Document 6w1QR02y30VBL7RV2wX38m28o

FlcICTIJi.' IATERIALS STANDARDS INSTITUTE, INC., 2-210 ROUTE 4, PARAiiUS, N.J. 07652 BULLETIN H 0. 7 0 6 January 29, 1981 ENVIROMUEirTAL PROTECTION AGENCY (EPA) PROPOSALS FOR REPORTIHG AHD RECORDKEEPIUG FOR ASBESTOS UANUFACTOEERS, IMPORTERS AMD PROCESSORS The EPA's Office of Toxic Substances has proposed requirements for asbestos prod ucts manufacturers, importers and processors on the reporting on asbestos usage. These proposals are authorized in Section 8 (a) of the Toxic Substances and Control Act (TSCA). To Indicate how far-reaching these reporting requirements are, one can note the following from the first page of the proposed rules: Importers Include those persons who import asbestos in bulk form, or as part of any product. Thus, persons who import automobiles that contain asbestos brake linings are "manufacturers" of asbestos for purposes of TSCA. A brake lining or clutch facing manufacturer in the United States would be a primary processor as he uses raw asbestos in the friction product. He would also be a secondary processor when he assembles brake linings to shoes. A party who imports lined or unlined shoes would be a "manufacturer" as Indicated above. A rebuilder who purchased brake linings for assembly would be a secondary processor. For more authoritative definitions, please refer to Page 8213 of the January 26, 1981 Federal Register, copy enclosed. The Institute is enclosing the notice as it appeared in the Federal Register of January 26, 1981. We have enclosed Pages 8200-8214 only. The forms that are referred to take an additional 35 pages (to Page 8249). If llembers vrish a copy of these additional pages, please request them of the Institute Office. It should be noted at this time that this notice is a proposal. As noted, the EPA will accept written comments relative to this proposal which are submitted on or before ilarch 27, 1981. While this is a far-reaching rule if adopted, a rule of this nature would be expected based on the reading of TSCA and the lnititatives that the Office of Toxic Substances has already taken in the asbestos area. EHD/erc Enc: E. !7. Drislane Executive Director Copies: Delegates and Alternates Health and Environmental Affairs Committee Active llembers - List C Regional llembers Licensees FMSI 03628