Solvent spray during asbestos brake repair

September 29, 1995
The Honorable Thad Cochran
United States Senate
[Recipient address omitted]
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 [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Joseph A. Dear
Assistant Secretary

[Requester letter reproduced on OSHA page; omitted here.]

[Corrected 12/6/2024]