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Occupational Safety and Health Administration (OSHA)
Copper is regulated by both Federal OSHA and Cal OSHA (Clanerman, 1995). The maximum permissible
exposure limit (PEL) for copper dust 1 milligram/cubic meter. This standard would apply to all grinding
activities in brake pad manufacture or servicing. The PEL for copper fumes is 0.1 mg/m3 which would
apply to welding activities in brake pad manufacture. The health effects associated with breathing copper
particles is that it disrupts the body’s normal enzymatic activity.
OSHA collects product composition information via material safety data sheets (MSDSs). Manufacturers
are required to submit MSDSs for all hazardous substances contained in the product. There is no set format
for MSDSs and manufacturers are not required to submit percentage by weight information.
The maximum airborne PEL for copper is not ordinarily exceeded during proper brake pad use and
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servicing. Auto repair shops are required to use the OSHA Awet method@ to replace brake pads. Under this
method, dust is washed into a catch container limiting worker exposure to airborne dust particles. Auto
repair shops that do not follow OSHA requirements may use air guns to remove the dust that builds up
around disc and drum brakes. The air gun method may cause worker exposure above the PEL when
servicing semi-metallic brake pads.
OSHA=s collection authority appears limited by the discretion product manufacturers can exercise when
reporting hazardous substances on MSDS forms. Brake pad manufacturers do not report percentage by
weight of copper since it is in their best interest to retain this information as a trade secret.