Document 1g3ZJOqxrvBnk6NDDz1Bj9o5E

FILE NAME Manville JMA DATE 1972 DOC JMA301 DOCUMENT DESCRIPTION OSHA Standard and Warning Labels Explained by AIA - Pg 1 Missing warning label prescribed in the regulations does not all of the criteria described in the law which only to the problem meet adds Each company will have to decide for itself whether a particular product requires a there should be uniformity on label or not this subject Obviously because if one company decides to label a certain product and another company decides not to label the the latter company whould be placed in a same most product untenable position with OSHA It is our understanding that OSHA is planning to use the list of locked products submitted by Dr. Fred Fundsack of M at the March hearing as its labeling criteria If this list is followed difficulties with OSHA should be few Nevertheless there are always products which do not fit any list or which may produce levels in excess of the standard at one step in the application or For example the field cutting or trimming handling process of asbestos pipe might produce levels in excess of the standard but only for the man doing the actual cutting and only very intermittently or rarely Thus to place a warning label on asbestos pipe would be quite misleading in that it would alarm all those handling the product when only one man has a potential excess exposure Our recommendations to you on labeling would thus be as follows 1 If the product is included on the list of nonlocked products it should be labeled 2 If a product is not included on the list of locked products but you consider it to be a border line case or if the product has an occasional handling or fabrication problem the following options are open a Label it and be on the safe side b Do not label it and hope OSHA doesn't question your decision C. Conduct tests to determine if the use of the product does indeed produce levels in excess of the standard Chances are that -More- PRODUCED JM - 83 most product uses of this type will meet the eight hour TWA standard of five fibers and that most problems will be in meeting the ton fiber coiling standard If tests determine that neither standard is exceeded the product obviously need not be labeled The test results should be kept in readiness in case an OSHA inspector questions your decision If the eight hour time weighted average is above five fibers per cc then the product should be labeled If the ceiling value is above ten fibers per cc which is the more likely of the two possibilities then the use of the product should be examined to determine 1 how far above ten fibers per cc is the ceiling value 2 does this particular work practice or use of the product occur frequently intermittently or only rarely 3 can the product be applied cut trimmed etc. in another fashion does not exceed such that the ceiling level ten fibers per cc After these questions have been answered it will be up to the individual company involved to weigh each answer carefully and to arrive at a decision based on the simple proposition Does this product or its use place the health of workmen in jeopardy Obviously if the answer is yes the product should be labeled If on the other hand you honestly believe that the answer is Ho then you should not feel constrained to label the product nevertheless you must be to defend your position with OSHA they question it prepared should There are a number of ways that you can place your company in a better defensive position should OSHA challenge your decision not to label a particular product The basic idea would be for you to alert the purchasers of this particular product that one or more operations in the handling application cutting etc. of the product might produce levels in excess of the standard and that JM - 83 precautions should be done through personal taken contact This could be between industry salesmen and customers or in the form of an instruction sheet delivered with the order that might specify certain work practices or types of machinery that should be used to keep dust levels low The instruction sheet for example might say nothing more than Powered bench saws without collectors should not be used in cutting this product If this is impractable operator should be provided with a U.S. Bureau of Mines approved respirator An approach of similar would this type or one indicate to OSHA somewhat should the question arise good faith on your part With regard to the coordination of industry labeling practices if your company has decided to label a product not included on the attached locked list I would appreciate being notified of this decision and the rationale behind it as soon as possible so that with other companies a uniform position can be established in the industry manufacturing the same product If you please advise have feel your or any questions problems with regard to free to contact us at any time I would asking OSHA for a decision on whether or labeling not not to label a certain product Almost assuredly they will tell you to label any border line product and that decision will become binding for the rest of the industry as well Very truly yours Matthew M. Swetonic Executive Secretary Enclosure PRODUCED JM - 83 LOCEED CONTAINING PRODUCTS REQUIRING REQUIRING A WARNING LABEL ACOUSTICAL PRODUCTS Dry spray type Foamed asbestos SILICATE SHEETS Low density sheets less than ft CEMENTS Dry Gypsum joint cements Insulating cements INSULATIONS Low density calcium silicate binders Corrugated paper Low density magnesia binders High temperature blocks & bricks PAPERS & FELTS Commercial grades unsaturated Roofing felts unsaturated Gaskets unsaturated or not encapsulated Millboards unsaturated or uncoated STUCCO & PLASTER Dry Dry mix mix cement stucco decorative plaster TEXTILES unsaturated or uncoated Braided products Cloth Listing Wicks Yarn ASBESTOS FIBER BAGS PRODUCED JM - 83