Document 1wyD40MyGjejdxV73n5r92LK

FICTION MATERIALS STAT 'RDS INSTITUTE, INC., -210 ROT^/?4^FARAMUS, N.J. 07$52_ November 6, 1972 "0: Delegates 4 Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements PLAINTIFF'S EXHIBIT The Chairman of the Asbestos Study Committee is requesting a survey of members on their interpretation of the labeling requirements for asbestos type brake lining and clutch facing shipments. _.__0n .June 20,_1972^jthe Institute distributed to alL members a copy of thazn: OSHA Standards for exposure to asbestos dust. A key paragraph in the standards had to dc with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no laoel is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material 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 coetaining 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 exposuce ,1 imits (5 fibers/cc TWA, or 10 fibers/^ ceiling). The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do vou plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 2. Dc vou ret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? Vould you please complete this--or have it done by the individual responsible for implementation of the CSHA Standards--and return to me at the Institute Office. E. i7. Drislane