Attached question

williambosu
unit2resource1.pdf

AJPH HISTORY

September 2017, Vol 107, No. 9 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now 1395

“Ain’t Necessarily So!”: The Brake Industry’s Impact on Asbestos Regulation in the 1970s David Rosner, PhD, MPH, and Gerald Markowitz, PhD

Canada is proposing a ban on asbestos, and the US Environmental Protection Agency has listed it

among the first 10 materials it is investigating under the new Toxic Substances Control Act revisions.

However, this effort is currently running up against enormous industry and political opposition.

Here, we detail the activities in the early 1970s of the Friction Materials Standards Institute, an

industry trade association, to stifle earlier attempts to regulate asbestos use in brake linings, one

of the oldest and most obvious sources of asbestos exposure to mechanics, among others. (Am J

Public Health. 2017: 1395–1399. doi: 10.2105/AJPH.2017.303901)

At the end of 2016, the US Environmental Protec- tion Agency (EPA) proposed

asbestos, the cause of fi brotic

lung disease and cancer, as one

of the 10 industrial chemi-

cals to be evaluated under the

newly revised Toxic Substances

Control Act.1 Under the new

act, a risk evaluation of asbestos

is to be completed within three

years and, if asbestos is found

to be an “unreasonable risk to

humans and the environment,”

the EPA is required to mitigate

that risk, possibly through a

ban, within two more years.2

By 1970, asbestos was used

in some 3000 products, such as

roof shingles, fl oor 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 fl ooring felt, but it is

still legal in brakes and clutches

and a host of construction and

industrial materials, such as vinyl

fl oor tile, roofi ng materials, and

cement pipe, among others.

Consequently, it is in millions of

homes, gas stations, and repair

shops across the country.3

Historians have documented

one major reason for the

delay in banning this known

carcinogen: private industry

trade groups stifl ed earlier eff orts

at regulation.4 Here, we look at

the specifi c eff orts of one such

group, the Friction Materials

Standards Institute (FMSI),

to forestall the regulation of

asbestos used in brakes and

clutches, one of the oldest

sources of asbestos exposure.

We examine the industry’s

reaction to the newly created

Occupational Safety and Health

Administration’s (OSHA)

dramatic reduction of the

Permissible Exposure Limit

(PEL) in the early 1970s. There

is a literature that addresses

the current medical and

epidemiological evidence of the

dangers from asbestos brakes.5

Here, however, using internal

corporate documents, most of

which have not been previously

reviewed but are now available

at https://toxicdocs.org,6 we

explore what the industry

understood about the dangers to

mechanics from asbestos.

The concern about asbestos

in brakes refl ects the broader

acknowledgment of the impact

of industrial toxins on workers

and consumers in the 20th

century.7 In the early 1930s,

E. R. A. Merewether identifi ed

the dust produced by “the

sawing, grinding and turning

in the dry state of articles

composed wholly or partly

of asbestos such as motor car

brake and clutch linings” when

inhaled as a cause of asbestosis,

the fi brotic condition that slowly

strangles aff ected workers.8

Merewether’s early observation

that any material that contained

asbestos could prove to be a

hazard was affi rmed in the

immediate postwar period, as

offi cials noted that “asbestos

has been incorporated into

… protective clothing, brake

linings, cements, … and other

forms of insulation” and that

exposure to asbestos dust caused

by “the breakdown of the native

mineral” was also associated with

cancer of the lung.9 By the mid-

1960s, asbestos was associated

with asbestosis, lung cancer,

and mesothelioma, a cancer

of the lining of the lung and

abdominal cavity, leading the

British Ford Motor Company

to host a conference in 1969 on

the possible dangers presented

to brake mechanics and those

installing or replacing brake

linings.10

In 1970, the Occupational

Safety and Health Act,

establishing OSHA and

the National Institute of

Occupational Safety and

Health (NIOSH), was passed.11

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

AJPH September 2017, Vol 107, No. 9

AJPH HISTORY

1396 Public Health Then and Now Peer Reviewed Rosner and Markowitz

Information Association of

North America (AIA), another

trade association, it sought to

forestall any drastic regulation.12

Among the ASC’s fi rst acts was

to meet with OSHA offi cials

who had issued an emergency

PEL of 12 fi bers per cubic

centimeter in 1971 and, a year

later, reduced it further to 5

fi bers per cubic centimeter, with

an even greater reduction to 2

fi bers per cubic centimeter by

1976.13

ACKNOWLEDGING DANGER PRIVATELY

The FMSI was aware of why

OSHA was considering this

reduction. At its meeting in June

1972, the ASC received a report

that Rohl and colleagues had

presented a paper at a 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 fi ve fi bers per cc

[cubic centimeter] allowance.”14

They acknowledged that

exposure to asbestos dust was a

possibility, if not a probability, for

workers installing and replacing

brakes.15

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.16 Hence, a new rationale

for not warning was developed:

they publically pronounced

that asbestos, when “locked

in” to fabrics, lacquers, plastics,

or other fi nished products,

was not a danger as it could

not be released into the

air.17 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-in 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 fl oor. One member

of the ASC suggested that “a

notifi cation be put in boxes in

brake linings or clutch facings,”

but this was quickly shot down

when another member objected

because “he felt it was another

‘red fl ag’ that would bring more

harm to the industry than the

alleged good that would come

from enclosing such notices.”18

Despite public assurances

that using “locked-in” asbestos

was safe, E. W. 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—cutting, grooving,

drilling and grinding [and that]

these subsequent operations

can produce concentrations of

asbestos fi bers in excess of the

current exposure limits.”19 “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.”20

AIN’T NECESSARILY SO In mid-1973, “Ike” Weaver,

an engineer with the Raybestos–

Manhattan 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

about the recent meeting of

the International Agency for

Research on Cancer at which

“the most important item

[was] the incrimination of all

major types of asbestos as causal

agents of carcinoma, particularly

mesothelioma.” He further

warned that “since most of us

[in the FMSI] use substantial

amounts of chrysotile asbestos in

our formulations association of

this material with mesothelioma

and other types of cancer is of

serious concern.”21

For an industry that

identifi ed friction as the primary

characteristic of its products,

he knew “of no way any of us

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 asbestos- containing products in any way was identified as a major concern. Here, we see an “asbestos-based” Johns–Manville disk brake ad from the 1960s with no mention of any potential danger.

September 2017, Vol 107, No. 9 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now 1397

AJPH HISTORY

of workers or bystanders to

airborne asbestos fi bre.” He

was “appalled to learn … of

instances where this problem has

occurred.”22

He objected to those in

his industry who argued that

most workers were exposed

only “relatively intermittently”

to respirable asbestos dust: “I

say emphatically this just ain’t

necessarily so!” Not only did

“large volume replacement

users [perhaps chains such as

Midas and Meineke] present

major potential hazards,” but

“even small job shops can

needlessly expose people to

high fi bre concentrations if

operations are performed

without controls.” There was

the risk for dread disease

even when exposures were

minimal or of short duration.23

“To me,” Weaver concluded,

“labelling all containers or

packagers of asbestos-containing

friction material is the very

least the industry can do to

fulfi ll its moral obligation to

its customers, their employees

and the public and at the

same time conform with

minimum requirements of the

Occupational Safety and Health

Act.”24

Further evidence about the

potential dangers to mechanics,

including cancer, was provided

with the publication of the Rohl

paper on New York City garages

that the ASC had heard about

before. The ASC acknowledged

that “some of the housekeeping

conditions in these shops

[were] deplorable.” And they

acknowledged that conditions

in New York were “perhaps

no worse than in other shops

throughout the country.”25

COLLAPSING DEFENSES By the mid-1970s, the FMSI

had learned that both national

and international experts,

NIOSH, the International Labor

Organization, the International

Agency for Research on Cancer,

and other researchers agreed that

the PEL was irrelevant to the

question of cancer.26 In addition,

one of the leading fi gures in

industrial medicine and the

leading asbestos researcher,

Irving Selikoff , echoed these

ideas, writing that the “only safe

concentration is zero fi ber per

cc.”27

In April 1975, as the date

for the proposed reduction of

the PEL to 2 fi bers per cubic

centimeter approached, the FMSI

faced a dilemma. They claimed

they were already “having dif-

fi culty meeting the 5 fi bers/cc

limit,” and worried that “it would

be near impossible to meet the

2 fi bers/cc limit due July 1,

1976.” Some on the ASC “sug-

gested that the industry should

oppose this change,”28 and Guy

Gabriellson, vice president of the

Asbestos Information Association,

said that the industry should

simply reject OSHA’s and

NIOSH’s position.29

GROWING PRESSURE, GROWING EVIDENCE

The situation was becoming

dire for the FMSI as they

faced growing pressure to

acknowledge that there was

no exposure below which

workers could be protected

from asbestos-induced cancers.

The pressure came from

NIOSH, the International

Labor Organization, and others.

Selikoff predicted an “epidemic

of asbestos related death and

disease in years to come.”

The FMSI Board of Directors

was alarmed by the growing

consensus that “no known dose

level [of asbestos exposure was]

‘safe.’ ” Furthermore, Selikoff

and his colleagues were “actively

promoting” the view that the

hazards were “associated with

asbestos emissions”—specifi cally

to mechanics—“from brake

lining wear and from brake

service operations.”30

The pressures became even

greater in July 1975, after

NIOSH called a meeting in

Washington of an automobile

company, union representatives,

the major asbestos companies,

researchers, and a trade

association representative.31

They learned that the medical

literature “revealed at least

four cases of these rare tumors

[mesotheliomas] in persons who

were employed in jobs involving

automobile brake servicing.”32

The liability dimensions of the

problem facing the industry

were frightening: “It has been

reported that approximately

900,000 persons are employed

in such work in the United

This ad from Raybestos-Manhattan emphasizes the “safety” of the asbestos brakes, despite the fact that by this point, it was clear that exposure to asbestos dust could cause cancer.

AJPH September 2017, Vol 107, No. 9

AJPH HISTORY

1398 Public Health Then and Now Peer Reviewed Rosner and Markowitz

States. It is recommended that

stringent industrial hygiene

measure to control exposure

be implemented as rapidly as

possible.”33 In a separate article,

the industry learned that “during

brake-lining maintenance and

repair, workmen in garages,

service stations and brake repair

shops are exposed to asbestos

and thus may be subject to

serious cancer risk. Others, at

some distance from the repair

work, are perhaps subject to the

same hazard.”34

RESISTANCE RAMPS UP At the same time that these

articles were being published,

OSHA proposed to reduce the

asbestos standard even lower,

which the FMSI described

as a “drastic reduction.”35

The ASC began to mobilize

committee members and the

general membership of the

FMSI to oppose OSHA’s

recommendation that the PEL

be reduced to 0.5 fi bers per

cubic centimeter instead of the

2 fi bers per cubic centimeter

standard that was scheduled to

go into eff ect July 1, 1976. In

June, they proposed a three-part

strategy. First, they intended

to educate their membership

on how to comply with the

2-fi bers per cubic centimeter

standard to go into eff ect in the

following month and further to

recognize “the impact that will

be required to cope with the

0.5 fi bre standard, should it be

imposed.” Second, they planned

to oppose the more stringent

standard with “every possible

means at our disposal,” and “to

enlighten government offi cials

of what informed members

within our industry regard as the

complete impracticality of the

[proposed] 0.5 standard.” Finally,

they planned on “cooperating

with the Asbestos Information

Association and the Institute

Offi ce in their response to

OSHA on the revised standard,”

an eff ort they believed had

already borne fruit.36 In the

end, the standard would not

be reduced until the mid-

1980s,37 and they congratulated

themselves and the AIA on

forestalling the reduction of the

standard. The FMSI thanked the

AIA for “the outstanding job

[they did] in rebutting some of

the reasons for OSHA’s stringent

proposals.”38 The committee

bragged that “we have been told

that our eff orts … have been

effi cacious.”39

The infl uence of the asbestos

industry can be observed

directly by comparing the

warnings the FMSI and AIA

recommended for gas stations

and auto repair shops with those

of the government. NIOSH in

1976 suggested that a sign be

posted at the entrance to the

work area of these garages that

specifi cally warned: “Asbestos;

Dust Hazard; Avoid Breathing

Dust; Wear Assigned Protective

Equipment; Do Not Remain

in Area Unless your Work

Requires it; Breathing Asbestos

Dust May Cause Asbestosis and

Cancer.”40 The FMSI and the

AIA adopted similar wording,

with one crucial diff erence:

they did not use the word

“cancer.” Instead, they adopted

OSHA’s wording from the 1972

standard:41 “Breathing Asbestos

Dust May be Hazardous to Your

Health.”42 As a result of the

FMSI and AIA’s opposition, the

lowering of OSHA’s PEL was

signifi cantly delayed. In addition,

they trivialized the dangers to

workers by not including cancer

in their warnings. As a result,

they belittled and undercut the

warnings of NIOSH, Irving

Selikoff , and many other

scientists that workers were

putting their lives at risk by

working with products made

with asbestos.

For policymakers, it is

important to understand the

tragic history we relate here. It

took 45 years of work on the

part of physicians, laboratory

scientists, regulators, and citizens

to achieve these monumental

victories for public health, but

all of this work can be undone

if the current administration in

Washington follows through

on its threats to undercut the

EPA and other federal agencies.

There are few materials in the

modern environment that are

documented to be as hazardous

as asbestos. It would be tragic if

all this work was to be undone

by new lobbying eff orts aimed

at a new administration and

EPA administrator particularly

receptive to industry’s siren call

to deregulate.43

ABOUT THE AUTHORS David Rosner is with the Center for the

History and Ethics of Public Health,

Department of Sociomedical Sciences,

Mailman School of Public Health, and the

Department of History, Columbia University,

New York, NY. Gerald Markowitz is with the

Department of Interdisciplinary Studies, John

Jay College, and the Department of History,

Graduate Center, both of the City University

of New York, New York, NY.

Correspondence should be sent to David

Rosner, Center for the History and Ethics of

Public Health, Department of Sociomedical

Sciences, Columbia University, Mailman

School of Public Health, 722 West 168th St,

Room 934, New York, NY 10032 (e-mail:

dr289@columbia.edu). Reprints can be

ordered at http://www.ajph.org by clicking the

“Reprints” link.

This article was accepted May 4, 2017.

doi: 10.2105/AJPH.2017.303901

CONTRIBUTORS The authors contributed equally to the

research, writing, and conceptualization

of this article.

ACKNOWLEDGMENTS We acknowledge that many of the

primary source documents were gathered

in the process of litigation regarding

asbestos-related diseases. These documents

are available online at http://www.

toxicdocs.org, a Web site of corporate

memos, letters, reports, and other articles

developed through the cooperative eff orts

of the Center for the History and Ethics

of Public Health, Columbia University

and the City University of New York.

We have appeared as expert witnesses on

behalf of plaintiff s in asbestos lawsuits.

ENDNOTES 1. This revision is now known as the

Frank R. Lautenberg Chemical Safety

for the 21st Century Act.

2. Environmental Protection Agency,

“News Releases From Headquarters:

EPA Names First Chemicals for Re-

view Under New TSCA Legislation;

Agency Answers Call to Move For-

ward on Chemical Reform, Naming

Asbestos Among the First to Undergo

Risk Evaluation,” November 11, 2016.

https://www.epa.gov/newsreleases/

epa-names-first-chemicals-review-under-

new-tsca-legislation (accessed December

29, 2016).

3. Environmental Protection Agency,

“US Federal Bans on Asbestos.” https://

www.epa.gov/asbestos/us-federal-bans-

asbestos#main-content (accessed Decem-

ber 29, 2016). See also Kathleen Ruff,

“Asbestos Lobby Launches Attack to

Undermine Upcoming UN Conference

on Trade in Hazardous Substances.”

http://www.rightoncanada.ca/?p=3963

(accessed April 17, 2017).

4. See, for example, Barry Castleman,

Asbestos: Medical and Legal Aspects, 3rd

edition (Englewood, NJ: Prentice

Hall, 1990); Gerald Markowitz and

David Rosner, “ ‘Unleashed Upon an

Unsuspecting World’: The Asbestos

Information Association and Its Role

in Perpetuating a National Epidemic,”

American Journal of Public Health 106, no.

5 (2016): 834–840.

5. See Castleman, Asbestos, pp 443–479,

for one of the first reviews of the

existing scientific evidence of the dangers

of asbestos in brake linings.

6. These documents are available on the

Web site https://www.toxicdocs.org, a

collection of nearly 6 000 000 corporate

memos, studies, letters, and notes

gathered through a variety of law suits

over toxic materials.

7. David Rosner and Gerald Markowitz,

“A ‘Gift of God’? The Public Health

Controversy Over Leaded Gasoline

During the 1920s,” American Journal of

Public Health 75, no. 4 (1985): 344–352;

William Graebner, “Hegemony Through

Science: Information Engineering and

Lead Toxicology, 1925–1965,” in

David Rosner and Gerald Markowitz,

eds, Dying for Work: Workers’ Safety

and Health in Twentieth Century

America (Bloomington, IN: Indiana

University Press, 1987), 140–159;

David Egilman and Marion Billings,

“Abuse of Epidemiology: Automobile

Manufacturers Manufacture a Defense

to Asbestos Liability,” International

Journal of Occupational and Environmental

September 2017, Vol 107, No. 9 AJPH Rosner and Markowitz Peer Reviewed Public Health Then and Now 1399

AJPH HISTORY

16. Title 29, Labor, Chapter XVII—

Occupational Safety and Health

Administration, Department of Labor,

Part 1910—Occupational Safety

and Health Standards, “Standard for

Exposure to Asbestos Dust,” Federal

Register 37 (1972): 11321: “Caution

Labels shall be affixed to all raw

materials, mixtures, scrap, waste, debris,

and other products containing asbestos

fibers or to their containers, except that

no label is required where asbestos fibers

have been modified by a bonding agent,

coating, binder, or other material so

that during any reasonably foreseeable

use, handling, storage, disposal,

processing, or transportation, no airborne

concentrations of asbestos fibers in

excess of the exposure limits prescribed

in paragraph (b) of this section will be

released.”

17. Ibid, p. 11319: “Employers in

general strongly contend that finished

products that effectively entrap asbestos

fibers, so that these would not be released

in the normal use of the products, should

not be required to be labelled.”

18. FMSI, Asbestos Study Committee,

“Minutes,” August 17, 1972.

19. E. W. Drislane to Asbestos Study

Committee, “Interpretation of OSHA

Labelling Requirements,” November

6, 1972.

20. FMSI, Asbestos Study Committee,

“Minutes,” February 16, 1973.

21. FMSI, Annual Meeting, “Minutes,”

June 27–28, 1973. Weaver noted that

“risk is greatest with crocidolite, less

with amosite and apparently still less

with chrysotile.”

22. FMSI, Annual Meeting, “Minutes,”

June 27–28, 1973.

23. Ibid.

24. Ibid.

25. FMSI, Asbestos Study Committee,

“Minutes,” June 14, 1974.

26. The International Labor

Organization’s “Meeting of Experts on

Safe Use of Asbestos” stated that “the

2 fibres/ml standard should be regarded

as an interim concentration related to

fibrogenic effects and not to carcinogenic

effects, for which no standards exist at

the present time.” See Report of

International Labor Organization,

“Meeting of Experts on Safe Use of

Asbestos,” in Geneva, December 11–18,

1973, in “Asbestos Study Committee

Report,” June 1974, attached to Minutes

of Annual Meeting, June 18–19, 1975.

27. FMSI Board of Directors,

“Minutes,” June 25, 1974.

28. See also FMSI, Asbestos Study

Committee, “Minutes,” April 28, 1975.

29. See: Gerald Markowitz and David

Rosner, “Unleashed on an Unsuspecting

World,”: The Asbestos Information

Association and Its Role in Perpetuating

a National Epidemic,” AJPH, 106(May,

2016), p.838.

30. FMSI, Board of Directors, “Minutes,”

June 17, 1975; “Asbestos Study Commit-

tee Report,” June 1975.

31. Department of Health, Education

and Welfare, CDC, NIOSH, “Minutes

of Occupational Exposures to Asbestos

Dust From Brake Linings Meeting,” July

21, 1973.

32. Department of Health, Education

and Welfare, CDC, NIOSH, “Minutes

of Occupational Exposures to Asbestos

Dust From Brake Linings Meeting,”

July 21, 1973. See also J. W. Lloyd,

NIOSH, to “Dear Colleague,”

“Current Intelligence Bulleting 5:

Asbestos Exposure During Servicing

of Motor Vehicle Brake and Clutch

Assemblies,” DHHS (NIOSH),

Publication No. 78-127, August 8,

1975 (in FMSI file). At the meeting, Dr

George Wright, representing the Johns

Manville Corporation, “emphasized that

manufacturers have a responsibility to

ascertain what happens to their products

after being sold to others.” He was not

surprised about “the [high] fiber counts

reported” and expressed the belief that

one might subsequently encounter the

full spectrum of asbestos-related disease

among grinders.

33. Arthur N. Rohl, Arthur M. Langer,

Mary S. Wolff, and Irving Weisman,

“Asbestos Exposure During Brake

Lining Maintenance and Repair,” Envi-

ronmental Research 12 (1976): 110–128.

In this article, the authors describe the

work practices in repair shops and the

attendant hazards: “When a vehicle is

brought into a repair shop for brake

lining inspection or replacement, the

wheel is removed and loose dust is

removed from the drums and back plates,

generally by means of a compressed

air jet. … The cloud of dust that is

produced is visible for several minutes

afterwards. Table 3 shows that fiber

concentrations are high in the operator’s

area under these conditions (an average

concentration of 16 fibers/ml), and that

there are significant concentrations at

least 20 ft away. … It is evident that any

person 65–75 ft away can be exposed”

(p. 118). “It was generally found that

there was minimal, if any, effort to control

dust in most garages. Workmen do not

use respiratory protection. There was

little awareness of the potential hazard

of brake dust” (pp. 117–118).

34. Arthur N. Rohl, “Asbestos Exposure

During Brake Lining Maintenance

Repair,” ca. January 1976, enclosed in

Selikoff to Drislane, January 14, 1976.

Rohl says in a handwritten note, “Dr.

Selikoff has asked me to send you the

results of our asbestos fiber counts

during brake repair work.” (This reference

is to the early draft of paper published

in mid-1976).

35. Asbestos Study Committee, FMSI,

“Minutes of Annual Meeting,” June

16–17, 1976.

36. “Asbestos Study Committee

Report,” June 2, 1976.

37. See US Department of Labor,

Occupational Safety and Health

Administration, “Occupational Exposure

to Asbestos,” Final Rules, 29 CFR

Parts 1910, 1915, and 1926, Final

Rule for a more complete review of

the unfolding attempts at lowering

the PEL in construction and other

industries. https://www.osha.gov/pls/

oshaweb/owadisp.show_document?p_

table=FEDERAL_REGISTER&p_

id=13404 (accessed January 17, 2017).

38. Asbestos Study Committee, FMSI,

“Minutes of Annual Meeting,” June

16–17, 1976.

39. “Asbestos Study Committee

Report,” June 2, 1976.

40. NIOSH, “Recommended (Interim)

Procedures for Asbestos Brake and

Clutch Servicing,” enclosed in FMSI,

Bulletin No. 581, October 12, 1976.

41. Markowitz and Rosner, “Unleashed

Upon an Unsuspecting World,” p. 837.

42. AIA, “Recommended Procedures

for Reducing Asbestos Dust During

Brake Servicing,” ca. September 1976

(these were sent out by the FMSI on

February 23, 1977).

43. Hearings on the Nomination of

Attorney General Scott Pruitt to be

Administrator of the US Environmental

Protection Agency Before the Senate

Committee on Environment and

Public Works, 115th Cong, 1st Sess

(2017). Transcript pw 011817.pdf

available at: https://www.epw.senate.

gov/public/index.cfm/2017/1/hearing-

on-nomination-of-attorney-general-

scott-pruitt-to-be-administrator-of-the-

u-s-environmental-protection-agency

(accessed July 17, 2017).

Health 11 (2005): 360–371; Castleman,

Asbestos; Anthony J. Lanza, ed, Silicosis

and Asbestosis (London, UK: Oxford

University Press, 1938), 419. See also

S. B. McPheeters, “A Survey of a Group

of Employees Exposed to Asbestos Dust,”

Journal of Industrial Hygiene and Toxicology

18 (April 1936), 229; he summarized

the problem created by “the dangerous

dust diseases, silicosis and asbestosis,”

writing that “while it [currently]

employs a relatively small number of

persons, the asbestos industry has had a

remarkably rapid expansion … by reason

of the widespread and varied uses of this

products which includes [sic] matches,

filter pads, paints, roofing, high pressure

jointing, electrodes, brake linings, clutch

rings, and insulating material.”

8. [E. R. A. Merewether],

“Memorandum on the Industrial

Diseases of Silicosis and Asbestosis,”

London, His Majesty’s Stationary Office,

1932, p.12, https://www.toxicdocs.org.

9. “Wartime Operations Emphasize

Industrial Hygiene Problems of Asbestos

Industry,” Illinois Labor Bulletin 3 (1943):

10–11. See also V. J. Castrop, “Fume and

Dust Exposure,” National Safety News 57

(February 1948): 20–21, 52, 73–79; H.

Wyers, “Asbestosis,” Postgraduate Medical

Journal (December 1949): 631–638;

“Asbestosis and Cancer of the Lung,”

Journal of the American Medical Association

140 (August 13, 1949):1219–1220;

Richard Doll, “Mortality From Lung

Cancer in Asbestos Workers,” British

Journal of Industrial Medicine 12 (1955):

81–86; “Hygienic Guide Series,”

American Industrial Hygiene Association

Journal 19 (1958):162.

10. E. Hickish, “Exposure to Asbestos

During Brake and Clutch Maintenance,”

Annals of Occupational Hygiene 13

(1970):1; D. E. Hickish and K. L. Knight,

“Exposure to Asbestos During Brake

Maintenance,” Annals of Occupational

Hygiene 13 (1970): 20–21.

11. L. Leopold, The Man Who Hated

Work and Loved Labor: The Life and

Times of Tony Mazzocchi (White River

Junction, VT: Chelsea Green Publishing,

2007).

12. Friction Materials Standards Institute

(FMSI), Bulletin No. 406, “Asbestos

Study Committee,” ca. 1975. All of the

FMSI documents were attained through

discovery proceeding in a variety of

asbestos lawsuits, in some of which

we participated, and we are making

all of them available at https://www.

toxicdocs.org.

13. FMSI, Asbestos Study Committee,

“Minutes,” February 10, 1972;

Markowitz and Rosner, “Unleashed

Upon an Unsuspecting World.”

14. FMSI, Asbestos Study Committee,

“Minutes,” June 14, 1972.

15. FMSI, Asbestos Study Committee,

“Minutes,” August 17, 1972.

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