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Asbestos During Brake and Clutch Service Work


October 2003
DHHS (NIOSH) Publication Number 2004-101
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Self-Inspection Checklist

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This checklist covers Occupational Safety and Health Administration (OSHA) asbestos regulations (29 CFR 1910.1001). It applies to school district employees and students who have potential exposure to asbestos fibers from asbestos-containing materials. This checklist focuses on the most common exposure situation in schools–brake and clutch service work on motor vehicles. Since asbestos can also be found in materials such as floor tiles, textured paint, soundproofing compound, insulation, joint compound, spackle, oven-door gaskets, lab bench tops, cement board (Transite), shingles, siding and heat- resistant gloves, the teacher should be constantly on guard against handling any asbestos-containing materials. The regulations cited apply only to private employers and their employees, unless adopted by a State agency and applied to other groups such as public employees. Definitions of terms in bold type are provided at the end of the checklist. This checklist does not cover asbestos abatement work, asbestos exposures other than encountered during brake and clutch service work, or the Asbestos Hazard Emergency Response Act (AHERA) regulations.

  1. Engineering Controls and Work Practices

  2. Are one of the following methods used during automotive brake and clutch inspection, disassembly, repair, and assembly operations? [29 CFR 1910.1001(f)(3)] (see definitions for descriptions of methods)
    1. Negative-pressure enclosure/HEPA vacuum system method [recommended method]
    2. Low-pressure/wet-cleaning method [recommended method]
    3. An equivalent method clearly documented to be as good as or better than the negative-pressure enclosure/HEPA vacuum system method for controlling asbestos exposure.Note: OSHA has accepted the solvent spray method as an equivalent method that may be used when proper work practices are followed.
    4. Wet method, if no more than 5 pairs of brakes or 5 clutches are inspected, disassembled, reassembled, or repaired per week.
  3. Are hand-operated and power-operated tools that produce or release asbestos fibers, such as saws, abrasive wheels, and drills provided with local exhaust ventilation systems? [29 CFR 1910.1001(f)(1)(iv)and(v)]
  4. Is compressed air prohibited for cleaning asbestos dust unless it is used in conjunction with a ventilation system that effectively captures the dust cloud created by the compressed air? [29 CFR 1910.1001(f)(1)(ix)]

    Protective Equipment

  5. If the possibility of eye irritation exists, are face shields, vented goggles, or other appropriate protective equipment provided? [29 CFR 1910.1001(h)(1)(iii)]
  6. Is the protective equipment cleaned, laundered, or repaired as necessary to maintain its effectiveness? [1901.1001(h)(3)(i)]
  7. Is clean protective equipment provided at least weekly to each affected person? [1901.1001(h)(3)(i)]

    Warning Labels

  8. Are warning labels affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers? [29 CFR 1910.1001(j)(4)(i)]Note: Warning labels are not required if the manufacturer of an asbestos-containing product can demonstrate that no airborne concentrations of asbestos fibers will exceed the allowable limits during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation.
  9. Do warning labels include the following information? [29 CFR 1910.1001(j)(4)(ii)]DANGER CONTAINS ASBESTOS FIBERS AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD

    Information and Training

  10. Is training as required by the OSHA standard provided to employees who are exposed to airborne concentrations of asbestos at or above the permissible exposure limit and/or excursion limit? [29 CFR 1910.1001(j)(7)]Note: The training must be provided at the time of initial assignment and at least annually thereafter. The training must include information about the following:
    1. health effects of asbestos
    2. the relationship between smoking, asbestos, and increased risk of lung cancer
    3. how quantity, location, manner of use, release, and storage of asbestos could result in exposure to asbestos
    4. the engineering controls and work practices for reducing asbestos exposure
    5. the proper procedures to be followed to reduce the risk of exposure
    6. a description of the medical surveillance program
    7. the OSHA standard(h) asbestos labeling and posting requirements
    8. where to get additional information
    9. the proper use of respirators and protective clothing
  11. Is asbestos awareness training provided at least once per year to people who do housekeeping operations in area(s) that have asbestos-containing material? [29 CFR 1910.1001(j)(7)(iv)]
  12. Does asbestos awareness training for people who do housekeeping operations in the areas(s) that have asbestos-containing material icnlude the following elements? [29 CFR 1910.1001(j)(7)(iv)]
    1. health effects of asbestos
    2. locations of asbestos-containing material in the facility
    3. recognition of asbestos-containing material damage and deterioration
    4. requirements of the OSHA asbestos standard regarding housekeeping
    5. proper response to fiber release episodes
  13. Are the OSHA asbestos standard (29 CFR 1910.1001) and its appendixes made available to all affected employers? [29 CFR 1910.1001(j)(7)(v)(A)]
  14. Are all employees informed self-help smoking cessation program materials are available on request? [29 CFR 1910.1001(j)(7)(v)(C)]Note: Materials such as NIH Publication No. 89-1647, or equivalent self-help materials must be provided on request.


  15. Are all surfaces maintained as free as practicable of asbestos-containing material waste and debris and accompanying dust? [29 CFR 1910.1001(k)(1)]
  16. Are all spills and sudden releases of asbestos-containing material asbestos cleaned up as soon as possible? [29 CFR 1910.1001(k)(2)]
  17. Is HEPA-filtered vacuuming equipment used for vacuuming asbestos-containing waste and debris? [29 CFR 1910.1001(k)(4)]Note: The equipment shall be used and emptied in a manner that minimizes the reentry of asbestos into the workplace. [29 CFR 1910.1001(k)(4)]
  18. Is shoveling, dry sweeping, and dry cleanup of asbestos only permitted where vacuuming or wet cleaning are not feasible? [29 CFR 1910.1001(k)(5)]
  19. Are waste, scrap, debris, bags, containers, equipment, and clothing contaminated with asbestos that is consigned for disposal, collected in sealed impermeable bags, or other closed, impermeable containers? [29 CFR 1910.1001(k)(6)]


Rinse: clear water that fulfills specified heat requirements.

Sanitary dispenser: a container that, when used with condiments, does not contaminate remaining products when condiment is dispensed.

Stem-type, product thermometer: a thermometer with a dial that reveals temperature by one or two degrees. The shaft on the thermometer can enter the product to ascertain temperature.

Potentially hazardous food: any food that consists in whole or in part of milk or milk products, eggs, meat, poultry, fish, shellfish, edible crustacea, or other ingredients (including synthetic ingredients) in a form capable of supporting rapid and progressive growth of infectious or toxigenic microorganisms. The term does not include clean, whole, uncracked, odor-free shell eggs or foods that have a pH level of 4.6 or below or a water activity (aw) value of 0.85 or less.