Brake and Clutch | Asbestos

Q.	Are the appendices on brake and clutch repair (Appendix F for General Industry and Appendix L for Shipyard employment) mandatory?
A.	Yes.
Q.	What are the two "preferred" methods for brake and clutch repair?
A.	The two "preferred" methods are the low pressure/wet-cleaning method and the negative pressure enclosure/HEPA vacuum system.
Q.	Is the solvent spray method prohibited?
A.	No. The solvent spray method is an "equivalent" method that may be used when proper work practices are followed.
Q.	What are the work practices that must be used when an employer chooses the spray/solvent can method?
A.	An employer who uses an "equivalent" method must follow detailed written procedures. At a minimum, the solvent spray method should include the following procedures: (1) the solvent shall be used to first wet the brake and clutch parts; (2) the brake and clutch parts shall be wiped clean with a cloth; (3) the contaminated cloth shall be placed in an impermeable container, and then either disposed of properly or laundered in a way that prevents the release of asbestos fibers in excess of 0.1 fiber per cubic centimeter of air; (4) any spilled solvent or dispersed asbestos shall be cleaned up immediately and not allowed to dry, either with a cloth or a HEPA vacuum. Dry brushing during solvent spray operations is prohibited.
Q.	What other precautions are required when solvents are used?
A.	The solvents typically used in brake and clutch work are hazardous chemicals, and the employer must therefore comply with the Hazard Communication standard. If the solvents used are flammable, appropriate precautions against fire and explosion must be taken.
Q.	If the employer chooses to use one of the two "preferred" methods or an "equivalent" method, does the employer have to conduct exposure monitoring?
A.	No.
Q.	Does Appendix F that covers brake and clutch work practices also cover brake and clutch work done on large stationary equipment like printing presses?
A.	No, the Appendix is only intended for automotive work. For other asbestos jobs as described above, the employer must use work methods that reduce the exposures to below the PELs.
Q.	What type of "aqueous" solution is allowed when the low pressure/wet cleaning method is used?
A.	The intent of the standard was to ensure that the asbestos is sufficiently wet so that exposures are kept well below the PELs. The solution can consist only of water, or water mixed with an organic solvent, or a detergent. It is important to note the potential danger of solvent use in these operations. The use of solvents, which are often flammable and may also present a health hazard, must be undertaken with great care. The employer must also be in compliance with the Hazard Communication standard.

Q.	Are other methods allowed for employers who do brake and clutch work infrequently?
A.	Yes, for those shops in which brake work is infrequent, OSHA has determined to allow the use of a wet control method as a "preferred" method. Therefore, in facilities in which five (5) or fewer brake "jobs" (five brake "jobs" is equivalent to five vehicles) or 5 clutches, or some combination totaling 5, are repaired each week, the mechanic/technician may control potential asbestos exposure through the use of a pump sprayer (bottle) containing water or amended water to wet down the drum or clutch housing before it is removed and to control fiber release during subsequent activities. The mechanic may use other implements to deliver the water such as a garden hose; however, the resulting wastewater generated must be captured and properly disposed of without allowing it to dry on any surfaces. The spray should be controlled through the use of low pressure to the extent feasible. OSHA anticipates that the use of a spray bottle will be adequate to control the dust without generating a large volume of wastewater. However, any waste water generated must be disposed of properly.
Q.	What provisions are required to perform a brake inspection?
A.	The extent to which an "inspection" is different from the other brake servicing depends on whether and how the drum is removed. Most inspections of brake shoes involve removing the drum which may contain a substantial number of asbestos fibers. Precautions must be taken against the release of those fibers into the workplace. If the drum is carefully pulled back just far enough to observe the brake shoe and brake components, it is sufficient to thoroughly wet the exterior and around the seam between the brake drum and backing plate. Any dislodged material must be immediately cleaned up in accordance with 1910.1001(k). Blows to the drum with a hammer or similar implement to dislodge a rusted-in-place or frozen drum may cause asbestos fibers to be released. For such cases, in shops performing 6 or more brake jobs per week, an enclosure must be installed around the drum to capture the dust or the drum interior and contents must be thoroughly wetted prior to striking or forcibly removing the brake drum. As with other brake servicing, this must be done using a preferred or equivalent method. When using the equivalent spray can method, first wet the interior and contents of the drum before striking it. Then, carefully pull the drum back just enough to allow another application of solvent and thoroughly wet the interior before removal of the drum. There should be no visible dust created during drum loosening and removal.