Document zzzRB2Vygv0ZkqrQLjLYdKNM0
FILE NAME: Friction Materials Standards Institute (FMS)
DATE: 1971
DOC#: FMS010
DOCUMENT DESCRIPTION: Comments by the British Friction Materials Industry on Proposed IL Asbestos Ban with Cover Letter from FMSI
B ritish P r ic t io n M a t e r ia l s C ouncil
AKK, OOKC * C O . A ew w r**rs
81*1*4 9411
99, Aldwych, Lo n d o n , W C 2B 4JY
3o2/m/3FMC
The S e c r e ta r y , fr ic tio n M aterials Standards J70 L exin gton Avenue,
Nev Turk, N .Y .110 1 7 i .S.A.
In stitu te,
In c .,
26th November, 1971.
Dear S i r ,
We have b eea asked by our members in th e B r it is h f r i c t i o a m a te r ia ls in d u stry in th e TJ.K. to. put t h e i r view s to you on th e proposed. I l l i n o i s S ta te R e g u la tio n s con cern in g a s b e s to s and a sb e sto s p ro d u cts. We e n c lo s e herew ith t h e ir comments on th e f r i c t i o n m a te r ia l a sp e c t o f th e s e d r a ft R egulations.
Ve have no doubt th a t th e American l in in g m anufacturers w i l l be making s tr o n g r e p r e s e n ta tio n s t o th e I l l i n o i s a u t h o r it ie s fo r amendmentsto th e p r o p o sa ls and perhaps you could l e t us know t h e ir comments. We s h a ll a ls o be g r a t e f u l i f you co u ld make our view s known as s e t o u t in th is enclosure.
Tours f a it h f u lly ,
S e c r e ta r ie s
one.
4
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The 3 r i t i s h f r i c t i o n m a te r ia ls in d u stry v iew s with deep concern th e roposed ban on th e use o f asb estos in brake lin in g s by th e S ta te o f U in o is.
I t i s n ot aware o f any a e c ic a l evidence th a t could p o s s ib ly j u s t i f y such l e g i s l a t i o n On th e contrary i t would have the e f f e c t o f withdrawing from the market p rod u cts th a t were used to promote road s a f e t y , w ithout producing- any s i g n i f i c a n t improvement in th e le v e ls o f urban atm ospheric p o llu t io n . I t would exp ect any o f th e known a lt e r n a t iv e s to a s b e s to s to produce g en era l p a r tic u la te p o llu tio n of a measurable amount.
1. Whatever m a ter ia ls are used for brake lin in g s the current s ta te of the art i s such th at the action, o f braking w ill generate products of wear. The asb esto s content o f conventional brake lin in g s i s alm ost e n t ir e ly converted by the a c tio n of braking in to f o r s t e r it e or oth er amorphous, in e r t m a teria ls which are no lo n g er a s b e s to s . On th e o th er hand, i f n o n -a sb e sto s a lte r n a tiv e s are used ( e . g . iron powder, sin te r e d m etal, ceram ics, s t e e l wool e t c .,) the r e s u ltin g wear produ cts w i l l be rele a sed unchanged.
2 . Measurements have been made of th e amount o f fr e e a s b e s to s f ib r e l e f t in brake l i n i n g d u s t. I t is an in s ig n if ic a n t p r o p o r tio n o f what is in any c a se a minute amount o f t o t a l d u s t .
The amount o f fr e e a s b e sto s fib r e th a t has been found in brake l i n i n g d u st from v e h ic le s , i s about 1io o f the t o t a l p ro d u cts o f w ear. ( l ) . Indeed e stim a te s vary down to I0 ~ 9 g /g , i . e . f o r each gramme o f wear products only *[0-9 grammes of fr e e a s b e s t o s may may rem ain.
3. We assume t h a t the r i s k o f c o n tr a c tin g m eso th elio ca i s th e p r in c ip a l c a u se o f environm ental concern - there i s c l s a r l y no p o s s i b i l i t y w hatever as a r e s u lt o f v e h ic le b ra k in g , o f a community r is k o f a s b e s to s is or lung cancer, which are s o le ly o ccu p atio n a l r is k s . For tech n ica l reasons only ch ry so tile asb estos i s used in th e m anufacture o f brake lin in g s and d is c brake p a d s. T h is is-. not the type o f a sb esto s with which mesothelioma has been mainly a sso c ia te d .
k. Measurements o f c h r y s o t ile a s b e sto s in the ambient a ir in an in d u s t r ia l c e n tr e in th e United Kingdom have shown th a t th e l e v e l must be l e s s than 10"? g/o^ because of the lim ita tio n s o f th e method u se d . T his means th at th ey must be a thousand tim es lo v e r than th e B r i t i s h Government a ccep ta b le le v e l for o c c u p a tio n a l ex p o su re. - C urrent in v e s t ig a t io n s u s in g a more s e n s i t i v e method in d ic a te l e v e l s of 10"^ to 10"10 g/c-5, i . e . 2 or 3 ord ers low er s t ill. (2).
Brake lin in g wear cannot th erefore be a serious source o f atm ospheric p o llu tio n .
3. In one o f th e la r g e s t brake t e s t in g la b o ra to ries in tn e w orld, h ou sin g cany dynamometers engaged 2^+ hours a day in w earing away f r i c t i o n m a t e r ia ls , the average m onthly a sb esto s co u n t i_s C.2 f ib r e s / c c , a 'te n th o f the B r it is h Government' s o c cu p a tio n a l standard.
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j 34 N0VEM3.
1 1071
03
Chrysotile Asbestos in Urban Air,
T h e industrial use of chrysolite asbestos is increasing and tha question of whether its concentration in urban air constitutes a hazard has been raised. But measurements o f asbestos in air near asbestos factories have proved negative 'with present analytical method, so under the sponsorship o f the Asoestosis Research Council sve are developing a more sensitive technique. This article is a preliminary account of the estimation of chrysoTile near a large asbestos textile factory "at RochdaJc,
Lancashire. There are several uncertainties a the technique; so we were,expecting to obtain only an order of magnitude v
estimate. Nevertheless this would have been an im p o rtan t. . figure to have because of the lack of data on the amount of.* asbestos in air. As it happened, wc were only able to determine an upper limit for the chrysotile concentration which turned out to be three orders of magnitude lower than the threshold vaJue for occupational exposure set by asbestos regulations. Obviously even more sensitive techniques are required a n d are now being developed.
NVe used an X-ray diffraction technique based on the measure- ment of the integrated area under the (002) jwaJe of chrysotile..The equipment, which consisted o f a Phillips 2010 generator, * a vertical goniometer with a step scanning aranchment;-and r. proportional counter with pulse height discrimination, could be reliably calibrated down to 10 pg of chrysotile compared with the 1 to 10 mg range reported by (Treble1, ard-vras crocs- checked by estimating the magnesium content o f the calibration samples by atomic absorption spectroscopy. Sampling involved the collection of airborne solids from J,000 ns* (lO4 I.)'o f air . by an electrostatic device (H. Litton Systems Inc.) in which upto 10,0001. m in*' are drawn through a 20 kV corona discharge. . Particles in the air are electrostatically precipitated oato-a plaje .-
and concentrated into ~ 100 mL o f liquid. ^
V."
The collection efficiency depends on the srzo-distribution of
the particles and the sampling rate, but the size distribution o f'
chrysotile in the atmosphere is not known. . Therefore- -e
estimated the collection efficiency indirectly 6 y running the .. sampler in part of the asbestos factory where &low concentre- tior* of asbestos is known to occur CFtg. 1) and we found the collection efficiency to be almost 100% when the air is sampled ;
at about 2,000 I. min*1, dropping to betweea 25 and 50% at
ilia rite of 10.000 1. n i . f \ depending on the actual sire dis tribution present. .As we were aiming at only ah order o f magni- -.
94
2ocr
2 JOiL o Fig. 1 Observed amounts of chrysotile in ijX C I. of factory air, sampled at different rates.
O
NATURE VOL 234 NOVEMBER \ 2 *3
Thl* 1 Vearner Conditions during Sampling
Date (1970) Site
April 22
1
April 24 .
1
April 27
1
April 29
1
May 6
1
May 13
1
May 2S
3
May 2S
3
May 30
4
May 30
A
June 3
2
June 10
2
June 10
2
October 23 1
October 23
I
October 23
1
October 2S
1
October 28
1
October 28
1
Wind
SW moderate SW slight NE moderate Sw moderate S strong N fresh W light W light W light. w light SW liht SW slight SW slight W moderate W moderate W moderate N light N light N light
Weather
Broken doud
Ground haze Ground haze Ground haze Ground haze Ground haze Overcast, dull Overcast, dull ' Overcast.dull Overast. dull Overcast Heat hxze Heat haze broken cloud : Broken doud Broken cloud Brokea cloud Broken cloud Brakes doud.
tude assessment of asbestos in urban air, we were prepared to
accept this uncertainty in the collection efficiency. The map (Fig. 2) and Table 1 show the location o f the sampl
ing sites and the conditions in w hich the samples were obtained. The factory is i" r hollow, m d v tm p iiij sir*. No. 2 is at the same height as the roof of the filter gallery, which is the chief air outlet from the factory. Sampling site No. 1 is about 30 foot higher than site No. 2. Sites 3 and 4 were in the gardens o f houses, site 3 being about 5 ton upwind of the factory and site 4 being about 300 tn downwind.
AU the diffraction traces (for example. Fig. 3) contained strong lines of kaolinite and quartz, probably from the local soil, which made the assessment of chrysotile difficult because the broad
(001) line of kaolinite (7.12 A) is dose to the m ajor (002) lioe o f chrysotile (7.36 A). Fortunately chrysotile is. easily decom
posed by boiling in 1 N hydrochloric a d d whereas kaolinite is unaffected, so. it should be possible to measure the amount o f chrysotile present by subjecting the cample* to a d d leaching and measuring the corresponding reduction of the intensity o f the composite X-ray band. The fact that tilts process led to no reductions in band intensity for any o f the m p le s indicated that the amount of.chiysotile present was below our detecuon
limit. We ought to have been able to detect 10 uS of chrysotile by
itself, but dearly the presence o f kaolinite may have reduced
the sensitivity. But the addition of 100 pg orchrysotile to o collected samples could easily be detected, so we can say tk our samples collected from 1.000 mJ of air contained less tfc 100 jig of chrysotile--in other words, there was less than 0.1 of chrysotile per m~ o f air. The threshold limit forcccupauor
Fig. 3 X-ray diffraction panent from a typical dust sample nea the Rochdale factory.
A more sensitive method for estimating chrysotile is requir
and we are developing a technique based cn electron mic scopy. Preliminary examinations under the electron mic
scope of samples collected by the Litton sampler indicate t
the actual chrysotile level may be a further three orders magnitude below the X-ray detection limit (th at is, a b
0.1 ng). The samples have so far beer, collected in the close vicii
of the Rochdale factory. It is now proposed to sample ai'.
certain representative urban and rural locations in U K ;
estimate their chrysotile content.
A L_ Rj o o . k.c
D. V. Badami
Turner Brothers Asbestos Co. Lid,
PO B ox 40, riocr.dalc, Lancashire
deceived April IS; revised September 22, 1971.
Crable. J. V., Amer. hid. Hyr. Assoc. J.. 27, 293 (1966). Standardsfor Asbestos Bust Concrntraticn for Use * tth the Asbt
1CX O T#(/i m i m i t n t a A* 1 ' , n u Cf a ^ /tri* r\ *
September 2 3 , 1971
Dr. U. G. Jkcko Sendx Research Labrate'ies Sendix Center Southfield, Uichigan #3075
Dear T j k e J
Thile you were at the meeting of the Asbestos Study Committee la st week, you asked for some information about the Friction f/aterials Standards Institute* 1 believe you were trying to understand the basic servicaa that the in stitu te performs with out getting into the detail as spelled out in the Constitution and By-Laws* Hcwever to be sp ec ific, i as enclosing a copy of the Constitution and 8y-Laws*.
The Friction Materials Standards Institute, is made up of most o f the United States manufacturers of brake linings and clutch facings* One of i t s earliest services was ©righted numbering system for the brake linings and clutch facings. In th is way i f a custcr-.-er were ordering a set of brake linings to fit a 1963 Chevrolet, he would
check our book end select #2065* for the fronts end 2006* for the rears. L'osi brake
lining manufacturers would provide th is lining with the ? 2065* and #2C06* master. The various brake lining manufacturers cake th is lining to the dimensions spelled cut for original equipment purposes from information we furnishad them. Se s o lic it and compile data on a ll new brake lining and clutch facing releases and we publish a book every other year, with supplements in the in-between year, which keeps the field up to date on the brake lin in g s end clutch facings used on the cars and trucks they w ill be . servicing. Further, we publish bulletins about 'six or eight t io e s a year to bring the members up to dat9 cn any changes that are happening, when they happen.
Because of the cult ip H city o f brake shoes and tha problems in determining which shoe belongs-cn which vehicle^ we also prepare a brake shoe identification catalog. The shoe assignments which wa give aro used by most manufacturers to describe the lining shoe package which theVdistributo in the after market.
All members of the Institute are allowed to use ths F. S. I. numbering system which is copyrighted. Further, they can authorize their customers to usa th F..-.S. I. numbering system in their catalogs and on their price cheats. *s an example o f the type of work the F.L'.S. I. is doing currently in th is area, we are vjorking cn a brake block ident i f icat ion book which would allow people in tha fla ld to identify the r.U .S .l. ixsber for the block by making certain basic measurements* As you w ill note, our services are oriented to the replacement market.
Brgk 3er form nee Stud/ Ccm ittee
embers of the Institute ever the past ten years ware being deluged with State le g is lation in tha automotive safety area which was then followed by tha Federal Government legislation in 1966 setting up under tha Department of Transportt ion, v/hat is now the
's
Dr.Jacko Sendix Research Laboratories
--2 -
September 23 1971
National Highway T raffic Safety Adainstration --N.H.T.S.A. The Friction Materials
Standards Institute organized a Cccnittee to help give tha various safety acminstra--
tors gui defies so that reasonable regulations would be issued, Shen regulations
establishing brake lining certification te sts were S9t up by such States aa New York, Pennsylvania, Massachusetts and others, the Friction 'Jaterials Standards Institute worked with the administrators in establishing requirements During various hearings in Cashing-ton for the M.H.T.S.A, on brake systea safety regulations, the Friction
Materials Standards Institute would review the proposed standards, prepare te s ts and cocaoile cccsaents on tha proposed standards, ffe s t i l l maintain a close watch cn Sashingtcn and the various States as regards legislation and regulations concerning brake linings. To th is date, clutch facings have not been ranch o f an itara as regards automotive safaty.
Asbestos Study Committee
This particular Cacm ittee, as you are stta re, i s newly foraed w ith i t s obvious emphasis on a sb esto s. It may take a somewhat s i n i l a r posture a s the Brake Performance Study Couariltee and 1 ) disaeulnate information to the msnbers. and ( 2 ) preparer.- formal ccctaon ts to tha va rio u s environciental agen cies where they may be drawing up regulations that concarn a sb esto s in brake lin ings or clutch fa cin g s.
Within tho In stitu te we can take any reasonable steps that w ill further the friction
materials industry in line with the Constitution and By-Laws. Among other things, the Institute has organized tha accumulation of information on h istorical sales by the' members of fric tio n a rtic les - brake blocks, disc brake lin in gs, other brake linings and clutch facings. This information is submitted to a Certified Public Accountant
' who reviews tho original input from tha members and prepares the sunrazries o f to ta ls. This information iesfin a l form is confidential and is returned to the centers.
As I do not fcaliove you are interested in the Institute concerning cur cataicg in formation,,! am not sending any of th is type catau Should you wish a copy of cur Data Book and Shoo Catalog, ploass le t me know, ifhen 1 have received an approved copy of the minyies o f our recent meeting, I wiLl send you a copy. Sr. Spurgeon of
course will be receiving a copy nhen the minutes are distributed.
Sincerely,
EfDrislane/src Enc:
Executive Secretary
