Document z61vdMmpM3DmqjVGp5V2bQpa

BULLET I N NO. 4 16 October 28, 1971 PROPOSED ILIINDIS BW ON ASBESTOS IN BRAKE UNINS ' . There has been considerable activity by members of the Asbestos Study Commit! ' as regards the proposed Illinois regulations on "Asbestos and Spray Insulation". Te quote from Part VII, Section 702 of the regulations proposed by the Illinois Pol lution Control Board: "The use of asbestos in the brake lining of vehicles manufactured after January 1. 1975. and sold for use in Illinois is prohibited." In the Board's explanation it notes that the prohibition is worded to avoid the necessity of fitting vehicles manufactured prior to 1975 with "non-asbestos" brakes* However, there is no question but that the ban- includes original equipment linings, and therecan be little doubt but that replacement linings on these vehicle must also be of a "non-asbestos" type* Further, interpretation of the proposed reg ulations indicates that all vehicles are included: Passenger Cars, Trucks, Off High way Equipment, Farm Tractors and the like. Also, the Board apparently considers "clutch facings to`be the same as brake linings"* While the immediate effect would be on those supplying original equipment linings, the secondary effect would be felt by all friction material manufacturers. in the Board's explanation they state: "These prohibitions have been made with full consideration given to the available alternative materials." . From the Illinois hearings this past month, the Institute has received severe articles of interest: . (l) Johns-Manville memorandum, October 20, 1971, by Mr. Swatonie sunma* . rizing the Chicago hearinpon October 15, 1971. (2) Written presentation by Dr.F. Pundsack of Johns-Manville as given at the Chicago hearings. e. (3) Dr. W. J. Nicholson, Mt. Sinai Hospital, a presentation in support of the Board's regulations, at the Chicago hearings* (4) Chicago Sun-Times October .18, 1971 report on the Chicago hearings. (5) Waukegan newspaper report of October 20, 1971 concerning the hearing in Waukegan. (6) Johns-Manville memorandum, October 20, 1971, by W. Paines summerisir the Waukegan hearinpon October 19, 1971. Attached to the delegates copies only of this Bulletin are excerpts: T ' dullat in .^416 -2- October 28, 1971 (2) Entire J-W summery of the Waukegan Hearings. (3) Pages 20, 21 of Dr. Pundsack's presentation at the Chicago Hearings. All those who have appeared at the hearings feel it is most urgent that the brake lining manufacturers advise the Control Board of their, position on this pro posed ban. It has been learned that the Control Board was surprised over the lack of response to the brake lining ban from friction material manufacturers. ' Realizing the unreasonable deadline you must work against, comments should be in the hands of the Pollution Control Board bv November 10. 1971. Please write: Ur. Samuel T. Lawton State of Illinois Pollution Control Board - 189 West Madison Street Suite 900 Chicago, Illinois 60802 The oeranente must be your own. We suggest that the primary force of these comments might be the lack of availability of known substitutes at this time. A secondary point might be that the Federal EPA (Environmental Protection Agency) is currently having studies made concerning the extent of emissions in the general en vironment from brake linings, and these results will not be known till mid 1972. Uniess you have specific medical background, we suggest you not question the proposed safety standards on ^asbestos concentrations. Further, as is the case with most ' government bureaus, any pleading on cost or economics should be avoided. Please note that the portion of \he proposed regulations that we are concerned with at this time ' is the general environment from brake lining emissions on vehicles in use. While the in-plant environment is also covered in the proposed regulations, we are advising our members primarily on the proposed ban on brake lining on vehicles. Should you write Ur. Lawton, it would be appreciated if you would send a copy to the Institute. .If there are any questions, please give me a call. E. W. Drislane Executive Secretary Distribution: Active beet Mr, C. J. Weber Kr a. R. jailer Mr* Q* X* Vilaon Pit* X, s* V* Drlalane - FKSI Vermber U, 1971 . Mr* Farieel 7* Lavton State of ZUlso&e foliation Coctroi Board 18? West Kadieen Street - Suite fOO Chicago, TinmH m 60602 . fear hr* Lestc*it . Aa e manufacturer of brake lining* it ease as s eosplate shock to World Sestos Caopeay, Sirialea of The Firestone- Tire 4 Robber Coapaajj to lean of the proposed 157$ restriction of the nee of asbestos la the brake lining of vehicle* sold far use la Ulisols. for each o widely affecting regulation to bar* been proposed nust hare bean besed oe a substantial aaount of dawning evidence ef an onequlvocal noture* Ve wosld Ilka to bo supplied a list of refsruseas or still batter copies of all scientific data upon idilnh the pro* posed regulation waa based or used as support so that w can sake our om analytic of said data and begin oar alternative research program IpwflitaTy, If these studies for which tha regulations were based open are Indeed scientifically reliable, than a three year waiting period is in question* Qan you espials how the three year figure was MTrirwd at and the thinking and reasoning for sueh a delay and grace periodT ' 2 V* eould also Ilk* to hare wads available that infersatloa re- gsrding suitable available alternative aaterlalf and the teat date elsariag these aatarials* Further* w* would like to see th* available dots irfilch supports the alternative watcrial* in brake ^ teeta such as Eepartaent of Transportation vshiole taste sod pertissat Indoor tyxaacnoter tests* We should like to nay that reference* which w* hare seen and are aware of do not suggest that brake lining salsaLone eon* rtitut* any btoui health hasard. Therefore* we feel that the . proposed regulation will not accoepTlth In fact Its Intent (that is* to rodoee asbestos levels In snbient air) through sseh an anaeteaat* ' In conclusion our observation at tbs prasant tins la that the proposed regulation nay b# based an unsupported end insufficiently eosprshecsive data tc warrant sueh axtanair* aetiee "by the itate of niinois* Very truly yours* VCRIT S3T70S Ca-PUT JCUHtlkm Attachment Janes S* V* Banning Manager* Teeininal-aasearoh --nr MGRGMOIMT ill MOftTH MICMiaiN AVSMUS ' CMiCllO. IUINOII *OIOl TtLIPHONI (313) 33.r?| November 5, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: 1 am writing you to register concern on the part of Maremont Corporation relative to the proposed Illinois ban on asbestos in brake lining, effective after January 1, 1975. Maremont currently produces, under the brand name "Grizzly", both pas senger car and heavy duty vehicle brake lining for the aftermarket and has been a part of the Friction Material industry for over twenty years. We are most concerned with this proposed legislation since it is our com bined technical opinion that there is not, at the present dme, nor will there be in die foreseeable future, a suitable alternative to asbestos in friction material that will yield the performance characteristics required in today's braking systems. Further, proposed federal improvements in braking sys tems to be effective after 1975 will require those manufacturers now par ticipating in the industry to devote their time and energies to sophisticated improvements within an asbestos based product, making the research for an asbestos substitute a goal beyond the available technical abilities of most manufacturers, should chat substitute really exist. Mr. Lawton, I would appreciate your continued review of the matter and hope that Maremont's concern will be given appropriate consideration. Sincerely, AAL/gjk Andre A. Laus Vice President and General Manager Brake Systems Division AUTO FRICTION CORP. MANUFACTURERS OF BRAKE LINING November 3, 1971 Mr. Samuel T. Lawton State of Illinois Pollution Control Board 185 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: It has com to ay attention that the State of Illinois is considering regulations or legislation which would prohibit the use of asbestos in the oanufacture of brake lining for use in your State. I also understand, chat there was a certain amount of disappointment expressed by manners of your Board that there was a lack of response from the friction material manufacturers. The reason that we have not responded before this, is that until I read a recent article in Chemical Week Magazine, I was not aware chat regulations or legislation was being promulgated. 1 may state quite succintly two basic objections to this proposed regulation or legislation on the part of our Ccxnpany: 1.* There is a complete lack.of availability of a known substitute at this time for asbestos in the manufacture of the broadest range of friction material products for safe and accepted use in automotive vehicles. 2. The Environmental Protection Agency of the U.S. Government has presently commissioned studies to be made concerning the extent of emission in the general environment from brake lining. The results of this study will not be reported until mid 1972. 1 spprecisce this opportunity to inform you of our comments, and remain. Sincerely, AUTO FRICTION CORPORATION Norman Comins Vice President bcc: Mr. E. W. Drisla EMSI, New York HASSBESTOS (201) AltKMr *<(SS LvaA*UFA6TUR|e26 05ATIQ3 2* EAST 5th STREET PATERSON. NEW JERSEY 0732:4 -------- QUAUTY FRICTION MATERIALS SINCE (SIR -------- Nov. S, 1971 G^~ State of Illinois Pollution Control Board 189 West Madison Street Suite 900 Chicago, Illinois 60602 Att: Mr. Samuel T. Lawton Gentlemen: As a brake lining manufacturer whose product contains asbestos we are much concerned over the Illinois Proposed Ban on Asbestos in Brake Lining, particulated by Part VII, Section y02 from the regulations proposed by the Illinois Pollution Control Board. Our cotooany, and our industry as an entity, is definitely not interested in producing products which will have harmful emission effects in the atmosphere. But we do believe the above cited section of the proposed law does not have evidence to back up its ..severity--evidence that proves a harmful emission-factor as a result of/or because of the asbestos content in friction materials. On the basis of reports of testing emissions we believe that although it is within the power of the State of Illinois Pollution Control.Board to have asbestos banned from brake linings* we feel that to do so would eliminate an effective and useful brake lining component without justification. We are certain that many of the emission tests have been forwarded to the Board, and that the Board is aware of the tests of emissions now being made by the Federal Environmental Protection Agency. We believe that this data will be most helpful in determining the effects of asbestos-emissions from use in brake lining, and will establish whether these emissions are of any danger or if they are negligible. T ;?.assbesto$ (201) ARMORY If the emissions prove to be a harmful pollutant our company will certainly support your Board in eliminating this hazard. But until reliable evidence supports this possibility we are reluctant to accept any unsupported position. Our company has been producing brake linings since 1919. (The basic company was formed in 1917.) During this span of over 53-years we have produced hundreds of millions of feet of asbestos brake linings. In our process, we dea-l closely with raw asbestos fiber. Of course, we use orotective measures in handling these materials----- as well as other fine powaers. We have never had, in our history, a case of asbestosis or anv other asbestos-induced illness among any of our personnel. We believe this record is not uncommon among brake lining manufacturers. We are aware of the fact that in other industries who use asbestos there are systems which do not control or contain the material. However, our chief concern is with the brake lining industry, and the effects in the atmosphere of the use of asbestos in brake linings. We believe that the asbestos is locked-into the brake lining material, and that during its normal usage the heat of the friction converts any residue into an inert non-fibrous material which will not be hazardous in nature. We look to your Board for a full analysis of this matter, and a just decision based upon proved and repeatable data of a factual, non-emotion&l, nature. Very truly yours, . BRASSBESTOS MFG. CORPORATION . S:g . . WILLIAM SIMON President /fa Abex Corporation November 8, 1971 Research Center UINWAM. HtW JttStr 874Jt . til m-ta.Hu Mr. Samuel T. Lawton State of Illinois Pollution Control 189 West Madison Street Suite 900 Chicago, Illinois 60602 Dear Mr. Lawton: In conjunction with hearings recently held regarding Regulation No. R71-16 "Asbestos and Spray Insulation" proposed by the Illinois Pollution Control Board, we believe it. would be helpful to you to have our contents as a major manufacturer of friction material. * The Abex Corporation, through its American Brakeblok Division is one of the major suppliers of friction material for brake and dutch use In the United States. During 1971, our sales of asbestos containing friction material for use in vehicles operating in the United States will be in excess of 20 million dollars. Our interest is specific to Part VII, Section 702 of the proposed regulations which states "The use of asbestos in the brake lining of vehicles manufactured after January 1, 1975, and sold for use in Illinois is prohibited". Our cooaents are as follows: 1. Asbestos 'fiber, is an important component of organic friction material used in brake and dutch facings for vehicles manufactured and used in the United States. Of known fiberous material, asbestos imparts unique strength and thermal properties to friction lining, in addition to pro viding unique performance characteristics essential to safe and reliable braking and clutching of vehicles. 2. We are aware of investigations conducted on the nature of wear products from linings in use, as well as the identification of airborne particles from operating brakes. Air sample analysis conducted by our Medical Department to collect wear product particles during brake operation on our laboratory dynamometers confirms the findings of J. R. Lynch as reported in his study "Brake Lining Decomposition Products" published in the Journal of tha Air Pollution Control Association, Vol. 18, No. 12, Deeenber, 1968. 3. Abex Corporation, in conjunction with Arthur D. Little, Inc., submitted a technical proposal to the Svlronmental Protection Ageney in response to that agency's request for proposal No. EESD 71-NEC 102 "Characterization of Emission from Automobile Brake end Clutch Linings". In this way we are well aware of the investigation work now being carried out by the Bendix Ax Mr. Samuel T. Lawton -2 November 8, 1971 Corporation under contract to the Environmental Protection Agency. Ue understand that results from this contract research will not be known until the middle of 1972 at the earliest. It is our opinion that the results of this study will verify again that airborne particulate matter from vehicle brakes and clutches does not con stitute e dangerous health factor in Urban air pollution. We believe that the proposed ban on manufacture and use of asbestos containing friction material is 'unwarranted and unnecessary. We reconmend that Part VIZ, Section 702 be removed and not made part of regulations proposed by the Illinois Pollution Control Board. Very truly yours. G. R. Graham Director Friction Materials Research GRG:nmp BC: Messrs.: N. G. Belury G. L. Romine F. B. Herlihy E. H. Fcierabend E. W. Drlslane, FMSI. Inc. W. P. Raines, AIA/North America  British Priction M aterials Council UMT4M4II AK(N. ROOKI m CO. yniMim i>w> 0111 99. ALDWYCH. London. WC2B 4JY 362/a/BFMC The Secretary, Friction Material* Standard* Institute, Inc., 770 Lexington Avenue, Mew lark, N.1.10017, . D.S.A. 26th Noreaber, 1971* Dear Sir, We have been .asked by our oesbera in the British friction Materials industry in the U.K. to put their views.to you on the proposed Illinois -State Regulations concerning asbestos and- asbestos products* --We enclose herewith their comments on the friction material aspect of these draft Regulations. * We have no doubt that the American lining manufacturers will be making strong representation* to the Illinois authorities for amendments to the proposals and perhaps you could let us lotow their consents. We hn also be grateful if you could sake our views known as set out in this enclosure. Eac ^J. OK The British friction material* industry views with deep concern the proposed ban os the use of aabeato* in brake linings by the State of Illinois. It is not aware of any medical evidence that could possibly justify such legislation. On tbs contrary it would have the effect of withdrawing from the market products that were used to promote road safety, without producing any significant improvement in the levels of urban atmospheric pollution* It would expect any of the known alternatives to asbestos to produce general particulate pollution of a measurable amount. 1. Whatever materials are used for brake linings the current state of the art is such that the action of braking will generate products of wear. The asbestos content of conventional brake linings'is almost entirely converted by the action of braking into forsterite or other amorphous, inert materials which arc no longer asbestos. On the other hand, if non-asbestos alternatives are used (e.g. iron powder, sintered metal, ceramics, steel wool ate*,) th* resulting wear products will be .released unchanged. 2. Measurements have been made of the amount of free asbestos fibre left in brake lining dust. It is sn insignificant proportion of what ia in any case a minute amount of total dust* The amount of free asbestos fibre that has been found in brake lining duat from vehicles, ia about 1S of the total products of wear. (l). Indeed estimates vary down to 10-9g/g, i.e. for each gramas of wear products only 10-9 grammas of free asbestos may may remain. 3. We assume that the risk of contracting mesothelioma ia the principal cause of environmental concern - there ia clearly no possibility whatever as a result of vehicle braking, of a community risk of aabestosia or lung cancer, which are solely occupational risks. For technical reasons only chrysotil* asbestos is used in the manufacture of brake linings sad disc brake pads* This is. not the type of aabsstoo with .which mesothelioma haa been mainly associated. 4. Measurements of chryaotile asbestos in the ambient air in an industrial centre in the United Kingdom have shown that the level must be leas than 10"? g/m^ because of the limitations of the method used. This naans that thsy must be a thousand times lower than tha British Government acceptable level for occupational ezposurs* Current investigations using a more sensitive method indicate levels of 10"* to 10"TM g/a , i.e. 2 or 3 orders lower still. (2). oraks lining wear cannot therefore be a serious source of atmospheric pollution* 5* In on* of th* largest brake testing laboratories in the world, bousing many dynamometer* engaged 24 hours a day ia wearing sway friction satcrisis, th* average monthly asbestos count is 0*2 fibres /ee, a tenth of tha British Government's occupational standard. T /,/tohu'*C liA fcOVEV.ifft U *.37*. S. Chrysotiie Asbestos in Urban Air Tme industrial use of chrysolite asbestos is insttsint one is: question of whether its concentration in urou air commutes a hazard has been raised. But measurements of asbestos in air near asbestos factories have proved negaiwc with present analytical method*, so under the sponsorship of the Asoctiosn Research Council we are developing a more sensitive technique. This ankle is a preliminary account of me estimation of chrysolite near a large asbestos textile factory'a: Rochdale. Lancashire. There are several uncertainties is the technique, so we were, expecting to obtain only an order of rpigntiude estimate. Nevertheless this would have bees an important ' figure to have because of the lack of data an the amount of asbestos in air. As it happened, we were only able to determine an upper limit for the chrysotiie concentration which turned out 10 be three orders of magnitude lower than the thtesnoid value for occupational exposure set by asbestos refutations. Obviously even more sensitive techniques are required and are now being developed. We used an X-ray diffraction technique based on the measure- ment of the integrated area under the (002j peak of chrysolite. * The equipment, which consisted of a Phillip* 1010 generator, * a vertical goniometer with a step scanning attachment, and a ' proportional counter with pulse height discnmicaiion, could be reliably calibrated down to 10 pg of chrysolite compared with the 1 to 10 mg range reported by Crebte1. and was cross checked by estimating the magnesium content of the calibration samples by atomic absorption spectroscopy. Sampling involved the collection of airborne solids from 1.000 m* (I04 I.) of air by an electrostatic device (H. Litton Systems Inc.) in which up to 10.0001. min'1 are drawn through a 20 kV eorona diarbatgs. Panicles in the air are electrostatically precipitated ontoa plate and concentrated into -- 100 ml. of liquid. , . The collection efficiency depends on the sne distribution of the panicles and the sampling rate, but the sob distribution t* chrysotiie in the atmosphere is not known. Therefore- we estimated the collection efficiency indirectly by running the ,, sampler in pan of tlie asbestos factory where a low consents*- tion of asbestos i known to occur fKig. 1) and i found the collection efficiency to be almost 100% when the air is sampled at about 2.009 . min*1, dropping to between 25 and 50% at the rate of 10.000 I. min*1, depending on the actual sis dis- ' tribuiicn present. As we were aiming at only an order of magni- JW Fig. I Observed amounts of chrysolite in 5.000 L of factory air, sampled at different rates. NATURE VO- 234 N0v2f,*.5g. *5 Takw 1 V. Miner Conoiuwu outing Somoung Dale (1970) April 22 April 24 April 27 April 29 May 4 May 1J May 21 May 21 May 30 May 30 June 3 June 10 June 10 October 23 October 23 October 23 October 2S October 21 October 21 Site Wind Weather 1 SW moderate Broken doud 1 SW tlictlt Ground baa 1 I I 1 3 NE moderate SW moderate S straits N fresh W light Ground haa Ground haxc -Gfotmd base Ground haze Overcast, dull ' 3 W light Overcast, dull ' 4 w hpni 4 w light Overcast, dub Overran, dull 2 SW light Overcast 2 SW sligrn 2 SW slight Heat hast Heat haze * 1 W moderate broken doud J W moderate Broken doud l W moderate Broken cloud ) N light Broken doud - 1 N light Broken doud 1 N light Broken doud tude assessment of asbestos in urban air, we wen prepared to m^r-ept this uncertainty in the collection efficiency. Toe map (Fig. 2; and Table 1 show the location of the sampl* ins sites and the conditions in which the samples Were obtained. The faaoty is in a hollow, and sampling she No. 2 is at the same height as the roof of the filter gallery, which is the chief air outlet from the factory. Sampling site No. 1 is about 30 foot higher than site No. 2. Sites 3 and 4 were in the gardens of houses, site 3 being about 5 kin upwind of the factory and site 4 being about 300 m downwind. All the diffraction traces ffor example. Fig. 3)comained strong hoes of kaoiinite and quartz, probably from the local soil, which fffAm the of chrysolite difficult because the broad (031) line of kaoiinite (7.1S A) is dose to the major (002) line of chrysolite (7.36 A). Fortunately chrysotOe is easily decom-' posed by boiling ia 1 N hydrochloric add whereas kaoiinite is so. it should be possible to measure tbs amount - of chrysotile present by subjecting the samples to add leaching and measuring the corresponding reduction of the intensity of the composite X-ray band. The fas that this process led to no reductions in bend intensity for any of the samples indicated that the amount of.ehrysotik present was below our detection limit. We ought to have been able to detect 10 pg of chrysolite by itself, but dearly the presence of kaoiinite may have reduced the Knsitrvity. But the addition of 100 pg ofehrysotite to ow collected samples could easily be detected, so we can say tbai our samples collected from 1,000 m1 or air contained tea thsc J00 ft* of ehrysoxik--in other words, them was teas than 0.1 pg of chrysolite perm* of air. The threshold limit for occupation* exposure set by the 1969 Asbestos Regulations* is (LI mgttT* Fig. 3 X-ray diffraction penern from a typical dust sample near * the Rochdale factory. A mote sensitive method for estimating duysotile is required, and we are developing a technique based 00 electron micro scopy. Preliminary examinations under the electron micro scope of samples collected by the Litton sampler indicate that the actual chrysolite level may be s further three orders ot magnitude below the X-ray detection limit (that h, about 0.1 ng). `' The samples have so far been collected in the dosa viemity of the Rochdale factory. It is now proposed to sample ate at certain representative urban and rural locations in UK and estimate their chrysolite content. .' ALUtcam D. V. Bapami Turner Brother* Asbestos Cm. Lid, fO Box 40. Backdate, Lancashire . B,waived April 11; revtesd September 22. 1971. Crafate. J. V., Amer. tod. ttrr. Assoc. /., 27.293 (19661. ' * Standard..s..f.o...r..A. s1bruers*tos Dust Coei.rm-.ire* u..o.n/rtv*rUijst#e wish the Ashe**