Document zo3a1DXgR4Q3mQO4OoxjoGRp3

\FRICTION MATERIALS STATOAFJS INSTITUTE, INC., E. 210 ROUTE <*, ^t ~ MINUTES or THE MEETING of the -- ASBESTOS STUDY COTSOTTEE Thursday, August 17, 1972, at 9:30 A.M. at the Institute Office, E* 210 Route 4, Paranus, N. J. MESSRS PRESENT 1. H. Weaver, Chairman J. C. Banning W. Spurgeon H. Wagner E. H. Felerabend Raybestos-Manhattan, Inc. Firestone, Tire & Rubber Co., World Bestos Division Bendlx Corporation Bendlx Research Laboratories Carlisle Corporation . Molded Materials Division Abex Corporation Aserlcaa Brakeblok Division HgSERS NOT PRESETS V, B. Reitze Johns-Manville Corporation * OTHERS PRESENT D* E. Stone E. W. Drislane Bendlx Corporation Friction Materials Division Friction Materials Standards Institute The nesting was called to order by Mr* Weaver, Chairman, at 9:30 A.M. MINUTES OF PREVIOUS `MEETING The Secretary read a turnery of the Minutes of the Meeting held February 10, 1972* These ninutes had been released and a motion-for their acceptance had been obtained* Upon notion duly made, seconded and unanimously passed, it vas RESOLVED: To accept the ninutes of the February 10, 1972 nesting as distributed* INTERPRETATION OF THE OSHA REGULATIONS The Asbestos Information Association (AZA) net with representatives fron OSEA late in June* The purpose vas to interpret various Individual requirements in the OSUA regulations. Letters fron the ALA to their member companies, dated July 5, 1972 and July 12, 1972, were distributed to the Connittee Members. In the first letter, they covered areas such as labeling, elothes lockers. .Minuses of Meeting Asbestos Study Committee -2- August 17, 1972 respirators, monitoring and physical examination*, citations, OSHA inspections and employe* notification. In the second letter. the.AlA distinguishes be tween non-loc!;edrin asbestos containing" prodtrlsJ^9ifiicB1GoEiaeS^^rn5.e llEing and dutch facings)* There are certain labeling requirements tied in to the non-loeked-in containing asbestos products, but this letter also discussed < the problems of subsequent working of locked-ia asbestos containing products* The members discussed some of the items Is the OSHA regulations* One member indicated that during an Inspection, there were 3 OSHA people at their plant for 7 to 8 days* Interestingly, the 3 OSHA people case on site the first day veering respirators. Whether this vas for effect or Is.a standard procedure for OSHA vas noc known. One of the items pointed out by an OSHA inspector on the scene vas the dry sweeping of loose asbestos-type compounds vs. the vet sweeping or vacuum cleaning that OSHA calls for. Another member advised that they had taken out. all air hoses around briquette presses and other machinery where loose asbestos is handled before It becomes locked in* Surprisingly to some members, asbestos sampling indicated that the inspection and drilling locations vert problem areas* One member required that the respirators be worn at all drilling locations* In an inspection at ena member's plant, the OSHA people set up 5 stations and while 4 of them sampled below the 5 fiber per ee TUA, one station xaad 18 fibers per/cc TUA* This member vas citad (is averaging the readings). * 4rWhen the Federal Government vas considering the necessity for asbestos regula tions, two of the eoopanies represented by Members os the Committee were asked to cooperate in a survey by NIOSH* This study by HIOSH vas to check over medical records and other such items to attempt to put the problem in prospective. KZOSH had Indicated to the cooperating manufacturers that the information they were providing would be kept confidential. However, as it turns out, the OSHA people have copies of the NIOSH studies which would indicate that the confidentiality has been violated. A member questioned what happens when the asbestos concentration in a work area exceeds 10 fibers per cc (the delllng concentration in the OSHA regulations). The answer is thee the employer must notify the worker so exposed. In writing, that he ves exposed to such a concentration and the worker oust wear a respirator in that area* The next question concerned what the proper means for notification of the worker would be. Zf en interpretation is officially asked of OSHA, they will indicate that e registered letter to the employee Is the proper weens of notification* In ocher ersss, OSQA hes indicated thee meeting the spirit of the lev la what counts and It is felt that bulletin board notification would suffice. disposable The next question concerned respirators* It vas indicated that there were 3 / respiratorSP?rov8y the Bureeu of Hines, and these are.manufactured by the A* 0* Smith Company, Welsh, and Minnesota Mining and Manufacturing (MMM). Respirators furnished employees must have a proper fit and the employees must be instructed both as to the fit and the servicing of the respirator* Responsibility for testing and approval of respirators *for protection against asbestos dust re cently ves transferred from Bureeu of Hines to NIOSH* Until NIOSH approvals are issued, it is recommended only respirators (reusable or disposable type) having Bureeu of Mines approval specifically for use on asbestos duet be used in asbestos contaminated atmosphere#. . .lliautes of feting Asbestos Study Committee -3- August 17, 1972 USSLISG PRACTICES there are 3 areas for concern on labeling. One Is the handling of the loose asbestos fiber from the point where it is received to the point where it is nixed and briquetted. The next is the handling of the products with supposedly lodted-la asbestos during subsequenf operations,' such 'as drilling,'grinding, inspection and boxing. The last concerns the handling of the brake lining or clutch facing by the customer where he may also do tome drilling or grinding before the lined assembly is a-finished product. It was reported during this topic thee there was a higher concentration of asbestos in the air in the Inspection Departaent than most menbers had realized. One member indicated that when pallets of brake linings were shipped there apparently is additional dust created during transportation. The question of surfact dust, on the working surface of'a brake lining or a clutch facing was discussed. Where mesbers have taken action to reduce the dusty type surface, they have found that they have actually altered the frictional characteristics of the material during the early miles on a vehicle. In other words, the brakes are not very responsive during the early mileage after reline. In the AIA recocatedstlons, it is suggested that where a manufacturer Is shipping his brake linings or clutch facings (locked-in-asbestos products) he should* notify the user of his product to the effect, "Power bench saws.without collectors should not be used in cutting this product. If this is impractical, operators should be provided with a Bureau of Hines approved respirator." It was suggested that a notification be put in boxes of brake linings or dutch facings being shipped to customers. A sample of the caution labels suggested is attached to these minutes. Mr.' Feierabend indicated that this recommendation would not be accepted warmly by many manufacturers. Mr. Wagner objected to the recommendation that warning notices be put in the brake linings as he felt it was another "red flag" that would bring more harm to the industry than the alleged good that would come from enclosing sueh notices. Several members have had customers call in to their Sales Departments asking if the handling of locked-ln-asbestos in brake linings and dutch facings is a hazardous condition. Another asked if this notifcation was a requirement of the OSHA regulations. It was indicated that this was not specifically required by the 0S8A regulations. The concern is, do those customers doing additional grinding and drilling of. tht brake linings or clutch facings create working conditions vhera the con centration of asbestos would be a hazard. Sines small manufacturers are exempted from the OSSA regulations, they, will probably not be running tests. Larger customers will, of coursa, be covered under the OSSA regulations and it la expected that tests will be run In these manufacturers1 work areas. Whether the Institute would recoasend sueh labeling in finished products shipped to the customers was not decided. It was felt that this st&ject should receive further consideration from the Kerbera of. the Committee before a recommendation is mads. One member commented that there were instructions by some manufacturers advising that bloving out the wear debris from used brakes was not recoaaended. This subject of recommending chat braka lining and clutch facing manufacturers include e versing sheet in their shipments appears to be somewhat controversial and it is suggested that this matte; receive some serious discussion by. the Mesbers of the Committee with those responsible st their companies. This item will most definitely be on en egenda for the next meeting of the Asbestos Study Committee.  Minutes of Meeting . Asbestos Study Committee -4- August 17, 1972 SAMPLING FOR ASBESTOS FIBER COUNTING *-3r. Stone questioned the possible movement of asbestos inside the filter sample when sene to th& lab for examination. Hr. Weaver indicated that this possibility was quite remote. Apparently the question arose after an OSIIA visit to the member's plant* In response to a question, one member indicated it takes about two months from the OSHA 5sapling until the OSHA report is received. Further, it vas indicated that the company hears if it is to be cited and not If the conditions are aatlsfactory. The OSHA regulations call for an eight hour time weighted average (TWA) for the measurement of air. borne concentration of asbestos fibers. One member indicated that he runs his sasple test for a continuous four hours to compute the concentration. With a continuous four hour sampling, there are sometimes reactions from the shop people. Returning to the question on sampling for fiber counting, OSHA reeos&ends a full straight eight hour sample. It vas indicated they used 8 filters during this continuous sample. A member suggested using 90 minute sampling for most areas, or s complete job cycle if it took longer than 90 minutes* He recommended four hours of sampling for specials. A member questioned as to vhrfe minimum time vas necessary la sampling to determine the peak concentrations that cannot exceed 10 fibers per ec. No specific answer was given, but Weaver indicated some sampling procedures which he felt were optimum for counting fibers entrapped by the filter. The tnsober of tests for various conditions is suggested in this tabulation. One condition is where you are measuring friction materials with asbestos in the compuad, and the other is for areas where you are handling all asbestos. Optimized time for fiber collection - depending on TWA fiber per ce concentration expected in area. (Optimum for counting fibers on the filter) Friction Materials TWA Fibers per cc Optimum Number of Tests All Asbestos TWA Fibers per cc 0- 5 5-10 10-15 l$-20 - 1-8 hr. test 2-4 hr. tests 3 tests, 3,3,2 hrs. 4-2 hr. tests 8-1 hr. tests . 0- 3 3- 6 6- 9 9-13 13-20 The question erose concerning the sample, where one ie trying to pick up asbestos for counting. What about the oc&^'i&i&rlals in brake lining that are not?ons)deri hazardous? Might these not be counted on the filter as well es esbestos? One answer that is indicated for the skilled laboratory man making the examination is that he should ha able to distinguish between asbestos fibers and oeher materials. Further, one can go to 300X on the microscope and gee a closer look at the materials picked up on the filter. Or. Spurgeon indicated thee one can use low temperature ashing to Tamove resins and other organic materials (primarily friction dust). , Canutes of Meeting 1 Asbestos Study Committee -5- August 17, 1972 SPA AUTOMOTIVE EMISSIONS Dr, Spurgeon Indicated that the Bendix Research Laboratories are working under contract for E?A on particulate emissions from brake linings and clutch facings and will not be finished until March 1973. Dr. Spurgeon felt It would not be proper to discuss results and progress to date on this study under contract to the government. THE STATUS 07 E?A REGULATIONS Mr. Weaver indicated that one of the reasons for scheduling this meeting in August was to go over the new E?A regulations. However, this agency has not finalised their regulations aa yet and It Is not expected to be published until sometime la September. Mr. Weaver indicated that the problem was not with the asbestos sections, but rather with some of the other materials and he expected that their regulations will noc be very much different from the eerller temporary regulations on asbestos. Ones again, those earlier regulations were more concerned with control practices (collectors and .disposal techniques) than with numerical emission values. No further action can be eaken in this area until the LPA regulations are published. CONSIDERATION OF SUBSTITUTES TOR ASBESTOS / At the Annual Meeting,in June, this Committee was directed to consider a * recoo&endation that the Institute sponsor a research study to determine the possibilities of substitutes for asbestos. The purpose of this suggestion was that if an outside study were to show thee certain materials might very veil be acceptable substitutes for asbestos, Che information would be made available to the members. If the outside study indicated that there were no satisfactory substitutes for asbestos in friction materials, this information could be used as a defense should ve have a recurrence of action similar to Illinois* banning of asbestos based brake linings. The Committee discussed this and as most of ehem art working on asbestos substitutes and some, in particular, have marketed materials without asbestos (primarily metallic*), they felt this suggestion would not be warmly received by many members''. One member indicated that it would ba vary difficult for Cham to sanction the Institute making any such study considering the work they have done in the past. Upon motion duly made, seconded, and unanimously passed, it vaa RESOLVED: That the Asbestos Study Cosnittae dots not racosntnd an Institute study in the area of substitutes for-asbestos, WASTE DISPOSAL Someplace between the point where the asbestos product is finished and the waste materials era disposed of, the OSSA requirements will become EPA require ments. In other words, we are moving from the condition of standards in tha work place to standards in tha atmosphera or environment. The area of vastt disposal is a major problam. All asbestos, bearing wastes, according to the OSKA regulations, must ba collected and disposed of in sealed impermeable bags or other elosad impermeable containers. Whether a closed steal truck body Is considered "impermeable" is s question. Xf tha OSHA people mean what they say Minutes of Meeting .'Asbestos Study Committee -6- August 17, 1972 vhen they suggest thee an employer who is attempting to meet the spirit of the lav vill not have .difficulty, it will be assumed that removal of the vaste material in enclosed steel truck bodies would be an acceptable means of disposal. Host members indicated that they had great difficulty with polyethelene bags - they are too soft and they tear when they are stacked. The next area, which is a major problem, la the actual disposal of the dust. Usually, It is unloaded as land fill. One member uses a screw-type conveyor to fill a truck with a fixed container. The material is then dumped into land fill. The material is vet down after dumping and, after a hole is filled, it is covered up. Hr. Stone mentioned a procedure he had seen where they turn the dust into pellets and dispose of the pellets. One member indicated a solution for the disposal of the paper bags that are used to package the asbestos. They unload the asbestos bag inside a hood where they cut the bag. The hood has an empty plastic bag which the asbestos begs are picked up in. The topic of proper disposal of the friction material vaste products was discussed. The most desirable method of disposing of friction material vaste products is to put it back into the friction material. Where a manufacturer has a one-formula product line, this is reasonable. However, most of the larger manufacturers would find it very difficult to segregate the various mixes pieked up in their collection devices and recycle it back into the friction material without running into product problems. This Is obviously the most desirable thing to do with the vaste material, but for tuning out a quality product ifr becomes very difficult. The most common means of disposal arc to vet the ^ product down and dispose of it as land fill. In some areas the material is bagged and sent to the dump. The problem of eeonomieel means to dispose of the vaste from friction materials has been a problem In the industry for many years. It is likely to become a much mo-re perplexing problem considering the regulations by OSHA and EPA. Dr. Spurgeon brought up the question of the possibilities of the Institute sponsoring paid research on waste disposal. It was indicated that within the Constitution and By-Laws of the Institute ve could very well sponsor such research but It would be up to the Committee to make xecosnendetlons in this area. Generally, there are areas ocher than asbestos that are Involved In this waste disposal problem. Among the items to be considered ere: grinding dust, asbestos fibers and bags, phenollcs which are poked up in vet serubbers, lead end its compounds, sad the solvents that Are driven off during processing. The Committee will consider this possibility at a subsequent meeting. A member suggested a possible questionnaire to be sent out to Che Membership concerning the problems of waste disposal to see whether the rest of the Membership could contribute some Information In this ares and to determine the extent of latsrest la the study of vaste disposal by the Institute. The Members of the Cooaittee should consider Items to be included la such s questionnaire for discussion at the next meeting of the Committee. MATERIALS OTHER THAW ASBESTOS Because the problem of waste disposal is not s problem of asbestos only, questions were raised about tha possibilities of extending the scope of the Conlttee's ' work beyond that of asbestos alone. Tha Secratary indicated that it would be within tha aeopa of tha Committee to extend their activity to materials, other than asbestos. Lead and laad compounds are among tha hazardous materials being regulated by Federal agencies. As many manufacturers use lead and lead compounds 'Minutes of Meeting * A# sbestos Study Committee r August 17, 1972 la their friction materials, this might be e material to be studied by the Committee. Oa the other head, because of the seriousness of the asbestos regulations, by_ taking oa other eaterlalsy the efforts of this Committee might be diluted* Currently# there are regulations oa solvents, silica, end other msterfhls considered hazardous or noxious by the regulatory agencies. It Is requested that the members consider the possibilities of expanding the activities of this Comittee to' cover other materials. METHODS FOR EXAMINATION Of FIBERS Dr. Spurgeon questioned whether there were aay other reliable techniques for the measurement of asbestos fibers other than the membrane filter method. The question was also aimed et whether the regulatory agencies were considering other analytical methods. Mr. Weaver indicated that la conversation with AIA he had recently learned.chat the Department of Labor is considering e study oa the possibilities of the gravimetric method, for sampling asbestos fibers. He indicated that the merferane filter msttfof* would be in use for some years to come and possibly up to the July 1976 date when the stlffer two fiber per cc requirement goes into effect. The Department of Labor is considering e 15 man committee to study this possibility for sampling the asbestos. The make-up of such a committee would be as follows: 4 from industry, 4 "experts," 1 from HI OSH* 1 academic, 2 from labor, 1 medical, 1 from the American Industrial Haalth Association, and 1 consumer edvocate. It is suggested that members of the* Asbestos Study Cotaictee consider whether their companies might wish to volunteer for service on such a Federal eomittee. OTHER BUSINESS Some of the Committee Members art operations oriented and others are environment oriented. It was requested that those individuals responsible for corporate decisions in the hygiene environment area be listed. That list is as follows: Charles Boreherding James Armstrong Abes Corporation - Chicago, Illinois (Corporate Industrial Hygiene) * Bendlx Corporation - Southfield, Michigan (Safety Director) Ike Weaver Raybestos-Manhattan, Inc. - Kanheim, Fa. (Director of Environmental Control) George Vllaon Firestone Tire 6 Rubber Co. - Akron, Ohio There being no further business brought before the Committee, upon motion duly mado, secondod and unanimously passed. It ves RESOLVED: To adjourn Adjouraad at 4:00 F.M. Distribution: fnifttee Members J. Creescn L. ScIfkies British Council AXA/HA E. V. Drislane Executive Director rw / L[i\\nj Contains Asbestos Fibers .....^ . Avoid Creating Dust , - Breathing Asbestos Dust may cause serious Bodily Harm -v ' ' : v.*.** ?,'$zv *... :* *..<** Vw- \ y;yr , y r K ' ' * - * * *,*.. r * . **.* ' ** .cC ' . . T '. **- .-?**'-*-'*v i !*** * -> ..* ..*** 4 *>. * v j \V*-"`"""t-T.-'.J 't**'-*^,,'* *'T* ~"w- T:'"* ;*V** . * The "Instruction Sheet** should be the same size as*the caution label, black on wh and should read as follows: *,V> *-' -- ' . '.*: * * . \V.\- a-*' ys.` IMPORTANT `*:v\ *vW~r;-" * POWER TOOLS WITHOUT DUST COLLECTORS SHOULD . . .*^V '*V,*`* "/*' *.*' NOT BE USED FOR MACHINING, CUTTING OR SANDING . THIS PRODUCT* C* V *. * " * ; ... i . IF THIS IS NOT PRACTICAL,. OPERATOR SHOULD BE PROVIDED WITH A U.S ...BUREAU OF MINES APPROVED .-^.L ;. * *; RESPIRATOR*'*.- - ' & * *A*