- Standard Number:
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.
September 29, 1995
The Honorable Thad Cochran
United States Senate
188 East Capitol Street
Jackson, Mississippi 39201-2125
Dear Senator Cochran:
Thank you for your letter of April 28, on behalf of your constituent, Mr. James E. Williams, concerning the use of solvent aerosol for controlling exposure to asbestos during automotive brake repair. Mr. Williams does not accept that asbestos dust can be controlled with an aerosol spray. He believes the Occupational Safety and Health Administration (OSHA) should publish work practices to ensure that technicians who opt to use aerosol sprays are protected from asbestos exposure when loosening and removing rusted-in-place brake drums. I apologize for the lateness of this response.
OSHA issued corrections and clarifications for the standards for Occupational Exposure to Asbestos in the Federal Register on June 29. OSHA clarified that if the employer adheres to the work practices for the Spray Can/Solvent Spray System Method that are listed in the proposed standard, then the method is equivalent to the two preferred methods for controlling asbestos exposure during brake and clutch work. The preferred methods are the Negative Pressure Enclosure/High Efficiency Particulate Air (HEPA) Vacuum System Method and the Low Pressure/Wet Cleaning Method.
The required work practices for the Spray Can/Solvent Spray System Method are as follows:
(1) The spray can/solvent system shall be used to first wet the brake and clutch parts. Then, the brake and clutch parts shall be wiped clean with a cloth.
(2) The cloth shall be placed in an impermeable, properly labelled container and then properly disposed of, or the cloth shall be laundered in a way that prevents the release of asbestos fibers in excess of 0.1 fibers per cubic centimeter of air.
(3) Any spills of solvent or any asbestos-containing waste material shall be cleaned up immediately.
In those cases where removal of the brake drum is difficult, the wetting of the brake parts required under item (1) of the work practices must be performed before the drum is removed. Otherwise, excessive exposure to asbestos may occur during the removal of the brake drum. If it is not possible to thoroughly wet the brake parts with solvent before performing a difficult brake drum removal, then the spray can/solvent system is not an acceptable method for that particular job.
We appreciate the opportunity to provide assistance. Should you require additional information, please contact Gail Brinkerhoff of OSHA Office of Health Compliance Assistance at (202) 219-8036.
Joseph A. Dear
Senator Thad Cochran
United States Senate
Washington, DC 20510
Fax Num. 202-224-3576
Dear Senator Cochran,
I am writing to enlist your support of OSHA's asbestos standard that has come under intense attack from the aerosol and chemical manufacturers who are waging a strong lobbying effort to force OSHA to allow virtually unrestricted use of aerosols to control brake dust.
Aerosol sprays can be used only after the brake drum is removed. Unfortunately, rusted-in-place brake drums are common in the real world of automotive repair. A third if not half of all brake drums are rusted in place by the time the vehicle is due for a brake inspection. Everyday technicians loosen and remove these rusted drums using a hammer to shock the drum free from the axle. Each hammer blow produces an explosion of hazardous dust in the breathing zone of the technician. I cannot imagine a way to contain or control this dust with aerosol spray can.
Asbestos is not a thing of the past. Today over 90% of the brake shoes sold in the aftermarket by one of the top four US brake manufacturers is made of asbestos. Automotive technicians will be breathing this hazardous dust for generations to come if the aerosol coalition is allowed to have its way. Please demand that OSHA publish work practices to ensure that technicians who opt to use aerosol sprays are protected from asbestos exposure when loosening and removing rusted-in-place brake drums.
James E. Williams