Document zzVexQDmzaOz0MMRM7ww8bM60

FMSI 03098 FMSI 03099 '! TELIEI'HONS 1201 I 8415-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. June 30, 1975 Representative Millicent Fenwick U. S. House of Representatives Washington, D. C. 20515 Subject: H. R. 5683 National Stockpile of Chrysotile Asbestos Dear Mrs. Fenwick: The Friction Materials Standards Institute is an association of most of the manufacturers of brake linings and clutch faeings in this country. A list of our Membership is enclosed. Chrysotile asbestos is a basic material used in the manufacture of brake linings and clutch facings. As you are aware, a major asbestos processing mill was destroyed by fire in December, and there has been a prolon~ed strike at the Canadian mines. Several of our members have had to I1mit production because of the current asbestos shortage. Our Institute supports your H. R. 5683 to release the chrysotile asbestos in the national stockpile to help this industry, and the workers there employed. When this Canadian strike is settled, market conditions should permit appropriate re-stocking of the nati~nal stockpile. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE EWD/erc E. VI. Dr i slane Executive Director -----~--- FMSI 03100 '. 1\UTOMOT!\/E SERVICE 11\!DUSTRY ASSOCIATION -------- ------~--- --~ ~------ -------~------------------ .f\Ul'. ChicJ>]o.lllino's GOG01 (312) 236-8720 1\CJ!.'<~:;cnl ;' l i vc l''lilliccnt Fenwick u.s. J)C'U"''' uf H:preE.;entat.i.ves Ha :; ll :i n ~l t o ll , D . C . 2 0 51 5 Washington Office 1725 "K" Street, N.lv. Washington, n.c.'zooo6 Hay 20, 1975 Thank you very much for your letter of Hay 5th reguest.:i.ng our 7\s:::ociaUon' s com1nents reg-arding HR 5683 on the disposal of ashe:; to~: cllrysot.i le from the national stockpile. -:-_ 'J'1w \vmld':: l>c'l 1.l:iJ' Lthnujclo~l:tlto tjve nnd , JH'i>l''l'l:::::inrJ Sllm\eOo~r;nvt ~i cceotmhpa~nnn~hdcu:;s,>otnofr~oyivic:\is.ncncn:ol:ccqp:uclnanc:tliim.ozlnln: t iinosunt,:tm;nwhocti~t h\aru0t:iotns\d, ol]toc:,.elimvee:-- Eil 1c1 ::., tr i I \ll ', nCenl,Ll~:,1 ('! , J ,.,., 1 r !: , ,: rl\1 'dir .1Ll,1d,luC1olJ'l:cuu(:f):ncim'onrtio.d~i;v;j<l1o~:Ltf~rcn:<girJIc.JpcmulcCttaro~:trLcenccmr1cisanehtlre.svn,ipvcysaeu-r!tdp[ncp;1tl1iy.isetUDop:o<i,lubs:\->a1tBnt1 od1ac:nqasucd,cicpmDfm:q;aSc\nd>;.nuOptflln.a:ric;'ccll:th":.t.;nl:.::,rm0(1ir:iss; l\~;Ti\ cnjoyf; uffil.iation with the l\utomotive Booster Clubs Jnl('Ui<lt-:i_on,tJ, imd lllili.'ntains close and constant liaison \lith the i\u u'mo Li w SL' 1vi cc Cot{ncil; Nationnl Congress of Petroleum Retai len>; Et.qiVuL'i ~p;i;ll' liiC>ll\'1' rr t E. Tool l'iILll'tci1u'u(L'rLicio~n; I nJi\s:~n;tq~i;itnuuccitiell;t~icom1na\unotuoffranCcotatuni vraecdras',i ' 1holesalcr l\ss ll.sE;ociat:i.on qivinq li.Sl]\ ociat.ion Execuand the Auto.:.' reprc!;enta- 1.iOJI il1 cVCl'/ pu:int Of the aut.OHlOt.iVC SCrViGe ff\{lr]:Ct fl:Oli\ the manU- filCllll'C'J' to tl11.' u'J t.i.It"ll:C consumer. borfc: !lo~cu,r,_l ;I!j n"1c1:ni.tt1l.1lw<l.;:~:; "i~j u::<d in the <HlLDElot.ivc~ aftcrnwd;c~t. inclus1.:~ry fot' <lnd for clutch facings. In checking with a numbe1: firms \;ho manufu.ct.urc t.hesc Droduct.s, v;e arc infor::-ned' 'lhill duc l !:l1oJ Ut<'rl' i <'I 1 J i iilliC', i~; Jlc:;. ::uJI\1' on TJ)nnlccr~;csac~aic.ntigo Li nns may be sh n fo ortage o is rce ta d kt~eon f s asl)cstos fen: immedia tcly to eveJ:cly restri their reLie ct or prove th halt i s produc l i n11 u f the~:(~ replacement: parts. JJ(, it :ll 1' ()tt1 lcill'.l l<tm undctl~:t<tJid:\Jlq pn>lJJtJt\ :in th thnt at wi t thit hin ; n u hnrbl<W X"ei.wunii \J blu ill ill pr~oh:th:ty ltOlmt oJ;' LinliuH~t FMSI 03101 .., t.11e ~Jobn:>-t'ldnv i llc Corpora t:i.on mine will be fully opeJ:a. tional nnd tltc oL!J('J' Ct~lliHlian mines which are prcf;ently on strike will be bacl;; to \vork. In other .words, if Congress docs not move to rel~eve this ~;hurl:etqc in the vcry nc0r future, tl1c dam<:HJC will be done and the huc~inC'~;:_; ncovcry of the brake linincr and clutch fu.cing mai1ufact 1JH'r:; v.' i. Jl h,1vc t:o await the resumption of imports from cc:.nada. ' In li~Jht of the information supplied by our members, we stro!).gly S11];port l!H 5683 as introduced by you to release asbestos chryso-. t:i 1 c~ from tJw na tionol stocl<:pilc nnd the supplcriwntal stocl;.pi lc . , -L<..l tick i nduc;try over t.hi~.: temporary shortage. ' ' '~ .\' ' ' ~ IU'T/ldc cc: Pc!prc~~cn L :1tive Charle~3 E. Bonnett CJllo1ui~1_.;i cn:1 1 C-Jrl, l\.1. n<'c1 Sc:r:v:ices Subcqmmi ttee on Strn tcgic Stockpiles: f ~ l~ ' ;.1 b c c : ,'To h n \J. Ncr 1 in 9 e r , ~~ r Haru1 c1 'J'. !lal fpcmny ,!'"roll\ l'ic L<:J m CJ n r-.. , ::y I .\r ' ' FMSI 03102 .fJvg~ ASBESTOS INFORMATION A..S_. .S._O,._C_IA_TI_O_N_NORTH AMEHICA rma:mm-=----.,........,......,.....,..,.._..,.._,.,...,~ 1660 L Streel. N W WJ~hngton 0 C 20036, (202) 223-4tl85 12 May 1975 Memorandum For: Subject: MEHBERS ~.... ~ Pending legislation concerning sale of chrysotile asbestos from the national st:ockpile On April 8, Representative .r.1illicent Fem7ick (R-NJ) introduced a bill (H.R. 5683) which would authorize the General Services Administration (GSA) to dispose of about 9,900 s.t. of chryso~ tile asbestos fro~ the national stockpile. This amount is in excess of the nation's current chrysotile stockpile objective of 1,100 s.t. GSA has advised that such disposal, if approved, would be by sealed bidding. The basic justification offered in support of this legislation pertains to the current unemploy:uent situation in the United States which is expected to be further aggravated by the shortage of asbestos available from Canada in I975. (News & Notes, 4/28/75) A copy of Congresswoman Fenwick's bill and pertinent excerpt from the Congressional Record for 8 April are attached. A detailed inventory oi the chrysotile asbestos in the national stockpile that would be affected by this legislation is also attached. H.R. 5683 has been referred to the Sea Pm.,er and Critical Haterial's subcommittee of the House Armed Services Co~mittee, chaired by Rep. Charles E. Bennett (D-Fla}. A date for subcor:".:nitt:ee consideration has not yet been announced. As may be noted in the appended copy of Rep. Fem.,ick' s letter of 5 May, the Association has been requested to provide general comment on the pending bill and, specifically, advise as to \vhat affect the current shortage of asbestos will have on members. Members may wish to communicate directly \vi th Congressv;oman Fenwick's office. Additionally, members may \!ish to express their interests in this matter to members of Congress representing those districts \here company plants are located for co-sponsorship of the bill, as may be desired. Related to the blll is interest in rebuilding the stockpile from the points of view of. strategic and econo~ic interests should the legislation be p~ssed. - . -- . ... ~ ~ . , ... . .. . . ~ FMSI 03103 Page -2Contac~ in Representative Fenwick's office for this matter is William Canis, 1610 Longworth House Office Building, \'lashing ton, D.C. 20515; (202)- 225-9546. Executive Director Enclosures ., .. <1: ------- .. . .. FMSI 03104 / I I I 1ilo 5 ,. . ,. .94Tn CONGRESS ~_,1 l&TSESSlO:i i~~(. So~ .. ; f : :. ': I , ;\ ~.J t ... ;. . ... .f . ,. ll~ THE IIOUSE OF REPRESENTATIVES ; .i ,;; APRIL 8, 1975 lis. FEX'\\"lCK introducetl the following b111; which was rcferreJ to the Committee on Armed. Services c- - -.....~- ~ . .... . ... .... .: ~: .. . =A BiLL ~' To nuth_orizc the disposal of nsh~stos chrysotile from the national '. _.. .; -stockpile and the supplemental stockpile. . .. ,..~.....\ 1 -~ J}e it enacted by the Senate and House of Representa- ~ ... 2 tives of the United Stales of America in Congress assembled, 3 That the Administrator of General Services is hereby 4 authorized to dispose of, by negotiation or other~vise, approxi- 5 mately nine thousand nine lumdred short tons of asbestos 6 rhrysotile now hrlJ in the national stocl~pilc established .. 7 pursuant to the Strategic and Critic::tl niaterials Stock Piling .. ~ 8 Act (50 U.S.C. 9S-9Sh) and the supplemental stoc1~pilc 9 estublishcJ pnr5uant to section 104 (b) of the .Agricnltur~1l 10 Trade Dcn~lopmrnt :mrl .As5istancc Act of 1!1:l-l {fiS St:tt. 11 I FMSI 03105 i II i. l r ..Ir . I ~ I It ~ lt !"I I ' 'I .I I 2 1 made without r~'ganl to the rcfl_nirtlllt'llt:-: of :'tTtion :1 of thl' 2 Strategic nnd Critical Jfateri;lb 8totk Piling ..\tt: Procirlcd, 3 That the time and mcthocl of di=-po:;ition shnll be fixeJ wi11 4 due r'egnnl to the protection of the L'nited Statts ngain:-:t. 5 avoidable lo~s and the protection of producers, proccs:>ors, .... ,. .6 and consmners against avo!dable dismption of their usual .7 marke.'ts'~ ' , j: . . - : I I -. ..... .. ;:- I;,.") .. :! '' .. : .:..: .. 't,: ,. :: . ; .: I ~ I' . . . .. ...:~. t.:::'~ ~ ~ )~ 4;: , ' I o :; I ""-..ll ~!I tt1!i I,I, l' '. .~r.ur.'., .......;. ..:. -1 /.:;. ~ t ~-; '; .. .... : .,. /"!;. :..:!, ..,,_,: ~~ .. : ;: ~ a : : 1 ~ .: ~ , .> :. o.;:..... .. ' ;.......,.. ' .:., ., . .. . . :..1{.-:~. ~ j -Pi~:. .. :. . I ... : ~ .r;. ..'. : . ... ...,.. :' ~: ~ r , .. .: .; :: :: -~ . ... r. . ~ .-~!. . .~ .... ~ ... . i. : . j . .... ' .. .,.,.: .. . .: ..,p'Z: ....:!: . c: -.. . ' . ..... ... : .. . .. ' I I ..I -. ' . FMSI 03106 111.A. .')~:-'.:J)-_ii : CONGR.ESS!ONAL RECOH.D -HOUSE Ap6l s, 11/; ..s.\J."""XV-JO~ IY!~as \ I 0 3 . ....:._Asc=:5r!:~__s:_~~ ~':r.c-r: r:,o;,r Tlf.; :;..\~r::o:::\L ~j :t'J.::.:::.i'lLL: The. SP.:::A;:L.<~ PIO tc:np.J~C. Ur.cicr a pre~io~:.s orc!~r or th~ Hoe~~::. the !;C!Itlc- v:o:r.~n !ror:1 New Jer;~y ( i\Irs. Fz:x\\"ICK) is reco;:ni~:tl for 5 minutes. Mrs. FE;:..~.viCK. Mr. Speakf'!", the Ln.bor Department a:u:ounced on Ap1il -1 that dwi..'1:;: 1\1arch. hnzm;:>lo:;ment in the UnHec! Stats!s increased substantial!;. \\'heren.s in JanuarJ n.r.d F'.::bruary oi thl3 year 8.2 percent of the labor force r.a.o mL'lout a Job. dt.:..:i.:::!; 1\Iarch th:l figure jtu:nped to 8.7 percent. Tn.is means that 8 mi!lio:1 A:1:~rica:-.s have no jobs. Both t.be President a~d the Co:~gress reco;r..ize the se~eri ty of L.'le economic cris!s and are searching for pro;r= v.ruch will lead to employment wJ.t.hout 5Urrin;;:- il"'.!i:ltion. Congrc"53 has passed, ' a.nd the Pres! dent h= sl:>Tied. J:md.rr'..=S: bx le:;i..:;lation to s:.i:n:ll:::.-;.e the econon!Y and the Pre,;idEn' h~ propo3ed an 13- mont!t e:"~n.sio:1 o! "..!...~em?!o::rr.er..t ben- efits !or jobless workers. I think we all agree that our goal at; this time Is to get people l::tck on the ' Job. The unemployed irom New Jersey v;ho ha\e visited my o5ce are not lookIng !on;-ard to another year or more of , unem;:>loyme:1t p~yments. 'Ihe:r wan~ ' !productive jobs. - At this time we should do all In our : power to see that these U.'lemployment lines do not lengthen. One way CoUo"ress can act t.o sa';e jobs Is t<J au;;hori~e the c!!spcsal of asbestos chrysotlle :!rom the nationa-l stockpile. Disposal oi this , osb<.'Stos would p~event the further cro- ; slon ot jobs and -.;ould be one .Federal employment program that would cost the ta.xpayers r:o~hing. Today I :un i.!ltro- . duclng disposal legislation because- of the 1 sudden short supply of :lSbestos chryso- j We in the United States. 1 The United Statc5 imports 100 percent ' o!' its asbestos chr;sotile. O\er 96 percent comes !rom Quebec, Ca!l:l.da. The major Canad.lan asbestos mir.e-which is the largest 1n the !re.e world nnd is opc!":lted by the American-ownl"d Johns-Manville Co:p.--sturered a l:l.:1d..slic!~ in J;1.!luar:; 1915. thus ef:"ectively eli:nL'1ati:-:;; t!"le m:J.- Jor U.S. source oC this ir:dustri:J.l ore. Other supplies of the asbestos ore are not presently ;:wJ.i!.lbie on the world market. In !act, :lCc::Jrdin:; to the U.S. Bure:lu of the ).tines. t.'1ere is a world- Wide shorta~e of asbestos mtni!l!:: cap::tc- lty a.nd consequ~ntl:, a ~horuge o! the ore. The effects or this s:.~dc!en intcrrup- tlon in suppi~ are ob\"ious. ~.t::~ny o! the two cozen mJ.jor primary producers of t asbeste:s pro:iucts--..-.ho mJ.nuiacture I s.u.ch articles. :l'i tcxtil~~. brake l:.n:n~s. , ( 1\re-pro~ecti\e clot!u!l~. r;>orin;::. in.:mla- tlon. and other r:rc-rcta:-d~nt bw!Jin~ materi:~ls-wall be !orcc<l to curb pro- duction and lay on: personneL Prvducllon cutb.1cks could a!I~ct many of the H:! f::cor:c! In t!t~ a. IL'St:ls products Ill du.;tr}' throu~~Hlt l!tc Uni<.:<.l S:.\tes. ln. c!:1din~ the John.;-:.t.!n\lll<! pl.1nt Ill catt<.l in my own con;n.::;~I<Jn:ll ut.tnd at l'>t:lmllle. N.J. \';hich t:nploys 2.100 pe?:lle. Oth~r St:~.tcs whlrh han~ nsbcs- tos products f1rms lncl~de: New Harr.p- shirc, 3; il.1=achwct~. 5: Cunn~cticut, :!: New York, 1:1: l':~w J,~rcPr. 15; Pe!1n- ~yl\'~n!~. 15; O!t!o. S: I!tclbn::t, 5: lilt- noLi. 11: ~.. r;.::;:,tJuri. 5: V1r:;inia. :!: :-.-. u!-~h C~.rolin:\, ~; Sout.:t C:uohna. :!; G~o~:::a, :!; Flolida, 2; Kcntuc;;:y, 2; Tennc5;ee, 1: Al::.bam:\, 3; l\.li::;sis..~ippi. :!; I..oui.;t:lr.:J., 4; Te:as. li; California, l!:l; and Ariwna. l. The additional W1er:lployme!l~ L'lat will be cre:~ted Is unnecessary for t~>o re::.so:u. First, the d~~and !or asb<::3toS chry~oWe h:J.S not declined. Ur.li!.:e in the automobile ind~try, -..-here demanJ. for new c:us has drop;:~ed sub.stan~l~ll:;, de- mand ior asbestos products has no~ sl::.ckcncd with t.'"le rece~:.On. Second-and most i:n!"lortant to us in Cor.gress-the Federal Govemmen~ maintains cb..rysoti.le a vnst stockpile or !or na.tiGn.cl de!"i!rue :lSb;;;;:os r:eeC:.S. It l Is. oi cou::-se. alto;~ether fit::.l::J.:; tl::t.t the Government mai.nt~ such a stoc:,pi.le. Yet. the present 11.000-ton. stoc!;:;l:.Ie is',_, iz.r in exces!! of o. prudent supply. The defense requb..!!'ll!!l~.i of asbe-stos cl-.r.;soti!e o.r:! quit~ lir::::.:~ed. T:e :n::t]o:- } t:'lilitarJ uses of this ki!!d. ot C!.,:;bcstos r'.re in the production of tanks =d !or hood.> oCr<!jretatinengg:liSnkeest..sTfhoet / Joh!'..;-1\fanville Corp.-the ma.icr C.e- 1 fe!~e supplier-estimates th:J.t less tha!l _ 1 percent of its tot;ll production Is rruli- tary related. The General Sen-ices Admil"'.Jstration h::..s recognized thnt our de!ense needs fa!' this n:1tural resource are more than met by the present stockpile. GSA recently completed a thorou:::h review oi our re- quireme!lts ior 3Sbestos ctu;soti.le, based on the needs of the first 3 years of a war. GSA determined tha.t 1,100 short tons of the :lSbestos would be adequ:lte :md th:J.t 9,900 short tens was in. excess of stcc::pUe needs. I thi:ck my colleagues >>ill agree that the proximity o! the CaiUd.i..a.n mines a.nd a. 1,100 ton stock.p!.le are slilli- cient !or our defense preparedness. :r.Ir. Speaker. under p::-esent Ia-:\', our stockpiling system does not provide for disposal when domest.ic indus~ries are critically in need of short-supply m:lte- rials. This is the situation in whkh we noo;~; find oursehes: a major U.S. L'1dustry !s deprived or its supplies of a r:.w m:J.te-. rial nnd consequently faces the pros;:;ect of diminished output a~d w::.employr:::ent of many of its worke:-s. In the case ot asi.lcstos chrysotile, there was no mali- clous Canadian. embar~o. The mice was closed by a Jandsli:ie. The only a1at!able source-until the mine c:tn b~ reor~ned later this yea1-is the U.S. :;ta-::~p!:e. The Oi"ll:; ~.-ay the domesti.: ast.l:ostos users cnn :;et the nsbesto.> th'!Y need is th1ou;:h a con~resslonal CTJ.nt or authority su.:h :ts the one I n.'"n intrcducin::: todny. 1\Ir. Speaker. Cun~r~s3 pas~~u simi..l:u. legislation in 19i0 which :mtilari::<!d the dl~posal o( !!.33-1 tons or a:c-besto~ .::hryso- tlle !rom the national s~vc:.;pi!e. Th~ as- bestos W"as sold orr throu-:h :~n o;Jen b::t procr~~- Thi:; <!l:ifhJ~:tl w.t; co:np!ct~-:1 in l~i-1, nnd no lurL:::r nc.'Jeslo.; c;lll i:~ !-):.! tt~\tU C\:-:::-.~".; ;'.:U!lt.lL:.:.~; l~. .u a conclulllno; noLo!', 1 woul..t llkt!' ~o point ou~ ti1nt :l-':llcoot0o5 i.:> used in til:: pro- duction oC home lnsul:lt:on. l h.\Vt!' Je>lncd vdth m:my urced tax doer d urncyt i ocnoslk:Hn m:ule:;c rwr ult1ot ; ;h:rl\o't,: hom~owner3 who lnsula~e their home~ nnd who lhcrcby :t.hl our r.acr;-j' cor.. \'~Lion c~!'ort. Unlc...,.:; our nt:.:~uf..!c.~.: h:l\"1! tl:c r:lw a''J~:;to.; t<>. -:-:or:: 't\ith. t?~ \'.'&11 b~ no ::t:.~e.~<Xi i~~.:-.l:l.:.tt}!1. !0r :,.l:!~-. can hu:-n.:.-o~-.-nc:-s to b~!y. !~rr. S;>t.::~~ker. \\'~ arc nll zeriou.~ :.b puttin.; people back,to work :J.ncl k;ep p~~;ent employe.~s on the Jc!J :J.nd -.:c !:; h::~c an O;l;JOrtun!ty to :t :::..,::-!:1 t!1: 5 c mitment \Yith p:-ompt and pas1Un! ~.c~i I ask t.he support ::.n::l. cocp~mt:on of my collca!nWS in seein~ th:lt this l~g1s Uo:-t !s sp~edily enact~d into Jaw, The text 9! my biU follows: ,. H.P... 558J A bUt to t\Utllorlze the dlsposnl of nsbe: chrysotue from the natlor:nl 5:oc:O:pile ' the supplemeo.tnl stockpU~ Bt: it ==ted by the Ser.a!o anf. Hnuco .P.epresen!'c!it:e.t of the Unit~= St.:::e! of A.:':-: ica. in Conrr.-e.ts C3Setr.biec!. T.b.:1! the Acl.--:-: lstr:1tor or Geaernl Services Is here07 : t!:J.O:-!.zed to dispose or. by x:e;ntta~1;:s Ot' 0 erwlse. apt>rO!:.i.::l::a.tely nl.!:.e t~oL::~~:ld. n o:hu~1..-ed sb.ort tor..s :t:;best~.s c~::-:~o:.ol.:! :- t:.etd ln. :0!'\e r.~t!0~:1t !:.~;:oc~:;l::e ~s~.:.=~t::;: P'..t:Sl..:.ant to th., St:-~~~3h: ;-.::d C:-!ti.:."!.t ; ter!a\s S;oc!t Plll::>g Act (;;.) 1J.S.C. ~J-g' and the suppleme:ta.l stoc;::~~e esta.b:Ls~ punu:u1t to seetton 10-l(b) o: th~ A:;-:-:: tur:1L Trac!e DeveLopceat :l."-d .".so!st:u1ce . or 1954, sa Stat. 456, as amen~d b;- 73 s 607. Such c!!S?O.sitto:l m~j t.e m~Ge .... ~,~~ re~a.r.:t to the requlrer:lect.-3 c:' s~c:!:Jn 'J th., Strntegte sed Cr~~~=~l :.:::.~c~!:l!s s:.. PHln~ Act: Prr:rcitied. Th~t- ~!'".e t!~a :: method or c:Hs::osltto:J. s!la.!..l be ~;t:ed t"~t~h c regard to the protection oC tt.e "lJ~l tea StJ agai.ns~ avoidable loss and the pro:ectlon producers, processors. and cor:.su.:::.~rs a.;:~.t aotd::~.ble dlsrupt!on or thel:' usunl ma:k FMS\ 03107 .. CHRYSOTILE ASBESTOS IN THE NATIONAL STOCKPILE AFFECTED BY H.R. 5683 GRADE c & G-1 C & G-1 MIR TYPE 4 C & G-2 C & G-2 lv!IR TYPE 4 3K CRUDE 1 CRUDE 1 MIR TYPE 2 CRUDE 2 CRUDE 2 MIR TYPE 2 CRUDE 3 ASBESTOS LAP 1500 GRAIN ASBESTOS ROVING 7 CUT ASBESTOS ROVING 10 CUT ..., 3K MIR TYPE 2 ..., 3K MIR TYPE 4 GRADE 2 MIR TYPE 2 GRADE 3 tUR TYPE 2 3T HIR TYPE 2 QUANTITY (SHORT TONS) 16.28 761 1258.. 170 1200 898 71 154.4 550 2 .3 .2 .3 .185 .1545 429 513 TOTAL 501. 9866.2 FMS\ 03108 "MILLIC!cN'I !'lnWIC..:k . .nc Dl,l'lliiiGT, Nt.:W .h:n'"-~Y IIANW,ING. CU<lRENCY AND HOu'srNG GMALL EIUSINESS Qlougrcss of fl~c ~lnitc~ ~tatcs ~1ou!;c of ~{~prcsctd~tiucs Pfnslriugton, p.QL 20515 May 5, 1975 ,.,fWA.,Ikr. ro .... or. r t6to I..DNr;wmru ''"''"''" o,.,. ..... ~ OtJILnti"Cl uWA".oHINC fUN, <;, 2\J$ I , Tl.L[Nfi'JN'" (.l02:) 223-7)00 DISTRICT 0"P1CII:a 1 No"TH Olltl~ Sr,...-rr SoMlftVILLC, Ntw Jr... ll:'t 0'1076 TI"UP'HON. (201) 7~Z-82'JO Pon o.-....::E UutLOING 1 Mo""'' SrNHT MOJtAISTowH. New JEAsr;:v 07?60 TD..I:PHQNE, (201) 5J8-7267 Asbestos Information Association of North America 1660 L Street, N.W. Washington, D. C. Gentlemen: On April 8, I introduced a bill to allm-1 for the release of asbestos chrysotile from the national stockpile. A Canadian landslide has wiped out most of our supply of asbestos and the damage cannot be repaired for many months. The unemployment that could result warrants action by Congress as soon as possible. I thought that your association might be interested in this legislation and I would like to know your thoughts on the problem--as described in my attached statement--and in the proposed bill. Will a shortage of asbestos affect the firms you represent? I would appreciate any help you can give me on this subject. With all good wishes, Sincerely yours, 17 >1- J {.~ I I, -~rI) It{\,' I t t-;Y.;,;1 MilLICENT FENWICK Member of Congress " MF:ck . .. THI.IITA"fiONOIY PIIINT0 ON PAPR MAOI: Wlni RE:CVCU:O FIBERS FMSl 03109 JI.Ule 10, 1975 I. H. WEAVER. NCORPORATE DIRECTOR EHVIAON1o4ENTAL CONTROL w !'1 Ul -I 1'1 G) .1'-1 :Mr. E. W. Drislane Friction Materials Standards Institute, Inc. E. 210 Route #4 Paramus, New Jersey 07652 Dear Ed: Recently I observed a showing of the British Granada TV series film entitled "Asbestos-- Killer Dust. 11 It is well worth showing to any group that has an interest in asbestos or asbestos-related products. It provides good insight regarding the nature and extent of the health controversies that are currently raging in regard to occupational and community exposure to air and water borne asbestos fibers. I recommend you make arrangements to show this film at the next FMSI Board Meeting and to the entire membership at the next convenient opportunity. I regret that we have not shown it before the Asbestos Study Committee and think we should plan to do this at our next meeting. I believe Ron Moalli now has R/M1 s copy of this film and am sure he will be glad to make it available for your use whenever you wish. Best regards, grb cc: Mr. R. R. Moalli -- Trumbull FMSI 03110 June 1975 ASBESTOS STUDY CO~~TTEE REPORT Most industrial managers are well aware of the increasing amount of time they must devote to problems relating to occupational and environmental hazards. In recent years new government agencies have been created which have broad powers to investigate, regulate and control industrial operations. During the same period the mandates of traditional agencies also have been broadened in respect to environmental concerns, and frequently there are duplicate and sometimes conflicting functions. Coincidentally, the scientific community has been producing an increasing volume of evidence regarding hitherto unsuspected health hazards associated with various raw materials, chemicals and manufacturing methods. Adding further to the burdens these developments place on industrial managers is a far more militant union attitude on occupational health matters. Union spokesmen, such as I. W. Abel, Tony Mazzochi and Sheldon Samuels, freely admit they have been negligent in facing these issues in the past. However, recently a new attituqe has been in evidence and it is exemplified by Mazzochi's statement that, "We live in a nation of corporate law breakers." Samuels has not been as charitable; he prefers to use the term "Corporate Murderers." The present union objective, as stated by Mazzochi, is to "use professionals to educate laborers to understand health hazards" and to "use collective bargaining to get legislation necessary to obtain good occupational health care." The AFLCIO has an active campaign to use the news media to get the message across to the general public as well as to their members. The friction materials industry position with respect to the asbestos health issue is almost unique. Few other industries are as heavily dependent upon asbestos for the successful performance of their products, and proper handling of occupational and environmental problems associated with the use of asbestos is essential to the survival of manufacturers of asbestos-based friction materials. During the past year your Asbestos Study Committee has worked closely with OSHA, EPA, NIOSH and their subcontractors as well as with AIA/NA regarding new standards and regarding changes to existing standards and guidelines for regulation of asbestos as well as other materials. We have sought to keep abreast of new information regarding asbestos health effects, control methods and regulations emanating from the medical/scientific communities, various government offices and other sources. The following highlights should be of interest. OSHA Proposed new standards for arsenic and for ketones present new formats with emphasis on the action level concept, on work practices and on improved medical surveillance. Expected revisions to the asbestos standard probably will follow one of these formats. Little or no change is expected in permissible airborne concentrations or in monitoring methods. The erroneous assumption by OSHA that the friction materials industry could immediately comply with the 2 fpcc standard hopefully has been corrected. FMSI 03111 - 2- Hazardous material labeling is under study by an OSHA advisory committee, and labor members have called for changes in asbestos product labeling. NIOSH A new electron microscope laboratory has been provided at Cincinnati and is being used to investigate the quantity and size distributi'on of asbestos fibers and other aerosols in occupational environments. Emphasis is on submicron particles and fibers less than 5 microns long. EPA EPA is undertaking a thorough investigation of the presence of asbestos in all areas of the environment. The work involves contract studies, in-house research and joint activities with other government agencies. There is considerable concern regarding the effectiveness of the "no visible emissions" standard in protecting the public from airborne asbestos. Pressure is on EPA from labor representatives and medical and environmental groups for a "no detectable level" regulation. EPA proposed waste disposal restrictions would create problems for some friction materials manufacturers. FDA A delay has been imposed on FDA's proposal to ban use of asbestos in filters for beverages and food products until they can conduct experiments to determine if long term exposure to ingested asbestos fibers represent a definitive hazard to human health. A four million dollar animal feeding study has been approved for determination of health effects from ingesting various doses of various kinds of asbestos. FTC Study is in progress in response to a petition from CSPI (Nader group) in regard to labeling of asbestos-containing products. CPSC There is no known action by this agency in regard to asbestos at this time. FMSI 03112 - 3- CDC This agency of HEW has issued a report indicating adverse effects on pulmonary function due to exposure to asbestos at two locations one of which was a textile based friction material plant in New England. MEDICAL Selikoff continues predictions of epidemic of asbestos related death and disease in years to come. He emphasizes the mesothelioma hazard and the fact no known dose level is "safe" and is pointing to the possible health significance of shorter, smaller fibers or particles not now covered by standards. Selikoff people have been actively promoting hazards associated with asbestos emissions from brake lining wear and from brake service operations. Acknowledgment of association between asbestos exposure and increased GI cancer has become accepted practice during the past year. The above and other activities and publicity during recent months offers ample evidence that controversy and concern over asbestos has in no way slackened. Many seem to think the fact that OSHA, EPA, NIOSH and others recently have been devoting considerable attention to other toxic materials has taken some of the heat off asbestos. While this may be true as far as the over-all environmental and occupational health picture is concerned, I see no significant change in the attitude of regulatory agencies, medical researchers, labor, or environmental groups in regard to the hazards of asbestos, Nor do I see any justification for such change. The friction materials industry should pursue all available means for achieving compliance with the 2 fiber per cubic millileter standard and all other requirements of the OSHA asbestos regulations as promptly as possible. It should be kept in mind the promulgated regulations are a "minimum standard." Wherever possible more protection than that afforded by the standard should be provided for friction materials workers exposed to asbestos dust. Emphasis should be given to worker instruction and training in methods for reducing airborne dust generation and for minimizing exposure to dust that is generated, Product labeling and other means should be employed to thoroughly inform:. ~ customers and the public of the dangers associated with improper use, fabriction, handling or disposal of asbestos-containing friction materials. In-plant antismoking campaigns would be laudable. Your committee solicits comments and questions concerning its past and future activities, and will endeavor to follow events in the above menti0ned areas and all other astects of the asbestos/health controversy during the following year. Respectfully submitted, ;~r.~. ~ I. H.~~ L_ Committee Chairman FMSI 03113 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N. J. 07652 Me;' 29, 1975 To: Asbestos Study Committee Subject: Changes to Minutes of April 28, 1975 Meeting Mr. Weaver, Chairman of the Committee, called relative to corrections to the "Unconfirmed Minutes" of subject meeting. Paee 3. Paraeraoh 2, Line 5 Eliminate 11 has a plastic bag 1 iner 11 Paee 3. Paraeraph 2. Line 15 Should say: 11 (3) The Nilfisk or other hiPh quality vacuum cleaner 11 Paee 3. Paraeragh 3. Lines 5,6 Change sentence to read: 11 ln some cases these could be counted by inexperienced operators as asbestos fibers." A new copy of Page 3 is enclosed. Please destroy old page 3 and replace with this corrected page 3. 1-.~:,;D/ ere Enclosure: s E. W. Drislane Executive Director FMSI 03114 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N. J. q?652 ~Aay 22, 1975 To: Asbestos Study Committee Subject: Recent Di etr i but ions-Relative to OSHA Asbestos Standard At the April 28, 1975 meeting, your Chairman, Mr. Weaver volunteered to send in data on the Nilfisk Industrial Vacuum Cleaner and the recent AIHA- ACGJH paper on the membrane filter method. This paper included two pages on a guard or shroud attached to the filter holder to protect the filter from picking up fibers from the wearer's clothing or from a falling fiber that would ordinarily not be breathed into the respiratory tract. These two items are important for (1) cleaning up the workplace to reduce airborne fiber concentrations and (2) to more accurately pick up fibers for purp~ses of counting. Copies of the literature forwarded by Mr. Weaver are included with this memo. In addition, I prepared a BULLETIN NO. 533 to the Membership and there will be some enclosures with that bulletin. I will try not to duplicate the enclosures. In addition, I am forwarding two articles which may be of interest to the Committee. These also were sent in by Mr. Weaver: "Insulation Hygiene Progress Reports", a publication from Mt. Sinai (1. J. Selikoff, M. D.) The main article is "Asbestos Disease can Spread to Workers' Families". "The Regulated and the Regulator11 by Leo Teplow of Organization Resources Counselors, Inc. In particular, please note his section entitled "What the Manager Can Do in Industrial Safety and Health Before the Doctor Comes". The foregoing is for your information. EWD/erc Enclosure: E. W. Drislane Executive Director FMSI 03115 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N. J. 07652 June 4, 1975 To: Asbestos Study Committee Subject: Assorted articles, reports on asbestos Your Chairman, Mr. Weaver, has sent along several items concerning asbestos which he felt would be of interest to members of the Committee. (1) Textjle World News, May 1975 Article entitled: "Will OSHA Feasibility Kayo Marginal Plants?" Article headed: "OSHA Using Personal Dust Samplings." (2) American Industrial Hygiene Association Journal, May 1975: "Counting Asbestos Fibers by the Probable Number Method, 11 by P. C. Reist. (3) Letters J. H. Marsh, Raybestos-Manhattan, Inc., re Dr. Selikoff meeting with Chief Industrial Hygienists of Ford, Chrysler, GM. Includes report by Dr. Nicholson of Mount Sinai from data given by Dr. Selikoff: 11 Asbestos Exposure During Brake Lining Maintenance and Repair." (4) Letter J. H. Marsh, Raybestos-Manhattan, Inc., relative to WCVB-TV of Boston Television "Awards Special" titled "Asbestos Related Deaths at Two Massachusetts Factories. 11 Copi"e' s of these articles are enclosed for your information. EWD/erc Enclosure: E. li'. Drislane Executive Director FMSI 03116 FR .I CT ION MATERIALS STANDARDS INSTITUTE, INC. , E-210 ROUTE 4, PARAMUS, N. J. 07652 BULLETIN N 0. 5 3 3 May 21, 1975 REPORT ON ASBESTOS STUDY COMMITTEE MEETING In late April, the Asbestos Study Committee met and discussed several subjects -- with emphasis on asbestos in the work place. One of the agenda items was entitled: 11 The OSHA Regulations and the Membrane Fi Iter Method for Measurement. 11 Excerpts of the minutes of this meeting on the above agenda item are enclosed. These excerpts indicate our industry's problems with the reliability of the membrane filter method for measuring airborne asbestos concentrations, and they emphasize the Members' concern where this procedure will be used for enforcement. We are making additional enclosures with the copies being sent to the individual listed below: These additional enclosures include: 1. Price Sheet on Nilfisk Industrial Vacuum Cleaner Models GA-71, GA-72, GA-73. Nilfisk of America, Inc. 706-8 Buncombe Street P. 0. Box 143 Greenville, S. C. 29602 2. Report of Joint AIHA-ACGIH Aerosol Hazards Evaluation Committee: "Recommended Procedures for Sampling and Counting Asbestos Fibers." This article is copyrighted and reprints are available as indicated on the first page (Page 83) Note: In the first two pages, a guard or shroud is attached to the filter holder. This may help in eliminating sporadic high counts. FMSI 03117 2 - , ... Reasons for two enclosures are given in the excerpts from the Asbestos Study Committee meeting: (1) The Nilfisk Cleaner has helped in cleaning up the workplace, when used in addition to a good central collecting system; (2) Use of the shroud may be of help in reducing the sporadic high counts from asbestos that ordinarily would not be taken into the respiratory tract. The foregoing information is sent for use by those responsible for compliance with the OSHA Regulations. EV!D/erc Enclosures: cc- Active Members Regional Members (U.S.Copyright) Asoestos Study Committee E. W. Drislane Executive Director FMSt 03118 EXCERPTS FROM APRIL 28, 1975 MEETING OF f1SBESTOS ST\-)DV COMMITTEE The OSHA Reeulations and the Membrane Filter Method for Measurement Originally this subject was to be two items on this agenda: (1) The Membrane Filter Method for measuring airborne asbestos concentrations, (2) The OSHA standards with emphasis c;m .the July 1, 1976 two fibers/co limit. In discussing these subjects it was''found difficult to separtae the membrane filter technique from the OSHA standards~ They are being combined for purposes of these minutes, It was suggested that with the current economic climate that perhaps there might be some de-emphasis in OSHA regulations. There has been de-emphasis on seat belts, and bumpers, emissions control and it was suggested that perhaps OSHA might ease off on their regulations. One Committee member said that it was most un-likely that there would be backtracking on the OSHA regulations. If anything they might be stiffened. One member stated that there were five different types of asbestos and that some were more harmful than others. It was suggested that while this might be so, all asbestos is apparently linked with lung cancer and asbestosis. It would be difficult to win an argument that there are some types of asbestos that are not harmful to the respiratory tract. At this point the method for counting fibers was discussed. It was stated by one member that originally a fiber would/B~tcoonted if it was not totally within the field. This was from Johns-Manville course on the use of the membrane filter technique. It was stated now that anything that is in the top or the left hand borders of the sample, even if only partly in the field, are to be counted. Another member indicated that when he took the NIOSH course at Cincinnati that this was the way that he was told to count: any fiber on the left hand or top border, even if not fully within the field being counted, would be counted in that field. It was stated that the crystallization of the solvent used on the slide could sometimes make it appear to be an asbestos fiber. There is a method of preparing the slides so that the formation of crystals will not appear similar to asbestos fibers for counting purposes. This method is apparently used by most companies doing their' own counting of the fibers. It was pointed out also that slides should not be reused. Re-used slides may accelerate crystallization of the solvent. It was stated there is as much variation in readings of fiber count as there are people making readings. One member suggested that he used the NIOSH manual as a Bible. It was stated that this manual was subject to wide interpretation. A member indicated that he exchanged samples with NIOSH in Cincinnati and has had decent correlation with their counts. It was stated that on the lower counts that three different readings would come out plus or minus 10% on the count. However, when higher counts were read, the three different readings would come out with plus or minus 50% in the count. Over how long a period were these samples collected? One member stated that OSHA takes 8-hour samples. Another states that they took samples for a minimum 3-hour period with a 30-minute cycling. Another had three one-hour periods for collecting samples using one filter. As regards differences, it was stated by two members that the OSHA inspectors have actually picked up lower counts than some of the members. It was stated that there were differences in results depending upon whether the counts were done in house, by outside organizations or by government people. With these differences in fiber count, a question was raised 1- FMSI 03119 a's to how can one solve a problem when they don't know how severe the problem is. In response to a question as to what this Committee could recommend it was suggested that members should at least test each operation every six months. In aHemptinr to get counts down to the 5 fiber limit &nd eventually down to two fibers a member stated that good housekeeping is required. Several members mentioned the Nilfisk vacuum cleaner This particular vacuum cleaner can be used for getting into places that a central unit cannot reach. It has a plastic bag liner and runs on a 15 a~ circuit. Of the movable type vacuum cleaner the members seem to prefer this Nilfisk. This is a Swedish make vacuum cleaner. More information will be gathered on this vacuum cleaner for distribution to the members. In addition it was suggested that one must have a good central collection system. One that was mentioned was the JM modified central vacuum system, which utilizes the main duct system as a central vacuum system. Several memebrs stated that good0ousekeeping was one of the main things that must be taken care of in order to bring the fiber count down. It was suggested that there are three points for good housekeeping: (1) Good shrouding and good dust collection; (2) There should be a central cleaning system for the work area; (3) The Nilfisk vacuum cleaner should be used for general housekeeping in the work area. In addition it was stated that there should be no dry sweeping in the work area. It was suggested that the friction materials business is different from regular asbestos manufacturing. In addition to asbestos, we have other materials in the product such as resins, carbon blacks, friction dust and various minerals. It is possible that some of these may be picked up during the sample gathering before the count. In some cases these will be counted by operators as being asbestos fibers. In essence it is more difficult to count asbestos in a friction material environment than it is in a textile environment. It is felt that there may be greater difficulty in getting consistent readings on fiber counts in the friction materials business. For that reason friction material manufacturers would prefer a work practices oriented standard. - It was stated that the membrane filter method should not be abandoned as it is the only tool for measurement. However, reliance on this tool for enforcement may be almost unbearable in friction materials factories. It was suggested that OSHA be advised of our industry's concern with the wide variation in fiber counts. Based on the fact that materials other than asbestos might be involved, it is necessary that the counts be interpreted realistically. In other words, while the membrane filter method may be the only method that is available currently for measureng airborne asbestos, and it is not felt that there is another method that can take its place, it is a tool that should be used by manufacturers only in trying to clean up their areas. It is not felt that this tool is accurate enough to be used for enforcement purposes. It is suggested that OSHA inspectors must realizethisbefore factories are closed down and fines are levied when there is doubt as to how accurate the measurement is. Because of the wide variation in results there is concern among members as to the millions of dollars now being put into control methods. Even 1.11ith these expenditures, there is no way of knowing positively whether industries are getting their counts down to required levels. Various words were used to . describe the reliability of the membrane filter method for enforcement: One indicated that it was "unreliable," and another indicated that it was "inadequate". The emphasis was that it is the only tool now available but it is not the proper tool for enforcement. Ironically, it had been suggested by some government people in the past that the friction material industry would be the first to comply with the OSHA standards. NIOSH felt that the friction materials business could most readily meet these standards. At this meeting, industry members are indicating that it may be more difficult for the friction materials business to meet the levels because of the difficulty in counting fiber samples. It was suggested that if we're having difficulty - 2- FMSI 03120 ~eeting the 5 fibers/cc limit currently, it would be near impossible to meet the 2 fibers/cc 1imit due July 1, 197(,, It was suggested -that the Industry should oppose -this change. It was stated that realistically it is unlikely that OSHA will not go to the 2 fiber/cc limit on July 1, 1976. The only question is will they go lower than the 2 fiber limit? Dr. Selikoff has spoken of a 1 fiber/cc limit a,nd has even said no fibers. It was stated that the /~sbestos Information Association had circulated information concerning the NIOSH suggestion that the friction materials business would come under the standard now. Such literature was never received by the Institute. Most members on the Committee were unfamilar with this NIOSH suggestion. As had been suggested earlier, it is necessary to make the counts as accurate as possible. For this reason suggestions on counting procedures, possible crystallization of solvents, and a prohibition on the re-use of slides are important. Mr. Vleaver pointed out that in a recent publication he noted that a plastic shroud is placed about the entrance to the pump being worn at the work place, in order to keep large particles of asbestos from getting pulled in to the filter. This shroud would prevent material from being taken from a worker's clothes as well as from some large pieces that would ordinarily fall to the floor without being inhaled. He stated that Turner Brothers has been using such a shroud. The unit is completely open on the front and it is felt that this technique gets rid of some sporadic high counts. Mr. Weaver will get a copy of this and distribute it to the members. This could be another possible improvement in the sampling technique which might make the membrane filter method more palatable. It was suggested hat this be considered and perhaps a proposal be made to OSHA for its use. The problem is twofold: (1) Improving the reliability of the membrane filter technique, and (2) The use of the membrane filter as a tool for enforcement with its lack of reliability. This subject has been fairly well covered. There was some agreement about the problems in using this technique as a tool for enforcement of the OSHf-\ regulations. The question was what should be done about it? One member stated that the Committee would be remiss if it did not advise the members of these difficulties. It was suggested that the Board of Directors be advised that there is a problem and that there is going to be more of a problem when the 2 fiber limit is put into effect. To repeat the problem: while we need the membrane filter method as a tool for measurement, this tool is not suitable for enforcement purposes. It is suggested that when the 2 fibers/cc limit takes effect that this will become a most serious problem. Recommendations should be put into effect on instructions to employees, the use of vacuum cleaners, the use of dust collecting systems, disposal, etc. 1;:/hen these work practices are put into effect the area will be cleaner. It was suggested that the Institute contact the Asbestos Information Association concerning the use of the membrane filter technique for enforcement. (See later section of these minutes cancer ni ng Asbestos Information r.sso i cation). The Im:lustry must concentrate on collecting, cleaning and housekeeping, using the membrane filter as a tool to see how the levels are being reduced. One member brought along a work sheet with target dates for completion of various items that will help in meeting the OSHA standards. This is essentially a schedule with dates projected for each step which will move their factory nearer to compliance. The aim is to have the factory at the 2 fiber limit by July 1, 1976. Various critical areas are covered with detailed steps projected to clean up each area. It was suggested that this was almost necessary for control and would cert ainly help in proving intent to comply with the regulations. - 3- FMSI 03121 -May 5, 1975 Mr. E. W. Drislane Friction Materials Standards Institute, Inc. E. 210 Route #4 Paramus, New Jersey 07652 I Co~P~~~o~~fi~ i\jENVIRONMENTAL CONTROL w !'1 Ul -1 1'1 G'l 1'1 r Ul ;-u1 1'1 1'1 :-1 3: ~ J: l'l 3: "1l zzl'l Dear Ed: The enclosed abridgement of a lecture given by Leo Teplow at the Industrial Health Foundation is well worth reading. This clearly defines the struggle between NIOSH and OSHA over the zero TLV approach by NIOSH (particularly Joe Wagonner) and the need for OSHA to consider "feasibility" in developing standards. Also please note particularly the column headed "What the Manager Can Do in Industrial Safety and Health ... Before the Doctor Comes." This may be worth circulating to Asbestos Study Committee members. Yours very truly, grb enc. FMS\ 03122 Rccomincndcd Procedures for Sampling and Counting Asbestos Fibers Procedures for the Evaluation of Occupational Exposures to Airborne Asbestos Joint AIHA-ACG/H Aerosol Hazard~ Evaluation Committee F IBROUS ASBESTOS HAS BEEN IDENTIFIED as the causative agent of asbestosis and has been associated with an increased cancer incidence. The American Conference of Governmental Industrial Hygienists (ACGIH) has established (1974) a Threshold Limit Value (TLV) for asbestos of 5 fibers greater than 5 micrometers in length per milliliter of air. A TLV footnote specifics the determination shall be made by the membrane filter method at 400 X to 450 X magnification and with phase contrast illumination. These procedures define a standard of sampling and of processing the collected samples in order to evaluate occupational exposure to asbestos fibers. Sampling Airborne samples of asbestos must be collected on membrane filters which retain at the surface essentially all of the particles in excess of 0.5 JLm in diameter. The filter must be rendered transparent by the mounting medium. The filter should be packed in a sealed holder which is capable of being readily opened for sampling purposes and of being resealed after the sample has been collected. The filter must be fully exposed during sampling. (Recommended filters and filter holders are listed under Supplies). The filter must be practically dust-free with an average background count of less than 25 Reprints of this article are available for purchase from either the American Industrial Hygiene Associalion. 66 South \\Iiller Road, Akron, Ohio 44313 or the American Conference of Governmental Industrial Hn1ienists, P.0. Box 1937, Cincinnati, Ohio 45201. The cot is $1.00 per copy. fibers per square centimeter. At least 2% to 4% of the filters intended for collecting samples should be set aside to determine the background count. (See Counting and Cal culations sections). In addition. the filter resistance should not exceed 3 mm of mercury when filtering air at the rate of 0.3 liters per minute (lpm) per square centimeter of filter. When collecting the sample, care must be taken to prevent dust from falling or from being projected onto the open filter. This may be accomplished by pointing the filter head downward. A guard or shroud should be attached to the filter holder to further protect the open filter from contamination as well as optimize uniform deposition on the filter. Its diameter should be about the same as the holder so that it can be attached tightly to it and it should project at least llh times the filter diameter in front of it. A protective device is particularly important if the filter head is to rest on contaminated clothing. (See Figure 1.) The filter holder may be stored for a limit of six months once it is resealed. The sample should not be too dense, since samples in which particles overlap must be rejected as uncountable. Similarly, a large enough volume of air should be sampled so that there are sufficient numbers of fibers in each field. Experience indicates that more than 150 particles per field, including nonfibrous background, may interfere with counting the sample. It is desirable that there be no more than 10 fibers per field. Two or three samples should be collected at each sampling location. The results should 83 FMSI 03123 84 Fcbmary, 1975 ___rl::::::::~;: tl__-_J_D_____. tFFIILLTTEERR APANDD liters. If a filter other than 37-mm is used, the volume of air sampled should be altered in direct proportion to the open filter area. Samples collected during short periods of exposure should be collected at a high flow l rn:t; rate and if necessary. for the entire exposure period. In all cases the count should be ~ adjusted with regard to time, so that the c . lll CAP exposure is expressed as an 8-hour time- weighted average exposure. For compliance .~-CL-1-P~------------- evaluations with short term exposures, 37- TAPED IN PLACE Figure 1. Diagram of shroud for membrane fil- mm filters samples should be collected for 15 minutes at a minimum of 2 lpm. ter holder. The shroud may be constructed from a plastic bQtt!e by cutting off the neck and drilling Sample Preparation a hole in the botlom. To use, push the filter holder through the hole and reach in through the top to remove the holder cap. To remove the holder, replace the cap and push the filter holder forward through the hole. A solution one-to-one by volume of dimethyl phthalate and diethyl oxylate in which has been dissolved 50 milligrams of membrane filter material per milliliter of solution is the preferred counting medium. be averaged to obtain the fiber concentra- The chemicals used to prepare the medium tion. should be examined microscopically to be Breathing zone samples should reflect the certain that they are dust free. The fiber worker's entire normal work day. They material to be dissolved should not be must be collected as close to the worker's marked and should have a maximum back- nose and over as long a time period as ground count of 25 fibers per square centi- possible. Calibrated battery powered per- meter of filter. The counting medium may sonal pumps (sec Appendix III, Pump Cali- be stored in a wide-mouthed Wheaton Bal- bration) are satisfactory air movers. They sam bottle and should be applied with a can be worn by the worker and supported glass rod. The counting medium has a re- at the belt by means of a clip. The sam- fractive index of 1.461 at 25C. The me- pling head, which can be pinned to the col- dium should be made in small quantities lar, is connected to the pump by flexible since it has a 6 month shelf life. tubing. Such pumps can be operated continu- Asbestos fibers are counted on wedge ously for about eight hours and recharged shaped sections cut from the filter. The overnight. wedge should be reasonably sized so that If a 37-mm filter is used to collect the it can be mounted on a 25 x 75 mm (l x 3 sample, the pump should be adjusted to sam- inch) glass microscope slide. The slide ple between 1 and 2 liters per minute. The should be cleaned of dust before it is used. volume of air sampled should be adjusted A drop or two of counting medium is placed so that an optimum density of dust is col- on the slide and the filter wedge is placed lected on the filter. Since the dust concentra- dust side up on top of the medium. The tion is not known before sampling, the op- wedge is covered by a No. 11;2 coverslip. timal sampling period must be determined by Care must be taken while lowering the cover- trial and error. It is suggested that, uniess slip to avoid trapping air under it. Air bub- experience indicates otherwise, the first sam- bles may be forced out by exerting slight ple should be collected from 20 liters of air, pressure on the cover slip with a pencil the second from 40 and the third from 80 eraser. Extreme care must be taken to avoid FMSI 03124 - - ----------------~----------~-~---------> American lmfu.ltrial 1/y~:it'll<' Association lou mal too much pressure, since this causes distortion and stretching in the filter. The wedge is usually cleared within 15 minutes; however, a residual background granularity may be noted. This will disappear within a day. Counts must be completed within two days since there is a tendency for fiber migration and crystal growth. Tbe prepared medium should be checked periodically for a background count. (See Counting and Calculations sections.) An alternate medium may be used when the samples must be counted immediately. It is prepared in the same manner as the preferred viscous medium, except that the added membrane filter is omitted. Since this medium is much less viscous it should be stored in narrow-mouthed bottles. This medium is applied with a glass dropper -after the filter wedge has been placed dust side up on the slide. However, a drop should be placed on the slide adjacent to but not on top of each corner of the wedge. This medium acts very rapidly and the No. 1112 coverglass should be lowered within a minute. Slides made up with this "alternate medium" are ready for counting within five minutes and the count must be completed within two hours after preparation. Filters which have been used to collect samples and which have been resealed in a holder should be removed only in a clean environment. They should not be held with the fingers. They may be held with tweezers and cut with either a scalpel -or scissors. Bottles containing media must be tightly closed except during use. All bottles, tools used for handling and cutting filters, and containers used for storing tools must be thoroughly cleaned and dried. Tweezers, scissors, scalpels, etc. should be set aside for this purpose exchisivcly. Although slides and coverslips are purchased pre-cleaned, they should be wiped lightly with clean lens tisuc to remove traces of dust. Do not attempt to reuse slides or covcrslips. Microscope A microscope equipped with a phase con- 85 trast substage condenser, a 4 mm "high dry" phase-contrast objective (40 X to 45 X) and a I0 X eyepiece is used to count the sample. It should have either a pre-focused built-in illuminator supplied with an iris diaphragm or be lighll:d by a separate bright illuminatorflat mirror combination. If a 5eparate illuminator is used it should be equipped with a condensing lens, iris diaphragm, and means for adjusting both the illuminator level and the distance between the condensing lens and the bulb. Zoom microscopes may be used for counting asbestos fibers, provided that the total magnification is within the 400-450 X range. The illuminator should be equipped with an adjustable constant voltage transformer. Both the microscope condenser and stage require close adjustment and both should be rack and pinion mounted. The stage must move along two perpendicular axes in a horizontal plane, while the condenser must move up and down in a vertical plane. Lighting must be adjusted for optimum balance. The Kohler method of illumination is recommended. (See Appendix I for procedures required to establish Kohler illuminator.) The counting field is defined by a reticle mounted at the level of the field-limiting diaphragm in the 10 X eyepiece. The Parton reticle (Figure 2) is recommended. However, any reticle which contains markings which, in addition to .outlining an area of about 0.005 square millimeters, as determined by 1 2 ) .. 'S ' ., ' oooOQQ e eo so 11 12 tJ Figure 2. Porion reticle. FMSI 03125 86 the combination of eyepiece and objective, and which defines linear distances that may serve as measuring aids, is satisfactory. The _-.: ;reti~le. must be' calibrated prior to usc and . .-: r~d'~i:flbr~ied- each- time it is removed from the miCroscope eyepiece. or when the microscope tube length or interpupillary distance is changed. Zoom microscopes must be recalibratcd each time the zoom position is changed. (See Appendix II for recommended calibration procedures.) Counting A fiber is defined as a particle whose length is at least three times greater than its diameter. All fibers longer than 5 pm within the area delineated by the reticle, or which enter it from either of two adjacent sides, arc counted. Fibers entering the area from either of the other two sides, i.e., those not arbitrarily chosen as "counting" sides are not counted, nor fibers in excess of 5 p.m in diameter. Touching fibers, i.e., one of whose ends touch another fiber regardless of the resulting <mglc, arc considered as one. Fibers that cross each other arc counted individually. Fibers that pass through the delineated area arc counted provided that they cross at least one of the arbitrarily chosen "counting" sides. (Sec Figure 3.) Fiber length should be determined by measuring against standards such as a circle or a space defined by markings on the calibrated reticle. If the fiber is curved or wavy the total length should be estimated by measuring along the curve. Once sufficient experience has been gained in judging length, only fibers whose length or diameter arc in question need be measured. A routine for choosing counting fields must be selected so that fields arc not counted more than once and that a representative fraction of the total filter area is viewed. A convenient procedure which may be used is to select a series of microscope viewing fields along a radial line extending from the apex of the filter to the outer edge of the sample wedge. The viewing fields must be February, 1975 chosell without preference to a particular area and should be approximately equally spaced along the line. The first field should be located a little bit in from the point at which matter is deposited on the filter. If the required number of viewing fields cannot be located on a single radial line, additional lines parallel to the first should be chosen. Preferably l 00 fibers should be counted but all the fibers in 20 fields should be counted even if there are more than I00 fibers. The counting may be terminated after I 00 fields have been searched even if I 00 fibers have not been counted. Calculations The concentration of asbestos fibers in air can be expressed as: Asbestos Cone. = Fibers x R Fields x Vol \ ...... {oooo Figure 3. Illustration of fiber counting with a Porton reticle. The top and left side of the large box have been chosen as "counting sides". Circle 6 is 5 pm in diameter. (A) Fiber A crosses the top of the box and is counted, therefore. One end of Fiber A 1 touches Fiber A and thus is considered as part of it and is not counted separately. (B) Fi bcr B is a bundle containing many spikes. [t passes through the box crossing bottom and top. [t is counted :1s one fiber. (C) Fiber C passes through the box but it crosses the right side and bottom. It is not counted. (D) Fiber D is entirely within the box and crosses over Fiber A. It is not part of Fiber A, therefore it is counted as a sep:1mte fiber. (E) Fiber E is less than 5 pm in length. It is not count ed. FMSI 03126 America11111dustrial flyt:iene A.uociatio11 Jounwl where: Fibers = total number of fibers counted Fields = total number of fields counted R = filtration area area of a counting field Vol = sampling rate (lpm) x time (min) X 103 = sample volume in ml of air Since both the filtration area on the membrane filter and the area of the counting field are normally constant, the ratio of areas, R, is constant for the given conditions. To illustrate: Air is sampled at l liter/ minute for 50 minutes on a 37-mm membrane filter (filtration area 855 mm2). A total of 60 fibers each longer than 5 p.m are counted in 100 fields each 0.003 mm2 in area: R= 3x85150-mm3mm2 2 = 2.8 x 105 and =Asbestos 2.8 x 10' x 60 Fibers Cone. -1-0-0-F-i-el-d=s -x-1~x;-1 ~-.m,.l .x.5-0-m-i-n mm . . = ~A Fibcr$4lltl ... Since the precisio'n of this metr~jifJs 'limited, the averaged results of the .several samples should be reported to the nearest significant figure. Appendix I Recommended Procedure for Establishing Kohler Illumination The microscope is set on a level surface at a convenient height and in such position that sighting through the eyepieces is possible without undue strain or discomfort. The illuminator is placed direc~y in front of and aligned with the microscope. If the illuminator is equipped with a coil filament bulb, its iris should be ten inches from the mirror. If a ribbon filament bulb is used, the front of the filter holder should be at least seven inches from the mirror. Only the plane surface of the mirror should be used. All filters should be removed from 87 the system except that if desired, neutral density filters may be used to reduce the light intensity. If the microscope is equipped with a built-in illuminator, proper illuminator positioning has already been accomplished and need not be of further concern. Fix a mounted sample on the stage and recheck the alignment. Raise the substage condenser until it nearly touches the bottom of the slide. Turn on the illuminator and use the tilt controls to direct the light to the center of the mirror. Tilt the mirror, directing the beam upward into the stage condenser. Close the microscope substage iris and the illuminator iris. Use the illuminator focus control to focus the image of the filament on the "bottom of the substage iris. The reflection of the iris may be viewed in the mirror by leaning over the microscope. After adjusting the illuminator condenser so that there is a sharp image of the filament on the substage iris, open it about halfway. Recheck proper position of the mirror and then put the objective in place and focus sharply on the sample. It may be necessary to open the substage iris during focusing. After the sample is in focus, fully close the iris. Readjust the condenser height so that the edge of the iris leaves are in sharp focus and there is a bright spot within the iris. Readjust the mirror to obtain maximum brightness. If the color around the iris is not uniform, recheck the illuminator tilt and focus. If the color is uniform and maximum brightness has been achieved, open the field iris until the blades just pass out of the field of view. The proper phase stop is inserted or rotated into place in the substage condenser. The phase objective is rotated into place. The eyepiece i~ replaced with the phase ring centering telescope. The telescope is adjusted for sighting. The location of the phase ring is observed through the telescope. It may be adjusted by using the two rotating shafts provided with the phase condenser. When the ring is centered it appears as a bright annular ring mounted on top of a FMSI 03127 -------------------------------- 88 grey ring. The center is black. There should be no overlap of the bright ring into the center. When the phase stop is centered the telescope is removed and the eyepiece is replaced. The microscope is now ready for usc. Appendix II Recommended Procedures for Calibrating Reticle The reticle must be slightly smaller in diameter than the eyepiece in which it is to be used. It fits into tl)c tube and is held in place at the eyepiece focal point by spring pressure. The focal point. is marked by an internal collar which prevents the reticle from passing further into the tube. Some manufacturers locate the focal point just below the collar while others prefer a point immediately above it. Thus it may be necessary to insert the reticle between the lens and the collar on one microscope and below the collar on another. In either case the projected image of the reticle on the field must be clear and sharp. The reticle must project a constant counting area as well as provide markings for sizing. Many types of reticles are satisfactory. The Porton reticle illustrated in Figure 2 is recommended..It outllnci a large rec- tangle that fits easily within the field of vision. The rectangle is divided into two equal squares. The left square is further divided into six rectangles. Each side of each square has a length equal to 100 L, then the large rectangle is 200 L units long and the small ones 50 L units long and 33Y:1 L units high. To the left of the left square is a scale which divides the side into 20 equal increments of 5 L units each. The right square is divided horizontally in thirds corresponding to the small rectangles and vertically into a series of increasing spaces. The distance between each vertical line and the center of the large rectangle corresponds to the diameter of a circle. Circles of sizes 1 through 9 arc located above and below the large rectangle. The diameter of each circle Flhruary, 1975 is related in terms of L units of length in accordance with the formula: D = Ly2N where D is the diameter of the circle or the width of the space and N is the number of the circle, or space. The unit L is determined by measurement. A stage micrometer is the primary ruler. Any one or more of the definitive linear dimensions may be measured. If the length of the large rectangle is measured then L equals l/200th of that value. If the stage micrometer is marked in hundredths of millimeters the value of L is in hundredths of millimeters. If the left square is used as a counting area, its area is equal to (100 x 0.01 L)2 mm2 The filtering area of a 37-mm filter is 855 mm2 and thus R = 855 L2 If other areas arc used as counting fields or other sized filters are used, the value of R must be calculated for the individual condition. It is wise to prepare a chart showing each linear dimension and area for ready reference while counting. Appendix Ill Pump Calibration Personal sampling pumps should be calibrated for flowrate frequently. They may be calibrated against a primary meter such as a spirometer or against a previously calibrated secondary standard such as a wet gas meter or dry gas meter. The train should be arranged so that the pump is operating against the same resistance it would normally operate against, and that the calibrating meter is at atmospheric pressure. Figure 4 illustrates the recommended arrangement. Air flow through the filter may be limited by both restricting the air flow to the pump as well as by admitting secondary air into FMSI 03128 American Industrial Hygiene Association Journal PUMP lllnER Figure 4. Diagram of set-up for calibration of pump. the pump. Most personal pumps arc constructed with adjustment valves that permit both actions. Calibration should be repeated after each 24 to 36 hours of pump use. If the pump has not been used for a prolonged period of time it should be recalibrated. Temperature and altitude corrections should be made. Personal sampling pumps should not be used to such an extent that the batteries arc allowed to run down below normal operating voltage. Since battery life varies, it is wise to occasionally check the life of the battery by allowing the pump to run down to the first indicated change in voltage under timed simulated conditions. Supplies Filters and Filter Holders Millipore Corp. Field Monitor filter holders preloaded with 37-mm Type AA filters, either white plain (catalog #MAWP037AO) or griddcd (#MAWG037AO) are recommended. These are sold with a guaranteed average particle background and can be used without additional background checks. It is less expensive to purchase unloaded field monitors ( #MABG037AO) to be loaded with plain or griddcd filters pur chased separately in packages of 100 ( #AAWP03700, and AAWG03700). The field monitor can then be reloaded :~ftcr each usc. However, it is necessary to carefully clean the empty monitor and to check the background count on filters in the reloaded monitor. 89 Type AA filters can he used in any diameter in any non-leaking open-type filter holder, as long as proper adjustment is made in the calculations for the change in filtering area, and periodic background checks arc made. Membrane filters of other types and manufacturers cannot be recommended at this \ time, either because they do not become optically clear in the mounting medium or because of excessive particle background. Per.wnal Battery Powered Sampling Pumps ( 1) Casella" MK II or MK Ill Personal Sampler (2) MSN Monitairc Sampler, Model G. (3) Bendixci VM 22 or Micronair Personal Sampler or C-115. Microscopes: Phase Equipped . (a) microscope body with a fine focus accuracy of 0.006 mm; (b) lOX eyepiece; (c) mechanical stage; (d) illuminator (preferably built in and having provisions for adjusting light intensity) ; (e) 40 X to 45 X (0.65 N.A. at least) positive (bright field) phase-contrast objective; (f) annual ring condenser diaphragm (corresponding to the objective); and (g) phase ring centering telescope. (Note: Most manufacturers sell a basic body unit and built-in illumination system as a unit. Phase-contrast accessories can usually be purchased as a kit consisting of lOX, 40X and 90X phase objectives, a phase condenser containing appropriate annular ring diaphragms, a phase ring centering telescope, and a green filter. It is to the microscopist's advantage to purchase the kit.) A Jist of manufacturers of phase-contrast microscopes and rcticlcs1 is given below ro aid in selecting a proper inslrumcnt. MiUipore Corp., Bedford, Mass. 07130. o,.xb Willsun Pmt.lucls Div., P.O. 622, Rcru.ling, Pennn. 19603. C. F. Casella & Co. l.ld., Rc~cnl ll<tu.e, Rrilannrn fMS\ 03129 90 Walk, London, N.l, England. c Mine Safety Appliance Co., 201 Braddock Ave., Pittl hurp.h, Penna. 1520H. Bendix-NEt, P.O. Box 590, Fall River, Mass. 02722. Bausch and Lomb, Scicntiric Instrument Division. 72624 Bausch Street, Rochester, N.Y. 14602. Olympus Microscopes, Micro Optics Company, 2816~ Greenfield, Southfield, Mich. 48075. American Optical Corporation, Reichert Products, Buffalo, N.Y. 14215, Febr11ary, 197$ E. Leitz Inc., Rockleigh, N.J. 07647. Nikon Inc., Instrument Division, Garden City, N.Y. 11530. Unitron lnstmmcnt Company, Microscope Salea Division, 66 Needham Street. Newton Highland, Mous. O%Uil. Carl Zeiss, 444 Fifth Avenue, New York, N.Y. 10011. r Edmund Scientific Co., 701 Edsorp Bulldins. Barrinaton, N.J. 07007. BGI, Incorporated, 58 Guinan St., Waltham, M-. 02154. Joint AIHA-ACGIH .Aerosol Hazards E1alualion Committee AIHA ACGHI Morton Lippmann, Ph.D., Chairman J. LeRoy Balzer, Ph.D. Douglas K. Craig, Ph.D. Graham W. Gibbs, Ph.D. William C. Janes William H. Krebs, Ph.D. Carl A. Mangold Eric B. Sansone, Ph.D. Marvin Tillery Thomas F. Tomb Russell W. VanHouten Wesley R. VanPelt, Ph.D. Donald L Webster Howard E. Ayer George Carson, Ph.D. Harry J. Ettinger Murray Jacobson Geoffrey Knight Jeremiah R. Lynch G. Major Owen Moss Milton Scheinbaum Glen W. Sutton Industrial Hygiene Training in Israel Medical and engineering students at Tel Aviv University will be obligated in the future to undertake training in occupational safety, hygiene and health to inspire them with an awareness of their obligations for the maintenance of the health of the worker and for the prevention of ill effects from work on man. This has been made possible by the establishment in 1974 by the Faculties of Medicine and Engineering of the University, in collaboration with the Ministry of Labor, of the National Insurance Institute and the Workers Health Insurance (Kupat-Holim) of a Center for Occupational Safety, Hygiene and Health, with four major departments-Physiology of Work and Rehabilitation, Occupational Toxicology, Occupational Hygiene, and Safety Engineering. It comes to fill long-standing gaps in the promotion of safety and health of the working population in Israel and the absence of training facilities for specialists in these fields. The new Center will immediately provide refresher courses for physicians and nurses, but curricula for the training .of Occupational Toxicologists, Hygienists and Physiologists arc in preparation. Ultimately the Occupational Health Physician will also be trained at the Center. Due to lack of suitable personnel in the country the Center is seeking to recruit specialists from abroad. FMSI 03130 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PAR~US, N. J. 07652 March 10, 1975 To: Asbestos Study Committee Subject: Various Papers Concerning Asbestos Mr. 1. H. Weaver, Chairman, forwarded three papers concerning the asbestos problem which he suggested I send on to the Committee. Internal Raybestos Report by I. H. Weaver 3/4/75 This concerned ameeting at Rutgers University for the Occupational Health Conference. The safety of the 2 fiber/co limit (June 1976) was questioned. Also concern was expressed for fibers less than 5 microns in length. Industrial Hyeiene Proeress Reports Dr. Selikoff is Program Director for these Reports. In it is a fairlystrong push for reducing the standard to 1 fiber per cc or less. Mesotheliomata in Rats---- This is a British paper that indicated mesotheliomata was observed in a considerable proportion of animals with all the samples of asbestos. Mr. Weaver indicated that this was bad news for those hoping that chrysotile would be proven not to be associated with mesothelioma. The foregoing is for your information. EWD/erc Enclosure: E. W. Dri slane Executive Director FMSI 03131 Maahela, Pa. Ill'. J. H. Marsh - 'lr\a'bull Mareh ... 1915 On 'l'ueada7, l"e'bruar7 25th, I attended au Oecupatlcmal. Beal.th Ooatereaee at :a.taera tJaiTeralt7 la :Bru.uvlclt, Rev JerafiT, apcmaored br the DepartaeDt o~ EnTlra--a1. Scleace o~ Cook College at Ruts.,._, &llCl the .A11ericaa Luas Aaaoclatloa ot X. lent~~. fte IIOI"BiDB propaa ._. 4eYotecl to a paaeJ. 41acuaaioa aa4 qll88tioa &llCl 8D1I1IV perled oa currat health repl&tiou, eatOII'C...t probl_., aa4 l'eYiew ot cnarreat reaearoh ftD41Dga u4 tlaeil' potential appUcatioa to htlll'e policlea and at&D4ar4a. Much of the .ondq 41acuaa1oa coacenaed rel.&tive rita of state veraua J'tldwal prosna ccmtro1. !'he recnt deciaioa to turD OYeZ' reapoaaibil1t7 tor the OOCUJ&\loaal health lD. Rew Jeraey to t"he federal BOTe:rDel'lt waa aeYerel.y cl'itlcistld. J_.. COD11a, Rw JerMT' DepartaeDt of lAbor Deptt7 Director, out11De4 featlll'ea o~ the CJeaera1 Factory Act of 1885 that atlll are llelag Tiolated 1D Rw Jenfi'T aD4 exprene4 41a4a1D o~ purported aeed tu a441t1cmal. lqialatloa la the OCC1Q'I&t10Dal. health field.. Be feela there is plcmt7 o~ lqialatlon that ball aot beea atorced effectivelJ 81'&4 cited lack of cc.malcation aa the MJor probl lD. 1aprori.Ds occupatiOD&l haltll eoatlltiona. Bew JerH7 has operated a prog:raa that la far troa adequate 1D the oplaloa o~ ....,., lntt better thau ia likelJ" UDder federal coatrol. A JUJor problta 1a tlaat lalilos" .... the OBJIAet as a worker' a bill o~ l'isbta aD4 1I&J1ta to wipe oat atate pl.aea 'llll4el' 'the 1apl: Haloa their iatereata will be better aerre4 br feleral :pi'OII'aa. In aoat euea theJ' are 'tMa4l.7 lliapicled, aa it appears verr ulikel7 tll&t tlle fecl.el'al ~ 1dll be la a poaltioa to iaprove on the better ada:f.niatered atate prop- ~t haft bee in effect tor acae tiae, _.,. ot Vhich are beiac uppoaded. Ma:r.r Louiae Brown, Resioaal. Conaul.taot to OSHA Begion II, eatillated the Departaeat ot Labor "ll8Ul4 require aa __,. eaplOTees aa are DOW .-pl.OJ'tiCl 'b7 the eatil'e federal ~ to eaable OSJIA to acccapliah vbat COJISI'ea inteacled 1l'bea it paned the OSBAet. Since lese thau oae-teath ot a perceat of the federal bwlget DOW 1a appliecl to ooeupatioaal aafet7 &D4 heal.th, it is diacoarll&iDilT eT14eat tlaat ve are aa extrae17 1oq 11a7 traa achleri.q Vb&t COJIII'H8 -.a4&te4. 'l'he afteraooa eeuioaa conaiatect ot au 1IOI'k8hopa COftl'iliC Yariou 'basal'cla. I atteaaed. tlaon COil1t4trDiDa lead Ul4 aabeatoa. Dl'. 11111:1.- Vu-ts, tcmaer Cb:l.e1' lle4:loa1. 'lnaf.aer tor M144leaa 0oaat7 11ew J....,_., preaeated. aa iaptaa10M4 41.....-tloa the ll&u.rcla o~ lead ezpoaare. Be cbaracterbed lead aa aa ina141owl, elcnr poiBOUI' that 1a capable ot -.kiDs people aiclr.er than 8DJ'th1q el.ae he Jmc:nna. Be ~1se4 the t"oUovlag poiata: FMSI 03132 - 2- 1. Ro one Yith any chronic ail.JD.ent should ever be placed in lead exposure. A Ter'1 thoi'O\I8h pre-apl.oJJD.ent pb.ysical should be siven to discern chronic ailments in candidates tor Wl"k in lead exponre areas. 2. Non lead siclmua oeevs in J'OUDC and in old -.,l.oTeea. PropensitJ' ot the JOUil8 to coatract lead aielmeaa ~be atvibll't&ble to ca-elasaeaa. 3. OBee a penon contracts lead poisoniDS -- clon't pel'llit """GJIOIIUJ'el ~. 'foo J1111Ch aapbasia is placed on blood lead anal..7aia. Monthl7 teats tor blood lead, urine lead, haogl.obin count, porphorine and stippliDS should 'be required tor all workers exposed to lead. 5. Lead poisoning is beat treated in the hospital by intravenoua therapy. Proteasor llorbert Biltalea or Rutsers spoke briet'l.y' on "fal"ioua non-induetrial sources ot lead exposure and recent renarch on ettecta ot lead on heal'th. He Mid the prinoiple aource or lead in hull&n enrtromaent 1a troll natval.l.y oecurriDg lead in tood sources. Recent work indicates eaoking agsra~tes the ettecta ot exposure to ],nd. , Dr. Arthur Lanser ot Mt. Binae reviewed their studies ot Hew Jersey aabeatoa insula./ tion vorkera and o1ted their di.aal. health picture. Be mentioned additional studies conducted in rural areas to eliJD.inate possible etiological ettects ot exposure to air pollution in the lew Jersey industrial JD.eCalopolia and aaid tha't conoluaions troll these again related excessive cancer Yi'th asbestos expo8\D"e. T;rler, 'l'exae also was reviewed, and the Bewhouae and Thcapaon neishborhood exposure Btud7 also vas mentioned. Mt. Binae hall studied etrecta ot neishborhood and aec01l4ar:f (coa.1\llal) exposure in the Patterson, Bew Jersey area. In the tirst 130 people checked, 5~ have cheat abnormalities. :Lanser sU.te4 pleural plaques are oecurriDg abroad more in non-asbestos workers in certain iDiluetries, notabJ.y' ship lndldins and conetruction, than they do in asbestos wrkers. This is attributed to the tact tha't the non-asbestos workers do their Jobs without reepiratorT protection but near enoush to the asbestos work to breathe contaJD.inated air. The asbestos vorltera wear respirators. The aatety or the OSHA. ~ tiber per cc liJD.it was questioned. IAnser and his associates are particularly concerned about exposure to fibers in the wb 5 JD.icron range. He mentioned tibers ot specitic orisin auch aa the Co&linsa area in California, which characterieticall.T contain tew tibera sreater tban 5 JD.icrons in lens1;h. Under the present standards, it voul.d be possible to have vorlutra exposed to Te1"7 high concetl'at10DB ot this t7Pe ot dust on a maaa baaia without exceedins the 5 fibers per ec sreaur thaD 5 lliCI'ODB in length paraaeter. A better 1ndu or exposure or hazard ia ba4ll' IUitl4ed tor tht.a 'tJPe ot 'teri&l., aa 1t is ,..u lmowll to cause probl... The GerMD llen~ buia was mea'tioned as a poaaibl.e al.terna'te moni'torins JD.ethod. \ 'ba't i't . is recopised ma117 ditricul'tiea would 1at aa4 'that 8CIIlle operators 'ftc are nov okay at the 2 or 5 tpcc s-tandard V0\1ld becoae in violation on a Jl&8a basis. Mt. Binae 1a extrel.y 'WU7 or 8Jl&l.l.er tibera and considers tha very 8U8pect in respec't to mesothelioma and lung CA. They question 'the etrectiveneaa ot exiatins respirators tor protection against JD.eaothelioma and lung CA and are not at all vUUns fN\S\ 03'\33 - 3- ! 'to dib thea aa beiag biolosical.l7 t.naigni.ticant. Thq haTe found aub lisht t-m1croacop1c tibera b)" electl"'Ol m1croacow in the tiaaue ot Tinual.l.7 all aJor body orpna ot ubeetoa workers. .Additional teats are beiq -.de to detendne quatit7 aad abe Uetribution ot fibera in tlaaue ot the general public. ...alhile tu OOPiW the ~ UM ot ubeatoe vorriac:ae~ If&\. Sl!lae HOOliD!.Ha tor it _. reoc ttll4 tt " uea . ...,... Meded })Z'O'fi.4ecl it cu '" aea.'l.e4 in ao it cloelln't becQae ~. La11cer cited good rela.tioaahit'NI with J-M contn.17 to 'fOPll&r opinion ad expreaaed bish :regaN tor Dr. Kotin. Be quoted I'Dtln aa aqiq J-M would "ban" aabeetoa it th83' can't control it. ( I..&n&er spoke to the :llllmunity ot some indi:riduala to aabeatoa diaeue, but said otbera alao se-. to be l'J7perii'Wiceptible. Bo one kDovs vbat leTel 18 uaate" it &D71 The Seliltott/Lftinaobn ccmtrcmtl"q vu uutioned. Luger r.Cerred to Mt. SiDae'a uiiPT&u in Orad Britain aa4 said the~' believe ineideaee ot aabeatoa diaeue to 8XJ0811re 18 :wm1~ TenUS ~ prerioual.7 reported. He mentioned the "trendoua furor" thAt vu raised in duriq the recent i!lternatioaal conference and predicts there v:l.ll be a aiaU.er furor here when OSliA reopens heariap on the ubeetoa stu4ard. He Ter'7 lllUCh ~atiou Vb.ether the 2 tpoc 'lLV vUl at&n4 in light ot the severe criticS. to which J it VIll be subJected. - Dr. Rohl ot Mt. Siuae brief'l7 discussed reaulta ot their atudiea 1n brake repair sbopa :la lfw Jere.,. ud the lew Yon area. He bad iaten4e4 to ahoY 1l1dea &D4 present a loqer talk, pre..abl7 siaU.ar 'to the one he pTe at the AOOIB contvence in Miuai, 'bllt the elide liMbiDe broke 4ovll &D4 Dr. L&aaer preapte4 moat ot the time tl'lat vaa &Tailable. Rohl ael'1tione4 J1U17 light m1croacope counts ot llSbrane filter a~lea Ji.el.dinc 3 to 5 fibers per cc up to 20 tt. :traa the aenice area vhen 'brake 4ruu wre blftn ott vitb air hoaes. HoveTer, he waa much JIDl"e concerned about the rel.a- ti~ larp llUilber ot aub 5 micron and aub light microacopic tibera touncl up to wa15 tt. .,.,. trcm this operation 15 minute and lonser atter the 'blovlas performed. I. H. WeaTer grb FMSI 03134 nhattan ___Mmllli!iro, Pa. OIVISION an<! LOCATION TO: SUBJECT: Messrs. H. }'. Anspach P. T <.) Bonitatebus H. P. l{aberstroh c. A. Kennedy R. T. Matthew DATE: ' March 6, 1975 M. E. Schumann,Jro L. C. Williams The ~tta.ched report is of :10 comf0rt to those of us vrb.o are struggling to achieve compliance r,..rith the current 5 fiber standard and the scheduled 2 fiber standarcL 'I'his can be considered one more stroke in Mt. Sinai's campf::l.ign to seal the coffin of the current asbestos TLV. They really are pushing to get the standard reduced to 1 fiber per milliliter or less. I. H. Weaver grb att. cc: 1.1r..:.J..:-~.Jl~ FMSI 03135 FRICTION MATER!ALS STANDARDS IN~TITUTE, INC., L:-210 ROUTE 4, PAR~US, N. J. 07652 February 13, 1975 To: Asbestos Study Committee Subject: Heaith Policy Advisory Center Bulletin Mr. I. H. Weaver, Chai rr'lan, passed along the enclosed article on 11 Asbestos Resea.rch11 as published in the Health PAC Bulletin of November/December 1974. It is an article most Gritical of industry, alleging a cover-up helped along by some scientists. This art iclE:l might be considered another part of the move to reduce the occupational exposure level from 2 fibe! q per cc which is to go into effect on July 1, 1976. Enclosed also is another article by Sprout Waldron, concerning wetting down dust in their new DA Mixer. This article is also sent at the suggestion of Mr. Weaver. EWD/erc Enc. E. W. Drislane Execuitve Director FMS\ 03136 rRICTION MATERIALS STANDARDS INSTITU1E, INC., E-210 ROUTE 4, PARAMUS, N. J. 07652 BUL L ET I N N 0. 5 1 6 C December 4, 1974 PROPOSED AMENqAENTS TO EPA EMISSIONS STANDARDS We have issued earlier Bulletins 516,516A, and 5168 concerning the proposed amendments to the EPA emissions standards. While we had a few verbal comments on these proposals there was no written comment sent to the office that we could incorporate into a letter to the EPA. The cut-off date for comments was December 5, 1974. After discussion with Mr. I. H. Weaver, Chairman of our Asbestos Study Committee, I prepared the attached memo to EPA, and sent it on its way yesterday. In addition to the waste disposal problem, an area for concern is that some of your customers ("fabricators" in the proposed amendments) who do subsequent drilling, grinding or cutting of friction materials are covered by these proposed revisions to the national emissions standards. 1. When an assembler grinds or drills or cuts 2. When a debonder burns off the linings 3. When any assembler, debonder or other disposes of friction material waste. Without any comments from the manufacturers or fabricators, these proposed amendments will become the standards. If your customers are not aware of the problem, perhaps they, or the EPA, will fault the manufacturers for not having alerted them. The following notices in the Federal Register cover these national emissions standards for asbestos: April 6, 1973 National Emissions Standards May 3, 1974 Clarifying Revisions October 25, 1974 Prop.osed Amendments If you wish a copy of any of these notices, we will be happy to send you a copy. In the meanwhile, it is felt that your customers who do subsequent work on these products should be advised on the scope of these proposed amendments. EWD/erc Enclosure: E. W. Drislane Executive Director FMSI 03137 TI!Lili"HONII c20 I) 8415-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 December 3, 1974 Emissions Standards and Engineering Division Environmental Protection Agency Research Triangle Park North Carolina 27711 INC. Attention: Mr. Don R. Goodwin Gentlemen: The Friction Uaterials Standards Institute, Inc. is a trade association representing most of the manufacturers of brake linings and clutch facings in the United States, and we serve several manuf&cturers outside of the United States. We wish to comment on the prr.posed amendments to the National Emissions Standards for asbestos, as pnolished in the Federal Register on October 25, 1974. There are items in these proposed amendments which lldll have considerable impact on customP.rs of our members (fabricators of friction products) and on land-fill operators who provide our members with waste disposal se~1ices. 61.22 (h) (2) Inclusion of fRbricators of friction products in the requirements of the emissions standards While we can understand the Administrator's reasons for including fabricators of asbestos friction products in the emissions standards, we do not feel that s these fabricators are sufficiently m~are of the impact of these proposed amendments on their operations, particularly in the waste disposal area. We feel your December 5, 1974 cut-off fc:r acceptance of relevant comments w.<~s too early to get satisfactory input from those most affected by the proposed amendments. We suggest that this paragraph be postponed until fabricators of friction products have the opportunity to consider the impact of these proposed amendments on their operations. 61.22 (1) (2) The require'1ltnt__ for \.;s.rning signs on inactive waste disposa!_ siteo This affects in:lividuals and compa.n::es who service our members. There may be a reaction on the part cf such op.'!~ators which could make waste disposal sites unava~lRble to both manufacturers and-fabricators. Many operators and df!<Jelo;:>e-r:s plan their l-'ll:d uc-e w::_th the intention of later re-sale. These warning s1gns could be requir~d forever on inactive waste disposal sites and this would effectively remove them from future development. We recommend this requirement for warning signs at inactive waste disposal sites be reconsidered. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE ]{wD/lmc E. W. Drislane Executive Director FMSI 03138 FR1CTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N. J. 07652 8 Ul l ET I N N 0. 5 1 6 B November 15, 1974 PROPOSED AMEND.'IAENTS TO EPA EMISSIONS STANDARDS On October 29, 1974 and November 5, 1974 we issued Bulletins 516 and 516A concerning the proposed amendments to .the EPA E.issions Standards. The impact of these propose~ amendments may not be fully understood, but they are quite far-reaching, and they may create problems in the solid waste disposal area. First, I must correct Bulletin No. 516A, where it stated that "--- all such sites must be fenced. 11 1. In the case of ctive wa~~9 is Of.al sites, fencing is not required provided 6" (15cm. of compacted non-asbestos 'containing cover is applied at least once every 24 hour period. 2. In the case of inaftive~a...Q~~..f!..s~l sites, fencing is nol rW~uired provided: (A) 6" (15cm.) of compacted non-asbestos containing cover is applied with a cover of vegetation~ or (B) 2' (60~Et.) of compacted non-asbestos containing cover _ _ is applied without a vegetation cover. "NO.... VI Sl BLE ~CM-I -SS"'O-NS-11 The proposed standards state "no visible emissions" during the rHsposal - colleciio~ ~~kaeinQ, tr~~orting or dYffiBine (unless eithor the spe~if1ed wat{ing or pelletizing c~thods are uaGd). Whsre they say "no visib:!.e emissions" at the dispos::\1 site,_ they interpret this to m-:'an not just the border 1i ne b:.Jt anywhere in the C::.Jolp. DE~B~NDI NG CPERATIONS De-bonding operations byr~uilders are considered fabricating operations and the materials removed must be disposed of in accordance with the procedure for manufacturers and fabricators. The re-Luilders with de-bonding operations are fabricators and it is proposed that they be covered. THE EXCEPTION FOR BRAKE SHOE RAD!~JS GRINDING Where the EPA is making an exception (je, not covering) brake shoe radius grinding, that is only when brake shoe radius grinding is done at the garage or shop actually installing the shoes on a vehicle. Where brake shoe radius grinding is done by a manufacturer or fabricator, that operation is not an exception. FMSI 03139 Bulletin No. 516B - 2- November 15, 1974 WAST.; _DISPOSAL SITE SIG.=-..l.tlJICT_tyE SITE~ There will be a problern where a site has been filled by a developer and the inactive site must have Asbestos Waste Disposal Sign posted thereon. This may make it difficult for a developer to market the property and in turn make it impossible for a manufacturer or fabricator to use this dicposal site. There are many problems for asbestos friction materials manufacturers with these proposed amendments, particularly on disposal of solid waste. It is suggested that the Standards (sent with Bulletin 516) be reviewed by those responsible for asbestos control in the factory, and that comments be sent (in triplicate), not later thqn December 5. 1974. to: Emissions Sta~dards and Engineering Division Enviornmental Protection Agency Research Triangle Park, North Carolina 27711 Attention: Mr. Don Goodwin. If you need additional copies of -(he proposed amendments please let me know. If you would rather have FMSI respond, please send your written comments to the Institute to arrive no la.ter tha:1 December 2, 1974. EWD/erc co- Delegates, Alternates Asbestos Study Committee E. W. Dr i slane Executive Director FMSI 03140 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N. J. 07652 BUL l ET I N N0516A November 5, 1974 PROPOSED AMENDMENTS TO EPA EMISSIONS STANDARDS On October 29, 1974 we issued Bulletin No 516 concerning the EPA Emissions Standards and we sent one copy of the notice as it appeared in the Federal Register to one person for each Member. Mr. I. H. Weaver, Chairman of our Asbestos Study Committee, has condensed the more important items of concern to friction materials manufacturers and his comments follow: It is proposed to extend coverage of the standard to fabrication of friction products, except those operations that primarily install asbestos friction materials on motor vehicles. Brake shoe radiusgrinding is specifically ~id in the rationale on Page 38065. Waste disposal requirements are spelled out in considerable detail. It appears that if there are no visible emissions with existing waste disposal methods, no change will be required. However, if existing methods entail visible emissions, then one or the other of two alternates must be pursued: a. Wetting with water and sealing the wetted waste into impermeable containers labeled to provide notice that a hazardous material is contained, and depositing the filled containers at a disposal site. b. Pelletizing into non-friable pellets and depositing at a disposal site. Incineration of containers such as paper or plastic bags that previously contained asbestos will be prohibited. Warning signs will be required at waste disposal sites to alert the public of the potential asbestos hazard, and all such sites must be fenced. In the event there are visable emissions from waste disposal sites, one of the following alternates must be followed: a. Cover with 15 centimeters of non-asbestos-containing material, and establish cover of vegetation adequate to control erosion. b. Cover with 60 centimeters of non-asbestos-containing ~terial and maintaining such cover in an erosion-free condition. EWD/erc cc-Delegates, Alternates Asbestos Study Committee E. W. Drislane Executive Director FMSI 03141 FRICTION MATERIALS STANDMDS INSTITUTE, INC,, E-210 ROUTE 4, PMIWUS, N.J. 07652 ,, ' BULLETIN N 0, 5 1 6 October 29, 1974 PROPOSED' JIMENIJAENTS TO EPA EMISSIONS STANDARDS On October 25, 1974 the EPA published proposed amendments to their National Emissions Standards. To avoid confusion: these are EPA proposals (not OSHA). They concern the requirements of "no visible emissions" into the environment. While these proposed amendments are concerned primarily with the demolition and removal of "friable asbestos materials", there are at least two proposals affecting the friction materials business. One isthatfabricators of friction pr~duct$ (such as re-builders) would come under the provisions of these regulations, whereas currently the manufacturers are covered. Amore important item is that proposals are made in the solid waste disposal area w~ich should affect all manufacturers. A copy of these proposed amendments for your eompany is being sent toa The foregoing is for your information, EWD/erc co-Delegates, Alternates Asbestos_ Study Committee E. W. Drislane EXecutive Director FMSI 03142 Mr. :&. M. Petmer1 Direot.or 'feohn1cal llel&tiou ~ Attain Dept.. Jo~v:llle Corp. P. o. Box 5100 Dea.,..1 ee1o. eon7 Dear Ed: A.tt.aobecl ia COPT of re'9'1Hd. dft.tt. of ~ A.-.\oe PJo1o\ioa Matoarial.a Work Prut.ioee aad a.....,. up oopy of t.lw ortatw to 1Ddloat.e challpa1 all ot wlrl.oh 1 OOJUdd. lll..n:w. I. H. Wea'NI" " oo-Heaare. J. Harah 1. Drielene ,/. c. Clarke FMSI 03143 Di\AFT - NOT FOH. ClECUU~TIGn nevised 10/23/74 Hecomrnended 'vJork Practices for Users and Fabricators of Asbestos Friction Eaterials This reconu"!lendation of "'Jork Practices" is prepared by the Standards and Technical Comr:tittee of t,he Asbestos Information Associat:inn/North America. The intent is to advise manufacturers and fabricators, who use asbestos friction materials, of l'l'ork Practices best suited to maintaining a workine environment within the levels required by l910.93a of the OSHA Standards (copy attached). l. Asbestos Friction Haterial Products covered by this work practice recommendation: 1.1 Clutch Facings 1.2 Brake Lining Segments 1.3 Brake Blocks 1.4 Disc B rake Pads l. 5 Brake Band 1-:aterials 1.6 Automatic Transmission Discs 2. Operations to ;-rhich the recommended vrork practices may apply: 2.1 Clutch Assembly and Rebuildin~ Operations 2.2 Brake Assembly and Relining Operations 2.3 Automatic TransmissionAssembly and Rebuilding Operations 3. Requirements of OSHA l9l0.93a. 3.1 The Asbestos Standard (l'JlO. 93a) applies to any manufacturi11g, fabrication or handling process or operations involving articles or materials composed viholly or in part of asbestos fibre. 3.2 lt is the employer's responsibility to rraintain "Exposure to airborne concentration of asbestos fibres'' at or below the levels described in 1910. 93a. Exposure levels may be controlled by isolation, enclosure, exhaust ventilation and dust collection. Stand,,~rd l9l0.9Ja does not limit the means used to maintain compliance. J,J Particular tools -All hand or power operated tools which may cause the release of asbestos fibre to become airborne at levels in excess of the standard shall be provided with exhaust ventilation .3 .4 Het Hethods - vJhen practicable asbestos products shall be procer;~::;ed \Jetted sufficiently to prevent emission of dust to the atmosphere. (Limited or not required Hhere wetting v:ould reduce end efficiency of the product.) 3.5 Protective Equipment and Clothing- V!henever it is necessary for employees to perform their normal work in an environment where airborne concentration of asbestos fibre exceeds tr,e allo1-rable level of Standard 1910" 93a, the employer must provide respiratory protection and clothing in compliance vril:,h the standard. The employer must also provide change rooms and separate lockers for work clothes and street clothes. 3.6 Air Sampling and Nonitoring- The employer is responsible as described in 1910. 93a. FMSI 03144 , 3~7. Storaee and Handlint;- It is recommended that asbestos-containing products be stored in sealed containers. Handling of asbestos-containing products shall be cione in a ma.nner to minimize t;eneration of airborne asbestos d11st. 3 .8 Caution Si.r:;ns a.Dd Labels - The employer shall use caution siens and labels in accordance Hith provision of Standard l910.9Ja. 4. Exhaust and Dust Collection Systems 4.1 \rlherever exhaust and dust collection systems are used to attain concentrations of airborne asbestos fibre belovT the levels allowed in Standard l910.93a, the systems shall be inspected and cleaned at least weekly. 4.2 lJesi[;n, installation and maintenance of exhaust and dust collection systems shall be in accordance with American National Standard Fundamentals Governin(; Desien and Operation of Local Exhaust Systems (AHSI Z9.2) or equivalent standard. 5. Housekeeping in :fanufacturing and Fabrication Areas: 5.1 All sur.faces, machinery, equipmcnts etc. she.ll be kept free of accumulation of asbestos du3t, preferably bJ' vacuum cleaning or other method that vrill prevent asbestos dust or fibre from becoming airborne. Vacuum cleaners should be equipped with a disposable ?ollection bag and a microfilter. 5.2 ilaste a.nd scrap material, such as dust, chips, off-cuts, edge trimrninss and hro:wn pieces shall be placed in sealed containers in preparation for dispo::;al. 5,3 Containers used to store or disr;ose of asbestos-containing m3.terials shall be labeled in a manner to cor:1p~y v1ith Standard l9l0.9Ja. 6. Recor.-.rr~ended Procedures for J!;anufacturing and Fabrication Operations Involving fl sbestos Friction I ~aterials: 6.1 1;iherever feasible, friction materials that are specially treated to reduce dust emission should be used. 6.2 !~aterials should be removed from containers gently and handled with care to avoid unnecessary 13eneration of airborne dust. Care should be taken not to disturb dust rernainine; in containers and packaging materials. Such dust should be removed by vacuum cleaning wherever feasible. 6.3 vfhercver feasible, m::tterials should be obtained from the manufacturer cut, machined and/o;.~ drilled to suit final requirements to avoid necessity for additional fabrication operations. 6oh On large volume operations with fixed 'wr;<:ing poihts or machines, local exnaust systems should be installed in accordance with American Hatirmal Standard AWJI Z9.2 or equivalent standard. 6.5 \'Jhen cutting, drilling, grindinr, or machining operations are of short duration, portable dust exhaust units may be suitable. Vacuum cleaning equipl!lent. sometiraes may be adapted for this purpose, provided the filter system is of adequate efficiency. FMSI 03145 ., ' 6'.6 vJhere dust control by means of local exhaust is not feasible, flooding of the v:ork and the tooling with water or other liquid may be effective in suppressing dust emission. 6.7 Fragnents and dust should be removed regularly, preferably by vacuum methods, and must be disposed of in accordance with paragraphs 5.2 and 5.3. 6.8 If surface dust is present on materials, it may be necessary to remove it by wipLng \-.rith a damp cloth or mop or by. vacuum cleaning with a brush head. attachment prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. 6. 9 Hhcre it is impractical to cort rol airborne dust by means of an exhaust system or by \vet processing, workers must be protected by approved respirators and protective clothin~;. ?. Personal Protection 7.1 Develop good personal hygiene practices. Vashing thoroughly before eatinc; will prevent D1gestion of foreiGn matter. Food shcu ld not be stored or eaten in the v10rk area. 7.2 It is well documented that smking is injurious to your health. The ill effects of smoking may be accentuated for those workL'18 where airborne asbestos dust may be encountered. Smoking should be avoided!, 7.3 Uce of approved respirators shall be mandatory vrhen required b:r OSHA Stands.rd l910.9Ja. Protective clothint; shall be provided and <urn vllH;revGr en,~:loyees are exposed to ceiling levels exceedin~ those prescribed in Standard l910.93a. Employees must be given tnorout:;h instruction in proper use, care and maintenance of personal protection equipment. 7.4 No person shall be assiened to perform any work for which respiratory protect- ive equipnent is needed unless he has been medically examined and determined fit. 7.5 Care should be taken to minimize dust generation and transfer of dust to the person or his clothing. Clothing not worn durin[i vmrking hours must be stored away from contamination, and contaminJ.ted work clothinr, shall be specially handled to prevent exposme to asbestos dust, as prescribed :in Standard l910.93a. FMSI 03146 H.ecomJnended ldmk Practices for Users and Fabricators of Asbestos Friction I-:aterials -Int"1"01iuat-:ioo. This recommendation of "Hork Practices' is prepared by the Standards and Technical Committee of the Asbestos Information Association/North America. wo~e-Ge~.e-ty--and-Healt.h Department, Gffi-ee-~-f--HeaJ.t.h-S.ta.P.dards. The intent is to advise r:~anufacturers <md fabricators, who use asbestos frictiou Tn3.!:.erials, in manners of \vork Practice best suited to the maintaining~;-,. working environmenttrJ. . ,\ atrnosj9here within the levels required by l910.93a of the OSHA Standards(ctf1o:J.J+, J.. Asbestos Friction Ha.terial Products covered by this work practice recommendation; ctli'o..Jv ~ 1.1 C1;ltch Facings ...._ 1.2 Brake Lining Segments - l.<j- Disc Brake Pads l.i; Brake Band I:aterials l.~ Automatic Transmission Discs "To V...f.\\q\ 2. l4anttf-ae-~iflg Operations \,~n the recomraended work practices may apply: 2.1 Clutch Assembly and Rebuilding Operations 2.2 Brake Assembly and Relining Operations 2.3 A1tomatic Transmission Assembly and Rebuilding Operations ~ro-sembly-&f--I.nd.u~&.La.Bd/-G~r~ti-on-Bquipment 3. Hequirerncnts of OSHA Standard 1910. 93a re:P-~-(fu!-1 , .~ ;.."11i f.lC< " s IA,._.-rt:1'llt..'- to-_.__.a;;- 13.1 The Asbestos Standard (1910.93a)~esol?- ~ t,.. ' c._ mam;.taa;ring, fabrication or handling process ~ vrMf'cm4- articleScomposed wholl,y or in part of asbestos fibre i~. 3.2 It is the employer's responsibility to maintain 11 Exposure to airborne concentration of asbestos fibres at or below the levels 9escribed in l910.9Ja. Exposure levels may be controlled byx ].solation, 8nclo;.mre, exhaust ventilation and dust collection. ';!.!i. Standard l910.93a does not limit the means used to maintain compl.:i.ance. 3 .J Particular tools - All hand or povrer operated tools which may cause the release of asbestos fibre to become airborne at levels in exceas of the standa~d shall be provided with exhaust ventilationV 3.4 Wet Hethods - ,l. vlhen practicable asbestos f.p.iction materiaY_.p/Sr~fd,cuc-tsd-i:R_; shall be processcct_")wetted sufficiently to prevent emission-"to ...:working atmosphere. (Limited or not required vrhere wetting of the product '\orould reduce end efficiency of tf.ttt product.) {fu_ 'v-iloi.~-"'J tt-R 3 .5 Protective Equipment and Clothing - At. 'f:!Ueh tlines that it is necessary for employees to perform their normal work in an environ- ment '"herei1;l the airborne concentration of asbestos fibre exceeds the allowable level of ~tandard l9l0.93a, the employer ~st provide FMSI 03147 respiratory protection and clothine in compliance with the standard. The employer must also provide change rooms and separate lockers for v1ork clothes and street clothes. 3.6 Air Sampling and Bonitoring -The employer is responsible as described in 1910.93a. Nl..- ot=- 3. 7 Storage and Handling - It is reco~-deI~dAI'lbtfh,.-a1 t asbestos-containing products be stored in sealed contai~s 1 ~ ~I'i~f -b:i:m~oess~---l:lamilo-. asbestos-containing productsK t.be I ! l handJARg shall be done in a marmer to G~~a-Efu---arootlnt of air- At,t .4. ~b,o'&rn("e"""a"'s(."b"e' SsLto~s.._do.u~ Exhaust ancf Dust st. J.i_e.l< e~...- 7 fU! Collection S~y~-s~teJ~m~s.\t"(uQ"."/}"."r.a'...\U.7,-wtt:v-CJ~o{..,C..;N"..-..ud'-A".v~rT~:~'"t'UfN.u.Jt"~\-V~LtC1t.fNir.\f .u17.vtr0-f-V 71f/)_o...,u"'"-.{~. ; ~- .-~.~"J"''j 11_ L..l 11-'he:~m exhaust an<:: dust collection systems are used to attain concentrations of airborne asbestos fibre below the levels allmmd /q I o. I 1 o-.. ,.. !,! in standard 1910. 93a, the systems ~"HH:d be inspected and cleaned weekly. S.'-!'~L ., ' r"'nil.~~ATt<~I.J AN~ A.v\u.r!B..il.l,,_;c;;z 4.2 ~ design) of exhaust and dust collection systems (~ ~-ma;i~~l_:,hall be in accordance \'lith American National c-Standard f#r~=::-=~~- JFtA-1'1-Atl.-.....: ,.:t_t._ G-c-tt~..u.:..,.r /lt.::.(~ Mcr-l 0 f-'u.J;..'n"- l-o~ t6.,k....v... S~-i~v._ \ .n.. ..kf!.L~v-a..&v:i ~tct.v:LN,/1..., . 5. Housekeepmg, itt~ Ua.nui'ac'Luri.ng and Fabrication areas. 5.1 All surfaces, machinery, equipment etc. shall be kept free of ~ accumulation of asbestos dust, 1i~ preferablv by vacuum cleanine meth~ or other method that \'ti11 prevent asbestos dust or i:ibre from becom:i.ng airborne. Vacuum cleaners should be equipped\with a disposable collection bag and a microfilter. 5.2 \'Taste and scrap r.-~aterial, such as dust, chips, off-cuts, edge '1trimmings and broken pieces shall be placed in~ sealed containers in preparation for disposal. 5.3 Containers used to store or dispose of asbestos-containing materials shall be labeled in a manner to comply with ~tandard 1910.93a. 6. Procedure recorrrrnendat.ions for manufacturing and fabrication operations involving asbestos friction materials. Ft:.IISIIH. 6.1 \'lherever p&5'5-ible, friction materials that are specially treated to reduce dust emission should be used. 6.2 Haterials should be removed from containers gently and handled with care to avoid unnecessary generation of airborne dust. Care should be taken not to disturb dust remaining in containers and packaging materials. Such dust should be removed by vacuum cleaning wherever :r--,o-sfl i bl.e. Fr:A'i.IM... " FMSI 03148 '. 7.5 Care should be taken to mini~ze dust generatjon and transfer of dust to the person or his clothing. Clothing not \lOrn during workine hours nmst be stored away from contamination, and contaminated work clothing shall be specially handled to prevent exposure to as'Qestos dust. fMS\ 03149 F/Jl.SI8LF 6.3 Whe~ever p&Ssib1e, materials should be obtained from the rr~nufacturer cut, machined and/or drilled to suit final require- ments to avoid necessity for additional fabricationoperations. 6.4 On large volume operations with fixed working points or machines, local exhaust systems should be installed in accordance with American National Standard ANSI Z9.2 or equivalent. 6.5 lfuen cutting, drilling, grinding or machining operations are of short duration, portable dust exhaust units may be suitable. Vacuum cleaning equipment sometimes may be adapted for this purpose, provided the fill3r system is of adequate efficiency. 6.6 Where dust control b~r means of local exhaust is not feasible, flooding of the work and the tooling with water or other li(juid may be effective in suppressing dust emission. ~~1J:..:J,,e1JTS 6.7 ~warf and dust should be removed regularly, preferably by vacuum methods, and disposed of in accordance with paragraphs 5.2 and 5.3., 6.8 If surface dust i3 present on materials, it may be necessary to remove it by v1iping Hith a damp cloth or mop or by vacuum cleaning with a brush head attachF~nt prior to performing secondary operations such as riveting, bonding, branding, inspection, etc. 1 6. 9 ln-exc.epw.o.na::::k~ where it is impracticablG.~ to control airborne dust by means of an exhaust system or by v:et processing, "~>mrken:, must be protected by approved respirators and protective clothing. 7. Personal Protection. \t ~~t~t\ 7.1 Develop good personal hygiene practices. \'lashing thoroughly before eating will prevent ingestion of foreign matter. Food should u\.~l! J#,,.l\.,il..N.\Jl.'l'.V\'t\~o0~-,"L,':-UA...IP\_\"11".J._. not 7.2 be It stored or eaten in is well <iocur..ent,ed the work area. t:1a.t smoking is injuric.us to y0ur . health. - ' - {'IJ.-0L{, 1J _l}}>v~ ~}~"ihen--eot~p4--Hi-t.h....aebee"Ws--4ust-p:r:.--o-hl-<}m~-..eilec-ta__ar.e- accentuated} ~ \,~~t~y-ti~ Smoking should be avoided! ~"'\ ~,IJ!~~ l_jiVtJ~ ' py.P'w.:J 7.3 Use of approved respirators shoBld b~t~:raged-wher-eveF measurable-airborne-asbestos- \l JV\sueh re cpir-at.w:s- shall be ma nddua.tsot.r-ycownclewnt~ra-t,ibonos-r-enxie&t-,f and-use-o-f ibre--limits l..~v. rv ( n c/ Q":>l<t-~ e~pe-s.ei'-ibed-il:l Standard l910.93a. Protective clothing I shall be provided and '\>TOrn wherever employees are exposed to ceiling levels exceeding those prescribed in Standard l910.93a. Employees must be given thorough instruction in proper use, care and maintenance of personal protection equipment. 7.4 No pereon shall be assigned to perform any work for which respiratory protective equipnent is needed unless he has been medically exanuned and determined fit. FMSt 03150 11:1". I. II. , _ . . ~ ftlt8d eal aela\JAMIIJ ~ Attain lleiJ' lo~c.p.. ......P.O. k 5108 l*rtw, ~ 8all.7 Sa,.........wA...- 1a ot I"CN&ll clnA ot 1'MI'I Utdld l"k ,.......U.ou tw __.. ud ~ ot .......-. fi'1.U. ~ tollDviJta: the .ror.t .... - Llll'z7 ffDctcV eMdl. . . . . ~ - ........ w.:..t.Uu. !ada 111 IMda& ~ bJ ott. .,.,..... ot the Prt.oUcm ICatW1IWt ....... JuU.-. .., ...... ....,. c-lt.t., 'tlld.ob l ..,. wU1 JII"'YW8 ftlnbu Sltplt ....-iaa _..IGI' t.M l"ftbed 4lnA ot ~ 11ft ot ..., 11 da\S..., 'tiM aet;u.l ..SC t.Mbuled :Ia . . . - . . ' a 6, it.e ),4 _. ? 8ll ...w.ct be ~ - .tor all -' pa allan P'l.INe ......_ tM attach 11 ..s tlllftee ...,. We II ...,., OC\oMr 16, :lt _, ,....14M..... ~" ..... fa tlde . . ., ..... 1 ........ \be ............ ...,. ot U. ~ ~ WoJok ~- aad tile far ot.be ~ ..............1 -.rd t.o .U to J'iRl P'I'Witr, tM 18\h 1. H. W.Wl" FMSI 03151 -iN\o"TovF~ttC\.).A<A:.-JF..A.T.c.t...ATcctt Recommended Work Practices for Users and Fabricators of Asbestos Friction Materials Introduction This recommendation of "Work Practices" is prepared by the Standards and Technical Committee of the Asbestos Information Association/North America, working with the Occupational Safety and Health Department, Office of Health Standards. The intent is to advise manufacturers and fabricators, who use asbestos friction materials, in manners of Work Practice best suited to the maintaining a working environmental atmosphere within the levels required by 1910.93a of the OSHA Standards. 1. Asbestos Friction Material Products covered qythis work practi~e recommendation. 1.1 Clutch Facings 1.2 Brake Lining Segments l.J Disc Brake Pads 1.4 Brake Band ~~terials 1.5 Automatic.Transmi~sion Discs 2. Manufacturing Operations wherein the recommended work practices may apply. 2.1 Clutch Assembly and Rebuilding Operations 2.2 Brake Assembly and Relining Operations 2.3 Automatic Transmission Assembly and Rebuilding Operations ~d A:ssembl:y--of Ind.Ystrial aREi~r1.1c:ti:ea -Eqttipment. 3. Requirements of OSHA Standard 1910.9Ja J.l The Asbestos Standard (l910.93a) applies to any manufacturing, fabrication or handling process etc. wherein an article compos.ed wholly or in part of asbestos fibre is concerned. 3.2 It is the employer 1s responsibility to maintain 11Exposure to airborne concentration of asbestos fibres" at or below the levels described in 1910.93a. Exposure levels may be controlled by, Isolation, enclosure, exhaust ventilation and dust collection. The Standard 1910.93a does not limit the means used to maintain compliance. 3.3 Particular tools -All hand or power operated tools which may cause the release of asbestos fibre to become airborne at levels in excess of the standard shall be provided with exhaust ventilation. 3.4 Wet Methods - ltlhen practicable asbestos friction material products shall be processed, wetted sufficiently to prevent emission to working atmosphere. (Limited or not rnquired l'rhere wetting of the product would reduce end efficiency of that product. 3.5 Protective Equipment and Clothing- At such times that it is necessary for employees to perform their normal work in an environment wherein the airborne coneentration of asbestos fibre exceeds the allowable level of standard 1910.93a, the employer must provide FMSI 03152 / respiratory protection and clothing in compliance with the standard. The employer must also provide change rooms and separate lockers for work clothes and street clothes. 3 .6 Air Sampling and f.fonitoring - The employer is responsible as described in 1910.93a .3. 7 Storage and Handling - It is recommen,ded that asbestos-<: ontaining products be stored in sealed containers, etc. During periods of time that it is necessary to handle asbestos-containing products, the handling shall be done in a manner to create the least amount of air- borne asbestos dust. 4. Exhaust and Dust Collection Systems. 4.1 Wherein exhaust and dust collection systems are used to attain concentrations of airborne asbestos fibre below the levels allowed in standard 1910.93a, the s7stems should be inspected and cleaned weekly. : . . 4.2 The design of exhaust and dust collection systems (installation and maintenance) shall be in accordance with American National standard (ANSI z 9 .2) Fun-k.-L.t4-t.. G-a(!~r ~r- ~ o~ ~ ~ ~ .s~, 61- .11.-jJ.J/u~ /~J.._. . . 5. Housekeep~g, in Manu!acturing and Fabrication areas. 5.1 All surfaces, machinery, equipment etc. shall be kept free of any accumulation of asbestos dust, lint and waste, preferable by vacuum cleaning methods or other method that will prevent asbestos dust or ribre from becoming airborne. Vacuum cleaners should be equipped witfi a disposable collection bag and a microfilter . 5.2 lofaste and scrap material, such as dust, chips, off-cuts, edge trimmings and broken pieces shall be placed in tightly sealed containers in preparation for disposal. 5.3 Containers used to store or dispose of asbestos-containing materials shall be labeled in a manner to comply with standard 1910.93a. 6. Procedure recommendations for manufacturing and fabrication operations involving asbestos friction materials. F~AS16J. 6.1 Wherever ~~le, friction materials that are specially treated to reduce dust emission should be used. 6.2 Materials should be removed from containers gently and handled with care to avoid unnecessary generation of airborne dust. Care should be taken not to disturb dust remaining in containers and packaging materials. Such dust should be removed by vacuum cleaning wherever possi~l~. Fr::-~s.tC.t..E FMSI 03153 '. FUSIAL" 6.3 Whenever p&sa~, materials should be obtained from the manufacturer cut, machined and/or drilled to suit final requirements to avoid necessity for additional fabricationoperations. 6.4 On large volume operations with fixed working points or machines, local exhaust systems should be installed in accordance with American National Standard ANSI Z9.2 or equivalent. 6.5 When cutting, drilling, grinding or machining operations are of short duration, portable dust exhaust units may be suitable. Vacuum cleaning equipment sometimes may be adapted for this purpose, provided the filer system is of adequate efficiency. 6.6 Where dust control by means of local exhaust is not feasible, fiooding of the work and the tooling with water or other liquid may be effective in suppressing dust emission. 6. 7 Swarf and dust should be removed regularly, preferably by vacuum, methods, and disposed of in accordance with paragraphs 5.2 and 5.3,. 6.8 If surface dust is present on materials, it may be necessary to remove it by wiping with a damp cloth or mop or by vacuum cleaning with a brush head attachr~nt prior to performing secondary op~rations such as riveting, bonding, branding, inspection, etc. 6.9 In exceptional cases where it is impracticable to control air- borne dust by means of an exhaust system or by wet processing, workers must be protected by approved respirators and protective clothing. 7. Personal Protection. 7.1 Develop good persona hygiene practices. Washing thoroughly before eating will prevent ingestion of foreign matter. Food should not be stored or eaten in the work area. 7.2 It is well documented that smoking is injurious to your health. When coupled with asbestos dust problems, the effects are accentuated. Smoking should be avoided! 7.3 Use of approved respilators should be encouraged wherever measurable airborne asbestos dust concentrations exist, and use of such respirators shall be mandatory wherever airborne fibre limits exceed those prescribed in Standard 1910.93a. Protective clothing shall be provided and 1'torn wherever employees are exposed to ceiling levels exceeding those prescribed in Standard 1910.93a. Employees must be given thorough instruction in proper use, care and maintenance of personal protection equipment. ?.4 No person shall be assigned to perform any work for which respiratory protective equipment is needed unless he has been medically examined and determined fit. FMSI 03154 .. 7.5 Care should be taken to minimize dust generation and transfer of dust to the person or his clothing. Clothing not worn during working hours must be stored away from contamination, and contaminated work clothing shall be specially handled to prevent exposure to asbestos dust. FMSI 03155 TllLilP'HON& ( 20 II 8411-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. October 161 1974 Mr. 1. H. Weaver Ray~stos-Manhattan, Inc. Manheim, Pa. 17545 Subject: Work Practices for Users and Fabricators of Asbestos Friction Materials. Dear Ike: I have reviewed your recommended work practices. You have done a very eomplete and to-the-point job. Confir~ing our phone conversation, I wish to make the following suggestions: 1. Add "Brake Blocks" as 1.3, and then re-number others to 1.6. 3.7 After " stored in s.aled containers. etc." Remove "etc." 3.8 New section, add: Caution Signs and Labels - The employer will use caution signa and labels in accordanee with pf'ovislone of standard 1910.93a. 5.2 Where .H says n placed in tightly sealed containers ... ,n remove the word "tightly." 6.7 I am not familar with the word "swarf. 11 It is not in my dictionary. 7.2 Reword this section to remove possible hint that smoking while working is the problem. Suggest: It is well documented that smoking is injurious to your health. The ill effects of smoking may be accentuated for those working where asbestos dust may be encountered. Smoking should be avoided! The forgoing are my comments and not necessarily those of the Committee. I phofted them to you simply to give you a quick turn-around. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE GvDI"-J~ EWD/erc Cc- Asbestos Study Cor1111ittee E. W. Dr i slane Executive Director FMSI 03156 PltiCTIQN MATERIALS STAliDARDS INSTITUTE, INC., E-210 ROUTE #4, PARAMUS, N.J. 07652 September 23, 1974 TO: Asbestos Study Committee SUBJECT: AIA/NA Recommended Revisions to OSHA Asbestos Standard. In August 1974 we distributed to Committee Members a copy of the AIA/NA recommendations for revisions to the OSHA Asbestos Standard. We asked for comments concerning these recommendations. Based on comments from Messrs. t-Jeaver and Wagner, I drafted a letter to AIA/NA. You Chairman reviewed the content of this letter which is being sent to AIA/NA. A copy is attached. The foregoing is for your information. EWD/lmc Enc. E. t-1. Drislane Executive Director FMSI 03157 TILI:J'HONIE ( 20 I) 8411-0440 . FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. September 23, 1974 Ur. R. H. Uereness Asbestos Information Association/NA 1660 L Street, ~1 Washington, D.C. 20036 Subject: Recommended Revisions to OSHA Asbestos Standard Dear Bob: The committee members within the Friction Materials Standards Institute responsible for monitoring asbestos regulations have reviewed your Association's recommended revisions and suggested wotk practices for the OSHA Asbestos Standard. An overall comment is that your proposal is well prepared and that it represents a realistic approach which if accepted will safeguard the health of employees who work in the manufacture of asbestosbearing friction materials. There is. however. one item on which committee members have expressed concern, and that is the recommendation to add a new section (d) (1) (vi): "(vi) Where respirators are permitted under subdivision (iv) of this subparagraph, their use shall be subject to the following limitations: 1. Respirator shall not be worn for more than 60 minutes in any 8-hour shift. 2. Respirator shall not be worn for more than 30 minutes in any hour in the 8-hour shift. 3. Exposures do not exceed 10 times the permissible limits and protection can be achieved by use of an air purifying respirator." It is felt that addition of this sub-paragraph vi is unnecessary, and that addition of sub-paragraph iv is sufficient. In addition, it is felt that the limitations indicated by suggested sub-paragraph vi may be confused with exceptions permitted by existing sub-paragraphs i, ii, iii and iv. Your Association's consideration of these comments will be appreciated. EWD/lmc Sincerely, E. W. Drislane FMSI 03158 MOLDED MATI!RIALS COMPANY Division of Carlisle Corporation P.O. Box P, Gillis Avenue Ridgway, Pennsylvania 15853 (814) 773-3187 August 20, 1974 Mr. E. W. Drislane, Executive Director Friction Materials Standards Institute, Inc. Bergen Mall Office Center E-210 Route 4 Paramus, New Jersey 07652 Dear Ed: The papers which you circulated under date of August 8, 1974 relating to the revision of O.S.H.A. Standards on "Exposure to Asbestos Dust" were carefully studied here. I immediately called our Chairman, Ike Weaver, and expressed my displeasure with the recommendation limiting the use of respirators to 60 minutes in any 8 hour shift, and 30 minutes in an hour. This is recommended as an additional section under (d) (1) (vi) which I feel would best be left as is. The entire proposal is well prepared and represents a realistic approach which will safeguard the health of employees. Yours very truly, MOLDED MATERIALS COMPANY DIVISION OF CARLISLE CORPORATION HHW:pj cc: Mr. Isaac H. Weaver Raybestos-Manhattan, Inc. Manheim, Pennsylvania 17545 Mr. E. R. Zacharias H. H. Wagner Industrial Relations FMS\ 03159 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 August 15, 1974 To: Asbestos Study Committee Subject: AlA Recommendations for Revision of OSHA Standard "Exposure to Asbestos Dust" On Augsut S, 1974, we forwarded several papers applicable to asbe~tos problems. The first paper was AlA's recommendations for revision of the O~YA Standard on 11 Exposure to Asbestos IAlst". This particular paper took the 1910,93a Asbesto~ standard by paragraph showirg recommended changes and thf;l reaoons therefor. Also included were suggeded work practices in the handling of e.sbostos. Would you please review lha3o proposed revisions and additions. Please also circulate tht111l to th0~'1 in your organization responsible for a.sbestos crmtrol. We would V".li"Y mur;h like wrihen comments and criticism of these proposals. Tneno would be paesed on to those at AlA who are dealing with OSHA. EWD/erc Enclcsurc:>: E W. Drislane Executive Director FMSI 03160 FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE 4, PARAMUS, N.J. 07652 June 19, 1974 To: Asbestos Study Committee Subject: Minutes of Meeting of June 14, 1974 I am forwarding minutes of the meeting of the Committee held on June 14, 1974. These are UNCONFIRMED MINUTES, and must be reviewed by your Chairman and Legal Counsel. In addition, l am enclosing with Mr. Dunderdale's and Mr. Feierabend's copies 'the following literature that was distributed at the Meeting: 1. American National Standard- "Fundal}'lentals Governing The Design and Operation of Local ExhauatSystems For The Control of Asbestos-Containing Dusts". TM2. 11 Analysis of Foamaerol Foam and its Comparative Efficiency as a Dust Collector". EWD/erc Enclosure E. W. Drislane Executive Director FMSI 03161 :;.c. lr. I. M. W.ver ~at=~t;l;.!tne . . .,.. Pa. #17S45 SllbJect Report of Aabeatoa stuay a-ttt.. hiran Dear lbt I .-rUer talked with J*t about a report f'w the Jtme "-tina You indioated that you WOtilhf not be able to atttend our ~ UeeU,.. Abet t stated I would aive you an ovtl iM or actions t.alcen within the lnatltwte _,...,,.,. Aahatoe durlna the 197,...74 FY (July 1, 19'7)'""- .30, 19'74). Enaloeed ia a list of uHoaa durl"l the 19'7,...74 flaaal year, listed in date ordw. I'd ""Y _.., aprweo&ate a brief C..lttM hi...,_ report soon aa you're able. tt WOtlld be fl08t helpful if I oovld have it by the ~ 14th ...tl"' Slnoerely, FRfattON MATIIUILS STANDMJ)S tNSTITUT E. I. Dr lelane Exeewtive Director FMSl 03162 - 1- 7/73 8/73 9/73 10/73 11/73 12/73 1/74 5/74 Questionnaire on Plant Operations Seminar Sent to Committee Members information on pelletizing asbestoscontaining dust. Sent to Committee Members information concerning Dr. Selikoff's presentation indicating that the 1976 2-fibers/cc exposure may be too high. Sent to Committee Members data concerning: (1) The Lyon, France meeting in 10/72 (2) Asbestos bag opening machinery by Fairmont Engineering. Advisied Membership of Sverdrup and Pdrcel study for EPA on waste water effluents from friction materials plants. Sent Committee Members additional articles on asbestos and brake 1inings. Advised Membership of Arthur D. Little study for EPA on economic impact of 1972 Federal Water Pollution Control Amendments. Advised Committee Members of change of address of Asbestos Information Association to Washington, D.C., and that Robert Mereness is the new Executive Director. Advised Committee Members of r.esultsof questionnaire concerning the suggested Plant Operations Questionnaire. Advised Membership that the suggested Plant Operations Seminar will not be hefd. (Lack of sufficient interest). Sent Committee Members considerable literature on asbestos as it relates to occupational health. Sent Committee Members copy of letter from R. Mereness of Asbestos Information Association relative to FMSI being listed as an organization affiliated with AlA. Attended meeting of American Industrial Hygiene Conference relative to paperson asbestos and friction materials. FMSI 03163 FRICTION MATERIALS STANDARDS INSTITUTE, IHC. E-210 ROUTE 1#4, PARAMUS, N.J. 07652 May 3, 1974 TO: Asbestos Study Committee SUBJECT: Activities concerning asbestos in the occupational area I've attached a copy of a letter from your Chairman, Mr. t. H. Weaver, con- cerning the American Industrial Hygiene Conference to be held in Miard. Beach on ~y 16-17, 1974. There are three papers to be delivered which should be of interest to the friction materials iDdoBtry: Schedule Thursday May 16, 1974 9:40 A.M. Authors Diberardinis, L. Burgess, W. A. Lynch, J. J. Title "Exposure of Turnpike Toll Booth Operators to Automobile Dust11 Friday May 17, 1974 11:20 A.H. Cowie, J. E. Rajhans, G. s. Moore, D. E. ''A Comparative Review of Dust Conditiona and Clinical Obeexvations of Two Brake Lining Manufacturing Industries 11 Friday May 17, 1974 11:40 A.M. Robl, A. N. Anderson, H. Nicholson, W. J. Langer, A. M. "Asbestos Exposure During Brake LinJ.ng Maintenance and Repair" I plan to attend these presentations and hope to secure copies of the papers while there. (I will be in Miami Beach for another conference at that time.) On another subject, 1-lr. Weaver and 1 have discussed the possibility of another com&idttee meeting. Our last meeting was on June 1, 1973. Your Otairman and I do not believe in calling for a meeting unless there are itelll of substance on the agenda. Currently, Ur. Weaver and others in the Industry are preparing a draft to send to OSHA concerning work practice standards for various asbestos p,-oducts. As asbestos containing friction materials will be one of the products, a committee meeting may be called relative to this subject. As I rec~ve wure information, I will let you know. EWD/lmc Enc. E. w. Drislane Executive Director FMSI 03164 April 24, 1974 Mr. E. W. Drislane Friction Haterials Standards Institute E. 210 Route #4 Paramus, N.J. 07652 I~o~,.O~~o~~fi.R ENVIRONMENTAL CONTROL N w !'1 Ul ::::! (TI G') (TI r Ul -i ::0 (TI (TI :i ~ z)> :I: (TI i 1l zz(TI Subject: American Industrial Hygiene Conference Program Dear Ed: There are three papers to be presented at the American Industrial Hygiene Conference that will be of particular interest to FMSI members. The first will be presented at 9.40 A.H. Thursday, May 16, entitled, "Exposure of Turnpike Toll Booth Operators to Automobile Dust". It is by L. Diberardinis, W. A. Burgess, and J. J. ~ch of the Harvard School of Public Health. The other t'WO papers will be presented 11.20 and 11.40 A.M. Friday, May 17. The first is entitled, "A eomparative Review of Dust Conditions and Clinical Observations of Two Brake Lining Manufacturing Industries" by J. E. Cowle, G. S. Rajhans, and D. E. Moore of the Ontario Ministry of Health. The second is entitled, 11 Asbestos Exposure During Brake Lining Maintenance and Repair11 by A. N. Rohl, H. Anderson, W. J. Nicholson, and A. M. Langer of Mt. Sinai School of Medicine, New York. You may wish to alert FMSI people who might be interested in attending one or more of these sessions at the American Industrial Hygiene Conference. The conference is to be held at the Fontainebleau Hotel, Miami Beach. Registration for one day at the conference costs $11.00. Sincerely, / r: J.' ' w~/k;f,r'7 t!o_.;: w FMSI 03165 ASfiF~'. )i, ': Although only one-ccmimittee meeting was held during the past fiscal year. Asbestos Study Committee members pursued a number of items of interest and concern to ~181 member companies throughout the year. Members maintained phone contact with one another and with the Executive Director with regard to numerous asbestos/health and environ- mentally related subjects of potential importance to the friction . material industry. Recommendations for compliance with OSHA labeling requirements were frequently discussed. These requirements have assumed a greater importance in view of the current intense interest in product safety legislation and recent judgements in which manufacturers' culpability has been challenged successfully in the courts in cases involving adverse health effects from expooure to hazards inherent in products where no warning of e~stence of the hazard was given. All manufacturers and markete~, of asbestos-containing friction materials should pay heed to the precedents that have been set establishing manufacturers' responsibility for informing customers of potential health or safety problems' that may exist in connection with the use or disposal of their products. Labeling friction materials in accordance with the OSHA Asbestos Standard would appear to be a minimU~ essential measure. Other major items investigated and revi~~ed during the year were as follows: !' I. PMSI membersi~te~~;t:-in plant_op.erations seminar on safety, health and compliance with Federal regulations. Survey indicated insufficient interest to justify suCh :, !. rl. Otl [.11 '.lfA '.8eminar'l.illbut (the,Ls.ulij.Ct <may;;fui reccins.i.clerel;kl:atelf.; cal i:::.:_ r ., A-::~~i.-~'-.3 1:03 ")tt~,:;.v Cof"F.-i tt!~.l r;1;s:.::b~:-:-s p~.rr::nJ.r-~d ;3, rH.r~.~~!)~:~~ of 1 tc:-:.9 of .; c\:.: ,:11:: .cd)r o::rS.eliko:li1 ir:attacki:.on the:..2;fibre/.c:el.WOU tplace yc~'c!. 1!enD,,~:. v: ::exp.cisure ~:level cand rthe ..(!ofltroversy. beween Dl!s ~~ Sellkoff T~;t.:,_,::>~ and.H,..,!C.<L-ewinsolm Of! Turner,& l~ewaU:Ltidarli.!: r>::'" :~11". :Lrc.~- "~,c:HI-. "rMeChanized bag opening systems. r~~ -:::IV:!o'l'tDPro"iecl we.a~e disposal.sya:teJnS:ofoJI ilaj)or. r.Sd\!Ct.ion ..... . f. _.,,,.,,_,": .1. .Y and :elimination saf ;fugi.tive..::dust ,-probJ.ems,., l a :~r; r; ;::c : .Lr..:: ..-;:.. :...... ~.- .1.:: \:::~-:: .. -~~:: t~ _;r;>~-r.,I 1.:1i_.:-.~-~..:: ild:t.rc;.~t j:~. LJl.od.."':".t. -~~cJt0t.:; 1,.,.: :V ... .Asbestos ~Ind~tryr:studies~ by,:.!Sverdrup~and:J~ar:Cel:;tl.i: :1}E~y ":.:: . ... ATthw; .:J)'. ~Little ~1Uid:;itlie; Illinoistlnstitute:.o.n:(..iv:Lr"~. ~ '::, ;.,. TeehnologyResearch.;Ins:ti.tute:on behalf>of.DAL pr;:-:.:!'<...l:t.s ::-- -=l_;~- 1 ~vt~ be<:_, :;.:~~ .. ~:t.2~-1.~f!:::Ii-,-~ 1.:=.;-~tt.~~t"t~-:::~~:.u:-er~\ ' ':. ;.:. ~---~ "'' r;._._. ;-:r;-~_p::. :..;2 ;~;._-,1 :.--1.!~-j ;.:~- tPw~n.lt~! GT' :.::1.~:-i._:\y- ;hobably :the most .important asbea.~os: health related :me~ting ,that d,c~.r .occurred during !.the past..year was :the Iuternatibnal Labor ;,Organiliation Jieeting of: Experts.. on S~f?H:Use tof Asbestos.;::cheld:_i.n Geneva;,;.Swi:tzerland. December 11-18, 1973. Approximately thirty representatives of labor. industry:, ;gav..ernment :and. ~the tnedit:al, .hatern1ty .p~rticivated: :~ab.e: main :subjects were: (A) Pathological Effects of Exposure. (B) Prevention of Risks Due to Exposure. and (C) ..Possibilities of International : ...,. . ,.. . :: ~ . . .~~~~!- Regulations. FMSI 03166  <t - 2- As far as I know, the final report of the ILO meeting has not been published, but the following highlights excerpted from the draft report should be of concern to all asbestos products manufacturers: ( 1) There is growing evidence of severe health risks follm~ing exposure to asbestos dust. ( 2) All types of asbestos fibre are associated with mesothelioma. ( 3) The proportion of asbestos workers who may be expected to develop mesotheliomas cannot be determined precisely at present. ( 4) There is nQ simple pattern of risk related to type of job, type of fibre, past dust exposure or other factors. ( 5) Substitutes should be used whereverpessible. ( 6) Whatever standards of maximum dust. ~xposure may be recommended as targets, the ultimate aim should always be minimum amount of occupational exposure. ( 7) The membrane sampling method should be adopted as an international reference method for comparison and correlation of environmental data concerning asbestos dust concentrations. ( 8) The 2 fibres/ml s~andard should be regarded as an interim target concentration related to fibrogenic effects and not to carcinogenic effects, for which no standards exist at the present time. ( 9) Wherever technically possible, processes or operations should be designed or redesigned so that dust exposure is reduced to the recommended target concentration or lower. (10) Wherever possible, mechanical means should be devised to avoid handling involving personal exposure. (11) Filtered air should not be readmitted to the work place, unless asbestos dust levels are not more than one tenth the recommended target concentration for the working environment. (12) Use of respiratory protective equipment and protective clothing should be limited to the interim period required to achieve dust control by technical measures. (13) Respirators should be individually fitted, and the duration of continuous use should be limited. FMSI 03167 - ::s- (14) On no account should dust be removed by compressed air or brushing. Cleaning should be carried out by vacuum cleaning equipment which has been approved by c.ompetent authority for use with asbestos. (15) Bags of asbestos fibre and asbestos waste material should be marked with an internationally recognizable symbol indicating that hooks should not be used. Those concerned tdth transportation of asbestos fibre and waste should be warned of the need to observe high standards of hygiene. (16) Workers suffering from respiratory disease or insufficiency should not be exposed to additional asbestos exposure. (17) l1edical supervision must be continued after exposure ceases. (18) Strict confidentiality of medical.,records should be observed, and personal files should be kept under the seal of medical secrecy. (19) Competent authorities must be informed of all work involving exposure to asbestos. (20) There should be a full understanding of the nature of the asbestos hazard by all persons concerned, both inside and outside asbestos processing facilities. Vinyl chloride and other chemical carcinogens appear to have replaced asbestos as far as noriety in the media is concerned for the present. Although government agencies. onv:lronmentalists, and occupational health zealots now appear to be directing their attentions elsewhere, we should not permit ourselves to be lulled into a false sense of security. Asbestos has been referred to by more than one medical researcher as the "next carcinogen", presumably for which much stricter controls than now exist must be devised and implemented. Asbestos still is very much under attack in many quarters, and its health effects are being very intensively investigated. There appeara to be no chance the 2 fibres/ml TLV will be increased, and strong pressure will be exerted by many to reduce this figure. Hore restrictive controls in the form of specific work practices and waste disposal regulations are almost certain to evolve later this year after OSI!A and EPA finish their deliberations regarding revisions to existing standards. The Asbestos Study Committee will attempt to keep abreast of information concerning this and other developments in asbestos/health and related fields throughout the ensuing year. Respectfully submitted, I. H. Weaver, Chairman FMSI 03168