U.S. Department of Labor

Occupational Safety and Health Admistration

Directorate of Science, Technology & Medicine

Office of Science Technology Assessment

Asbestos-Automotive Brake and Clutch Repair Work

Safety and Health Information Bulletin

 SHIB 07-26-06

Purpose

OSHA is issuing this Safety and Health Information

Bulletin to inform employees and employers in the

automotive brake repair industry of the precautions

that must be taken when working with automotive

brakes and clutches containing asbestos. In the case of

do-it-yourselfers*, OSHA does not have jurisdiction,

and OSHA does not require theses practices to be

followed. To reduce the potential exposure to

asbestos, EPA strongly recommends that all

automotive brake and clutch repair work be done by

professional auto mechanics. Although the use of

asbestos in friction products is declining annually, it

remains a substantial source of potential exposure. In

addition, there is still potential exposure to asbestos

contained in automotive brakes and clutches on older

vehicles in need of service. Exposure to asbestos, if

not properly controlled can cause mesothelioma, lung

cancer, and asbestosis. Symptoms may not appear

for years, even decades, after contact with asbestos

fibers.1

Background

Many brakes and clutches used in new and recent

model automobiles do not contain asbestos.

However, it has not been totally eliminated. Some

reports have indicated that many mechanics and

employees in the automotive repair shops as well as

do-it-yourselfers are unaware that asbestos may be

present in both old and replacement brakes and

clutches.

OSHA’s asbestos standard requires the use of

controls and safe work practices when employees

work with brake shoes and clutches that contain

asbestos. These requirements are detailed in 29 CFR

1910.1001 and specifically 1910.1001(f)(3) and

Appendix F of the standard - Work Practices and

Engineering Controls for Automotive Brake and

Clutch Inspection, Disassembly, Repair and

Assembly (http://www.osha.gov/sltc/asbestos/

index.html.). The requirements also are discussed in

the Federal Register at 59 FR 40964, 40985-87

(August 10, 1994) and 60 FR 33983 (June 29,

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 Asbestos in Brakes Exposure and Risk of Disease, Richard A. Lemen, PhD, MSPH, American Journal of Industrial Medicine

45: 229-237 (2004)

* Non-employees outside the automotive repair industry who typically repair or replace their own brakes at home. These

individuals are not subject to the OSHA requirements in this Safety and Health Information Bulletin.

For more information about EPA’s asbestos program, do-it-yourselfers may visit EPA’s website at www.epa.gov/asbestos or

you may call the asbestos ombudsman’s hotline/clearing house at 1-800-368-5888.

This Safety and Health Information Bulletin is not

a standard or regulation, and it creates no new legal

obligations. The Bulletin is advisory in nature,

informational in content, and is intended to assist

employers in providing a safe and healthful

workplace. Pursuant to the Occupational Safety

and Health Act, employers must comply with

hazard-specific safety and health standards

promulgated by OSHA or by a state with an OSHAapproved state plan. In addition, pursuant to Section

5(a)(1), the General Duty Clause of the Act,

employers must provide their employees with a

workplace free from recognized hazards likely to

cause death or serious physical harm. Employers

can be cited for violating the General Duty Clause

if there is a recognized hazard and they do not take

reasonable steps to prevent or abate the hazard.

However, failure to implement any recommendations

in this Safety and Health Information Bulletin is not,

in itself, a violation of the General Duty Clause.

Citations can only be based on standards, regulations,

and the General Duty Clause.
1995), as well as in OSHA Directive CPL 2-2.63

(revised).

OSHA Work Practices and Engineering Controls

/ OSHA Methods

All automotive brake and clutch repair facilities in the

United States must comply with the OSHA asbestos

standard. The proper use of engineering controls and

work practices by properly trained employees

working on automotive brakes and clutches will

reduce their asbestos exposure below the permissible

exposure level of 0.1 fiber per cubic centimeter of air,

expressed as an 8-hour time-weighted average.

Respiratory protection is not required during brake

and clutch jobs where the control methods described

below are used.

The two preferred OSHA methods to control

asbestos dust during brake and clutch repair and

service are: (1) a negative pressure enclosure/

HEPA (high-efficiency particulate air) vacuum

system, and (2) the low pressure/wet cleaning

method. The employer may use other methods (in

conjunction with written procedures), to reduce

exposure to levels equivalent to the negative

pressure enclosure/HEPA vacuum system. For

facilities that inspect, disassemble, reassemble and/

or repair five or fewer brake or clutch jobs per

week, the wet method (described in paragraph D

of Appendix F) can be used. The spray can/

solvent system method can be used as an

alternative preferred method since it meets the

equivalency criterion of the negative pressure

enclosure/HEPA vacuum system method. Proper

training is essential to ensure that employees use

the methods in an effective manner.

Negative pressure enclosure/HEPA vacuum

system method

The negative pressure enclosure/HEPA vacuum

system method includes the following steps:

1. Enclose the brake or clutch assembly to

prevent release of asbestos fibers into the

employee’s breathing zone during brake or

clutch inspection, disassembly, repair, and

reassembly operations. Use a transparent

enclosure with impermeable sleeves.

2. Seal the enclosure tightly and thoroughly,

inspect for leaks before beginning work.

3. The enclosure must be transparent so that the

employee can clearly see the operation during

brake or clutch inspection, disassembly, repair,

and reassembly. The enclosure must also have

impermeable sleeves to allow the employee to

handle the brake and clutch assembly without

penetrating the enclosure. The integrity of the

sleeves and ports must be inspected before

work begins.

4. Use a HEPA-filtered vacuum to keep the

enclosure under negative pressure

throughout the operation. Compressed air

may be used to remove asbestos fibers or

particles from the enclosure.

5. Use the HEPA-filtered vacuum first to

loosen asbestos residue from the brake and

clutch parts, then evacuate the loosened

material from the enclosure into a vacuum

filter.

6. When the vacuum filter is full, spray it with a

fine mist of water before removing it.

Immediately place it in a labeled,

impermeable container and dispose of it as

asbestos waste in accordance with federal,

state, and local regulations and in

compliance with 1910.1001(k)(6). The

label must include the following information:

“DANGER, CONTAINS ASBESTOS

FIBERS, AVOID CREATING DUST,

CANCER AND LUNG DISEASE

HAZARD.”

7. Immediately clean spills or releases of

asbestos containing waste material from

inside the enclosure or vacuum hose or filter.

Properly dispose of waste as asbestos waste.

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Vacuum enclosure units should be large enough to fully

enclose and remove the brake drum with enough room

for hammering if the drums are difficult to remove

because of wear, rust, or other reasons. Enclosure

systems should have good interior lighting to illuminate

the work area. The enclosure should completely

enclose the brake drum, and form a tight seal behind

the backing plate. Air guns should never be aimed

towards the seal as this may reduce or eliminate its

protective ability.

After cleaning with compressed air, the inside surfaces

of the enclosure should be HEPA vacuumed to keep

the inside clean and maintain visibility. Each brake

component should be vacuumed as it is removed and

the backing plate should be vacuumed after all the

components have been removed. Rags used to wipe

or clean used brake parts, should not be used to wipe

hands. Mechanics should wear an appropriate

NIOSH-approved respirator for asbestos when

changing vacuum unit filters.

Low pressure/wet cleaning method

The low pressure/wet cleaning method involves

the following steps:

1. Position a catch basin under the brake

assembly to avoid splashes and spills.

2. Gently flood the brake assembly with water

containing an organic solvent or wetting

agent to prevent asbestos-containing brake

dust from becoming airborne.

3. For drum brakes, ensure that the water

solution flows between the brake drum and

the brake support before removing the brake

drum.

4. After removing the brake drum, thoroughly

wet the wheel hub and back of the brake

assembly with the water solution to suppress

dust.

5. Thoroughly wash the brake support plate,

brake shoes, and other parts before

removing the old brake shoes.

6. If your system uses a filter, wet the filter when

it becomes full and before removal, with a fine

mist of water, and place immediately in an

impermeable container. Label the container

and dispose of it as asbestos waste.

7. Immediately clean spills of asbestos-containing

liquid or asbestos-containing waste material

using a HEPA-filtered vacuum and/or wet

methods. Properly dispose of waste as

asbestos waste.

8. Dry brushing is prohibited.

9. The brake washer solution should be changed

regularly for maximum efficiency of the unit.

Wet method

For shops that perform infrequent brake work and

clutch repair work, OSHA allows the use

of a wet method as a “preferred” method. Therefore,

in facilities in which five (5) or fewer brake “jobs” (five

brake “jobs” are equivalent to five vehicles) or 5

clutches, or some combination totaling 5, are

inspected, disassembled, reassembled and/or repaired

per week, the mechanic/technician may control

potential asbestos exposure through the use of a spray

bottle, hose nozzle, or any implement capable of

delivering a fine mist of water or amended water at

low pressure to wet down the drum or clutch

housing before removing it and to control asbestos

fiber release during subsequent activities. However,

any wastewater generated must be captured and

properly disposed of without allowing it to dry on any

surfaces. OSHA anticipates that using a spray bottle

will adequately control dust without generating a large

volume of wastewater.

The wet method requires the following steps:

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1. Brake and clutch parts must be wetted with

water or amended water before taking any

other action.

2. Wipe the brake and clutch parts clean with a

cloth.

3. Place contaminated cloth into an impermeable,

properly labeled container, and then dispose

of it as asbestos waste. Alternatively, the cloth

can be laundered to prevent the release of

asbestos fibers in excess of 0.1 fiber per cubic

centimeter of air, expressed as an 8-hour timeweighted average.

4. Any spilled water or amended water or

asbestos-containing waste material must be

cleaned immediately with a cloth or HEPAfiltered vacuum and not allowed to dry.

5. Do not dry brush.

The simplicity of the wet control does not eliminate the

need for correct work practices. For example,

holding the spray nozzle too close to the brake surface

may cause asbestos fibers to become airborne. Brake

components should be sprayed to saturate the parts as

they are removed from the assembly.

Equivalent methods

Like the preferred methods, an equivalent method

must include a detailed description of the practices

that must be followed when the method is used.

An employer who uses such a method must have a

written description of the method that contains

sufficient detail that the method can be reproduced.

The employer must provide information demonstrating

that the exposures resulting from an equivalent method

are equal to or less than exposures from the negative

pressure enclosure/HEPA vacuum system method.

For purposes of equivalency, employee exposures

must not exceed 0.016 f/cc, as measured by the

OSHA reference method and averaged over at least

18 personal samples.

The following method, spray can/solvent system,

may be used as an “equivalent” method. The spray

can/solvent system may be used when proper work

practices are followed. At a minimum, the spray can/

solvent system method must follow detailed written

procedures including the following:

1. Wet the brake and clutch parts with the spray

can/solvent before taking any other action.

2. Wipe the brake and clutch parts clean with a

cloth.

3. Place contaminated cloth into an impermeable,

properly labeled container, and then dispose

of it as asbestos waste. Alternatively, the cloth

can be laundered to prevent the release of

asbestos fibers in excess of 0.1 fiber per cubic

centimeter of air, expressed as an 8-hour timeweighted average.

4. Immediately clean any spilled solvent or

dispersed asbestos with a cloth or HEPA

vacuum.

5. Dry brushing during spray can/solvent

system operations is prohibited.

The solvents typically used in brake and clutch

work are hazardous chemicals, which requires the

employer to comply with the Hazard

Communication standard. If the solvents are

flammable, appropriate precautions against fire

and explosion must be taken.

Best Practices

Mechanics should assume that all brakes have

asbestos-type shoes. Worn nonasbestos-type brake

shoes cannot be readily distinguished from asbestostype shoes. If a mechanic assumes incorrectly that a

shoe is a nonasbestos-type and fails to utilize brake

dust control procedures, increased asbestos exposure

may result.

Mechanics must be trained in the correct and most

effective way to use the control system selected by

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the facility manager or owner. The danger of

increased exposure to asbestos as the result of

improper work practices should be explained.

Examples of improper work practice include: directing

an air nozzle at an enclosure seal, placing the nozzle of

a spray mist too close to the work surface, not placing

the vacuum nozzle close enough to the contaminated

surface, turning on the vacuum pumps before

positioning the vacuum enclosure over the wheel and

leaving them on when removing the enclosure, and

splashing or spilling contaminated solutions on the

floor. A control system must always be used and

consistent work procedures are essential.

Use pre-ground, ready-to-install parts when possible.

If asbestos-containing friction materials must be

drilled, grooved, cut, beveled, or lathe-turned, low

speeds should always be used to keep down the

amount of dust created. All machinery should have an

adequate, HEPA equipped local exhaust dust

collection system to prevent asbestos exposures and

shop contamination. Immediately clean spills of brake

dust or contaminated solutions by HEPA vacuuming or

wet mopping.

A regular maintenance program for the system

used to control brake dust is essential.

Maintenance should include checking and

replacing seals, nozzles, other hardware,

contaminated filters and solutions. Any

deficiencies such as ineffective seals, or air nozzles

should be repaired. Disposal of asbestos

contaminated material, whether it is filters or

solutions, must be in accordance with federal and state

regulations and in compliance with 1910.1001(k)(6).

Periodic cleaning will help reduce the possibility of

asbestos contamination of workbenches, floors, etc.

Mechanics should perform brake and clutch work in

an area isolated from other work areas. Signs should

be posted informing employees not to eat, drink, or

smoke in the brake and clutch work area. Asbestos

and other potentially toxic materials can be ingested or

inhaled during these activities.

Personal hygiene, such as frequent hand washing with

soap or detergent, should be stressed. Changing from

soiled work clothes into clean clothes before leaving

work provides additional protection against bringing

asbestos into the home environment. A laundry service

with facilities for cleaning asbestos contaminated

clothing must be provided for any asbestoscontaminated work clothes.

Conclusion

Engineering controls and good work practices must be

implemented throughout the process of performing

brake and clutch inspection, disassembly, repair, and

assembly. The four types of control systems or

methods described here can effectively reduce

employees’ asbestos exposure below the OSHA

permissible exposure level.

Information about job hazards must be disseminated

through a training program that describes how to do

properly perform a task, how each work practice

reduces potential exposure, and how employees can

benefit from these practices. No matter, which control

system, is used, employees must be trained in how to

properly use it. Employees (and do-it-yourselfers

who choose not to have brake and clutch work

conducted by professional mechanics) who can

recognize and control hazards are better equipped to

protect themselves from asbestos exposure. Training

and work practices should be frequently reinforced.

Business owners who are concerned about the cost

of professional help can contact the OSHA

Consultation Project Office in their state for free

consultation service. Priority is given to businesses with fewer than 250 employees at a

worksite, with further consideration given to the

severity of the worksite problem. The Consultation

Program can help the employer evaluate and prevent

hazardous conditions in the workplace that can cause

injuries and illness.

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