Document 44KDK1dmNjG1xV3jROpe9Rj9Q

FILE NAME: Allied Signal Bendix (ASB) DATE: 1972 Nov 28 DOC#: ASB051 DOCUMENT DESCRIPTION: Letter to Bendix from The Friction Materials Standards Industry RE Warning Labels November 28, 1972 Hr. J. H. Kelly Bed 'll Corporation 121" S. Walnut Struct ' Sou".h Bend, Indian.* 46621 De.'" Jack: Thic concerns our discussion concerning Labeling requirements when* brn>i linings a m being shipped to customers. In -ttempting to determine vhat practice one must use, OSHA. has statm-d that if one is meeting the spirit of its regulations it will not be cited for violations. As a result of this, it becomes necessary to interpret some of the OSHA regulations. I am enclosing with this letter copies of letters written by the Executive Secretary for tha Asbestos Information Association (AJA/NA). You will note on theae reports that Mr. Armstrong, from Beadix corporate headquarters, attended there meetings. There is absolutely no question concerning the requirements for Libeling where loose asbestoa is being shipped. The big problem develops where members are shipping what the AIA and OSHA refer to as locked in asbestos products - brake linings, brake blocks, clutch facings, etc. When customers of yours drill linings, chamfer linings, cut linings, or grind linings, they may very veil raise the asbestos concentrations in tha atmosphere to above the OSHA standard. Some members have indicated that the drilling and grinding operations are problem areas la brake lining factories with exisClog exhaust systems. Therefore, if a customer of yours started drilling or grinding without hawing proper dust collectors, he would problbly be in violation of the OSHA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to warn the customer of this possibility. The form which the warning takes is still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for a violation. Therefore, "2 yon cetrid'r put in every one of your skids, or cartons, or pallets, a warning notice to the effect: "Power tools without dust collectors should not be used for machining, cutting, or sanding this product." If a notice such as this were enclosed with every carton, or stenciled on the outside of the carton, it is likely that you would be meeting the spirit of the regulations, if you were to write your customer aad tell him about this with every shipment made, you would probably be also meeting the spirit of the regulations. If you send a one time letter to your customer saying this, it is hard to say whether you would be meeting the spirit cf the regulations. Mr. J. 2. Rally Bendix Corporation - 2- Noveaber 23, 1972 I as eneloing a copy of the warning label suggested in the OSEA regulation* vhere loose asbestos fibers are being shipped, and the "Instruction Sheet" suggested where a customer la to do further eachining on clutch facings, brake lining, etc. I hope this is enough information for you. Dave Stone attended our most recent Asbestos Study Committee Meeting vhere the subject of labeling was brought up. Your Mr. Armstrong is aware of some of the controversy concerning labeling. The current survey indicates that no members are new labeling shipments. A slight majority of those responding to date indicate that they interpret the OSSA regulations to require some kind of s warning where subsequent work is to be done on brake linings. This is controversial item for the Institute in that some members feel that one or two companies era trying to railroad them into labeling. Another group of companies feel that we should comply with the spirit of the law new and It is not fair if they do the proper labeling and their competition does not. ~ Sincerely, FRICTION HAXERIALS STANDARDS INSTITUTE EKDsllz E. W. Drislane Executive Director