Learning Advisor MCO Learning Advisor AO Learning Advisor Logistics Learning Advisor PEl Engineering Lead PEl Manager PEl R&M Team Lead CME PEl PEl Inspector Safety Instrumented Systems Focal Point Contracting & Procurement Manager Site Assurance Focal Point Casual Learning/ LFI Coordinator Sr.

To: Hupp, Sydney[hupp.sydney@epa.gov] Cc: Jay Vroom[JVroom@croplifeamerica.org] From: Mary Jo Tomalewski Sent: Thur 3/30/2017 3:21:45 PM Subject: FINAL Meeting Agenda and Materials Pruitt Meeting Materials.pdf Sydney, We have refined our proposed topics for today's CEO Council meeting with the administrator.

FILE NAME Brakes BRK DATE 2017 DOC BRK257 DOCUMENT DESCRIPTION Journal Article - The Brake Industry's Impact on Asbestos Regulation in the 1970s PUBLIC H_A_H HENAND HENAND NOW Ain't Necessarily So The Brake Industry's Impact on Asbestos Regulation in the 1970s David Rosner PhD MPH and Gerald Markowitz PhD Ys ODORING ADA NO foe Pestate Pestate Pestate asbestos a #ledSimiore #ledSimiore #ledSimiore la koku^Agencies Agencies Kedil 68 get a dere dere fl- - - KES Ac h OMES CE every every every every every aC 22 ae LOOT CLS WS Se Leah La os 4 5 * Get the err oT Dap tor ean 94rton 94rton 94rton McS McS McS McS McS McS SET at Sys e soot 0409fleur 0409fleur 0409fleur smp 2 OR KO) OEY ane ah ta cre Co ft TE ABC SS << A >>>>> >>>>> Pec Heach P wet or anval anval p20 p20 2017 < plecaMKOY plecaMKOY plecaMKOY plecaMKOY plecaMKOY plecaMKOY AN OC > C A 120 / 70 At the end of 2016 the US At Protection Agency EPA proposed asbestos the cause of fibrotic lung disease and cancer as one of the 10 industrial chemicals to be evaluated under the newly revised Toxic Substances Control Act Under the new act a risk evaluation ofasbestos is to be completed within three years and if asbestos is found to be an unreasonable risk to humans and the envirominent the EPA is required to mitigate that risk possibly through a 2 ban within two more years By 1970 asbestos was used in some 3000 products such as roof shingles floor tiles house siding ironing boards and particularly in brakes among other consumer items Today this carcinogenic material is banned in the United States in a few products including corrugated paper and flooring felt but it is still legal in brakes and clutches and a host of construction and Industrial materials such as vinyl floor tile 100fing materials and coment pipe among others Consequently it in mullions of honics gas stations and repair shops across the country Historians have documented one major reason for the delay in banning this known carcinogen private industry trade groups stifled earlier efforts 1 at regulation Here we look at the specific efforts of one such group the Fiction Materials Standards Institute FMSI to forestall the regulation of asbestos used in brakes and clutches one ofthe oldest sources of asbestos exposure We examine the industry's reaction to the newly created Occupational Safety and Health Administration's OSHA dramatic reduction ofthe Permissible Exposure Limit PEL in the early 1970s There is literature that addresses the current medical and epidemiological evidence ofthe 5 dangers from asbestos brakes Heie however using internal corporate documents most of which have not been previously reviewed but are now available " at toxicdocs org we explore what the industry understood about the dangers to mechanics from asbestos The concern about asbestos in brakes reflects the broader acknowledgment of the impact of industrial toxins on workers and consumers in the 20th century In the early 1930s ERA Merewether identified the dust produced by the sawing grinding and turning in the diy state of articles composed wholly or partly of asbestos such as motor car brake and clutch linings when mhaled as a cause of asbestosIS the fibrotic condition that slowly > strangles affected workers Merewether's Merewether's early observation that any material that contained asbestos could prove to be a hazard was affirmed affirmed in the immediate postwar period as officials noted that asbestos has been incorporated into protective clothing biake linings cements and other forms of insulation and that exposure to asbestos dust caused by the breakdown of the native muneral was also associated with of " cancer the lung By the mid1960s asbestos was associated with asbestosis lung cancer and mesothelioma a cancer of the lining ofthe lung and abdominal cavity leading the British Ford Motor Company to host a conference in 1969 o the possible dangers presented to brake mechanics and those installing or replacing brake 10 linings In 1970 the Occupational Safety and Health Act establishing OSHA and the National Institute of Occupational Safety and 11 Health NIOSwH as passed Almost immediately the FMSI established an Asbestos Study Committee ASC which focused on the possible impact of OSHA regulations on brake and clutch manufacturers Working with the Asbestos e1 Public Health Then and Now Peer Reviewed Rosner and Markowitz AJPH Published online ahead of print July 20 017 PUBLIC LAm 11 NOW NOW Information Association of North America AIA another trade association it sought to forestall any drastic regulation Among the ASC's first acts was to meet with OSHA officials who had issued an emergency PEL of 12 fibers per cubic centimeter in 1971 and a year later reduced it further to 5 fibers per cubic centimeter with an even greater reduction to 2 fibers per cubic centimeter by 1976 mA NOWLEDGING NOWLEDGING DANGER PRIVATELY The FSMI was aware of why OSHA was considering this reductioAnt its meeting in June 1972 the ASC received a report that Rohl and colleagues had presented a paper at meeting of the American Industrial Hygiene Association which was held at Mt Sinai School of Medicine in New York City According to the ASC the paper revealed that the dust concentrations during the blowing off of brakes are in excess of the five fibers per cc cubic centimeter allowance They acknowledged that exposure to asbestos dust was a possibility if not a probability for workers installing and replacing brakes This raised the question for the ASC as to whether the manufacturers under the new OSHA regulations had an obligation to warn workers of dangers they potentially faced to Hence a new rationale for not warning was developed they publically pronounced that asbestos when locked in to fabrics lacquers plastics or other finished products was not a danger as it could not be released into the air In private however the committee members noted that because their products were friction materials there was an inherent danger in the handling by employees of the products with supposedly locked asbestos during drilling grinding inspection and boxing Furthermore there was the potential for the release of asbestos during the handling of the brake lining or clutch facing by the customer even far from the shop floor One member of the ASC suggested that " notification be put boxes brake linings on clutch facings but this was quickly shot down when another member objected because he felt it was another red flag that would bring more harm to the industry than the alleged good that would come from enclosing such notices Despite public assurances that using locked asbestos was safe EW Drislane the executive director of the FMSI wrote to the ASC about an internal survey that revealed the problem that in many cases subsequent operations will be performed grooving diilling and grinding and that these subsequent operations can produce concentrations of asbestos fibers in excess of the current exposure limits Most members of the Committee believed that the OSHA standard was exceeded in many areas such as inspection drilling and grinding where there is not adequate dust collection " machinery ANIN PSSARY PSSARY SO In 1973 Ike Weaver an engineer with the RavbestosManhattan Corporation and chair of the ASC gave a major address to the entire membership that provides a summary of what the industry understood about the dangers of asbestos He informed them HOWARD, 2h My 4 Og ome, wpb Pas Retimsh EP tty, ***** ***** ***** 336 336 VOR 8 ged F Bag t^" *** *** *** mange em ad KA Xe at bf rom sat be " tebe un ERB HO A det Oe yore P42 OSaakas MA // Bee B allay Adthe ayes bas ater < > the Oregeee eage Sf we Str Reo FE ****** ****** ****** af ake OPK S gest 9 er eege maxx maxx gig~ ty > das et see stat wade a xxxxx xxxxx *** Wet Segesta we sSaey seach Segesta Segesta /,, Manville about the recent meeting of the International Agency for Research on Cancer at which the most important item was the incimination of all major types ofasbestos as causal agents of carcinoma particularly particularly " mesothelioma He further warned that since most of us in the FMSI use substantial amounts of chrysotik asbestos in our formulations association of this material with mesothelioma and other types of cancer is of 1121 serious concern For an industriyndustry that identified friction as the primary characteristic ofits products he knew of no way any ofus can be absolutely sure that his friction products regardless of whether they are sold as original equipment or on the replacement market would not result in excessive exposure Look What Makes the Disc Brake Brake From the 1930s on sawing cutting sanding or abrading asbestoscontaining products in any way was identified as a major concern Here we see an asbestos Manvil e disk brake ad from the 1960s with no mention of any potential danger Published online ahead of print July 2017 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now = -- -- PUBLICIDA PUBLICIDA LH NAND NAND NOW ** eS Fear wt aoe fox Qtnaal >> se di form BE y Sy 8 hadt eas ---- S ios Booger BS ohaty ase CBee x / / /, // /, / / /,, /fiR/F /ap ok vix sts sts ey ange INDO ee of ok * Car Gk ade ed awed a ifs ***** ***** hy matty SONI?

To: From: Sent: Subject: Jackson, Ryan[jackson.ryan@epa.gov] Bloomberg BNA Wed 12/6/2017 1:46:10 PM Dec. 06 - EHS State Regulatory Alert EHS State Regulatory Alert December 06, 2017 - Number 233 You can create a report customized by topic, jurisdiction, and date range by using the Regulatory Summaries Report Tool.

Q) Subject: ~ Keywords: EPA Lead Inspector Signature/Date Supervisor Signature/Date 08/11-14/2014 Air RMP Motiva Enterprises Port Arthur Refinery 2100 Houston Avenue I 2555 Savannah Avenue Port Arthur, TX 77641 P. 0.

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, IL 60604-3590 VIA ELECTRONIC MAIL DELIVERY RECEIPT REQUESTED James Hanna, Regional Vice President of Operations - Midwest Region Valicor Environmental Services, LLC jhanna@valicor.com Re: Finding of Violation Valicor Environmental Services, LLC Dayton, Ohio Dear James Hanna: The U.S.

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To: Hupp, Sydney[hupp.sydney@epa.gov] Cc: Jay Vroom[JVroom@croplifeamerica.org] From: Mary Jo Tomalewski Sent: Thur 3/30/2017 3:21:45 PM Subject: FINAL Meeting Agenda and Materials Pruitt Meeting Materials.pdf Sydney, We have refined our proposed topics for today's CEO Council meeting with the administrator.

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