilities Surveyed.......... .......................... 10 Description of Brake Servicing Operations................................10 Sample Collection and Analysis............. Airborne Samples.......................... .. Bulk Samples..................................... 14 ..................14 16 Vork Practice Characterization....................... 16 Compressed Air Blow-off......................... 16 Compressed Air/Solvent Mist Blow-off......................... .....17 Dry Brushing........................................... 17 Wet Brushing......................................... 17 Squirt-off.......................... 17 Vacuum Cleaning................ 17 Susmary of Survey Results.................................................................................18 TEM Fiber Characterization..........................................................19 Bulk Brake Dust.................... 21 Trace Metal Analysis........................... 21 Discussion.............................................. 22 Summary................................ 23 Conclusion............ ...........................................................24 Recommendations............. ...........26 References......................................... 28 TABLES 1. Fiber Air Sample Results.......................................................................... 31 2. Comparison Between TEM & Optical Microscopy Analysis....32 3. Fiber Size Data................................... 33 4. Trace Metal Analyses........................ >34 Attachment -- Recommended Procedures for Asbestos Brake and Clutch Servicing..............................................................35 INTRODUCTION A major objective of the National Institute for Occupational Safety and Health (NIOSH) is to determine environmental exposures of working populations through occupational health research, field surveys, and industrywide epidemiologic studies. Accordingly, NIOSH conducted comprehensive industrial hygiene surveys to characterize dust exposures resulting from vehicle brake servicing oper ations and to make a thorough assessment of work practices utilized, as well as document the types of personal protective equipment used. Of particular interest was the potential for exposure to asbestos fibers which could be generated by these types of operations. Limited studies of workers involved in brake servicing have suggested that their work-related exposures may be asso ciated with asbestos-induced diseases.* ' * ' NIOSH estimates that a workforce of 151,000 brake mechanics and garage workers 2 in the U.S. is potentially exposed to asbestos. Potential exposures are a re sult of 128 million pounds of asbestos used annually in the U.S. for the pro '3 duction of brake friction materials. Besides asbestos, other materials (e.g. binders, friction modifiers, fillers, etc-.) are used in the manufacture of brake linings, which can likewise have a potential for exposure. As noted in one study, thirty materials or compounds that make up the binders, fiber re inforcers, property modifiers, etc., were identified during brake lining manu- 2 facturing. 1 FMSI 03589 a: , ^ . - . ` BRAKE MATERIALS, PRODUCTS, AND USAGE Historical Development of Friction Products ' The requirements of early automobile friction materials were relatively mini mal. Passenger cars were light and designed for low speed operations. Brakes were of an external contracting type and utilized a variety of materials; this included leather and impregnated cotton products which were commonly used along with wool and felt. In 1903 woven asbestos friction materials were first marketed in the United States by the Keasbey and Mattison Company of Ambler, PennsylvaniaA Because of its superior heat resistance and durability they rapidly increased in use and soon dominated the market. The Model T Ford pro vides an example of the changing use of materials. Initially, cotton bands, reinforced with zinc, copper, or brass wire and impregnated with oils and bituminous material, were used for the brake bands. These were soon replaced by mixed cotton-asbestos materials and finally by woven asbestos products. The woven asbestos brakes continued to be the dominant product used in automobiles until about 1930. They typically contained 7071 or more wire-cored asbestos yarn, impregnated with drying oils, such.as linseed, and bituminous material. . ' Molded brake linings were developed in the early 1920's and gained increasing use with the introduction of internal shoe brakes in 1927. By 1940 virtually all automobiles were equipped with molded brake linings, although woven pro ducts continue to be used in trucks, heavy equipment and for specialized applications. The molded linings in use were cut to length, usually by the manufacturer, and mounted on brake shoes using rivets. Until the mid 1920's brakes were only mounted on rear wheels. However, with the development of internal shoes, four wheel mountings soon became standard, and by 1930, were , generally operated hydraulically. 2 FMSI 03590 DRAFT As automobiles were designed for use at even higher speeds, brake linings improved in both quality and performance. Various new materials were introduced as fillers, binders, and friction modifiers. In 1948 bonded brake linings were developed and soon accounted for approximately 40% of the original equipment brake market. Howewr,^ they rapidly dominated the replacement market because of the considerable savings in labor during installation. In 1965 the first disc brakes were introduced on American automobiles and rapidly increased in use. In 1975 virtually all original equipment cars had front wheel brakes of this type. However, because of less stringent braking requirements and the difficulty of adapting mechanical parking brakes to the disc configuration, the rear wheel brakes on 95% of currently sold cars are still of the drum variety. Requirements for Brake Linings A constant or slightly decreasing coefficient of friction (C.F.) with temperatures up to about 1000F is required for an efficient brake lining; values of from 0.30 to 0.45 C.F. are normally sought. Lower values produce brakes requiring excess pedal pressure and those with higher values are too sensitive to pressure and develop excess wear. Ideally, the desired frictional qualities should be maintained throughout the life of the lining material. During braking, chemical and physical changes occur in the material at the braking surfaces. These changes may produce an increase (build-up) or a decrease (fade) in friction. Satisfactory linings will fade slightly upon repeated applications, but will return to their initial state upon cooling.^ 3 FMSI 03591 draft Low wear of the linings is obviously desirable for economical and practical considerations. However, high wear resistance can be associated with the tendency of the lining to glaze, with a concomitant reduction in the coefficient of friction. This can be overcome by allowing a slow alteration of the brake lining material to occur. Pyrolysis of the organic I binders and thermal decomposition of the chrysotile fibers under braking provide the necessary continuing renewal of the lining surface. The lining should be non-abrasive to the drum surface. In addition to causing rapid drum wear, abrasive linings score the drums, which, in turn, leads to a rapid wearing of the lining. Drums made of cast iron and steel are common, with steel being the more susceptible to scoring. Since brake drums have a hardness of from 3.5 to 4.0 on the MOH (mineral hardness range of 1 to 15 in which talc is rated 1 and diamond 15) scale, virtually all lining materials used have lower hardness values. Other necessary or desirable properties of brake linings include: physical strength, dimensional stability, quiet operation, and safe and non-offen sive degradation products. Of the various properties desired in the lin ings, greatest attention is paid to build-up/fade and recovery characteris tics. Wear problems are not as serious and can more readily be overcome with the materials available. ,8,9,10 Compounding Ingredients of Brake Linings To achieve the desired friction properties, a wide variety of ingredients are commonly used in the manufacturer of automobile brake linings. These 4 FMSI 03592 Asbestos draft Asbestos is used for fiber reinforcement of the friction product. Chrysotile is used almost exclusively and comprises from 40 to 50 percent of the brake lining. Fiber grades 4 through 7 are used, and occasionally, several sizes are mixed or even calcined to improve performance characteristics. Amosite, crocidolite, or other amphibole asbestos varieties are not used because they are too harsh and tend to score the brake drums. Organic binders Organic binders are primarily phenolic type resins selected for high binding strength. Unmodified phenolic resins, when subjected to heat usually become hard and brittle. To prevent this, linseed, cashew nut, or China wood oils or cresols are added. Rubber, which also finds use as a binder, imparts desirable friction qualities and improves the flexibility of the lining material. Friction modifiers . V Friction modifiers are added to achieve a desirable coefficient of friction over all operating conditions. These modifiers also produce a more homogeneous lining surface. Included among these materials are lead, zinc, brass, cashew nut oil, graphite, and oxides of iron and copper. Fillers Fillers such as rubber scrap, barites, clays, silica, coke, coal and other minerals are used. These also have utility in achieving desired friction properties, in some cases through action as abrasives to recondition braking surfaces. It is important to note that one major purpose of the reconditioning 5 FMSI 03593 . - ..... '. draft agents is to retard the formation of forsterite which may accumulate on the * surface of the brake lining. Forsterite is a mineral not originally present in the brake material, but is created by dehydroxylation and recrystallization of chrysotile asbestos at high temperatures. The hardness of forsterite (hardness 6.5-7.0 on the MOH Scale) is such that it tends to score and gouge brake drums and discs (hardness 3.5), degrading them prematurely. Therefore, recrystalli zation of chrysotile to forsterite is an unwanted effect. Curing agents Curing agents and/or accelerators are used to assure that appropriate chemical reactions occur to produce the desired brake quality. Types of Brake Linings and Manufacturing Processes In making the of different types of brake linings various manufacturing processes are utilized to achieve a wide range of potential applications. These include: Wired Back These are made by a calendering process in which putty-like stock is formed 'Into a ribbon about a wire backing. The wire reinforcing serves to maintain strength during the curing process. Further, as linings of this type are in variably riveted, the wire reinforcing provides long term structural strength and prevents shearing of the lining at the rivets during braking. Linings of this type were extensively produced prior to World War II. They are in little use today. 6 FRASI 03594 Extruded Linings draft - *V--~ -- These are manufactured by extruding the soft plastic stock through an appro priately sized rectangular orifice. To minimize structural weakness in this lining, curing agents are added to produce a hard inflexible finished product. Sheet Linings These are laminated structures formed by winding a 0.001-0.002 inch film of stock about a hot roller. Since the fabrication process-is a relatively expen sive one, linings of this type are not commonly produced for general use. Dry Hixed Types This process involves the dry mixing of various ingredients capable of passing a 200 mesh screen, and then molding the lining under pressures of from 1000 to 3000 pounds per square inch. The resulting lining is among the most heat stable of friction materials in use today and obtains wide use in .the manu facture of brake blocks for heavy duty service. Millboard Type The manufacture of this type of brake lining material is by a process similar to that utilized.in the paper industry. Wet stock is formed and passed over rollers with various drying and baking operations producing sheets of uniform lining material. The equipment for producing such materials is expensive, but the volume of production leads to an economically produced molded lining. 7 FMSl 03595 BRAKE LINING REPAIR AND MAINTENANCE PRACTICES DRAFT ' To a large extent the changing character of brake lining materials has led to changing work practices and differing asbestos exposures over the years. From 192C until about 1930, when braking was done through the use of external brake bands made from woven materials, the predominant exposure to asbestos would have come from the cutting and fitting of the woven lining material. It is thought that airborne fiber concentrations were considerably less than those developed in later years when machining of molded materials was common. From 1927, when internal brake shoes were developed using molded linings, until 1948 when bonded brake linings were introduced, all internal brake linings were attached to shoes using rivets. The lining material for use in the replacement market would be precut' to appropriate size for various brakes or obtained from rolls of indeterminate length. The precut segments would usually be predrilled at the factory for rapid mounting on shoes. In some cir cumstances, however, drilling for the rivets and bevelling would be done by the mechanic installing them. The use of rolled linings required cutting the friction material to shape, drilling holes for rivets, and bevelling the edges appropriately. In this latter circumstance, asbestos exposure to workers could be considerable. Even when shoes with predrilled and bevelled linings were installed, the processes of punching out the rivets on the old shoes and riveting on of the new shoes would give rise to .greater exposures than that accompanying the use of bonded linings. 8 FMSI 03596 : - With the introduction of bonded linings, the need for drilling, facing, or grinding operations during installation decreased significantly. However, for a short period of time, in the mid-1950's when automobile shoes were first installed with a fixed anchor, some tapering was necessary on uniform thick ness bonded linings to achieve a proper fit. Previously, the end of the shoe opposite to that of the hydraulic cylinder could be mechanically adjusted. .7 .. Shortly thereafter, tapered bonded linings were available from the factory. Subsequent to 1960, considerably fewer bevelling or grinding operations were performed by an automobile mechanic replacing brake linings. During replacement of internal shoe brakes it was common practice to remove Che brake wear dust from the housing by air blowing or brushing. After 1970 increasing awareness of the hazards of asbestos and its presence in brake lining dust led to wet brushing, wet wiping, dry brushing, or vacuuming work practices in some brake servicing facilities. However, even today such iro- provements in work practices are not universal. ' In the 1930's and 1940's most automotive shops were relatively small and most mechanics performed all automobile maintenance and repair activities. In recent years, however, there has been an increasing tendency towards speciali zation, with shops existing for brakes and front end work exclusively. Here, while asbestos exposures during brake work on an individual job may be less than those of previous years, some workers are exposed for considerably longer periods of time. 9 FMSI 03597 SELECTION OF FACILITIES SURVEYED The purpose of the industrial hygiene study was to investigate and char acterize contemporary dust exposures resulting from vehicle brake mainten ance and repair operations taking into account the work practices utilized. Therefore, it was necessary to locate facilities where a variety of brake servicing techniques were used as well as where there were differences in number of vehicles serviced. Six of the eleven sites selected for the investigation were automobile brake service facilities which performed from 2 to 45 brake jobs per week at an average of 65 minutes per vehicle. One of the facilities surveyed only serviced trucks, which often required 6--9 hours per vehicle to service brakes, with an average of three brake jobs per week. The remaining four facilities serviced both autos and trucks and performed from 5 to 45 brake jobs per week which varied in service time depending on the type of vehicle. Detailed airborne dust sampling surveys were conducted at each facility. * . Description of Brake Servicing Operations The servicing procedures found at each facility were basically as follows. The vehicle is driven into a repair stall or bay for a brake system exami nation. Pending repairs, the wheels are elevated, removed, and then in spected. Loose dust is cleaned from the drums and brake assemblies by vacuuming, wet or dry wiping/brushing, using compressed air, or a com bination of these methods. Parts are then replaced or repaired as needed and the brake system is reassembled and adjusted. Test driving the vehicle for proper fitting and adjustment is the final phase of the servicing operation. 10 FMSI 03598 DRAFT A brief description of the individual facilities is outlined as follows. Industrial hygiene survey data collected at each facility are shown in Tables 1-4. -- Facility A Facility A, a private fleet service garage, was responsible for complete automotive maintenance and repair with the exception of internal engine repair and exterior painting. The shop normally operates 8 hours per day, 5 days per week. Of the seven employees working at the facility, only three were responsible for brake servicing. Brake servicing operations were performed (two to five jobs per week) in either of two service stalls. Facility B . -. Facility B, a municipal service garage, employed three mechanics that specialized in brake and clutch service and three employees that operated a separate brake repair shop specializing in brake shoe and drum recondi tioning. The brake mechanics serviced all vehicles which included, waste collection, dump, and light trucks, autos, and some 2-- and 3-- wheeled vehicles. The shop operated 8 hours per day, 5 days per week. Facility C At Facility C, a municipal garage, there was an average of one complete brake service job per day, taking about 5 hours per job, with most of the vehicles consisting of cars or light trucks. There were five employees responsible for brake servicing and the facility operated 8 hours per day, 5 days per week. n FMSI 03599 Facility D DRAFT At Facility D, a municipal garage, an average of eight brake jobs per day were performed on cars and trucks. Brake maintenance was performed by any of the 60 auto mechanics. The hours of operation were 8 hours per day, 5 days per week. Facility E Facility E, a private fleet service garage, performed complete automotive and light truck maintenance. The shop normally operated two shifts, 5 days per week, and there were usually four full-time mechanics per shift. About one brake job per week, per shift was performed. Facility F Although Facility F was an automobile brake service shop, front-end alignment and tire sales were also part of the shop mechanics' duties. The three full-time mechanics worked from two service stalls, 12 hours per day, 5% days let week. Brake maintenance operations consisted of 10 to 14 brake jobs per week. Facility G Major services at Facility G, an automobile brake service shop, consisted of front-end alignment, shock absorber servicing, and brake maintenance. The normal work week was made up of five, 9-hour days and one, 6-hour day. Three 12 pMSl 03600 service stalls were used by the three full-time employees for brake servicing operations during the 4 to 6 brake jobs per week. Facility H Major services provided at Facility H, an auto brake shop, were front-end alignment, shock absorber service, and brake maintenance. The three full-time employees worked from two service stalls, 9-hours per.day, 6 days per week. The number of brake jobs per week averaged from 20 to 30. Facility I Facility I was the largest of the automobile brake service shops surveyed. Other services provided by this facility were front-end alignment and shock absorber replacement or repair. The five full-time mechanics worked from four service stalls, 9 hours per day, 6 days per week. Brake maintenance operations consisted of 33 to 45 jobs per week. ~ Tacility J . The major services at this facility were front-end alignment, muffler in stallation, and brake maintenance. Automobile brake repair operations were performed by the shop's three employees and consisted on the average of 4 to 5 brake jobs per week. Normal brake servicing at this facility took about 1 hour and 45 minutes per vehicle. 13 * FMS1 03601 Facility K UrCMf Facility K, a truck brake maintenance facility, involved a somewhat dif ferent operation and exposure. Servicing operations were more complex and, therefore, involved more employees with fewer vehicles serviced than auto maintenance facilities. The four service bays at the facility were used by seven mechanics. Other service operations included pad grind ing, riveting, and punching (pad removed and/or replaced on shoe), sand blasting of old shoes, and milling of wheels. SAMPLE COLLECTION AND ANALYSIS Airborne Samples Personal and general air samples were collected at each facility on dif ferent occasions during a 3--year period. Brake servicing operations and areas not in the immediate vicinity of brake work within each facility, were monitored to provide overall asbestos exposure data. Personal air samples were collected in the breathing zone of the brake mechanics using Millipore Type AA, 37 millimeter (mm) diameter, 0.8 micrometer (pm) pore size, membrane filters at a calibrated sampling flow rate of 2.0 liters per minute (1pm). The filters were changed periodically during the work shift to prevent particulate overloading on the filter. Time-weighted average (TWA) fiber concentrations were determined for the time spent performing brake service at all facilities and peak concentrations deter mined for time spent cleaning brake dust from drums and assemblies. Samples for peak exposures were collected using Gast pumps calibrated at 11.0 or 10.6 1pm using identical media as above. At facilities B, C, and D, 14 FMSI 03602 a 2.0 1pm sampling train was used for peak samples. Analysis of the mem brane filters for asbestos fibers was conducted in accordance with the ' 11 procedures outlined by the Occupational Safety and Health Administration 12 and the NIOSH Manual of Analytical Methods P&CAM #239. These procedures require the counting of fibers greater than 5 micrometers (ym) in length and with at least a 3 to 1 length to width aspect ratio utilizing phase contrast optical microscopy at a magnification of 400-450X. Concentrations are expressed as fibers greater than 3 ym in length per cubic centimeter of air (fibers/cc). Random samples from each facility surveyed, as well as those samples having high fiber concentrations, as determined by the optical counting method, were analyzed on a transmission electron microscope (TEM) utilizing ' selected area electron diffraction (SAED) and energy dispersive X-ray analysis (EDXRA). Samples were observed at 17.000X magnification with fibers (> 3:1 aspect ratio) sized by length and diameter. SAED was at tempted on all observed fibers for possible identification. In addition, EDXRA was performed on individual fibers to determine their elemental composition. SAED patterns and EDXRA elemental spectrum ratios were com pared with reference minerals (UICC chrysotile, and forsterite obtained from the U.S. Smithsonian Institution). Sample preparation and analysis were performed using the NIOSH method described in the Technical Report "Review and Evaluation of Analytical Methods for Environmental Studies of Fibrous Particulate Exposure". 13 General area samples for trace metals (lead, zinc, copper, iron, and manganese) were collected at most facilities using Staplex Type TF-1A high-volume samplers at a flow rate of 10 cubic feet per minute, and 15 FMSI 03603 EaS^' 1 td n* a also with a sampling train and flow rate like that used for asbestos fiber collection. Samples were analyzed for metals by atomic absorption spectrophotometry in accordance with the NIOSH methods P&CAM Number 222, S186, S341, and S366.14,15 Bulk Samples Samples of brake wear dust were collected from the brake drums of several vehicles that were being serviced during the surveys. These samples were analyzed by TEM for characterization and identification of fibrous partic ulates and to determine fiber size distributions. WORK PRACTICE CHARACTERIZATION Considerable emphasis was placed during the surveys on detailing work procedures during brake servicing in order to document the types of clean - ing practices (i.e. vacuum, compressed air, brushing, etc.) used in replac ing brakes. As previously described in the section "Description of Brake Servicing Operations" the brake servicing work practices utilized were similar for all facilities surveyed; the major difference observed was the methodology utilized for clean-off of brake wear dust from the brake-- shoe/backing-plate assemblies. There were six different types of clean-off methods observed during the study. Those six methods are described as follows: 1. Compressed Air Blow-Off. A compressed air stream was used to blow away brake wear dust from the brake assemblies and drums. 16 FMSI 03604 2. Compressed Air-Stoddard Solvent Mist Blow-Off. The same as #1 except a spray gun containing Stoddard solvent was used to produce a solvent mist for blow-off. 3. Dry Brushing. Brake wear dust was brushed away with a small utility brush (usually 1" diameter). 4. Wet Brushing. Basically the same as dry brushing except the brush was kept saturated with a liquid such as gasoline, water, or Stoddard solvent. 5. Squirt-Off. A liquid squirt-bottle containing water was used to wash away brake dust. This was followed by drying off assemblies with a cloth. 6. Vacuum Cleaning. A shop type vacuum cleaner, equipped with a HEPA* filter, wab used in combination with compressed air. This system included a brake encapsulation cylinder that completely enclosed the brake-shoe/backing plate assembly. The mechanic ' operated a compressed air nozzle fixed inside the enclosure to blow off the brake dust, which was imnediately drawn into the vacuum system. A separate vacuum hose was used to vacuum the dust from the brake drums. In Methods 1 to 5, and especially 1 to 3, the brake dust has the potential to enter the ambient air of the facility. Conversely, in Method 6 the dust is contained by the HEPA filter which may be removed from the vacuum 17 pMSI 03605 cleaning system and disposed o. * '> i.* ysi era *HEPA: High Efficiency Particulate Air - 99.7% efficiency for 0.3 ym diameter aerosols. SUMMARY OF SURVEY RESULTS The optical microscopy fiber count analysis for the TWA, peak personal, and background area samples collected during the study are summarized In Table 1. The TWA and peak fiber concentrations for mechanics tended to fluctuate depending on the brake clean-off method used and the time spent performing the task. For example, regardless of the cleaning method utilized, peak exposures are high (up to 15.00 fiber/cc) when compared to their respective TWA exposures (0.01 to 0.28 fibers/cc). The differences between the TWA exposures and the peak exposures are most likely due to the brake assembly cleaning operation generating a higher dust level than the other repair steps. Peak exposures also varied from shop to shop. This is perhaps best explained by variations in work practices utilized, the inconsistencies in performing brake work that existed throughout the various repair shops, and because clean-off is done inter mittently and therefore represents a small percent of the work performed during the shift. For example, the amount of time spent servicing brakes and the number of brake jobs that were performed per shift differed among the mechanics; likewise, there were differences in cleaning methods (e.g., compressed air, brush, vacuum, etc.), and procedural techniques (e.g. distance from brake housing to breathing zone). In addition, there were some mechanics who dropped the brake drums on the floor, causing airborne 18 FMSI 03606 *'!*** '*v - '.ait 4 ii&W' i. V ilu u: dispersal of brake dust. Environmental conditions at each brake service facility, such as: shop size, ventilation controls, and open windows and doors would also affect individual worker exposure and background concentrations of airborne asbestos fibers. Regardless of the cleaning method utilized, TWA exposures for mechanics at all facilities were relatively consistent, and did not differ signifi cantly from their respective background (ambient levels in facilities) TWA exposures. The similarities between mechanic TWA and background expos ures suggest that all individuals in the immediate work environment are potentially exposed to the same fiber concentrations during a normal work shift. This observation is further supported by the fact that the mechanics spend much of the work shift away from the work site and in other areas of the facility. ' TEM Fiber Characterization Samples were randomly selected for transmission electron microscopy (TEM) with fibers sized by length and diameter. In addition, fiber concentrations (fibers/cc) were determined for total fibers and fibers >5 ym in length. These concentrations were compared to those found by the optical microscopy method and are reported in Table 2. In all but 3 samples, the concentra tions of fibers >5 ym in length determined by optical microscopy were somewhat higher than those determined by TEM. This difference could have been caused by particulate loss during sample preparation for TEM, or because of the small number of fibers actually counted on each sample; at low fiber counts, small differences in fibers counted by both microscopy 19 FMSI 03607 methods would have a significant effect in the calculation of fiber concen trations. Besides determining the concentrations for fibers >5 pm in length, total fibers observed were counted and concentrations calculated. As would be expected, the greatest proportion of fibers observed was shorter than 5 pm in length (80 to 90%). Fibers observed by TEM were identified utilizing SAED and EDXRA. Approx imately 507. of the fibers analyzed by SAED could not be identified due to ambiguous diffraction patterns. The remaining fibers which were identi fied indicated the presence of chrysotile (''<307.) and forsterite (`'<20%). The presence of fibrous forsterite was probably due to the dehydroxylation and recrystallization of chrysotile as a result of high temperatures (>650C) encountered during braking.Some of the fibers which revealed ambiguous diffraction patterns appeared to have crystalline structures similar to both chrysotile and forsterite (probably a transition intermed- 2 iate ) while others were too small for diffraction analysis. EDXRA was performed on the fibers to confirm the SAED analysis that was made for the chrysotile and forsterite fibers. Some of those fibers which gave ambiguous SAED patterns indicated magnesium, silicon, and iron in various elemental ratios. As shown in Table 3, when a fiber size distribution was performed for all fibers observed by TEM, a geometric mean length of 1.66 m, and a geometric mean diameter of 0.14 m were determined. Likewise, for those fibers identified as asbestos (chrysotile) a geometric mean length and diameter of 1.70 pm and 0.15 pm were determined, respectively. 20 FMSI 03608 Samples of brake wear dust were analyzed by TEM in the same manner as the airborne samples. Identification was attempted on all fibers using SAED and EDXRA. Approximately 45% of the fibers analyzed by SAED could not be identified due to ambiguous or the absence of diffraction patterns. EDXRA was performed on all fibers observed with elemental analysis being successful on about 707. of the fibers. When utilizing SAED and/or EDXRA many of the fibers observed were positively identified as chrysotile (407.) while the remaining were either forsterite (20%) or unknown (407.). Many of the unknowns were thought to be intermediate recrystallized forms between chrysotile and forsterite. In addition, a fiber size distribution was performed which indicated somewhat shorter lengths (0.24-5.88 ym vs. 0.24-10.0 ym) and smaller diameters (0.06-0.29 ym vs. 0.06-1.0 ym) than those observed in the airborne samples (Table 3). Trace Metal Analyses ' ' . Trace metal analyses were performed on airborne samples collected at Facilities B, C, D, I, and K with the results reported in Table 4. Samples were analyzed for the following metals: lead, iron, zinc, copper, and manganese. As noted in Table 4 the metals were, often non-detectable (n.d.) or found in trace amounts that were always below the 0SHA and NI0SH expo sure standards. The range of concentrations for all facilities were: Pb, n.d. - 63.3 yg/m3 ; Fe, n.d. - 1.5 mg/m3 ; Zn, n.d. - 352 yg/m3 ; Cu, n.d. - 8.7 yg/m3 ; and Mn, n.d. - 3.5 yg/m3 . 21 FMSI 03609 DISCUSSION V .-.-L V 3 fciajJS*' j3 The human toxicological significance for the inhalation of chrysotile asbestos fibers is well documented; and instances of mesothelioma in auto repair workers have been identified.In a detailed examination of 90 union vehicular maintenance workers in New York City,* with 10 or more years of shop work, 297. had decreased vital capacity; the percent age increased with age and most markedly after 20 years from the outset of auto work. Many of the workers examined showed signs consistent with asbestosis, with observed changes noted in chest x-rays and indication of restrictive pulmonary function. The prevalence of these changes was significantly higher after 20 years exposure, a result expected after occupational exposure to asbestos.*^ Unlike chrysotile, the health effects of exposure to forsterite, or transi tion series fibers (chrysotile/forsterite) with altered crystalline 20 structures are not well documented. In studies by Davis and Coniam, and Koshi21 in which fibers of chrysotile, chrysotile/forsterite, and forsterite were injected into the pleural and peritoneal cavities of mice, the results suggested varying degrees of toxic effects. Fiber implantation animal studies conducted by Pott, et. al. 22 ' 23 and Davis, et. al. 24 suggest that the morphology and size of a fiber, regardless of fiber type, are responsible for its carcinogenicity. Likewise, Stanton, et. al. 25 suggests that fibers <1.5 p-m in diameter and >8 pm in length pose the greatest risk in producing pleural sarcomas. These studies tend to suggest that the physical morphology (size dimensions), and to a lesser degree chemical and surface characteristics of a fiber are the determining factor for inducing a biological effect. The precise fiber dimensional 22 FMSI 03610 ife-TyJ**1 i:m'V"* i. ^$ characteristics required for thes_e observed pathologic responses have been difficult to determine experimentally because of the difficulties encountered in producing fibers of specific size dimensions. SUMMARY The TWA airborne asbestos sample results for all facilities were within the current OSHA asbestos standard. 26 This standard states: "The 8-hour time-weighted average (TWA) airborne concen tration of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micro meters in length, per cubic, centimeter of air (fibers >5 ym/cc). The ceiling airborne concentration to which no employee may be exposed shall not exceed 10 fibers >5 ym/cc." . However, two of four peak sample results for samples collected at Facility I (Table 1) during the compressed air cleaning of brake assemblies exceeded the OSHA ceiling standard. The compressed air cleaning method also indi cated the highest overall peak exposures (up to 15 f/cc) for all cleaning methods examined. When the overall TWA and peak sample results are compared to the NIOSH recommended standard for asbestos, 8 of 13 of the TWA exposures for mechan ics indicated concentrations exceeding the recommendation. This standard recommends an 8-hour TWA exposure of 0.1 fibers >5 ym/cc (fibers/cc) with a ceiling exposure of 0.5 fibers/cc for any 15-minute sampling period. 23 FMSI 03611 t ;' Many of the samples collected yielded such low fiber counts that their coefficient of variation (CV^) was above what is considered reliable (i.e. greater than 0.38). 27 Consequently, the fiber concentration data are best utilized for comparing exposure variations among the different cleaning methods/work practices. V J4j CONCLUSION 12 The results of this and other studies ' indicate varying concentrations of asbestos fiber exposure to brake mechanics. The exposure concentra tions are apparently affected by the work practices utilized, and the existing environmental conditions and controls at each facility. The results of this study show that 8 of 13 of the mechanics engaged in brake service had TWA fiber exposures above the NIOSH recommendation, however, all TWA exposures were below the OSHA standard. Furthermore, when samples were analyzed by TEM, only 30% of the fibers observed were identified as asbestos with the remaining fibers being categorized as forsterite (20%) or unknowns (507.). As a result of the TEM analysis the interpretation of the asbestos concentrations, as determined by optical microscopy, is questionable. The analysis indicates that actual asbestos fiber concen trations (>5 pm length) are often less than those reported (see Table 2). However, this does not preclude the possibility of high airborne asbestos fiber concentrations when all fiber size ranges are considered. As deter mined by the TEM analysis in this study and from other reported studies28 ' 29 a significant number (up to 1007.) of short fibers (<5pm in length) are always present (see Table 2) and research 25 has indica ' 24 FMSI 03612 ted that a potential health risk exists for asbestos fibers <5 m in length. Also, a potential health risk may exist for the unknown fibrous portion (007.) of brake dust. The results of animal studies in which ' 22 23 24 30 various size fibers were implanted--in animals ' ' ' concluded that the physical morphology (size dimensions), and to a lesser degree chemical and surface characteristics of a fiber, are the determining factor for inducing a biological effect. The mechanics surveyed during this study were either full-time brake mechanics, who performed only brake maintenance service and may have serviced up to five cars per day/six days a week, or mechanics who under took as few as one brake job per week. Regardless of the number of brake jobs performed (per work shift), the TWA fiber exposures were similar for all the mechanics surveyed. The exposures to mechanics who performed full-time brake work were not significantly higher than the exposures for those who did much less brake servicing. Conversely, the short term (<-3 minutes) peak exposures encountered in this study during the dust clean-off of braking assemblies were often higher when compressed air was used. All of the cleaning methods surveyed, except for vacuum cleaning, had peak fiber concentrations that were near or above the NIOSH-recommended ceiling exposure level of 0.5 fibers/cc. However, the compressed air cleaning method was the only type which ap proached, and in two cases even exceeded, the OSHA ceiling exposure limit of 10 fibers/cc. These findings strongly suggest that brake mechanics are at a higher risk of airborne exposure to asbestos fibers during the cleaning of brake assemblies, except when the vacuum cleaning methods 25 FMSI 03613 are properly utilized. The peak fiber exposures found for mechanics during the cleaning of brake assemblies were higher than most of the TWA exposure concentrations. However, there is some question as to the accuracy of the fiber counts from the analysis of the peak samples since the number of fibers counted were small, resulting in a large coefficient of variation. 27 RECOMMENDATION S The data from this study suggests that a potential for airborne fiber exposure exists during brake servicing operations, principally during brake assembly cleaning. While the fiber exposures reported do not repre sent 1007. asbestos fiber, a potential health hazard still exists since at least 307. of the fibers are asbestos. Also, the other fiber types may be pathogenic since animal studies suggest that fiber shape and size may be more important than chemical nature in terms of biological activity. Furthermore, the possibility exists for exposure to much higher asbestos fiber concentrations for fibers <5 pm length. Since there is no known safe asbestos fiber exposure level31 , and clinical evidence from a study of union vehicular maintenance workers reports that over 257. had evidence of x-ray abnormalities consistent with asbestosis, it would seem prudent to conclude that a potential health hazard exists during the performance of brake maintenance operations. Therefore, it is recommended that appropr iate control measures for reducing exposures, especially during brake assembly cleaning, be instituted at brake maintenance facilities. This 26 FMSI 03614 would best be accomplished by using an appropriate vacuum cleaning system to remove all dust from brake assemblies and drums. Above all, any blow-off of brake dust by compressed air must be eliminated. To further protect the health of the brake mechanics, it would be advisable to initiate a personal respiratory protection program. This would include the wearing of NIOSH approved respirators for asbestos, a program for proper fitting, and a routine maintenance program for the cleaning and replacing' of respir ator filters. As the exposure data indicates, it would only be necessary for mechanics to wear respirators while performing brake assembly cleaning. In order to minimize asbestos dust exposures to vehicular mechanics per forming brake and clutch maintenance NIOSH has prepared guidelines "Recoamended Procedures for Asbestos Brake and Clutch Servicing" (see Attach ment 1) to be utilized during those types of work tasks. 27 FMSI 03615 `vko, Ww -ai Mi. , ' * s' su REFERENCES 1. Lorimer, W.V., Rohl, A.N., Miller, A., Nicholson, W.J., and Selikoff, I.J. "Asbestos Exposure in Brake Repair Workers in the United States". Mt. Sinai Journal of Medicine, 43:207-218, (May-June 1976). . 2. National Occupational Hazard Survey. U.S. Dept, of Health and Hunan Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety and Health; estimate, April 1981. 3. Stanford Research Institute (1976). Chemical Economics Handbood, 712.1000C, October 1977. 4. Much of the historical information on the development of fricition products was obtained from interviews by Dr. William J. Nicholson, Mount Sinai School of Medicine, with Edward W. Drisane, Friction Materials Standards Institute, Paramus, N.J., Harry, H. Wagner, Jr., Molded Materials Co., Ridgway, Pa. 5. Keasbey and Mattison products catalog, 1926. Ambler, Pa. 6. Friction materials on automotive brakes. Fleet Owner, (August 1963). 7. Carroll, W.G. The manufacture of brake linings. British Plastics 414--417 (August 1962). 8. Anderson, A.E., and R. Gealer. Ford Motor Co., Detroit, MI. Unpublished notes. ' 9. White, Andrew J., Brake Dynamics: an introduction to brakes at the inspection station level. Motor Veh. Resh. of N.H., Lee, N.H., Chapter 11, 463-472% (1968). 10. Rohl, A.N., et al. Asbestos exposure during brake lining. 11. U.S. Code of Federal Regulations, Title 29, part 1910.1001. U.S. Department of Labor, Occupational Safety and Health Administration, ' Occupational Safety and Health Standards. 12. Taylor, D.G., (1977). NIOSH Manual of Analytical Methods. 2nd Edition, Volume 1, P&CAM No. 239, Publications No. .77-157--A. 13. Zumwalde, R.D;, and Dement, J.M., (1977). Review and Evaluation of Analytical Methods for Environmental Studies of Fibrous Particulate Exposures. DHEW (NIOSH) Publication No. 77-204. 14. Taylor, D.G., (1977). NIOSH Manual of Analytical Methods. 2nd Edition, Volume 1, P&CAM No. 222, Publication No. 77-157-A. 15. Taylor, D.G., (1977). NIOSH Manual of Analytical Methods. 2nd Edition, Volume III, S186, 341, 366 Publication No. 77-157-C. 28 FMSI 03616 16. Newhouse, M.L. and Thompson, H. Mesothelioma of pleura and peritoneum following exposure to asbestos in the London area. Brit. J. Ind. Med. 22:261-269, 1965. 17. McDonald, A.D. et al. Epidemiology of primary malignant mesothelial tumors in Canada. Cancer 26:914-19, 1970. 18. Greenberg, M. and Lloyd Davies, T.A. Mesothelioma Register 1967-1968 Brit. J. Ind. Med. 31:91-104, 1974. 19. Bader, M.E., Bader, R.A., Teirstein, A.S., Miller, A. and Selikoff, I.J. Pulmonary function and radiographic changes in 598 workers with varying duration of exposure to asbestos. Mount Sinai J. of Med. 38:492-500, 1970. . 20. Davis, J.M.S., and Coniam, S.W. Experimental Studies on the Effects of Heated Chrysotile Asbestos and Automobile Brake Lining Dust Injected into the Body Cavities of Mice, Experimental and Molecular Pathology, Volume 19, pp. 339-353 (1973). 21. Koshi, K., Hayashi, H., and Sakabe, H. Biological and Mineralogical Studies on Serpentine Minerals in Heat Treated State, Ind. Health, Volume 7, pp. 66-85 (1969). 22. Pott, F., Huth, F., and Friedricks, K.H. Tumorigenic Effect of Fibrous Dust in Experimental Animals. Environmental Health Perspectives, Volume 9, pp. 313-315 (1974). `23. Pott, F., Dolgner, R., Friedricks, K.H., and Huth, F. Animal Experiments Concerning the Carcinogenic Effect of Fibrous Dusts. Interpretation of Results Considering the Carcinogenesis in Humans. Annales d'Anatomie Pathologique, Paris (1976), Volume 21, pp. 237-246. 24. Davis, J.M.G. The Fibrogenic Effects of Mineral Dusts Injected into the Pleural Cavity of Mice, British Journal Exp. Pathology, Volume 53, pp. 190-201, (1972). 25. Stanton, M.F., Layard, M., Tegeris, A., Miller, E., May, M., and Kent, E. The Carcinogenicity of Fibrous Glass: Pleural Response in the Rat in Relation to Fiber Dimension. J. Natl. Cancer Institute 58:587-603, (March 1977). 26. U.S. Code of Federal Regulations, Title 29, Part 1910, Section 1910.1001. 27. Leidel, N.A., Bayer, S.G., Zumwalde, R.D., and Busch, K.A. NI0SH Technical Report "USPHS/NI0SH Membrane Filter Method for Evaluating Airborne Asbestos Fibers". DHEW (NI0SH) Publication No. 79-127, February 1979. 29 FMSI 03617 ^-v-- * ' : -* ' 28. Bayer, S.G., Zumwalde, R.D., and Brown, T.A. Equipment and Procedures . for Mounting Millipore Filters'and Counting Asbestos Fibers by Phase . Contrast Microscopy. Available from U.S. Department of Health and Human Services, National Institute for Occupational Safety and Health. 29. Gillam, J.D., Dement, J.M., Lemen, R.A., Wagoner, J.K., Archer, V.E., and Blejer, H.P. Mortality Patterns Among Hard Rock Gold Miners Exposed to an Asbestiform Mineral. Annals of the New York Academy of Sciences. 271:336--344, 1976. 30. Stanton, M.F., Blackwell, R., and Miller, E. Experimental Pulmonary Carcinogenesis with Asbestos. Am. Ind. Hyg. Assoc. J. 30:236--244, 1969. 31. U.S. Department of Health and Human Services, Public Health Service, National Institutes of Health. Asbestos: An Information Resource. DHHS Publication Number (NIH) 79-161. May 1978. 30 FMSI 03618 4' ' A\ r` 4 *4 Ip <*r? 3-' a- } 31 FMSI 03619 C leanlne Method Camprasaed A ir Compressed A ir Compressed A ir Compressed A ir Comptessed A lt . Compressed A ir Compressed A ir Compressed A ir Compressed A ir ' -Compressed A ir -S o lv e n t M is t Compressed A ir -S o lv e n t M is t Comptessed A ir S olvent M ist -Comptessed A it S olvent M ist f . Dty Brush Dry Btush -. Wet Brush Wet Brush Wet Brush Wet Brush Liquid S q u irt B o ttle Vacuum C le a n in g Vacuum C le a n in g Vacuum C le a n in g r* - PM l- Q Q O O O O A bXUM HHHH OOUOU x4d1 0> o 9>u 9* M9 Em ploys* Sampled M echanic 8 1 M echanic 81 M echanic # 1 M echanic 8 1 M echanic 81 M echanic 81 Mechanic 82 Mechanic 82 M echanic 83 M echanic 8 1 1 M echanic 8 1 M echanic 82 M echanic 82 Mechanic 8 1 M echanic 8 2 Mechanic 8 l M echanic 82 M echanic 82 M echanic 83 M echanic 81 M echanic 81 M echanic 81 M echanic 81 u. O P O O` O OOO O O O O OO 989(00 O CM a? O (A 40* 0CM00 N04HPp> 9n<90 409d490O - O O cm NO*44 0+ -auu mu ad 9 0*1 40 9m md md 91 N P- pb a* Jt 0 a. O9m<dOcmmdO9a8d 0m O> n W <91r <4N O* O* 4m0d CenOd 9O8 H md ^ 1 fa > cm e o X w | Sample T im e (S e c .) 0 9 0 id Sample Volume (L ite rs ) 1 1 TWA E x p o s u re s ** 1 0^ *- * g. 6 e & ** HZ CO w 1- - - | - - F- - - i- b- - -e- - -r- s- - -/- - - - - 1 j c c * ____ 1 Sample I 1 Volume | F ib e r * / |i (!___ L it e r s ) ___1L___ i ____11 6o 9 O U 0 Ji U as Sample ;T im e 1| Pn )_ ]1 a n ui m 9 u w * Sample Volume (L ite rs ) * sr -- 0 M0l 0 a o 0 p O m ** m m 4 n 0 .0 3 0 .0 1 3 F- <N* CM* A* r*. O *A <A 4 4 4 n n omnm 0 cn . 0 m ^ <o 0 </> 0 NS ^ n po 4 p> n 9 *> 0 0 <044 nnn <n co O 9 pb o^OO <e4nn n 0 4 -* m n -4 0 n O 0 n*4 Om *s a* 4 w m O 9M 0 .1 2 0 .1 0 0 .1 9 0 .0 8 0 .0 7 0 .2 0 0 .1 9 0 .2 3 0 .2 8 ' 0 .2 4 . 0 .2 1 0 .0 1 nw nn n m nnn <4 N 4 <0 n 90 ao 4 0 , v> m <n pv n 4 0 0n m m4 a n 9 n p- mo <0 o ao 0 cn n c -4 r* o 0 .1 0 0 .0 8 0 .1 3 0 .0 4 0 .0 3 ' '0 .0 7 0 .0 3 0 .0 7 0 .0 7 0 .0 7 0 .0 6 . 1 j ! 0 .0 1 co ^ o o o o N 0 N P4 N p* p p> r 4n O O O ^ a 440 4m n n n O4*8 O4 00 OmdO0m4&dnO4n ... 0) p n n OO0 so lA r*> A r n F ib e r* > 5 urn In le n g th o c r c u b ic c e n tim e te r o f sampled s i t Table 2 Air Sample Results For Fibers Comparison Between TEM and Optical Microscopy Analyses Optical Microscopy >5 pm in length fibers/cc Transmission Electron Microscopy >5 pm in length Total Fibers 7. Fibers fibers/cc fibers/cc >5 pm in length 0.54 6.0 0.58 1.18 0.13 6.84 5.59 0.82 0.01 0.01 0.02 0.38 1.44 0.01 0.26 0.24 0.06 0.12 0.01 0.03 0.0 (Blank) 0.12 0.17 0.18 0.06 0.12 0.25 5.97 0.17 0.67 0.10 0.07 0.33 0.02 0.0 0.0 0.19 0.16 0.0 0.0 0.09 0.04 0.0 0.01 0.0 0.0 0.0 0.42 0.10 0.14 0.05 0.50 0.50 11.33 1.01 2.35 0.74 0.43 0.39 0.02 0.11 0.0 2.72 0.48 0.08 1.43 0.09 0.16 0.0 0.01 0.03 0.0 0.0 0.86 0.20 0.43 0.15 0.73 50 53 17 29 14 17 83 100 0 0 14 33 0 0 100 25 0 100 0 0 0 48 50 33 33 68 * Note: Fibers counted by TEM represent asbestos fibers only. 32 FMSI 03620 Brake Dust F ib e r S ize Data O *H Is u> 00 EQ o 0* o *o 4J CO o H *4 E 4J 0 EC XO0 aJJ 0 0 6 s r-* CM CM O r- O' o <oo CM CM >0 V0 o o o m O' ^4 O' ^d e o O O NO 00 U 0 o o r 00 *4 m H 0 1 11 Us U -d d C CM CM CM CM o0 OS o o o >s CooL 0ou o 0 uu 6o u 00 6^ 3 Us Z H m CO CM m 00 Oo' H4oOi ua <44 o eo o r* 0 W> 4J 0 S0 r* CO CO 0E Q CO n lT| o CM CM 0 *o c<Us(A3 o *J H CO ->D> E 3 o u 4J U0 0 c 0 4J O 4) 0 E S) o s 0 m *-4 e o -4 o o ^4 o 0o0 o *3 c0r4 M 404OJ) o w 0 o e O 00 ON CM *40<oJ4 JO ^4 H 0 oo 0) U* oc 1 c a0s >o0 \o0 o NoO o i NoO o N *4 (0 .uO0 0 Vi h0 0 -O < ,0 6 U m CO CM 03 O' o 03 ^4 u-> H 4JZ <44 zoo O6 0u aE jS 0 Us CO 0 0o uoC U 0 0 0A 4H <0 < 0 0 a 6 00 CO M 0 0 .0 C *o M Us O A r- U 9-k n< oe 30 .Om O >4 U. 0 X0 |04 4OJ A0 0 .* A ^0 3< A N-' 4J 0 Q3 0 0U X0 0A u H A Us X 4 n4 3< A 'W' ee FMSl 03621 Trace Metal Analysea vO tn o* o o o m* * ooo n * ao c 1 1 1 1o x z CO o o o o am o oo z 1 3 o* E cn CM CM r- * * w ooo eo o 3 ao 3 t 1 I 1o 1 mo e CM CM z o Q C3 vl o o E 4J Z u Jri 3 c E *3 o cn (O m O' > ec <0 c oo ooo CM 3 * *3 fc e n o o Q o <n o w O 4 e N i I 1 i i *o o CO o 4J c m 3 m s CM o en o tn o a e (0 a 4J to *3 c zz u pj to 14 t* 03 u 4-1 cn 00 cn O 00 a o X CM p4 O' CM Ed X Of <* CO m < fc O too c X o 1-4 (8 9) K U* i 1 | 1 1 to o o o 2 i r- CM lA aa H *-4 zz 4>1s n O' 00 . r> o oo o Cl <<e8 oCM 'O CM A o >s Q* l 1 1 1 1 m o 4 c CM m -* *4 O' o Q Q H ZZ TU<JU US3, u 3S (ft* a SB 4J -a "O0) 303 Q >%*o 4J *4 H > M u QM* o <0 3 k to X0 4J 0 c o u Hc a-- 2 Ou c H a- O 1 *"< N O C O * ** * ** * ** 2* 34 f m t*a*r?Ti * V;>S *cmmS FMSI 03622 ATTACHMENT I RECOMMENDED PROCEDURES FOR ASBESTOS BRAKE AND CLUTCH SERVICING The National Institute for Occupational Safety and Health (NIOSH) has conducted research on dust exposures which are generated during brake and clutch servic ing. Based on data demonstrating the potential for significant asbestos expo sures during brake and clutch servicing, NIOSH has investigated various work practices which are utilized in reducing asbestos exposures. These investiga tions have indicated vacuum cleaning systems to be the most effective method for minimizing asbestos dust exposures during brake and clutch servicing.* Vacuum cleaner testing have demonstrated that these units operate reliably 2 within design specifications. Therefore, NIOSH recommends vacuum cleaning as the primary method to be used for cleaning of asbestos dust during brake and clutch servicing operations. The following are additional procedures recommended by NIOSH to minimize asbestos dust exposures. 1. Where possible, an area shall be designated for brake and clutch repairs and servicing. Entrances into this area shall be posted with the following asbestos exposure warning sign printed in letters of sufficient size and contrast to be readily visible and legible: Asbestos Dust Hazard Avoid Breathing Dust Wear Assigned Protective Equipment Do Not Remain in Area Unless Your Work Requires It Breathing Asbestos Dust May Be Hazardous to Your Health FMSI 03623 ,, . . ................ . ............. , ... . ... ..........,, -=- 4 \ i'A.f I 2. Dust shall first be cleaned from brake drums, brake backing plates, brake assemblies, and clutch assemblies using an industrial type vacuum cleaner equipped with a high efficiency particulate air filter system (HEPA-greater than 99% efficiency for 0.3 pm diameter aerosols). After vacuum cleaning, any remaining dust shall be removed using a water dampened cloth or rag. Under no circumstances shall compressed air or a dry brush be used for cleaning. If vacuum cleaning equipment is not available the wet brush cleaning method may be used until a vacuum cleaning system in obtained. Where wet brushing is necessary for cleaning, a NIOSH certified respirator approved for asbestos shall be worn. 3. During brake pad grinding, riveting, and punching operations local exhaust `# ^ . ventilation and dust collection systems shall be designed, installed, and -maintained in accordance with the American National Standard Fundamentals Governing the Design and Operation of Local Exhaust Systems, " ANSI Z9.2 - 1977 to meet the asbestos airborne exposure standard. 4. During clutch servicing, a NIOSH certified respirator approved for asbestos shall be worn during the removal and cleaning of the clutch, pressure plate and housing assembly, and during installation o-f the new clutch assembly. Whenever possible, cleaning shall be performed with an HEPA vacuum system as described in (2) above. . 5. All cable and floor cleaning in areas where brakes and clutches are re paired shall be done with the HEPA vacuum cleaner as described in (2) above. Grinding and riveting machines- shall also be cleaned with such a 36 FMSI 03624 cleaner and the remaining dust wiped with a water dampened cloth. A N10SH certified respirator approved for asbestos shall be used during this cleaning. ' 6. If not in effect, a respirator program shall be established in accordance with the Occupational Safety and Health Administration (OSHA) Standards, Title 29, U.S. Code of Federal Regulations (CFR), Part 1910.134. 7. HEPA vacuum cleaner filters containing asbestos dust, cloths or brushes used for wiping brake and clutch assemblies, and all liquid used for wet brushing shall be disposed of in accordance with U.S. Environmental Protection Agency (EPA) regulations. These regulations state that the asbestos waste shall be disposed of in sealed impermeable bags or other containers at a disposal site which meets EPA criteria for asbestos dispos al. Also, the waste containers shall display the following warning label or tag printed in letters of sufficient size and contrast to be visible and legible: .* CAUTION Contains Asbestos Fibers Avoid Breathing Dust Breathing Asbestos Dust May Cause Serious Bodily Harm - The EPA regulations for proper asbestos waste disposal are detailed in Title 40, CFR, Part 61, Subparts A and B. FMSI 03625 8. A NIOSH certified respirator approved for asbestos shall be worn during . removal of vacuum bags which contain asbestos dust. ' 9. Consumption of food and beverages shall not be permitted in work areas where asbestos exists. An area designated for food consumption shall be separate from the work area so as to provide maximum protection against asbestos dust contamination. 10. If the employee is exposed to airborne concentrations of asbestos fibers which exceed the OSHA ceiling level, the OSHA requirement regarding special clothing, change rooms, locker, etc. as detailed in Title 29, CFR, Fart 1910.1001 (D) shall be followed. The current OSHA asbestos standard is as follows; the 8-hour time-weighted average (TWA) airborne concentrations of asbestos fibers to which any employee may be exposed shall not exceed 2 fibers, longer than 5 micrometers in length per cubic centimeter of air (fibers >5 pm/cc).The ceiling airborne concen tration to which no employee may be exposed shall not exceed 10 fibers >5 pm/cc. ' OSHA in 1975 proposed an 8-hour TWA of 0.5 fibers >5 pm/cc with a permissible ceiling exposure of 5 fibers >5 pm/cc for any period not exceeding 15 minutes. NIOSH currently recommends that the TWA exposure to asbestos be 0.1 fibers >5 pm/cc with a ceiling exposure of 0.5 fibers >5 pm/cc for any 15--minute sampling period. 38 FMSI 03626 NOTE: Strict adherence to the above procedures should minimize exposures to employees duting brake and clutch servicing. These recommendations are based on the results of research conducted by NIOSH. Prepared By: Division of Surveillance, Hazard Evaluations, and Field Studies National Institute for Occupational Safety and Health Cincinnati, Ohio 39 FMSI 03627 FRICTION IIATERIALS STANDARDS INSTITUTE, IHC., 2-213 ROUTE 4, PARAIIUS, N.J. 07652 BULLETIN N 0. 7 0 6 January 29, 1981 ENVIRONiIENTAL PROTECTION AGENCY (EPA) PROPOSALS FOR REPORTING AND RECORDICEEPIMG FOR ASBESTOS IIANUFACTURERS, E1P0RTERS AND PROCESSORS The EPA's Office of Toxic Substances ha3 proposed requirements for asbestos prod ucts manufacturers, importers and processors on the reporting on asbestos usage. These proposals are authorized in Section S (a) of the Toxic Substances and Control Act (TSCA). To indicate how far-reaching these reporting requirements are, one can note the following from the first page of the proposed rules: Importers include those persons who import asbestos in bulk form, or as part of any product. Thus, persons who import automobiles that contain asbestos brake linings are "manufacturers" of asbestos for purposes of TSCA. A brake lining or clutch facing manufacturer in the United States would be a primary processor as he uses raw asbestos in the friction product. He would also be a secondary processor when he assembles brake linings to shoes. A party who imports lined or unlined shoes would be a "manufacturer" as indicated above. A rebuilder who purchased brake linings for assembly would be a secondary processor. For more authoritative definitions, please refer to Page 8213 of the January 26, 1981 Federal Register, copy enclosed. The Institute is enclosing the notice as it appeared in the Federal Register of January 26, 1981. We have enclosed Pages 8200-8214 only. The forms that are referred to take an additional 35 pages (to Page 8249). If Ilembers wish a copy of these additional pages, please request them of the Institute Office. It should be noted at this time that this notice Is a proposal. As noted, the EPA will accept written comments relative to this proposal which are submitted on or before Uarch 27, 1981. While this is a far-reaching rule if adopted, a rule of this nature would be expected based on the reading of TSCA and the inititatives that the Office of Toxic Substances has already taken in the asbestos area. EWD/erc Enc: E. N. Drislane Executive Director Copies: Delegates and Alternates Health and Environmental Affairs Committee Active Ilembers - List C Regional Ilembers Licensees FMSI 03628 TaUPHOttl (IOII *48-0440 FRICTION MATERIALS STANDARDS BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUB. N. J. 07882 INSTITUTE, INC. May 12, 1980. Mr. Richard Guimond Environmental Protection Agency Office of Toxic Substances 401 M Street SW Washington, D.C. 20460 Dear Rich: You will recall that we met with a group from EPA in Washington on January 3, 1980 concerning information needs of your office. We stated that we would circulate our Members to get answers to some of the questions that you had asked concerning non-asbestos lining. Our questions were in the area of automotive disc brake lining only. Respondents asked that their submissions be kept confidential. I am not therefore disclosing the names of those who answered the questionnaire.^ I feel they are representative of the industry. I have enclosed a copy of the summary of replies that I received relative to this questionnaire. I had earlier sent you information on usage of non-asbestos disc brake lining on passenger cars and light trucks. This listing included information as to whether there was an asbestos backing with the non-asbeatos linings, and where the usage was both inner and outer, or inner only or outer only with asbestos material at the other position. 1 believe these answers should give some background as to usage, advantages and problems with the non-asbestos disc brake linings. EWD/lmc Sincerely, . FRICTION MATERIALS STANDARDS INSTITUTE p. i ' E. W. Drlslane ' Executive Director i FMSI 03629 NON-ASBESTOS DISC BRAKE LININGS FOR PASSENGER CARS AND LIGHT TRUCKS INTRODUCTION In November 1979, the Environmental Protection Agency's Office of Toxic Substances drafted several questions on what they considered their informa tion needs on friction products containing asbestos. This was general state-* of-the art information concerning non-asbestos linings. And, this included all linings--disc and drum. An Institute Task Force met with EPA on January 3, 1980 to review their needs, and one essential change was that the questions would concentrate on disc brake linings only. The questions were then routed to the Members, asking that replies be only made for (1) disc brake linings used on (2) passenger cars and light trucks. Of the nineteen United States Members* twelve were involved with disc brake linings for passenger cars arid light trucks. Of these twelve--and not knowing how many of the twelve have worked on non-asbestos disc brake linings--three replies were received. They represented a decent cross-section with both original equipment and replacement market emphasis. Some were further along on development of non-asbestos disc brake linings than others. As the request of those replying, names have been omitted. The answers are grouped together tinder the questions as they were circulated to the Members. 1. What are the basic ingredients used in non-asbestOs disc brake linings which Were not used in earlier asbestos type formulations? Of particular interest are the materials used to substitute for asbestos---those that reflect a net change. Without entering into detail on the layered construction with what is usually predominantly resin-asbestos backing, there are essentially two types of non-asbestos compositions. The foremost is what is referred to as semi-metallic, and which is normally compounded using a resin binder similar to that used with asbestos type linings. The other is a synthetic fiber type mixed with resin binders of a conventional type. 1.1 Semi-metallic - This is a resin-bonded metallic type which uses steel v fibers (chopped steel wool) predominantly, with or without iron powders (sponge iron). Because of the ferrous nature of the product rust inhibitors may be used. While materials such as graphite, silicas and the like may also be used, these had been used in earlier asbestos type materials. ' t 1.2 Synthetic fibers - This is primarily fiberglass. These are chopped glass fibers sized to adapt to the needs of a friction material compound. ' FMSI 03630 4 Ay cn6 suoscicucc niticLittxtti n IDUI1C D UUO t J. 1UCC X XU X. U UQ WUCIb are the physical characteristics of the fiber--structure, fiber size. size distribution? 2.1 Steel fibers Rectangular cross-section: Circular or elliptical cross-section: 73 - 100 microns wide 100 - 250 microns diameter Fiber length: 1-5 millimeters 2.2 Fiberglass Circular cross-section: 13 microns diameter Fiber length: 3-13 millimeters 3. What are the performance characteristics and the problems associated with the uSe of substitute products for disc brake linings containing asbestos? How do the substitute non-asbestos pads compare with asbestos pads for lining wear, rotor wear, noise, wet recovery 3.1 General - Both the semi-metallic and the fiberglass types are Inherently more aggressive. That is, they would normally have higher friction levels, more rotor wear, more brake noise. However, In compounding the materials, other ingredients are added to control friction levels, rotor wear, noise and the like. Before hew materials can be sold in either the original equipment or replacement markets, the manufacturer must be satisfied that these problems are under control. Where these materials have been sold commercially, it will depend on the manufacturer if his materials--and they will have more than one material--have such properties as wear, noise and friction characteristics better than or equal to earlier asbestos types. 3.2 Advantages - With commercial semi-metallic types, fade resistance and wear resistance has been improved over asbestos materials. This is particularly true where solid rotors have replaced the earlier ventilated rotors on front wheel drive cars with unit brake loading (and temperatures) higher than the passenger cars in the early 1970's. Some manufacturers have shown improved rotor conditions and in some cases less noise with semi-metallics, while others still have problems in these areas. 3*3 Problems - The higher conductivity of metallic type non-asbestos linings results in increased heat transfer to the brake fluid which can result in brake fluid boil. Generally, inferior physical strength is associated with semi-metallic types which can result in attachment problems particularly if the material is riveted to the steel brake t shoe. Some, because of the inherently more aggressive nature of the material, have experienced "reverse speed spread." That is, a brake will be more aggressive at higher speeds than at lower speeds. Ferrous materials will show oxidation (rust) and this could be a problem both on-the-shelf and on the vehicle if left standing for long intervals. Some materials--and this depends on the manufacturer--have experienced lower friction when the brakes are cold. - , -2- FMS1 03631 3. A Backing Layer - Where the manufacturer uses a backing layer (currently backing layers contain asbestos) these can improve the thermal conductivity and physical strength problems. However, these asbestos types are also used because the vehicle owner may permit his linings to wear through to the backing materials, before replacement, and the backing materials must have acceptable friction properties to insure adequate braking. 3.5 Synthetic fiber types - These types are in the development stages and have problems with rotor wear, lining wear and the characteristics normally associated with a more aggressive lining. 4. Where you are the original equipment supplier of non-asbestos type disc brake linings, would you describe the packaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: A.1 Full non-asbestos linings A.2 Non-asbestos friction material with asbestos backing A.3 Use of non-asbestos lining at one position (inner or outer) with asbestos type at other position This question was answered in detail in a letter from Mr. E. W. Drlslane of the Friction Materials Standards Institute to Mr. Richard Guimond of the Environmental Protection Agency--letter dated April 21, 1980, a copy of which is attached. 5. Describe the historical development of non-asbestos disc brake linings with data and/or time from (1) initial research. (2) successful labora tory prototype, to (3) availability of commercial product. Also, estimate research and development cost for development of commercial non-asbestos disc brake linings (either in total or for each phase of the development). There is a wide variation in the answers to this question. The shortest times and lowest costs are those estimated by a manufacturer who has been working on development of non-asbestos linings over the last year or two. The highest costs and longest times are those from a manufacturer who has developed resin-bonded metallic type disc brake linings which are now available commercially. The estimated time by one manufacturer is a total of four to five years, with two years from initial research to laboratory prototype, with another two to three years from that point to the availability of a commercial product. The low estimate was $250,000. Another manufacturer states that the semi-metallic types have been studied for fifteen years, and its estimate for commercialization would involve a minimum of three years and $500,000. The manufacturer who has a product considered commercial (a semi-metallic type) states that the overall development period took about eight years from initial research, with research and development costs of about $2,000,000 in 1969 dollars. . -3- FMS1 03632 6. If a vehicle has a non-asbestos pad as original equipment, what problems or advantages do you see in use Of asbestos type pads for replacement? There are essentially two answers to this question. The semi-metallic types have become original equipment on passenger cars in essentially two different environments. One is where the semi-metallic was phased in on a brake originally developed using asbestos linings. These were primarily domestic passenger cars with ventilated rotors. On the other hand, as is best illustrated by the 1980 General Motors X Cars (Citation, Phoenix, Omega and Skylark), recent developments are with solid rotors on front wheel drive cars where the new materials were required due to the increased operating temperatures of the brake. Where non-asbestos disc brake linings--semi-metallic types--were introduced in existing brake envelopes with ventilated rotors, there should be no problem servicing them with standard asbestos type linings. There may be advantages to use of asbestos type linings to ease problems with thermal conductivity or poor physical strength. One manufacturer believes that there may be some problems magnified in the replacement market where semi-metallics are used, particularly where a rebuilder is assembling lining to the shoe. Also, there is some concern on the oxidation problem due to the time it takes for a product to get through the distribution system. However, where a semi-metallic was designed originally for the solid rotor brake it is felt that the replacement should also be of that type for fade resistance and lining wear properties. 7. Are the composition and manufacture of non-asbestos disc brake linings developed by your company protected by patent? If so, what are the patent numbers? There are some patents in this area. It is suggested that EPA make its patent search for the information they believe relevant. Caution should . be exerted to look at patents probably with dates no earlier than 1970, as the earlier patent literature has considerable information on sintered metal friction materials which are used in aircraft, and in special off-highway high torque high-temperature applications. The sintered materials have not been commercially acceptable in conventional vehicular braking systems. 8. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brake linings? For example, would your company consider licensing of the technology to manufacture non-asbestos brake pads? While respondents indicated that they have licensed others in friction material technology In the past, all such licensing has been done with organizations in international markets and not in the domestic market with direct competitors. Respondents have either not considered this question, or Indicate that any ' situation involving licensing would be reviewed on its own merits. ' -4- 9 FMSI 03633 9. Can non-abestos disc brake linings be manufactured in existing production facilities or will new facilities be required? Please estimate the capital and operating costs, and the availability and lead times associated with acquisition of the machinery and tooling. All respondents concur that non-asbestos disc brake linings cannot be manufactured in existing production facilities. There will be additional operating costs as well as capital costs. Estimates on capital costs including tooling run from $2,000,000 to $6,000,000 to convert to manufac ture of all non-asbestos disc brake linings. Operating costs are estimated to increase by 5 to 10 percent. Estimates on equipment and tooling acquisition run from twelve months to twenty-four months. 10. What is the projected unit cost differential between these three popular domestic disc brake lining sizes containing asbestos and non- . asbestos substitutes? (FMSI 728A, 7013A, 7017A) Two respondents indicated that the non-asbestos formula would be 200% of the asbestos formula. One respondent indicated (depending on FMSI number) costs of from 275% to 315% of the asbestos formula. 11. Based on your 1979 production, how much asbestos would-be eliminated in a total conversion to non-asbestos disc brake pads? This question could not be answered directly from the respondents as it would be meaningless without knowing the volume produced by each. Based on the answers and an estimate of asbestos disc brake lining production in the United States in 1979, the Institute attempted to develop a response for this question for the entire industry. Based on estimates of 76,000,000 pieces of disc brake lining sold in the aftermarket, and approximately 40,000,000 pieces sold for original equipment, an estimate for disc brake linings sold in 1979 for passenger cars and light trucks is 116,000,000 pieces. Of the 40,000,000 original equipment, an estimate is made that 30%, or 12,000,000 pieces were non-asbestos types, leaving 104,000,000 pieces of asbestos type disc brake linings sold in the United States in 1979. With an approximation that for domestic cars each lining weighs .35 pounds, and that half the content is asbestos, a projected total use of asbestos in automotive disc brake linings for 1979 is: 104,000,000 x .35 x .50 x 1/2000 - 9,100 Tons Allowances were not made for the asbestos in the backing for some non-asbestos linings. However, it Is not felt that this would alter the projections significantly. It is estimated, therefore, that 9,100 Tons of asbestos * would be eliminated in a total conversion to non-asbestos disc brake pads. ' i -5- FMSI 03634 TILCPHONI HOI) 84B-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E 210 ROUTE 4 PARAMUS N J 07652 INC. APR 21 1980 Mr. Richard Guimond Environmental Protection Agency Office of Toxic Substances Waterside Mall-East Tower 401 M Street Southwest Washington, D.C. 20460 , Dear Rich: In our meeting in January we drafted several questions for the Membership concerning friction products containing asbestos. At our January 3, 1980 meeting we agreed on revision of some of the wording. Our question #4 was worded as follows: "Where you are the original equipment supplier of non-asbestos type disc brake linings would you describe the packaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: 4.1 4.2 4.3 Full non-asbestos linings Non-asbestos friction material with asbestos backing Use of non-asbestos lining at one position (inner or outer) with asbestos type lining at other position The Friction Materials Standards Institute gathered some of this informa tion from original equipment sources and we have the enclosed presentation to make as regards that information. I wish to caution, however, that some of the information is not clear-cut. In other words, in certain model years some semi-metallies which have been used on disc brakes were phased in and may not have been production for the full year. We are still attempting to gather the information on the other questions that were^asked. I must admit that replies have been slow. I will continue to attempt to gather sufficient information to provide you with reasonable answers to the other questions that were sent the Membership. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE, INC EWD/lmc / E. W. Drlslane Executive Director FNISl 03635 POLICE AND TAXI USAGE OF NON-ASBESTOS DISC BRAKE LINING ON FRONTS Police and Taxi usage of non-asbestos disc brake linings was as a Police/Taxi Option--actual usage depended on customer ordering that option. Ford-Mercury in 1976-78 also had non-asbestos disc rears for the Police/Taxi option. Non-Asbestos Lining (With Asbestos Backing) AMERICAN MOTORS 1978, Concord Police, Taxi 1978-75, Matador Police Outer only . Both I & 0 BUICK 1980-71, 1980-79, Buick Police, Taxi Century Police Both I & 0 Both I & 0 CHEVROLET 1980-71, 1979-77, 1980-79, Chevrolet Police, Taxi Nova Police Malibu Police Both I & 0 Both I & 0 Both I & 0 CHRYSLER 1980-76, 1980-78, 1980-77, Chrysler Police, Taxi Cordoba Police LeBaron Police, Taxi Both-I & 0 Both I & 0 Both I & 0 DODGE 1980-77, 1980-79, 1980-77, 1978-77, 1977, Aspen Police, Taxi St. Regis Police, Taxi Diplomat Police, Taxi Monaco Police, Taxi Royal Monaco Police, Taxi Both I & 0 Both I & 0 Both I & 0 Both I & 0 Both I & 0 FORD 1980-78, 1980-76, 1980-76, 1979-78, Fairmont Police, Taxi Ford Police, Taxi Granada Police, Taxi LTD II Police, Taxi Both I & 0 Both I & 0 Both I & 0 Both I & 0 MERCURY 1980-78, 1980-76, 1980-76, Zephyr Police, Taxi Mercury Police, Taxi Monarch Police, Taxi Both I & 0 Both I & 0 Both I & 0 0LDSM0BILE 1980-71, Oldsmobile Police 1980-79, - Cutlass Police Both I & 0 Both I & 0 PLYMOUTH 1980-77, 1980*77, 1978, Volare Police, Taxi Gran Fury Police, Taxi Fury Police, Taxi Both I & 0 Both I & 0 Both I & 0 PONTIAC 1980-71, 1980-79, Pontiac Police, Taxi Phoenix Police , Both I & 0 Both I & 0 FMSI 03636 PASSENGER CAR AND LIGHT TRUCK USAGE OF NON-ASBESTOS DISC BRAKE LININGS (See separate listing for Police/Taxi option usage) AMERICAN MOTORS 1980, 1980, 1979, Spirit, Concord 4's Spirit, Concord, Eagle 6's AMX BUICK 1980, 1980-79, 1980, 1980, 1980, 1980-76, 19 79-78, 1979-78, 19 79- 76, 1977-76, 1975-73, Buick Electra Riviera Regal, Century Skylark (Power brakes) Skylark (Manual brakes) Skyhawk Regal, Century (Power brakes) Regal, Century (Manual brakes) Skylark Century (Manual brakes) Apollo (Manual brakes) CADILLAC 1980-79, 1980-79, 1980-68, Eldorado (Diesel) Seville (Diesel) Commercial CHEVROLET Non-Asbestos Lining (With Asbestos Back) Non-Asbestos Lining Only Outer only Outer only Outer only ' I &0 I &0 1 &0 or ` Outer only I&0 I &0 I &0 Inner only I &0 Outer only Outer only Outer only I &0 I &0 I&0 1980, 1980, 1980, 1980-76, 1980, 1980-76, 1979-78, 1979-78, 1979-76, 1977-76, 1977-76, 1975-73, Monte Carlo, Malibu Citation (Power brakes) Citation (Manual brakes) Monza Chevette Camaro Monte Carlo, Malibu (Power brakes) Monte Carlo, Malibu (Manual brakes) Nova Malibu (Manual brakes) Vega Nova (Manual brakes) I&0 I&0 Outer only I&0 or I & 0 I &0 Inner only Outer only Outer only I &0 Outer only Outer only Outer only I " Inner Lining 0 " Outer Lining FMSI 03637 CHEVROLET TRUCK 1980-78, 1980-79, 1980-79, 1980-79, 1980-79, 1980-79, 1978-76, 1978-76, El Camino C-,K-,P-20 C-.P-30 K-30 P-30 (JF-9) G-30 C-,K-,P-20 C-,G-,P-30 (Front & Rear) DODGE 1980-78, Omni DODGE TRUCK 1978-76, -Mini Bus 1976, W-300 FORD 1980-79, 1980, 1980-79, 1980-79, 1980, Fairmont V8 Thunderbird Mustang V8, Turbo 4 Fiesta Mustang V6 FORD TRUCK 1980-76, 1980-77, 1980-76, 1978-76, 1980-76, 1980, F-100 (4x4) F-150 (4x4) Bronco F-250 (Lt) E-250, F-250 (HD), E-350, F-350 E-350 School Bus CMC TRUCK 1980-78, 1980-79, 1980-79, 1980-79, 1980-79, 1980-79, 1978-76, 1978-76, Caballero C-,K-,P-2500 C-,P-3500 K-3500 P-3500 (JF-9) G-3500 C-.K-,P-2500 C-,G-,P-3500 (Front & Rear) MERCURY 1980-79, 1980, 1980-79, 1980, Zephyr V8 Cougar Capri V8, Turbo 4 Capri V6 Non-Asbestos Lining (With Asbestos Back) Non-Asbestos Lining only I&0 I & 0 or I & 0 I & 0 or I & 0 1 &0 I &0 I&0 I &0 I &0 or or I &0 1 &0 I &0 I S, 0 I &0 I&0 I&0 I &0 Outer only I &0 I &0 I &O I &O I &0 Inner only I &0 I&0 I &0 I &0 I &0 I &0 I &0 or or OT or I&0 I&0 I&0 I&0 I&0 I &0 I &0 I,& 0 I &0 I &0 FMSI 03638  OLDSMOBILE 1980, 1980-79, 1980, 1980, 1980, 1980-76, 1979-78, 1979-78, 1979-76, 1978-76, 1977-76, 1975-69, 1975-74, 1975-73, Oldsmobile 98 Toronado Cutlass Omega (Power brakes) Omega (Manual brakes) Starfire Cutlass (Power brakes) Cutlass (Manual brakes) Omega Toronado Cutlass (Manual brakes) Oldsmobile Commercial Toronado Omega (Manual brakes) PLYMOUTH 1980-78, Horizon PONTIAC 1980, 1980, 1980, 1980-76, 1980-76, 1980-79, 1979-78, *1979-78, 1979-78, 1977-76, 1977-76, 1977-76, 1975-73, LeMans, Grand Prix Phoenix (Power brakes) Phoenix (Manual brakes) Sunbird Firebird (drum rears) Firebird (organic disc rears) LeMans, Grand Prix (Power brakes) LeMans, Grand Prix (Manual brakes) Phoenix Ventura LeMans (Manual brakes) Astre Ventura (Manual brakes) Toyota 1980, Corolla Coupe Non-Asbestos Lining (With Asbestos Back) Non-Asbestos Lining Only I &0 I &0 I &0 Outer only Outer only I &0 I &0 I &0 or I & 0 I &0 Inner only I &0 Outer only Outer only Outer only I&0 ' I &0 I &0 I &0 Outer only I &0 i or I & 0 I &0 Inner only Outer only I&0 Outer only Outer only Outer only Outer only / FMS1 03639 Telephone (20!) 648-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. March 6, 19 80 Mrs. Joni T. Repasch, Record Clerk Office of Toxic Substances (TS-793) Environmental Protection Agency 401 11 Street, S.W. Washington, D.C. 20460 Subject: D :-et ITumber 0TS-61005, Environmental Protection Agency ANPRM on Asbestos--Friction Materials Gentlemen: The Friction Materials Standards Institute is an association of manufacturers of brake linings and clutch facings. The Institute would like to comment on the Environmental Protection Agency's Advanced Notice of Proposed Rulemaking in the FEDERAL REGISTER of October 17, 1979, concerning the use of products containing asbestos. In particular, we would like to comment on questions posed on Page 60067 as they relate to Friction Materials. Friction Materials is a broad classification which covers such products as automobile brakes, both disc and drum, truck brakes, fan and transmission clutches, and other devices used in the Automotive, Truck, Bus, Heavy Vehicle, Aircraft and other industries to stop, slow or control moving mechanical parts. We believe the largest usages to be in the Automotive, T*uek, Bus, Heavy Vehicles and Aircraft industry. Friction Materials may contain anywhere from zero (0) to 60% asbestos by com position depending upon the nature of the heat build up generated and required for control of the mechanical device involved. Brake and clutch emissions and information related to the disposition of asbestos is contained in a report prepared for the Environmental Protection Agency, Office of Air and Water Programs, Ann Arbor, Michigan 48105, entitled Brake Emissions: Emission Measurements from Brake and Clutch Linings from Selected Mobile Sources, EPA Contract #68-04-0020, conducted by M. G. Jacko and R. T. DuCharme, Final Report for Period May 1971-March 1973. The EPA technical officer was Dr. Joseph H. Somers. We call this report to your attention in that it provides the information and data to answer many of the questions posed in the EPA advance notice of Pro posed Rulemaking. The answers to the questions of (a) number of people exposed (b) routes du ration and frequency of exposure (c) the intensity of exposure and (d) fiber size distributions require several source documents. We suggest you refer to a January 3, 1979 draft by Dr. W. J. Nicholson of Mount Sinai Hospital entitled "Investigation of Health Hazards in Brake Lining Repair and Main tenance Workers Occupationally Exposed to AsbestosV As that paper was a draft for comments, we believe you should contact Dr. Nicholson for that information on exposure levels and fiber sizes. FMSl 03640 Environmental Protection Agency -2- We are familiar with an 1IT Research Institute report prepared for the Office of Toxic Substances, in which they attempted to develop a people exposure index based on several factors such as releasability of the fiber, frequency of exposure, duration of exposure, etc. While we will comment analyzing the inputs used for the IIT Research Institute exposure index, we do not wish to indicate that the mathematical exposure index is a meaningful index. It is constructed with several assumptions and arbitrary numerical levels which make it anything but an absolute index, We would like to provide an explanation of the brake repair business within the framework which IIT Research Institute arbitrarily constructed. By doing this, a better understanding of the actual number of persons exposed and duration of exposure will be presented. Essentially, there are two areas xfhere a brake repair worker may be exposed to airborne asbestos dust. They are: (1) In a shop which performs machining operations--such as grinding, drilling, bevelling, etc., and (2) In a shop where the brake repair worker blows brake wear debris from the drum and brake parts of a car being serviced. To take three factors from the IIT Research Institute report from their Table 2 for Brake Linings (Releasability 2, User 1, Population Exposure 2), these factors cannot be put in the same equation for perhaps 99% of brake work. Where the User and Population Exposure is high,i.e., the national chain, the corner garage--the shops involved most often do not have access to machining equipment and thus the releasability code would be 3 rather than 2--"fibers locked in and not likely to be released in normal use." Contrariwise, in the shops that have machining operations,i.e., fleets, municipal garages, where the releasability factor may be 2--"fibers locked in but releasj&le ' during machining--the overall work force exposed is small. The IIT Research report gives all brake repair a duration factor of I (12 hours per day). The average brake repair worker In a busy shop could do three or four brake jobs a day. The only exposure he will have--since most brake repair shops do not machine the friction materials--would be from the dust blown from the brake being serviced. While we agree for common sense reasons that blowing dust of any type should be discouraged, the brake wear debris has only a small fraction of asbestos--less than 1% im most studies, ' Even itfith the blowing out of debris from brake drums, the duration cannot be 12 hours. The duration is more likely less than one minute per brake. With . the advent of disc brakes on the fronts of most cars, this means less than 2 minutes per vehicle if the rear drum brakes are relined. When the time, the low asbestos content in the wear debris, and the fact that four brake jobs per day would be a busy shop, the 12 hour duration assigned to all brake repair is not justified. We would like to comment on the do-it-yourselfer. He has the best of all worlds. (1) He doesn't have machining equipment so his repair job cannot have a re leasability factor of 2; (2) He doesn't have access to an air hose so his duration must be near zero; (3) The do-it-yourselfer probably does no more than one brake job a year so he cannot have the frequency assignment of 365 (daily) given to the brake repair worker. FMSI 03641 Environmental Protection Agency -3- llhile additional examples could be given where the same factors or codes could not be assigned to all groups of brake repair workers, the point is that all brake workers cannot be categorized under one set of exposure codes. In other words, the IIT Research Institute report took the ''Population Exposed" and `'User" characteristics which are based on perhaps 900,000 workers in the brake repair area, and assigned them all the second most objectionable code for releasability and the worst codes for frequency and duration. The exposure criteria should be analyzed by the segments of the work force and not by the total work force if one is to assign correct codes for releasability, duration and frequency. 'Jhile estimates are necessary, we have prepared a table to indicate what we estimate the exposure factors (or codes) to be in brake repair facilities. ESTIMATED EXPOSURE FACTORS IN BRAKE REPAIR FACILITIES BY TYPE Type Brake Repair Operation Releasability Frequency Estimated Number of Brake Repair Duration v"Workers Fleet Garages, Municipal Garages, with machining operations (2-20 jobs per month) (2-10 brake repair workers) 2 1-2 1-2 10-30,000 Fleet and Taxi Garages without machining equipment (2-20 jobs per month) (2-10 brake repair workers) National and Regional Chain, Tire Company, Car Dealer (10-50 jobs per month) (2-10 brake repair workers) 3 3 1-2 2 10-30,000 * 1 3 50-100,000' Gas Station, Corner Garage (2-10 jobs per month) (1-2 brake repair workers) Do-It-Yourselfer (1 joh per year) 3 3 1-2 3 400-800,000 4 4 1-5,000,000 FMSI 03642 Environmental Protection Agency -4- A simple conclusion is (1) Where the releasability, frequency, and duration is highest, the smallest population is exposed, and (2) Where the population ''exposed" is high, releasability, frequency and duration are low. In the fleet and municipal garages, where exposures are highest, these shops should be taking steps to comply with OSIIA regulations. Shops of this type should be in compliance with 0S13A regulations and thus will have the necessary exhaust ventilation equipment and procedures to maintain exposure levels below those suggested in the IIT Research Institute report and in the table shown above. In summary, the shops which may potentially have the greatest population exposed do not have the asbestos exposure factors of the fleet and municipal garages with grinding equipment. It is suggested that a voluntary action program, with labeling and education be aimed at these smaller facilities. Compliance with OSHA regulations should be emphasized at the larger facilities, and partic ularly those with machining operations and thus new regulation from the EPA is not necessary. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE, INC. EWD/erc E. W. Drislane Executive Director FMSI 03643 February 19, 1980 Mr. Albert Colli Environmental Protection Agency Office of Toxic Substances Waterside Mall - East Tower 401 M Street SW Washington, D.C. 20460 Dear Al: Thank you for the copies of your minutes of the meeting that we had with EPA on January 3, 1980. I do not believe that we have basic differences, but the questions drafted to correspond to your Enclosure III are as shown on the attached two pages. As I indicated, I don't believe there are any significant differences, but Question 2 for Enclosure III did not include a question regarding the evaluations on health effects of non-asbestos disc brake linings or materials used therein. As indicated at the meeting, no one has that Information and the question was re-worded to determine the physical characteristics of the fibers should they be the cause of health problems. Also, where you have Questions 4 and 5, we were more specific in our Question 4. The questions had to directly address the problem and be more specific than was indicated in your Questions 4 and 5. I believe the rest of the questions go along with the wording in your Enclosure III. After ray return from Washington I went over these questions and the wording to be used with both Mr. Moalli and Mr. Armstrong. It was agreed that this wording that we show was as we understood it from the meeting. If you feel that the differences in the wording are of substance and could present a problem please let me know, as we have already sent our questionnaire to the members using the wording Indicated in our write-up. If there are problems with the foregoing please let me know. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE EWD/lmc E. W. Drislane Executive Director FMSI 03644 February 19, 1980 Mr. Jim Armstrong Bendix Corporation Bendix Center Southfield, Michigan 480/6 Dear Jim: I am enclosing a copy of EPA's version of the "minutes" of the meeting held with EPA personnel in Washington on January 3, 1980. Without going into the wording of the covering letter and the minutes, any differences are in the wording of the questions as we agreed at the January 3 meeting. The questions indicated in Enclosure III do not appear to differ in substance from the questions the way we drafted them. There may be some question as regards Question 2 concerning the effects of non-asbestos disc brake linings and the materials used therein. My notes specifically indicated that we were not asking this question but instead were asking concerning the fibrous characteristics of the materials. Also, for example, our question number 4 and question number 10 are more specific then the questions indicated with their Enclosure III. I have replied to Mr. Colli with the comments indicated with the copy enclosed. The foregoing is sent to you as a matter of information. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE, INC. EWD/lmc E. W. Drislane Executive Director FMSI 03645 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 MN 2 4 80 OFFICE OF TOXIC SUBSTANCES Mr. E. W. Drislane, Executive Director Friction Materials Standards Institute Bergan Mall Office Center E. 210 Route 4 Paramus, New Jersey 07652 Incorporation Dear Mr. Drislane: I have attached a copy of the minutes of the meeting between Environmental Protection Agency (EPA) personnel and representatives of FMSI that was held on January 3, 1980. Please let me know if you have any corrections, deletions or additions to the minutes. Sincerely AiDert GOJ.il Enclosure FMSI 03646 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON. D.C. 20460 OFFICE OF TOXIC SUBSTANCES Meeting with the Friction Materials Standards Institute January 3, 1980 At the request of the Friction Materials Standards Institute (FMSI), EPA staff met with FMSI representatives at EPA, Washington, D.C. A list of attendants is attached as enclosure (1). The purpose of the meeting was to discuss a list of questions on friction products provided to the FMSI by EPA on November 16, 1979. FMSI was to determine whether their members would answer the questions and what mechanisms should be used to solicit the responses. The list of questions are attached to these notes as enclosure (2). Ralph P. Moalli, representing FMSI, stated that the chances of obtaining responses from the members of FMSI would be increased if the questions could focus on disc brakes and exclude drum brakes at this time. He suggested that a second questionaire could be submitted, specifically addressing drum brakes, after the responses to the questions on disc brakes had been secured. Changes to the original questions were made by mutual agreement during the meeting which resulted in a revised list which has been included as enclosure (3). At the conclusion of the meeting, E.W. Drislane, representing FMSI, stated that the questions as phrased would probably be submitted to 15 of their 19 members. He indicated that responses to the questions would be obtained in about 3 months. FMSI 03647 Name Al Colli Hope Pillsbury Jim Armstrong E.W. Drislane Eugene L. Rogers Ronald P. Moalli Alan Carpien Richard J. Guimond Jim Silverman David Mayer Jim Hughes Bob Liss Jane Nowak ENCLOSURE I Company/Code OPTS/CAD OPTS/CAD Bendix FMSI Bendix FMSI/Raybestos EPA/OGC OPTS-CAD OPTS/CAD OPTS/PID OPTS/ORA OPTS/CAD OPTS/CAD % Telephone Number 755-8023 755-8023 313-352-6350 201-845-0440 518-273-6550 202-371-0101 755-0794 755-8023 755-6660 755-5854 755-6660 755-8023 755-8023 FMSI 03648 '`" * } 1 r ;* *t }11 / /- ; p l ENCLOSURE II NOV J 5 i3?g Informational Needs for Friction Products Containing Asbestos 1. What are the basic ingredients used in nonasbestos linings for disc brakes? Specific formulations are not necessary. 2. What are the basic ingredients under consideration for use in nonasbestos linings for drum brakes? Specific formulations are not necessary. 3. What data or evaluations are available regarding the health effects of nonasbestos brake linings or materials used in them? . 4. What are the performance characteristics and the problems associated with the use of substitute products for brake linings containing asbestos? 5. Are nonasbestos brake pads used in conjunction with asbestos pads?. For example, is the outer part of the pad nonasbestos and does the inner pad contain asbestos? 6. Are nonasbestos brake pads interchangeable with asbestos brake pads? If the vehicle has a nonasbestos pad as original equipment, must the replacement pad be nonasbestos? 7. Are the composition and manufacture of nonasbestos brake linings developed by your company protected by patent or are they trade secret? * 8. Are there mechanisms for the transfer of this technology to other companies who manufacture brakes for vehicles? For example, would your company consider licensing of the technology to manufacture nonasbestos brake pads? 9. Can nonasbestos brake products be manufactured in existing production facilities or will new facilities be required? What will be the capital and operating costs associated with change over? 10. What is the projected price differential between brake linings containing asbestos and nonasbestos substitutes? 11. Do brake systems which utilize nonasbestos friction products require a different design from brake systems with linings containing asbestos? If component parts for use with nonasbestos linings are different, what is the product price differential? FMSI 03649 ENCLOSURE III Informational Needs for Friction Products Containing Asbestos 1. What are the basic ingredients used in nonasbestos linings for disc brakes? {Specific formulations are not necessary). The materials used to substitute for asbestos are of particular interest. 2. What data or evaluations are available regarding the health effects of nonasbestos disc brake linings or materials used in them? If the substitute is a fiber what are its physical characteristics and size distribution? 3. What are the performance characteristics and the problems associated with the use of substitute products for disc brake linings containing asbestos? How do the substitute pads compare with asbestos pads? (For example: expected wear, noise levels from use, etc.) 4. For orignal equipment applications describe the asbestosnonasbestos braking system. Include part number, vehicle application, and model years for each system decribed. 5. Describe the asbestos-nonasbestos braking system used for original equipment applications. Specify the vehicle applications and the model years for each system described. 6. Describe the historical development of nonasbestos disc brakes in your company. For example, provide date of initial research, dates of initial testing, dates of commercial available product.- Estimates research and development costs for developing commercial product. Provide either total cost or cost for each phase. 7. Are nonasbestos pads interchangeable with asbestos brake pads? If the vehicle has a nonasbestos pad as original equipment, what problems or advantages do you foresee with replacement pads that contain asbestos? ' 8. Are the composition and manufacture of nonasbestos disc brakes linings developed by your company protected by patent? What are the patent numbers? 9. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brakes for vehicles? For example, would your company consider licensing of the technology to manufacture nonasbestos brake pads? FMSI 03650 10. Can nonasbestos disc brake products be manufactured in existing production facilities or will new facilities be required? What will be the capital and operating costs associated with change over? (For example: machinery, tooling, and time considerations.) 11. What is the projected unit cost differential between disc brake linings containing asbestos and nonasbestos substitutes for the part numbers specified above. 12. How much of the asbestos used by your firm in 1979 would have been eliminated had all disc brakes been nonasbestos in that year? FMSI 03651 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 February 8, 1980 TO: Delegates and Alternates SUBJECT: EPA Office of Toxic Substances Questions Concerning Asbestos and Non-Asbestos Disc Brake Linings Based on Board of Directors recommendations, an Institute Task Force met with EPA in Washington to clarify and modify the Eleven Questions that EPA had drafted to ask manufacturers of friction materials. As you may be aware, the EPA is permitted under the Toxic Substances Control Act to subpoena information relative to initiatives in this area. The Institute feels it to be prudent to work with EPA on a voluntary basis in providing information and background so that any actions they take will be based on facts rather than assumptions. We are asking, therefore, that member companies who manufacture asbestos or non-asbestos disc brake linings for passenger cars and/or light trucks (under 10,000^ GVU) respond to this questionnaire. At some later date, the EPA will probably ask similar questions concerning drum brake linings, brake blocks, etc. Control of Individual Company Response It is suggested that individual member companies have one individual control and coordinate the response. In this fashion, he will Insure that contradictory responses are not sent to the regulators by in dividual contacts or questions from others in Washington. Along this line, it has been suggested that responses to EPA and others be only sent where the request for information is in writing. This is to avoid conflicting responses to telephone inquiries and the like. Institute-Coordinated Response Versus Individual Direct Response The Institute is attempting to coordinate the response to EPA. Replies will not be attributed to companies, but it must be remembered that EPA does have subpoena power and could determine the source of the answers. If individual companies wish to comment on other aspects of this subject-- beyond those suggested in the questions--they should add comments. We will code the answers for our response to EPA. Legal Counsel Review of Responses to Questionnaire Institute's Legal Counsel had asked to review the questionnaire. He has failed to respond to several requests to review and approve this questionnaire for circulation. It has been decided to release this questionnaire as written, but the Members are urged to have their own Legal Counsel review the individual replies. FMSI 03652 Delegates and Alternates February 8, 1980 Replying Directly to EPA If a member company feels it would be in its best interest to reply directly, the response should be sent to: Mrs. Joni T. Repasch (Record Clerk) Office of Toxic Substances (TS-793) U. S. Environmental Protection Agency 401 M Street, SW Washington, DC 20460 (Mark Prominently: Docket Number 0TS-61005) If you do reply directly, your response is part of the public record. If you provide any confidential or proprietary information, you should provide it only if the EPA can assure you that the confidentiality of the information can be safeguarded. * * * * * There is no question but that the EPA is considering a ban on asbestos In friction materials. Their first step Is with automotive disc brake linings. He believe that accurate objective information can influence decisions to be made in this area, and recommend that all member companies help with this response. As indicated earlier, if they do not get this information on a voluntary basis, they can compel it. We are trying to gather this information so that we can forward it to EPA no later than March 31, 1980. EWD/erc cc-Health & Environmental Affairs Committee E. W. Drislane Executive Director * FMSI 03653 1. What are the basic ingredients used in non-asbestos disc brake linings, which were not used in earlier asbestos type formulations? Of particular interest are the materials used to substitute for asbestos--those that reflect a net change. 2. As regards the substitute materials, if the substitute is fibrous, what are the physical characteristics of the fiber--structure, fiber size, size distribution? 3. What are the performance characteristics and the problems associ ated with the use of substitute products for disc brake linings containing asbestos? How do the substitute non-asbestos pads compare with asbestos pads for lining wear, rotor wear, noise, wet recovery, etc.? 4. Where you are the original equipment supplier of non-asbestos type disc brake linings would you describe the packaging of asbestos and non-asbestos linings within the brake itself? In other words, present model year and application data for: 4.1 Full non-asbestos linings 4.2 Non-asbestos friction material with asbestos backing 4.3 Use of non-asbestos lining at one position (inner or outer) with asbestos type lining at other posititon 5. Describe the historical development of non-asbestos disc brake linings with date and/or time from (1) initial research, (2) suecessful laboratory prototype, to (3) availability'iof commercial product. Also, estimate research and development cost for devel opment of commercial non-asbestos disc brake linings (either in total or for each phase of the development). 6. If a vehicle has a non-asbestos pad as original equipment, what problems or advantages do you see in use of asbestos type pads for replacement? 7. Are the composition and manufacture of non-asbestos disc brake linings developed by your company protected by patent? If so, what are the patent numbers? ' 8. What mechanisms are there for the transfer of this technology to other companies who manufacture disc brake linings? For example, would your company consider licensing of the technology to man ufacture non-asbestos brake pads? 9. Can non-asbestos disc brake linings be manufactured in existing production facilities or will new facilities be required? PJ.ease esti mate the capital and operating costs, and the availability and lead times associatedwLth acquisition of the machinery and tooling? 10. What is the projected unit cost differential between these three popular domestic disc brake lining sizes containing asbestos and non-asbestos substitutes? (EMSI 728A, 7013A, 7017A) FMSI 03654 11. Based on your 1979 production, how much asbestos would be elim inated in a total conversion to non-asbestos disc brake pads? The foregoing questions relate to passenger car and light truck (under 10,000 lbs. GVW) disc brake linings. The Office of Toxic Substances has indicated that they will be asking questions along a similar line,.at some later date, for drum brake linings used on passenger cars and light trucks. And at still a later date, they will ask about brake blocks and probably clutch facings. FMSI 03655 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, NEW JERSEY 07652 January 8, 1980 TO: BOARD OF DIRECTORS ENVIRONMENTAL AFFAIRS COMMITTEE SUBJECT: MEETING WITH EPA OFFICE OF TOXIC SUBSTANCES PERSONNEL CONCERNING THEIR REQUEST FOR INFORMATION ON FRICTION MATERIALS At the December 4, 1979 meeting of the Board of Directors, among the many items discussed were the eleven questions asked by the EPA's Office of Toxic Substances Control concerning asbestos and non-asbestos friction materials. At the Board meeting it was decided that a Task Force would be formed to meet with the Office of Toxic Substances to clarify and re-define these questions. This Task Force consisted of: Mr. R. R. Moalli, President of the Institute; Mr. J. W. Armstrong, Chairman of the Health and Environmental Affairs Committee and Mr. E. W. Drislane, Secretary. Mr. Armstrong invited Mr. E. L. Rogers of the Bendix Friction Materials Division to help with the questions. Messrs. Moalli, Armstrong, Rogers and Drislane met with the personnel from the Office of Toxic Substances on January 3, 1980 at 10:00 A.M. at the EPA Offices, Waterside Mall, Washington, D.C. Those in attendance from the EPA are listed below: Name EPA Office Telephone (Area Code 202) A1 Colli Hope Pillsbury Alan Carpien Richard J. Guimond Jim Silverman David Mayer Jim Hughes Bob Liss Jan Nowak CAD/OPTS CAD/OPTS EPA/OGC EPA/OCC CAD/OPTS PID/0PTS 0RA/0PTS CAD/OPTS CAD/OPTS 755-8023 755-8023 755-0794 755-8023 755-6660 755-5851 755-6660 755-8023 755-8023 The elven questions that had been submitted earlier were covered in detail at this meeting. Without going into the detail, every question was discussed and the proposed new draft of the eleven questions is attached. Essentially, the questions are limited at this point to automotive disc brake linings. Questions or inferences as regards drum brake linings or others have been removed. However, the EPA indicated that at some later date they will be seeking similar information on drum brake linings. The questionnaire at this time will refer to asbestos and non-asbestos disc brake linings only. FMSI 03656 BOARD OF DIRECTORS ENVIRONMENTAL AFFAIRS COMMITTEE 2- - January 8, 1980 Further, these are for passenger cars and light trucks which will be defined as vehicles under 10,000# GVW. For example, question #2 on drum brake linings was eliminated. Other questions were almost completely restructured. Question #11 of the original eleven questions was also eliminated because it involved a knowledge of the brake system itself rather than brake linings. Further, a new question #11 was added concerning how much asbestos would actually be eliminated by conversion to non-asbestos brake pads. In response to a question from EPA, the Secretary indicated that he felt that it would be three months before this information would be available. He suggested that this material must go to both our Legal Counsel and our Board of Directors before we can even solicit replies. Among other matters it was stated that where a respondent prefers to go direct to the EPA rather than through the Institute that replies should be addressed to the docket established with the Federal Register notice of October 17, 1979. That would be Docket OTS-61005. It was pointed out that replies would be concentrated on domestic passenger car linings which would mean that the imports are not being addressed directly. Also, the questions would be directed to United States Active Members and not to Regional Members. This would mean, of course, that some information relating to imported cars and replacement linings therefor will not be included. Before this questionnaire is sent to the Membership, it must be approved by Legal Counsel and the Board of Directors. The foregoing is sent along as a matter of information. EWD/lmc E. W. Drislane Executive Director FMSI 03657