Safe Practices Guide: Asbestos-Automotive Brake and Clutch Repair Work

Introduction

Professional automotive technicians and home mechanics who repair and replace brakes and clutches face potential asbestos exposure. By law, automotive shops must adhere to OSHA regulations, ensuring safe work practices in brake and clutch inspection, disassembly, repair, and assembly operations. Although home mechanics aren’t required to follow these regulations, using best practices can help minimize asbestos exposure and reduce the risk of developing asbestos-related diseases. This guide covers concerns about asbestos exposure for mechanics, how to identify asbestos in brake or clutch components, recommended work practices, and proper waste disposal. By following these guidelines, both professional and home mechanics can create safer work environments and protect themselves from potential health risks.

To minimize the risk of coming into contact with asbestos, the EPA urges that all car brake and clutch maintenance be handled by expert auto technicians. Even though asbestos usage in friction materials is decreasing year by year, it still poses a significant exposure threat. Moreover, asbestos present in the brakes and clutches of older vehicles needing service also poses a risk. Uncontrolled exposure to asbestos can lead to mesothelioma, lung cancer, and asbestosis. Symptoms might not surface for many years, or even decades, after encountering asbestos fibers.

Note: For do-it-yourself enthusiasts, OSHA does not hold jurisdiction, and these practices are not mandated by OSHA.

Background

A significant number of brakes and clutches in current and newer car models are asbestos-free. Nevertheless, asbestos hasn’t been entirely eradicated. Some studies suggest that a substantial portion of mechanics, automotive repair shop workers, and do-it-yourselfers may not realize that both old and replacement brakes and clutches could contain asbestos.

OSHA’s asbestos standard mandates the implementation of safety measures and appropriate work practices when employees handle brake shoes and clutches containing asbestos. These requirements are outlined in 29 CFR 1910.1001, specifically 1910.1001(f)(3) and Appendix F of the standard – Work Practices and Engineering Controls for Automotive Brake and Clutch Inspection, Disassembly, Repair, and Assembly (http://www.osha.gov/sltc/asbestos/index.html). Additionally, these requirements are discussed in the Federal Register at 59 FR 40964, 40985-87 (August 10, 1994) and 60 FR 33983 (June 29, 1995), as well as in OSHA Directive CPL 2-2.63 (revised).

This Safety and Health Information Bulletin does not serve as a standard or regulation and does not create any new legal obligations. The Bulletin’s purpose is to advise and inform, aiming to aid employers in fostering a safe and healthy workplace. According to the Occupational Safety and Health Act, employers are required to adhere to hazard-specific safety and health standards established by OSHA or by a state with an OSHA-approved state plan. Furthermore, in compliance with Section 5(a)(1), the General Duty Clause of the Act, employers are responsible for providing a workplace devoid of recognized hazards that may result in death or severe physical harm. Employers may face citations for violating the General Duty Clause if a recognized hazard exists and they fail to take reasonable measures to prevent or mitigate the hazard. However, not implementing the recommendations found in this Safety and Health Information Bulletin does not, by itself, constitute a violation of the General Duty Clause. Citations can be issued only based on standards, regulations, and the General Duty Clause.

OSHA Work Practices and Engineering Controls / OSHA Methods

All auto brake and clutch repair shops across the United States are required to adhere to OSHA’s asbestos standards. By employing well-trained workers who utilize proper engineering controls and work practices on car brakes and clutches, asbestos exposure can be reduced below the allowable limit of 0.1 fiber per cubic centimeter of air, calculated as an 8-hour time-weighted average. When using the control techniques outlined below, respiratory protection is not necessary during brake and clutch maintenance.

The two favored OSHA methods for controlling asbestos dust during brake and clutch servicing are: (1) a negative pressure enclosure combined with a HEPA (high-efficiency particulate air) vacuum system, and (2) the low pressure/wet cleaning approach. Employers may use other techniques (alongside written procedures) to lower exposure levels to those comparable to the negative pressure enclosure/HEPA vacuum system. For facilities handling five or fewer brake or clutch jobs per week, the wet method (outlined in paragraph D of Appendix F) is acceptable. The spray can/solvent system method may also be used as an alternative preferred method, as it meets the equivalency criterion of the negative pressure enclosure/HEPA vacuum system technique. Thorough training is crucial to ensure employees effectively apply these methods.

Negative Pressure Enclosure/HEPA Vacuum System Method

The negative pressure enclosure/HEPA vacuum system method consists of the following steps:

First, encase the brake or clutch assembly to avert asbestos fiber release into the employee’s breathing area during inspection, disassembly, repair, and reassembly. Utilize a see-through enclosure with impervious sleeves.
Secondly, securely and comprehensively seal the enclosure, checking for leaks before commencing work. • Ensure the enclosure is transparent so the employee can clearly observe the operation during inspection, disassembly, repair, and reassembly. The enclosure must also have impervious sleeves permitting the employee to manipulate the brake and clutch assembly without breaching the enclosure. Examine the sleeves and ports’ integrity before starting work.
Employ a HEPA-filtered vacuum to maintain negative pressure within the enclosure during the entire operation. Compressed air can be used for removing asbestos fibers or particles from the enclosure.
Initially, use the HEPA-filtered vacuum to detach asbestos residue from brake and clutch components, then extract the loosened matter from the enclosure into a vacuum filter.
When the vacuum filter reaches capacity, mist it with water before removal. Promptly place it in a marked, impervious container and dispose of it as asbestos waste in accordance with federal, state, and local regulations, and in compliance with 1910.1001(k)(6). The label should read: “DANGER, CONTAINS ASBESTOS FIBERS, AVOID CREATING DUST, CANCER AND LUNG DISEASE HAZARD.”
Immediately clean any spills or releases of asbestos-containing waste material from within the enclosure or vacuum hose or filter. Dispose of waste appropriately as asbestos waste.

Keep in mind that vacuum enclosure units should be spacious enough to fully enclose and remove the brake drum, allowing room for hammering if necessary due to wear, rust, or other factors. Enclosure systems should have ample interior lighting for a well-lit workspace. The enclosure must fully enclose the brake drum and form a tight seal behind the backing plate. Never aim air guns toward the seal, as it could compromise its protective capacity.

After cleaning with compressed air, HEPA vacuum the enclosure’s interior surfaces to maintain cleanliness and visibility. Vacuum each brake component as it is removed and vacuum the backing plate once all components have been detached. Refrain from using rags meant for wiping or cleaning used brake parts to wipe hands. Mechanics should wear a suitable NIOSH-approved respirator for asbestos when changing vacuum unit filters.

Low Pressure/Wet Cleaning Method

The low pressure/wet cleaning technique involves these steps:

Place a catch basin beneath the brake assembly to prevent splashes and spills.
Gently douse the brake assembly with a water mixture containing an organic solvent or wetting agent to keep asbestos-laden brake dust from going airborne.
For drum brakes, make sure the water solution flows between the brake drum and brake support prior to taking off the brake drum.
Once the brake drum is removed, thoroughly moisten the wheel hub and rear of the brake assembly using the water solution to suppress dust.
Carefully clean the brake support plate, brake shoes, and other components before taking out the old brake shoes.
If your system has a filter, dampen the filter when it’s full and before removal, with a fine mist of water. Immediately place it in a sealed container, label it, and dispose of it as asbestos waste.
Promptly clean up any spills of asbestos-containing liquid or waste material with a HEPA-filtered vacuum and/or wet methods. Dispose of waste appropriately as asbestos waste.
Dry brushing is not allowed.
To maintain the unit’s efficiency, change the brake washer solution regularly.

Wet Method

For establishments conducting occasional brake and clutch repair work, OSHA permits the wet method as a “preferred” approach. Thus, in facilities where five (5) or fewer brake “jobs” (equivalent to five vehicles) or 5 clutches, or any combination totaling 5, are inspected, disassembled, reassembled, and/or repaired per week, mechanics/technicians may manage potential asbestos exposure by using a spray bottle, hose nozzle, or any device capable of producing a fine mist of water or amended water at low pressure to moisten the drum or clutch housing before removal and to control asbestos fiber release during subsequent tasks. Nevertheless, any generated wastewater must be captured and disposed of properly, preventing it from drying on surfaces. OSHA expects that using a spray bottle will sufficiently control dust without producing an excessive amount of wastewater.

The wet method necessitates the following steps:

Firstly, moisten brake and clutch components with water or amended water before taking any further action.
Next, clean the brake and clutch parts with a cloth.
Place the contaminated cloth in an impervious, appropriately labeled container and dispose of it as asbestos waste. Alternatively, launder the cloth to avoid releasing asbestos fibers in excess of 0.1 fiber per cubic centimeter of air, expressed as an 8-hour time-weighted average.
Immediately clean any spilled water, amended water, or asbestos-containing waste material with a cloth or HEPA-filtered vacuum, ensuring it doesn’t dry.
Do not use a dry brush.

Despite its simplicity, the wet control method doesn’t negate the importance of proper work practices. For instance, holding the spray nozzle too close to the brake surface may cause asbestos fibers to become airborne. Spray brake components to saturate the parts as they are removed from the assembly.

Equivalent Methods

Similar to the preferred methods, an equivalent method must come with a detailed explanation of the practices that need to be followed when using it. Employers employing such a method must possess a written description containing enough detail for the method to be replicated. They also need to present data showing that exposure levels resulting from the equivalent method are equal to or lower than those from the negative pressure enclosure/HEPA vacuum system method. For the sake of equivalency, employee exposures must not surpass 0.016 f/cc, as determined by the OSHA reference method and averaged across at least 18 personal samples.

The spray can/solvent system method can be employed as an “equivalent” method. When adhering to proper work practices, the spray can/solvent system may be used. At a minimum, the spray can/solvent system method should follow comprehensive written procedures, which include:

Dampen the brake and clutch components with the spray can/solvent before taking further action.
Use a cloth to clean the brake and clutch parts.
Put the contaminated cloth into a sealed, appropriately labeled container and dispose of it as asbestos waste. Alternatively, the cloth can be laundered to prevent the release of asbestos fibers exceeding 0.1 fiber per cubic centimeter of air, expressed as an 8-hour time-weighted average.
Promptly clean any spilled solvent or dispersed asbestos using a cloth or HEPA vacuum.
Dry brushing is not allowed during spray can/solvent system operations. The solvents typically employed in brake and clutch work are hazardous chemicals, necessitating that employers comply with the Hazard Communication standard. If the solvents are flammable, proper precautions must be taken to prevent fires and explosions.

Best Practices

Mechanics ought to assume that all brakes have asbestos-type shoes. It’s difficult to distinguish worn non-asbestos-type brake shoes from asbestos-type shoes. If a mechanic mistakenly assumes a shoe is non-asbestos-type and neglects to employ brake dust control measures, this could result in increased asbestos exposure.

Key point: Back in the 1990s, most carmakers stopped using asbestos in their brake pads due to the health risks for folks working on brake repairs and maintenance. However, it may surprise you that asbestos-containing products are still being used in the automotive aftermarket in the US. The main reason for this? The high demand for low-priced, asbestos-containing brake parts from countries like China and India. As a best practice, OSHA states that mechanics should assume that all brakes have asbestos-type shoes. Worn non-asbestos-type brakes cannot be readily distinguished from asbestos-type shoes.

Proper training in the effective use of the control system chosen by the facility manager or owner is crucial for mechanics. The risk of heightened asbestos exposure due to improper work practices should be emphasized. Examples of such practices include: aiming an air nozzle at an enclosure seal, positioning a spray mist nozzle too close to the work surface, not placing the vacuum nozzle near the contaminated surface, switching on vacuum pumps before situating the vacuum enclosure over the wheel and keeping them on when removing the enclosure, and spilling contaminated solutions on the floor. Consistently using a control system and adhering to work procedures is vital.

Whenever possible, use pre-ground, ready-to-install parts. If asbestos-containing friction materials need to be drilled, grooved, cut, beveled, or lathe-turned, always use low speeds to minimize dust generation. All machinery should feature a sufficient, HEPA-equipped local exhaust dust collection system to prevent asbestos exposure and shop contamination. Promptly clean brake dust spills or contaminated solutions by HEPA vacuuming or wet mopping.

Implementing a regular maintenance program for the brake dust control system is essential. Maintenance should involve inspecting and replacing seals, nozzles, other hardware, contaminated filters, and solutions. Repair any deficiencies, such as ineffective seals or air nozzles. Dispose of asbestos-contaminated materials, whether filters or solutions, in accordance with federal and state regulations and in compliance with 1910.1001(k)(6). Periodic cleaning can help reduce the likelihood of asbestos contamination on workbenches, floors, and other surfaces.

Mechanics should conduct brake and clutch work in a separate area from other workspaces. Post signs to inform employees not to eat, drink, or smoke in the brake and clutch work area, as asbestos and other potentially harmful substances can be ingested or inhaled during these activities.

Emphasize personal hygiene, like frequent handwashing with soap or detergent. Changing from dirty work clothes into clean clothes before leaving work offers added protection against bringing asbestos into the home environment. Provide a laundry service with facilities for cleaning asbestos-contaminated clothing for any affected work clothes.

Conclusion

Asbestos exposure is a significant concern for professional automotive technicians and home mechanics working on brakes and clutches. While asbestos usage has decreased, it remains a threat in older vehicles and some replacement components. To protect workers and DIY enthusiasts, it is crucial to implement engineering controls and effective work practices, such as the methods outlined in this article. These methods, coupled with comprehensive training and adherence to proper work procedures, can reduce asbestos exposure to levels below the OSHA permissible limit. By consistently following these guidelines, both professionals and home mechanics can create safer work environments and protect themselves from the potential health risks associated with asbestos exposure.

Disseminate information about job hazards through a training program that outlines proper task execution, how each work practice diminishes potential exposure, and the advantages employees can gain from these practices. Regardless of the control system employed, employees need to be trained in its correct use. Employees (and do-it-yourselfers opting not to enlist professional mechanics for brake and clutch work) who can identify and manage hazards are better prepared to safeguard themselves from asbestos exposure. Training and work practices should be reinforced regularly.

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