Document 2jZ1m26RQ4OKa3gMp2R6aYdLp

FILE NAME: Asbestos Cement Pipe and Sheet (ACPS) DATE: 1977 Sept21 DOC#: ACPS023 DOCUMENT DESCRIPTION: Letter from Johns-Manville to A/C Pipe Producers Assoc Johns-Manville Sales Corporation Ken-Caryl Ranch Denver, Colorado 8021 7 (303)979-1000 C*JL_6S'lfe September 21, 1977 Mr. J. C. Jackson A/C Pipe Producers Association 1600 Wilson Blvd., Suite 1308 Arlington, VA 22209 Dear Joe: ' WARNING LABELS FOR A/C PIPE At the Market Development Committee Meeting, the subject of putting some type of warning label on our pipe was discussed. It was the consensus of the committee that we should not do so, but, if required, the label should be similar to page 19 of the Work Practice Manual. As you know, Jay Baker and I were in Los Angeles on Friday and spoke to the California OSHA inspectors regarding steps being taken by the AC Industry to protect the health of workers who install A/C Pipe. At this meeting, we asked their opinion on whether or not we should put a sticker similar to page 19 on our pipe, and, if we did, would it infer that A/C Pipe would be considered a "labeled" product, and one that would require reporting, etc. Generally, the inspectors thought it would be a "good idea*, but that "Not recommended" should read "Do Not Use". Dr. Fred Ottoboni was unable to be present at the meeting, but I spoke to him today to get his opinion regarding the advisability of such a notice on our pipe; and if we put it on, would he advise us in writing that this act on our part would not be interpreted as "labeling" our pipe. Dr. Ottoboni was of the opinion a label of this type was not necessary, and wondered why we wanted to put it on. He said he would not consider it a "label" in the OSHA sense of the word, but would not care to put this opinion in writing at this time. In about 30 or 60 days, after there was time to evaluate the situation further, he said he would be in a better position to make such a comment, and also to possibly issue an "administrative interpretation" on the California OSHA Asbestos regulation stating compliance with the ACPPA Work Practice Manual would be considered as being in compliance with the California OSHA Asbestos regulation. Page 2 Mr. J. C. Jackson September 21, 1977 He also stated he had received some communications from an A-C Pipe producer that they planned to label their pipe in some manner. My interpretation of conversations with Dr. Ottoboni is that he is confused as to why we are so anxious to "label" our pipe in some manner. It is my opinion that we wait the 30 or 60 days that Dr. Ottoboni suggested before we take any action in this regard. Let's see what Dr. Ottoboni and California OSHA do before we act. Manager nd Environmental Development CTS MARKETING DIVISION A. C. Boush Lloyd Ambler Lee Taylor John Beals fEd Fenner Denis Kelleher Art Kahn COPY FORM INITIALS DATE BOX 0 / / ^ NUMBER 2 SEGMENT NO. REQUESTING PARTY NOTES LoS-c-^-^-q tY\e^ 9 T 7