Document x5N3DMJ24MEBGoZ44dRLgYYOG

F12CTX0S MATERIALS STAUUEDS INSTITUTE, HIC., E-210 ROUTE #4, PARAMOS. H.J. 07652 ASBESTOS STUDY COMMITTEE Friday, October 24, 1975, at 9:30 AM Institute Office, E-210 Route 4, Paramus, H.J, MEMBERS PRESENT K. l-Jagner, Chairman E. H. Feierabend D. E. Stone I. H. Hearer J. Dunderdale OTHERS PRESEMT Carlisle Corporation Abes Corporation Bcndlx Corporation Raybestos-Maahattaa, Inc. Royal Industries M. R. Cole E. W. Drislana. MEMBERS KQT PRESENT Clapp & Eisenberg Friction Materials Standards Tnsuixst* M. Jacko E. P. Stefl Bendix Corporation - B. E. Porter Co. The meeting was called to order by Mr. Wagnar, Chairman, at 9:30 A.M. MIHUTES OF PREVIOUS HEEIPC The Minutes of the Masting hald April 28, 1975 had been distributed. These minutes were reviewed and a motion for their acceptance was made. Upon motion duly made, seconded and unanimously passed, it was FMSI-0213 RESOLVED To accept the minutes of the April 28, meeting as written. SI P FMSt- 0003 ASBESTOS INFORMATION ASowux^law jnumut. The Asbestos Information Association (AIA) hald their annual GovernaentIndustry Conference in Washington on Septeider 10-11, 1975. Hon members of ALA were invited to attend this conference. Several individuals representing friction materials attended. One of the items of interest was the proposed OSHA regulation which was dua near the end of September. It had been Indicated that the OSHA standards would be oriented more towards work practices than to a numerical standard* Mr. Weaver Indicated that the OSHA individual who indicated this did so believing that the new standard would not have a new maerical limit. Apparently there was alot of movement within OSHA by other -uossiblv labor unions and NIOSH--and that the proposed lower T Minutes of Cfa* Hsecing Asbestos gfudy Cornice** -2- October 24, 1975 prepare* fpr publication. The standard, which will be discussed later, proposed numerical standard of 0.5 flb*rs/cc (TWA). Several tttsmdaes statod that this confarenc* was most worthwhile, it gar* s food s**rvlav on asbestos. The only criticism Bade was that the speaker* did not have sufficient tin* to b* questioned after their presenta tions. The Institute will continue to monitor thia conference and expresses its support of the work of the AIA. PLANS FOR IKSTITPTE SEMINAR OH ASBESTOS !!r. Wagner and Mr. Drlslane had taken the steps to organise this saolnar. At the April 28, 1975 meeting of the Asbestos Study Cn--ittes a resolution uas passed race--udlng that the Institute sponsor a workshop on the asbestos problem in the fall of 1975. This resolution was reviewed with the President of the Institute, Mr. Siaon, and It was decided to proceed with such s seminar. Mr. Wagner contacted Mr. Noel Hendry of Johns-.'Unville relative to hie putting on a session similar to that which J-H prssented two years ago. (For reference: Mr. Noel Hendry, Denver, Colorado, telephone 303-770-1000, Extension 2142). It was suggested that the Johns-Manvllle presentation would have to be the corner-stone of any seminar and that this would have to be arranged first before arranging other presentations. Mr. B. K. Kifon of OSHA had been invited by Mr. Vagner to * address this seminar. Mr. Kwon had Indicated chat he should bs able to attend. It was suggested that the seminar would be a good time for e synopsis of the major points of the new OSHA standard. Also it would be well for Mr. Kwon to talk with people from our industry. A comment was made to the effect that OSHA had aisled those attending the conference in Washington indicating that the proposed standard would be work practices oriented. (The standard came out with a lower numerical Hale.) It was stated that Mr. Kwon was kaowladgsable in the hygiene area but ha waa not a policy maker. Be was not responsible for the addition of numerical standard in the proposed amendments to the OSHA regulations. Mr. Drlslane indicated that he bed talked with Mr. Bob Mereness of the Asbestos Information Association, and Mr. Mareness indicated that he would be pleased to attend. Also'Mr. Drlslane contacted Mr. R. Magdelain of Mlfiak of America Inc. Mr. Magdelain would be most pleased to put on a presentation relative to that type of vacuum cleaner for the work place. Mr. Wagner also talked with Mr. W. Eageleightener of Ferro-Tech relative to their pelletizing equipment. Mr. Engeleightener will also make a presentation. At the meeting Mr. Wagner called Mr. Noel H^pdry to firm up the J-M participation. In summary, it was indicates that Mr. Bill Reitze would discuss the medical aspects of ths*regulations. Mr. Ed Fenner would review OSHA and EFA regulations. Mr. Noel Hendry would discuss fiber handling. The J-U presentation will requires 35 vm projector, e 60 x 60 screen, along with a podium and a PA system. Mr. Drlslane indicated that arranpsnants for these would be made. T T Minutes of Che Meeting Asbestos Study Cotnittae -3- October 24, 1975 The seminar will be scheduled for Wednesday, December 3, and Thursday, Decsober 4. The opening session will be a presentation by Johns-Mastvllle for the full afternoon on Deceid>er 3. Other topics will be scheduled on Thursday morning, vlth Itc. Mereness (or someone else from A1A) talking at the luncheon on Thursday. There would be a registration fee of $10 for the seminar. Ur. Drlslene will try to make arrangements at either the Harriott at Saddle Brook, the ksmada Inn In Rochelle Park, or the Sheraton Heights in Easbrouek Heights. Mr. Deis lane will write Mr. Magdelaln and Mr. Mereness to officially Invite them. Mr. Wagner will writs to Ur. Kwon, Mr. Engelelghtener, and Mr. Hendry to firm up the arrangements. The conalttee recommends that Massrs. Wagner and Drlslene plan end schedule the seminar. It was suggested that tha type of person to be Invited should ba someone involved with plant problems, but It ehould also ba the foreman or ochar individual who could get across tha message to not use an air hose or e broom. The possibility of e movie being shown was discussed. It was suggested that tha controversial Interview of Dr. Sellkoff and Dr. Lorlasoha of Turner Brothers would not bs the right presentation. Perhaps a movie that emphasised controls In the work place might be worthwhile. Ho decision was msds as regards s movie. ' Another suggestion was to have a presentation by those who have used foam to envelops tha work station so that no dust is raised during miring. Mr. Heaver felt that this was an Interesting technique. Hr, Scons had discussed this at an curlier meeting but had made no further progress on this since that time. It was decided that this would not be added to the agenda. '. As regards the Hilfisk equipment, it was noted that this Is good equipment for local pick-up of dust and debris In the work place. However, this subject should be expended to include a central system such as a Hoffman unit. It was felt that this session should be called 7'housekeeping In the work place" rather than '"Nilfisk1'. However, the Nilfisk representative would discuss his unique equipment. The idea was to sell the concept of cleaning the work area (not to sell the vacuum cleaner). Mr. Drlslene will Indicate this particular point to Mr. !Sagdelaln In his Invitation. AIA BOCSLET ''ASBESTOS AMD BRAKE LTHINGS" Mr. bareness requested Mr. Drislens to have this booklet reviewed for update and corrections. The first question raised was "Who is this booklet aimed at?". Also, "What* is the purpose of this booklet?" It was stated that this vrlcs-up was not a complete presentation of any particular aspect of the asbestos problem, and while Interesting Insofar as It vent, was not particularly convincing. It is not tha type of message that would ordinarily ba given to customers of friction material manufacturers. The aesaage for re-bullders and the garage people la to not create dust in the work place. Ihere should he mere emphasis. If this was the direction of the booklet, on such things as labelling, possible use of instruction sheets, the handling of lining, and the proper use of exhaust systems. One of the problems in the field is that these customers will often groove, chamfer or provide extra drilling. It Is during these subsequent operations that asbestos concentrations may be raised to levels above that allowable. It was pointed out the Asbestos Study Committee could not re-write a draft unless It knew what the booklet was aiming at. It was stated that the title is wrong. Perhaps there should T Minutes of cbe HeLing Asbestos Study Committee -4- October 24, 1975 be two separate pamphlets, one for the garage and the re--builder type operation (for tbose who ere doing broke service), and another for the general public. It was stated that the audience for this booklet, as written, mist have been the environmentally concerned customer. Ur. Weaver suggested alternatives as regards this write-up:. (1) .Drop it-- do not use it. (2) Rewrite It for those servicing end installing friction naterlals. (3) T7rite a complete new article. She vrlte-'up made has little Impact. One advantage may be the listing of reference materiel at the end of the booklet. If the AZA believes that the booklet should get to the user (the curtomer of the friction materials manufacturer) it la suggested that information be given to the user as indicated in the proposed regulations under "DA3GES" `labels. This concerns the requirement during "any reasonably forseeeble use, handling, storage, disposal, processing, or transportation" that no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed be released. Tbs items that follow this section on housekeeping end waste disposal are particularly pertinent to the users of friction materials prior to Installa tion on a vehicle. . iir. Drlslane was advised that the Asbestos Study Coanlttae will not Te-wrlte the article. The Committee recosneada emphasis on recommendations for garages and the re-builders. The Committee would be happy to review a new vrite-up prepared by A1A which was aimed for this user, with emphasis on the tbose who actually do subsequent work on friction materials such as grooving, cutting, grinding, chamfering, etc. RECCCggHDZP PROCEDURE FOR BRAKE AMD CLUTCH SERVICING This write-up had been prepared by the Raybestos-Manhattan, Inc. Hr. Weaver distributed copies, to Committee mashers. Raybestos would welcome comments on this write-up along with any recommendations for changes. Committee members wishing to comment should send their recommendations to the Institute office. ' THE PROPOSED OSHA STANDARD AND THE 0.5 FIBER/CC LIMIT Prior to discussing details on the proposed OSQA standards, several members stated that they had been inspected by OSHA. While in a few eases citations wart made for higher concentrations of asbestos than permitted, there had been many instances where counts were mads without a citation. While the values on the concentration are revealed when a citation is made, OSHA does not provide information on the counts when a citation is not Issued. Several members Indicated that they believed that OSHA will not provide written results on their test in the work place unless it is necessary to support a citation. In other words, where a citation is not involved they will not reveal the data. Legal Counsel will check on the availability of this information and whether OSHA can be requested to provide this data when a citation is sot involved, and will report in writing to the Institute on this. The proposed OSQA standard is far reaching. The main problem is the new more difficult numerical standard (0.5 flber/ce). OSHA has put out a list of rather specific Items for public participation with the main item being that the comments must be postmarked on or before December 8. 1975. T ir Minutes of the He*tin" Asbestos Study Coaoitece -5- Oetobar 24, 1975 Writ ten comments concerning the proposal must b* submitted in quadruplicate: Docket Officer, Docket H-033 DS Department of Labor, Boom H3620 200 Constitution Avenue H.W. Washington, D.C. 20210 . The question vas asked as to vhat would be the most effective means of communicating with Washington to Indicate the problems with this new numerical standard. Should the Institute comant7 Should the Individual members comment? It la not enough for the manufacturer to feel his views will be represented to the regulators by the Asbestos Information Association or FMSI. It was suggested that It would be best if both the Institute end individual members respond with points that are particular to their factories. It is felt that participation by the small manufacturer will be most meaningful. The Asbestos Study Committee will review the proposed standard and note some of the points that mashers may wish to conment on. It should be pointed out that even if aethers comment to the effect that they support the AIA comments or they support the ntSI comments, at least they will be on record espousing their viewpoints. A comment was made to the effect that everyone has been gearing to get their concentrations down to the 2 flber/ce limit by July I, 1976. The technology necessary to take the count down to 0.5 fiber/ce Is not known. Bow can comments be made on the coat Impact, effects on competition, effects on employment, effects on energy supply, when the technology for getting to the 0.5 flber/cc is not even known at this time? The least that can be done is to request an extension of time for consents past December 8, 1975. Upon motion duly made, seconded, unanimously passed It was RESOLVED: That the Institute will request the Department of Labor to delay the cut-off date for cosent on these proposed amendments to April 1, 1976. The friction materials Industry does not know whether the 0.5 fiber/cc limit can be reached. Perhaps It will be necessary to go to materials with a material cost ten times that of asbestos in order to get the work place down to the proposed level. Industry is confronted with requirements for Standard 121 and Standard 105-75 from the National Highway Traffic Safety Administration with stringent friction materials requirements at the same time that they must evaluate whether they can still use asbestos in their products. There are several points in the OSHA standard besides the 0.5 fiber/cc limit. However, the main problem is the 0.5 fiber/cc limit. Some of the comments to follow concerned new problems that may arise as a result of this proposed standard. These problems will he pointed out to the members so that they can look at these from their viewpoints with the aim of advising Washington on their Individual problems with this standard. The reduction of the limit to the 0.5 level is going to offset processors such as the re-builder and the garages who ware not really included in this standard before. Any outfit that handles friction materials may very well find airborne concentrations of asbestos fibers that exceed the 0.5 fiber/cc level. For example, a junk yard which might have a T Minutes of Che Meeting Asbestos Study Committee -6- October 24, 1975 any work that they might do which could bring their concentration above 0.5 fiber/cc would now be s problem. These people would now be covered by the requirements of the OSKA standard. Many smaller operators have to drill materials to adapt them to unique shoes in the field. Additional drilling would probably move concentration .levels well above the maximum ceiling concentration of 5 fiber/cc. . . .. A point to be mentioned is not to adopt the tactic of .'Too can't do it." The point is that at the present time technology is not available in the factory to get down to these levels. The industry does not know what the costs are. How can comments be made on cost impact, competition, employment, energy, etc. when the technology to get there is not known? ' Still further, is such a limit necessary? n. It is suggested that unless a member has specific medical information suitable to refute the proposals in the standard that he not attempt to resist the 0.5 fiber/cc limit based on non professional observations of workers made in the past. In other words, if It was not good medical information don't use it. The Asbestos Information Association will try to assemble some realistic medical information for consideration by the Department of Labor. As regards the problem with cost Impact on the consumers, it may be that clean rooms for the elimination of asbestos may be required. Without knowing figures perhaps costs will mors than double with poorer performance at a time when the National Highway Traffic Safety Administration is calling for even higher performence. Members have made extensive plans for equipment, exhaust aysteme and procedures to get to the 2 fibers/cc limit on July 1, 1976. Since this equipment will not get them to the 0.5 fiber/cc level, this huge capital investment should perhaps be stopped until such time as a new standard is decided. Should a manufacturer discontinue his heavy commitment to equip ment for the 2 fibers/cc limit when this equipment will not meet the 0.5 fibers/cc limit? Could there be more emphasis on protective clothing with cover-alls, smocks, boots and gloves as well as a respirators. With reduction to the two fibers/cc level on July 1, 1976 and better work practices, the clothing might do the Job as well ms the new difficult-to-measure ' 0.5 fiber/cc limit. The manners don't know how low they can get in fiber counts until this new collection equipment is actually installed and in operation. Suggestlona made for cleaning the work area are all well and good but the only proof that one has reached an arbitrary fiber limit is when the installation is completed. As regards energy who can say that If double the horsepower was added to collection systems that they would get down to the new limit? How can the energy cost be estimated until this same equipment has actually reduced the concentrations down to the new levels? Where regulated ereas are established where allowable concentrations may be exceeded, it is difficult to get employees to wear the proper clothing. If one were trying to operate a dean room along with proper protective clothing, employees would want air-conditioning in the r ir Minutes of Che ?leeting Asbestos Study Coomlcte* "7_ October 24, 1975 work place for the uncomfortable clothing. To require air-conditioning Id the work place while also maintaining the extensive exhaust systems would be prohibitively expensive--if it can be done at all--because one Is at cross purposes with the other. Costs also will be increased because of the new monitoring requirements. , % As regards the effect on competition 'It 'was pointed out "that this may very veil be the trigger which would dose down some marginal operations with a resulting traasfar of jobs outside of the U.S. Even in Creat Brltein where much medical information has been gathered they have not gone to the 0.5 fibers/cc lialc. It does not appear that Great .Britain has sufficient smdical evidence to support such a limit. Countries on the continont do not have this 0.5 fiber/cc limit. The Latin American countries have no limits. As regards the effect on employment and competition, the huge capital expenditures required for the U.S. plants may very veil export additional jobs. . While some of the procedures recommended for handling asbestos end removing the worker from contact with the produet may shorn labor saving remits, the actual level of exposure to the remaining workmen from' these changes still will be quite high. There would be considerable costs for members in the friction materials industry to requalify brake blocks and heavy duty segments for the requiremants of the ifflTSA Standard 121 which went into effect during 1975. Thera has been a considerable expenditure of funds for Standard 105-75 (hydraulic brake systems standard) by many members. Any changes in the processing or compounding of friction materials necessitated by the proposed OSHA standard would add additional costs for manufacturers In requalifying their materials. The friction materials industry In particular ia caught between the forces of improved performance of braking materials along with restric tions on how to manufacture and distribute their materials. There may be considerable testing to requalify materials if there should be a change in processing or compounding. . As regards the.costs to consumers and society in ganaral the industry does not know what can ba dona if it la necessary to remove asbestos from brake lining. The industry could be subject to 5 - 10 years of serious dislocation. In addition to the problems with the OSHA standard that appear evident, costs can nor be quantified at thla time. Industry needs more time to respond to these far reaching regulations. One of tiie requirements for record keeping stated that the records must be maintained for forty years, or for an employment interval plus 20 years, which ever is longer. This is a considerable record keeping requirement. However It was stated that perhaps this Is necessary in order for subsequent study of the epldeallogy of asbestos. It was suggested that perhaps this is one of the new proposals that can be lived with. In prior meetings and at prior workshops the problem of correlation of fiber count has been discussed. In general there seems to be some agreement that different experienced counters may total up results showing as much as e 301 variation in counts from the tame sample. This is already a problem. However these counts vhart the 30Z variation ia evidenced ere in the 2 fibers per ce to 5 fibers/cc area. A 30Z difference with a 5 fiber/cc count it 1.5 fiber/ec. Here, OSHA is asking for a concentration limit of 0.5 flbers/ee when with currant observations there can be variations of as much as 1.5 fibers/cc. .. ---- -------------* * * fibers/cc not only does technology get tHniifM of die lieetlng Asbestos Study Committee -ft- October 24, 1975 Industry conditions In 1975 (under the current 5 fibers/cc Unit) are much improved over Industry conditions which were In effect through most of the 1960's. Each additional step approaching zero fibers/cc is a lot more difficult than the steps that were taken to get industry down to the 5 fibers/cc limit. While it 17111 be burdensome to move the concentrations to the .. 2 fibers/cc .limit, the steps necessary to get down to 0.5 -fibers/cc are not known. . There are requirements in the proposed standard for worker rc-asslgment. If many employees are moved to lesser and lesser duties maintaining the seam premium pay that they had received for working with the asbestos products, there will be a negative productivity result. It has been industry practice in the past for night shifts and more difficult tasks to command higher pay preiums. This rotation to another job with no loss in pay will be another penalty to productivity. The recommendations that will be made by the RSI or the AZA are not known at this time. It is believed that the AZA stand will include background on medical information. However, it- is most important that the individual companies make e response. They should not expect that someone else will write it for them. The Secretary will prepare e bulletin to be seat to the membership suggesting that they comment to OSHA on these requirements. It will be pointed out that the comments must be those of the individual member and they should not echo the suggested outline of problems which the Institute will prepare. It was also pointed out that there are a lot of new items in the proposed regulations including 1 tarns on loading, unloading and storing of asbestos cargo. The carrier--be it a railcar, ship or other--must make e visual Inspection of the cargo and cargo space to determine if leakage or spillage of asbestos has occureed. Who does this? Does the carrier do this? Are the carriers aware of this problem? A close reeding of the proposed OSHA standards revealed many problems of this nature which will have to be pointed out to others who may not feel that they are effected by Che asbeatos regulations. THE EPA NATIONAL EMISSIONS STANDARDS FOR ASBESTOS The Environmental Protection Agency published the amended standards for the iJational Emissions Standards for Asbestos. This appeared in the Federal Register October 14, 1975. Ordinarily the EPA amendments would be an item of prime concern to the manufacturers. However the proposed OSHA standards are so extensive and so far raaching they must take priority over these new EPA Standards. It was pointed out that the EPA notice is the adoption of the amendments to the standards. These are not proposed amendments. In particular the waste disposal requirements are of interest to friction materials manufacturers. The friction materials manufacturer is responsible to see that land-fill operators and trucks carrying waste comply with the requirements of EPA on disposal of asbestos bearing materials. The manufacturer is responsible for supervision to see that these requirements ere carried out. timbers reviewed the section 61.25 on waste disposal. There was some difficulty with interpretation. Mr. Weaver pointed out that the requirements for covering the asbestos containing materiel were applicable only if there were visible emissions to the outside air from the waste disposal site. In *-*.........--' r -----------" --J -- --" w t > --j T Hinuc* of the Meeting Asbestos Study Committee -9- Occober 24, 1975 of 61.25 do not come Into play. However these requirements for cover do take offset if there ere any visible emissions. The most difficult areas of the new EPA standard are in the waste disposal area. There was no other business called to the attention of the committee. Open motion duly made, seconded and unanimously passed it was RESOLVED: To adj ourn. Adjourned: 2:15 PM ' . W. Drislana Secretary T T