Document 0qepoZkeVJgge5E1DL62g838b

tfiCTjon materials standards institute, in:., i-2'c fcovwnber i, 1972 TO: iDaiegates A Alternates Asbestos Study Committee SUBJECT: Inierprstation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is roqv&siing a survey of members on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. On June 20, 1972, the institute distributed to ail members a copy of the OSHA Standards for exposure to asbestos dust. A key paragraph in the standards had to do with labeling requirements? (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products contain ing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other materia! so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. The problem. In this case, is the shipment of asbestos obtaining brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos fibers in excess of the current exposure limits (5 fibers/cc TWA, or 10 fibers/cc ceiling). The questions are: 1. Tip vou now 'tvbei arsbws+es t-ype fr ieiion at-er 4-als -'<Lih the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. do v&j_b\en_fo label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? y* Ip you jnierprpt the OSHA Regulations on leveling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? Would you please collate this--or have it done by the Individual responsible for implementation of the OSHA Standards--and return to we at the institute Office. E. t iDrislant Executive Director WV-06024 HALS STAOAnOS 6. I > OSHA LA39JNG ftgCUIREK-NTS 1. Current Labeling Practice 1.1 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original eouioment friction material shipments, we now provide the OSHA caution label. 2. Planned Labeling Practice 2.1 For replacement market friction material shipments, we plan to use the OSHA caution label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. interpretat ion of OSHA Label ino _Begu 1st ioos 3.1 We interpret'the OSHA labeling regulations to require caution labels on friction material shipments that will have subse-t quent working (drilling, grinding, etc.). ... _ -- ( _) ^--. () ( -) ..... -- L__J & cz:i !) <) {) BY COMPANY. DATE