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Work Practices and Engineering Controls for Automotive Brake and Clutch Inspection, Disassembly, Repair and Assembly
This mandatory appendix specifies engineering controls and work practices that must be implemented by the employer during automotive brake and clutch inspection, disassembly, repair, and assembly operations. Proper use of these engineering controls and work practices by trained employees will reduce employees' asbestos exposure below the permissible exposure level during clutch and brake inspection, disassembly, repair, and assembly operations. The employer shall institute engineering controls and work practices using either the method set forth in subsection [A] or subsection [B] of this appendix, or any other method which the employer can demonstrate to be equivalent in terms of reducing employee exposure to asbestos, as defined, and which meets the requirements described in subsection [C] of this appendix. For those facilities in which no more than 5 pairs of brakes or 5 clutches are inspected, disassembled, reassembled, and/or repaired per week, the method set forth in subsection [D] of this appendix may be used.
[A] Negative Pressure Enclosure/HEPA Vacuum System Method:
(1) The brake and clutch inspection, disassembly, repair, and assembly operations shall be enclosed to cover and contain the clutch or brake assembly and to prevent the release of asbestos fibers into the worker's breathing zone.
(2) the enclosure shall be sealed tightly and thoroughly inspected for leaks before work begins on brake and clutch inspection, disassembly, repair, and assembly.
(3) The enclosure shall be such that the worker can clearly see the operation and shall provide impermeable sleeves through which the worker can handle the brake and clutch inspection, disassembly, repair and assembly. The integrity of the sleeves and ports shall be examined before work begins.
(4) A HEPA-filtered vacuum shall be employed to maintain the enclosure under negative pressure throughout the operation. Compressed-air may be used to remove asbestos fibers or particles from the enclosure.
(5) The HEPA vacuum shall be used first to loosen the asbestos-containing residue from the brake and clutch parts, and then to evacuate the loosened asbestos-containing material from the enclosure and capture the material in the vacuum filter.
(6) The vacuum's filter, when full, shall be first wetted with a fine mist of water, then removed and placed immediately in an impermeable container, labeled according to subsection (k)(8) of this section, and disposed of according to subsection (l) of this section.
(7) Any spills or releases of asbestos-containing waste material from inside of the enclosure or vacuum hose or vacuum filter shall be immediately cleaned up and disposed of according to subsection (l) of this section.
[B] Low Pressure/Wet Cleaning Method:
(1) A catch basin shall be placed under the brake assembly, positioned to avoid splashes and spills.
(2) The reservoir shall contain water containing an organic solvent or wetting agent. The flow of liquid shall be controlled such that the brake assembly is gently flooded to prevent the asbestos-containing brake dust from becoming airborne.
(3) The aqueous solution shall be allowed to flow between the brake drum and brake support before the drum is removed.
(4) After removing the brake drum, the wheel hub and back of the brake assembly shall be thoroughly wetted to suppress dust.
(5) The brake support plate, brake shoes and brake components used to attach the brake shoes shall be thoroughly washed before removing the old shoes.
(6) In systems using filters, the filters when full shall be first wetted with a fine mist of water, then removed and placed immediately in an impermeable container labeled according to subsection (k)(8) of this section, and disposed of according to subsection (l) of this section.
(7) Any spills of asbsetos-containing aqueous solution or any asbsetos-containing waste material shall be cleamed up immediately and disposed of according to subsection (l) of this section.
(8) The use of dry brushing during low pressure/wet cleaning operations is prohibited.
[C] Equivalent Methods:
An equivalent method is one which has sufficient written detail so that it can be reproduced, and for which it has been demonstrated that the exposures resulting from the equivalent method are equal to or less than the exposures which would result form the use of the method described in subsection [A] of this appendix. For purposes of making this comparison, the employer shall assume that exposures resulting from the use of the method described in subsection [A] of this appendix shall not exceed 0.016 f/cc, as measured by the OSHA reference method and as averaged over at least 18 personal samples.
[D] Wet Method:
(1) A spray bottle, hose nozzle, or other implement capable of delivering a fine mist of water or amended water, or other delivery system capable of delivering water at low pressure, shall be used to first thoroughly wet the brake and clutch parts. Brake and clutch components shall then be wiped clean with a cloth.
(2) The cloth shall be placed in an impermeable container, labeled according to subsection (k)(8) of this section, and then disposed of according to subsection (l) of this section; or the cloth shall be laundered in a way to prevent the release of asbestos fibers in excess of 0.1 fiber per cubic centimeter of air.
(3) Any spills of solvent or any asbstos-containing waste material shall be cleaned up immediately according to subsection (l) of this section.
(4) The use of dry brushing during the wet method operations is prohibited.
NOTE: Authority cited: Section 142.3, Labor Code. Reference: Section 142.3, Labor Code.
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