Document wrbMmKJBdJg96Bg1o6Mj1K8JB
FILE NAME: Friction Materials Standards Institute (FMS)
DATE: 1972Jun 16
DOC#: FMS018
DOCUMENT DESCRIPTION: Report on FMSI Asbestos Study Committee Activities from 1971 with Cover Letter from Raybestos
U l i- j t S 1 IE G E L STR EET. MANMEIM, PENH. 178-18
R aybestasTM anhattan
WE R
C
June 16, 1972
Mr. E. W. Drisiane Executive Secretary Friction Materials Standards In stitu te, Inc. Bergen Hall. Office Center E.21Q Route #4 Paraaus, ii.J . 07652
Dear Ed:
Attaci-cd i s 37 report cn the part 7e a r` a a c tiv itie s o f tha Asbestos StudjfcCoaaittee which I hope w ill he satisfacto ry for your presentation th e w d e a fte r next. I regret I won't be on hand at the meeting and certain ly appreciate your pinch-hitting for me.
I f you have any questions or recommendations concerning rev isio n s or or deletions to the attached report, please c a ll me. I expect to be in the o ffic e .Monday, Tuesday, Wednesday aid Friday next week and Monday, the 26th. After that I w ill be away u n til July 17.
.Also attached i s a copy of a tabulation prepared by AIA/NA comparing each, major item in the fin a l QSH& standard against the industry position and th e recommendations of.KI0SH and.the Advisory Committee on Asbestos Dust. I think th is a ig h t be worthwhile copying-and-forwarding to the-other aeahogae of the FKSI Asbestos Study Cosn&ttee.
I an not returning the form you sent me regarding the schedule for the next meeting as a l l of the dates liste d on th is schedule s t i l l are open as Tar as I aa concerned. Unless you advise otherwise I w ill wait u n til I get back iron vacation to return th is schedule to you, as by that time I expect to know a l i t t l e more regarding my plans for the la s t veek in July and th e month of August
oes; eaver
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The f ir s t Committee meeting was held September 15, 1571 and was cnaired by Dr. Z. ? . steJ of B.ayoesto s-Hashatdan, with members iron V.brldbestos, Acex, 3endix, end Carlisle Corporation and J-M present. The following it e s s were reviewed and/or discussed: (1/ .relationship with Asbestos Information Association/North America. (2) Proposed IHinc Regulations. (5) Tehicle frictio n material eaission te st program to be conducted by Bendix under E?A contract. (4) fonitoring for airborne asbestos fib r e . (5) Districotion and circulation c i lite ratu re on Asbestos/Heaith subjects.
The purpose of ths Asbestos Study Ccanattee wae restated a s follow s: "to gather cessimate to i t s members information about pending regulations concerning asbestos ia. the work place (ccsupaticnal exposure) and in th s general environment(particulate and to d raft cosecants relativ e to proposed regulations in defense o f reasonableness."
The following i s a l i s t of ths actions taken by the FK5X Executive Secretary on behalf o. the Asbestos Study Coarrittee during the remainder of 1971:
SepteaLer 'jO - Issued minutes yf f i r s t Cousnlttes restin g vrith le t t e r cosamting on proposed Federal EFA and I llin o is emission standards. -
October 2S - Issued bulletin and further information on I llin o is hearings.
Kovember 10 - Issued information on membrane f i l t e r monitoring method.
November 14 - Issued bu lletin on revisions to I llin o is and Federal I?A proposals.
December S - Issued information concerning fin a l draft o f proposed I llin o is regulation, proposed Z?A emission standards, and Federal Department of Labor Regulations on Occupational Exposure.
On January 26, 1972 arrangements were announced for B ill Eeitze o f J-M to conduct an instruction seseicr. on asbestos fibre monitoring at Fl-iSI headcaarters February 10. Ca Fecroary I I this session was presented to nine attendees representing s ix member ccmmamiss.
Ths second Asbestos Study Committee meeting also was held cn February 10 with I . H. Weav .".aybestcs-TIanhattan, acting as chairman ana members representing V/orlabestos, J-H, Bendi ar.d T arlisle. attending. The following items were covered:
.-.ev-ev A/I.a comments regarding CSHA meeting in Washington on January 26.
2. Iev le v o f prcpcsec OSKA asbestos standard ar.d comparison with B ritish standards ar.d re g u la tio n s.
Vis -",,VS
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M aterial I cun
mr.snts or. I l l i n o i s soar.dards. ss o i future FTHI ...soastos
u. .-.scoxr.sr.oatior. made th at tra -VIZ Asbestos Study Committee maintain
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..... / . .
reviewed back around and excectec thrust of OSHA .r.d E?A re g u la te 44 J
course for Asbestos Stud/ Committee.
* *.e
ng i s a susoary of- actions taken by the Ixecuti Secretary during the f i r s t
'2 in regard to Asbestos Study Corrittee nutters
February IS - Circulated Bulletin 427 regarding various standards for asbestos dust exposure ar.d control'. This included copies of the January 12 Federal Register announcement of proposed permanent CSHA standard for asbestos control in the work place.
February 13 - Issued Bulletin L2S reporting on February 10 demonstration by Mr. Ra o f membrane f i lt e r monitoring method.
June 1 - Circulated announcement of Microscopy Seminar scheduled by McCrone Seseaz In stitu te in Chicago week of June 26.
June 6 - Circulated supplementary informatinn received from I llin o is In stitu te of Technology .Research In stitu te regarding frictio n material emissions and issued tentat schedule for third Committee meeting to be held late July or August.
June 12 - I ircsd'anmnur cement nf CSHA nemnert standards on asbestos dusfc^espesm as published in June 7 Federal Register.
The la tte r item has been rather intensively studied by your Chairman* by A Il/feA ^aai no doubt also by concerned individuals in p ractically a l l companies represented in FM5T. The consensus appears to be that the new regulation i s s t r ic t e r than need be-in respect to the future TLV o f 2 fibres per cc, but is more lenient than was expected, in regard to many other important matters. Major changes between the new regulation and the earlier emergency standard and earlier proposed permanent regulations are a s follow
t i c reduction c f 7LV to 2 fibres in four years.
se of procer cual le oker recuired.
e clothing recuired above 1C fpoc ceiling lim it. Change rooms, o i l i t i e s , and special laundering and clothing handling procedures
A w -ease every six mentis at operations exceeding llc v a b le
erar, and doctor's appr z use of resm irators.
required before assigning employees to jobs
Ilinir.atior. cf references to career" and "danger" cn signs and la b e ls. Labeling eliminated fer orocucts cor.tainir.r locked-in fibre.
c
e c
s cn "dry sweeping" and use of
ssed a ir for cleaning
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cords
ed . employees enpesed to
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itin;
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lockec-ir. fibre need not be sealed nor labeled.
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i l s pose
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d i f f i c u l t i e s are expected in acn ievm e ccm pli nee wit h the new rgula rm nufaccurers, ar.d in sulation fa b ric a to rs and --- we.,, .er s , it appears
roso : : : .ction cate r i a l manufacturing operation s not r
on te x tile techno
l y l i t t l e trou ble, aithougn some dry noId ty- e fric tio n operation s a
Perhaps of a acre serions nature i s the potential threat of banning o f asbestos in fric t m aterials, p a r tir d a r ly in automotive vehicles, to eliminate emissions freo wear debris. It i s doubtful that any further action in th is direction w ill be taken until re su lt oi the coapreher.siva study by Bendix Corporation for EPA have been announced. I have been advised' that th is study, origin ally to hare been completed th is month, now i s not expect to be finished untij. la te th is year.
l i s t c f the d iffic u ltie s that arose in this study to date have occurred in connection vi the gas collection phase o f the program. Since the study involves collection and analys of g"aseous enissior.s as well as particulates, precision rotary se als and gas collectior systems had to be developed and evaluated, and th is has necessitated extensive and tine consuming engineering design e ffo r ts.
Another v it a l EPA pro gras also i s running behind schedule. That i s promulgation o f the permanent regulations and standards for asbestos emissions to the ambient atmosphere. 'r have been revised by the EPA Hazardous Pollutants Branch that the e a r lie st dit^thesestar.dards are expected to be issued i s the beginning o i August, ana they could bo delay* u n til early September. However, no major changes are expected in the portions o f the proposed regulation affectin g manufacturing operators. Sign ifican t changes are expectac in the sections applying to mining and spraying operations. Probably the only sign ifies change between the proposed regulation and the eoqaected fin a l regulation as far a s manufacturing operations are concerned i s the broadening o f sp ecificatio n s on fabric f i l t e r s and vet c ist co llecto rs. This should be helpful to industry in permitting some* more fle x ib ility in dust collector selection and application.
Before closing, 1 should like to recomend a few o f my thoughts and suggestions th a t I have received from ethers concerning items that should be considered and reviewed by the Asbestos Study Committee during the following year.
1. Uniform interpretation o f CSHA standards. Liaison with AIA/fol w ill be . ra"- *"* Z S .
- S . S . inaoion c f tech n o lo gical f e a s i b i l i t y o f ach ievin g both 2 and 5 f i b r e s che in d u stry .
in a tic n c f the o v e r a ll e ffe c t on the f r ic t io n m a te ria l industry o f
. . . 3 *,.%
Stearn s.
pmsnt c f gu id elin es, a id s, and education al programs to help customers a t he. re ro tatio n s.
lo se s a su ita b le standard method fo r a n a ly sis fo r asb e sto s in brake lin in 4 -*ar :s -
m aesrial prir.iir.o v isce .
as c lo se ly as p o ssib le medical and occupation al health research coneem i b e s te s-re ia te d d iseases and d eterain e whether FV.3I or i t s ciemier
oormmiss .'.rule help sponsor or otherwise support* work o f t h is nature.
All of these subjects probably v i i l be reviewed at the third Asbestos Study Ccaaittee reeting to be scheduled within the next nonth or so. Please advise us of sny addition; ite rs yrau or others in your organization ray wish to aad to our agenda for th is upconing reeting.
Respectfully submitted, I . Hi Weaver, Chairman