Document 2jJyVpM481yKLoX9eYa35zj95

'FRICTION MATERIALS STAliDARDS INSTITUTE, INC., E-210 ROUTE 114, PARAMUS, N.J. 07652 September 23, 1974 TO: Asbestos Study Committee SUBJECT: AIA/NA Recommended Revisions to OSHA Asbestos Standard. In August 1974 we distributed to Committee Uembers a copy of the AIA/NA recommendations for revisions to the OSHA Asbestos Standard. \ole asked for comments concerning these recommendations. Based on comments from 'Hessrs. \oJeaver and Wagner, I drafted a letter to AIA/NA. You Chairman reviewed the content of this letter which is being sent to AIA/NA. A copy is attached. The foregoing is for your information. EVID/lmc Enc. E. l\1. Drislane Executive Director fMSl 06739 TELEPHONE 120 II 84!5-0440 FRICTION MATERIALS STANDARDS INSTITUTE, BERGEN MALL OFFICE CENTER E. 210 ROUTE 4 PARAMUS. N. J. 07652 INC. September 23, 1974 !1r. R. H. Uereness Asbestos Information Association/NA 1660 L Street, Nt-1 Washington, D.C. 20036 Subject: Recommended Revisions to OSHA Asbestos Standard Dear Bob: The committee members within the Friction Materials Standards Institute responsible for monitoring asbestos regulations have reviewed your Association's recommended revisions and suggested work practices for the OSHA Asbestos Standard. An overall comment is that your proposal is well prepared and that it represents a realistic approach which if accepted will safeguard the health of employees who work in the manufacture of asbestosbearing friction materials. There is, however, one item on which committee members have expressed concern, and that is the recommendation to add a new section (d) (1) (vi): "(vi) t..Jhere respirators are permitted under subdivision (iv) of this subparagraph, their use shall be subject to the following limitations: 1. Respirator shall not be worn for more than 60 minutes in any 8-hour shift. 2. Respirator shall not be worn for more than 30 minutes in any hour in the 8-hour shift. 3. Exposures do not exceed 10 times the permissible limits and protection can be achieved by use of an air purifying respirator." It is felt that addition of this sub-paragraph vi is unnecessary, and that addition of sub-paragraph iv is sufficient. In addition, it is felt that the limitations indicated by suggested sub-paragraph vi may be confused with exceptions permitted by existing sub-paragraphs i, ii, iii and iv. Your Association's consideration of these comments will be appreciated. E\ID/lmc Sincerely, E. W. Drislane FMSI 06740