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pcoaucad L& ciMrt undar al by ordac ot V Judga# Paul Riley and Gordon H*g, October U, 1909, in Jattlaoq v. A. g.r Staafl. at al. 07-U23O
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to c, E. Pock - T/25 subject. ASBESTOS CAUTION LABEL
from Jon L. Kcnzen, M.D.
date July 5, 1972
cc: B. E. Boyd
T/27
R. S. Grant
T/251
W L. Kreutz T/26
J, W. Overman T/26
L. W. Saxby
T/23
J. Vyverberg New Yoric
J. J. Young
T/12
The Standard for Exposure to Asbestos Oust promulgated in the Federal Register Vol. 37, No* 110, Wednesday, June 7, 1972 by the Department of Labor under the authority of OSHA of 197Q becomes effective July 7, 1972*
The Standard prescribes a specific caution label which must be
affixed to all raw materials, mixtures, scrap, waste, debris and other products containing asbestos fibers or ^to their container* so that during any reasonably foreseeable use, handling, storage, disposal, processing or transportation, no airborne concentrations of asbestos in excess of the exposure limits prescribed*
PLAINTIFF'S EXHIBIT
Qot
At the present time the caution labels prescribed in OCF Purchase Acceptance Standards PAS.2.1.13 and PAS.2.1.43 all dated 6-14-72 do not contain the exact wording noted in the Standard. From a health warning standpoint the OCF and OSHA cauticn label wording are reasonably similar.
It would be wise to determine if the two labels are legally simi lar enough 30 an (jCF label change is unnecessary. In the' event ~ itrlh'dat^rmined a label change is required It may be advisable to request a variance in order to use the labeled cartons already in stock and to cover the period until asbestos is renovedsfrm Kaylo products and possibly Fyrcor Products.
The procedure to request a variance is outlined under Rules of Practice for Variances - Exemptions Itadar the Occupational Safety and Health Act (Code of Federal Regulations, Title 29, Chapter XVII, Part 1905, 36 F.R. 12290). Subpart B - Applications for Variances, Limitations, Variations, Tolerances, Exemptions and Other Relief, paragraph 1905.11 Variances and other relief under Section 6 (d). This information is also contained in the BNA Occupationrl Safety and Health Reporter, Page 41:4101,
If it is determined a variance is required it is -suggested this be dene through the.. Legal Department.
If you have any questions or JLKtagm
iments please contact me.
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01 009 0317