Document 7MXb0KdQm7V6x9Y96R8gw8e36

Lead Industries Association, mo. 292 Madison Avenue New York, N. Y. 10017 Telephone: (212) 532-2373 Environmental Health Department July 19, 1979 TO: All Members of the Lead Industries Association, Inc. FROM: Jerome F. Cole SUBJECT: Possible Petition for Amendment to the Stay of the OSHA Lead Standard It has been brought to our attention that it will be necessary for some members of the Lead Industries Association to hire a substantial number of new employees in order to meet the requirement for medical removal at 70 ug/100 g on March 1, 1980 under the unstayed portions of the new OSHA Lead Standard. LIA is considering petition ing the U.S. Court of Appeals for the District of Columbia Circuit for an amendment to the stay which would retain the requirement for medical removal at the current level of 80 ug/100 g until our appeal has been settled. While we anticipate that we will have a decision on this matter prior to March 1, 1979, we have been advised that some compan ies will have to begin hiring new employees by October 1, 1979 in order to assure hav ing trained individuals in time for the March 1, 1980 deadline. In order to assist us in determining whether or not we should move for an amendment to the stay along the above line, I would be grateful if you could fill out the attached questionnaire and return it to us as soon as possible. While it is our intention to ag gregate the information received, it may be necessary to go back to individual companies for an affidavit substantiating our figures. Therefore, we ask that you provide that information which can be substantiated by you should the necessity arise. Sincerely, Jerome f. uoie, sc.jj. Director, Environmental Health cc: LIA Environmental Health Committee Enclosure iko N 3723 I Lead Industries Association, Inc. 292 Madison Avenue New York. N. Y. 10017 Telephone: (212) 532-2373 Environmental Health Department I QUESTIONNAIRE July 19, 1979 Dear Member of Lead Industries Association, Inc. Recognizing that the OSHA Standard for Lead requires that on March 1, 1980, any employee with a blood lead greater than 70 ug/100 g be removed from exposure and not returned until his or her blood lead is reduced below 50 ug/100 g, 1) How many workers do you anticipate having to hire in order to meet this requirement? Answer: _________________________;____________________________________________ 2) When would these workers have to be hired in order to provide them with sufficient training to be put on the job by March 1, 1980? Answer: __________________________________________ 3) Please provide an estimate of the total cost, preferably on a monthly basis, of hiring the necessary new employees. Answer: 11^0344q KINDLY RETURN QUESTIONNAIRE PROMPTLY TO: JEROME F. COLE, DIRECTOR, ENVIRONMENTAL HEALTH, LEAD INDUSTRIES ASSN., TNC 292 Madison Avenue. New York. N.Y. 10017. N 3723.01