Document 6p3K4YeO3N6X3rMr6OvRbQrg

KNS00003548 J. H. Walton Kaiser Cement Oakland, Calif. sum Association 201 North Wells Street, Chicago, Illinois 60608 PLAINTIFF'S EXHIBIT KG-343 (312)728-5675 June II, 1973 TO THE BOARD OF DIRECTORS Gentlemen: Re; Asbestos in Joint Treatment Compound On Wednesday, Hay 30, 1973, representatives of the Gypsum Association met with OSHA representatives at the Department of Labor, Washington, D. C. Present were: Frank H. Zimmerman Joseph Volk H. B. Carlsen National Gypsum Company National Gypsum Company Gypsum Association Representing OSHA were: Fred 3ishoff C. R. McClure M. SI Gabis -Deputy Administrator -Chief Enforcement Administrator -Industrial Hygienist The topic under discussion was Section 1910.93 of OSHA regulations (copy attached) pertaining to asbestos. Our concern was with the effect of the regulation on dry-mixing and sanding of joint treatment compound containing asbestos. We raised various questions in regard to responsibilities of the manufacturers of joint treatment compound where labeling, monitoring, contractor responsibilities, compliance, etc., are affected. . In strict interpretation of the text of the regulations, a number of questions arise. Although hazard levels for asbestos are stated, some preliminary investigations indicate that asbestos released In sanding joint treatment may be below OSHA hazard levels. On the other hand, preliminary tests indicate mixing of dry joint compound may be above the hazard level. It was proposed to OSHA that the Gypsum Association would consider sponsoring a monitoring program, conducted by an independent labora tory, to determine and report the dust conditions on job sites under actual field conditions. The Association program needs to be developed in detail. It should include monitoring of all dust generated in a sanding operation including mica, silica, quartz, talc and total dust. Following the development of the program and approval by the Board of Directors another meeting should be arranged with OSHA officials for their review and comnents on its acceptability. * KNS00003548 KNSOO.O03549 -2 The results of the program will provide the Gypsum Association with the necessary data to develop uniform procedures and guidelines for users of Joint treatment compounds. The OSHA representatives encouraged the Association to pursue this test program, and implied that this might allow a contractor group to possibly seek variances if they could show that Association pro cedures to mix and sand joint compound had been followed. It was definitely stated that if the proposed program was finalized and developed, it would certainly show good faith on the part of the manufacturer and the contractors who adhered to it. With the approval of the Board the Executive Vice President of the Association can appoint a three or four member Association Task Group of individuals knowledgeable in joint treatment compounds and monitor ing procedures to develop the program, evaluate Information available, and consider hazards as they relate to OSHA and N10SH requirements. This preliminary approach to the asbestos dust hazard in joint treat ment materials results from the Directors' approval of an investigation of the problem last April, and the suggestion that member companies contribute any accumulated data useful in determining a proper test program. The interest expressed by OSHA is encouraging. May we have your reaction to this report at your earliest convenience? Yours very truly. HBCrmj Enc. cc: Chairmen of all Committees H. B. Carlsen, Secretary Technical Committee KNS00003549