Document 2NRO3pKaJ1voBJrQ3vYX6KZ27

FILE NAME: Union Carbide (UC) DATE: 1972 Mar 15 DOC#: UC398 DOCUMENT DESCRIPTION: Letter to Director of Safety and Health Standards, Dept of Labor from the Manufacturing Chemists Assoc. RE Proposed RuleMaking on the Standard for Exposure to Asbestos 'f <30tl.v M A N U F A C T U R I N G CMCMI9TS A980CIATlGi# U 7 2 A CENTURY OP SERVICE 197 H2S CONNECTICUT AVENUE, N, W. WASHINGTON, D, C, MOM fW) 4S3-41M **rdh 15, 1972 i Ife' fi,- W. S can n ell, D ire cto r -lUCioft S afety **4 I n ^ b S ta a ^ b k tt. S . Department o f Xajbor 400 F ir s t S tre e t, a . a . Washington, 0. C. 20210 *ar Mr. Scannell* The Manufacturing chemists Association (MCA) submits the following eomeenta with respect to the Sotice of Pro posed Rule Making on the Standard for Exposure to Asbestos Oust which appeared in the January 12, 1972 Federal Register. MCA is a nonprofit trade association of 165 United States aoapany embers representing ore than 90* of the production capacity of basic industrial chemicals within this country. Our comments deal specifically with the labeling pro posal in the "Criteria for a Recommended Standard on Occu pational Exposure to Asbestos* which, according to the s ^ l e m e n t to the above notice that appeared in the February 5, 1972 Federal Register, will be submitted by the National Institiite for Occupational Safety and Health for inclusion f in the record of the proceeding. Since this labeling proposal was introduced following the 30-day period for comment, it was obviously not possible i to reply to it within that period. A phone call to your office on March 2 resulted in an indication that Oar comments on this proposal would be considered as though they had been submitted within the time limitation. . Attached is our suggested label text for asbestos. This ext incorporates all the language proposed by NI0SH, and expands upon it to reflect additional critical information in the criteria which, in our opinion, will strengthen the message. l . Mr* G. F. Scannali March 15, lf72 Paga Two This l*bl text has been developed according to the principles contained in the MCA "fluid* to Precautionary Labeling of Hazardous Chemicals." First issued in 1945 ^ n a L x *ub8eqyent occasions, this guide has become a wideiy-irecogniaed text, its principles have been accepted b y the chemical industry in general, and by various agencies or government, for a period of over 28 years. You Will note that the attached suggested label does not include the HPPA 704M diamond sysfcol as proposed by MIOSB MCA has consistently objected to use of this symbol as a m e of expressing the hazards of substances, because of the need for an extensive educational program before interpretation of the numbers becomes comprehensible to the uninitiated, and because the system was designed to describe hazards under emergency conditions only. MCA believes that the English lan guage representation of hazards is more effective than the SFPA symbol, and therefore should be used in this case. Very truly yours. Attachment CCi Dr. Charles H. Powell ( 504) Micros WMU* tSG * * 2 ? * DEWS1tB M W * ISJOKY (ASBSST08XS, z * m CAUcm ) w not; breathe dust. " " E L S E .* - " * " 0l0th^ - U * va=u, " TM TM - = 1 . or t