Document 7OBz5G10wR3OLgD8aQyKyxw9R

FILE NAME: Friction Materials Standards Institute (FMS) DATE: 1972 Nov 6 DOC#: FMS077 DOCUMENT DESCRIPTION: Memo to Asbestos Study Committee RE Interpretation of OSHA Labeling Requirements & .210 ROUTE #1, PAR N W S, N . J . 07652 FRICTION MATERIALS STANDARDS INSTITUTE, IN C ., November 6, 1972 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements lining and clutch facing shipments. On June 20, 1*2. the '-titute distributed * OSHA Standards for exposure to asbestos dust. A key par-g **P had to do with labeling requirements. f ' "11' f (tor a*' < s6?s h L r11TM"*1TM r>' " P * t o * fib- of members >r,ke airborne concentrations ot asDesxo The problem, in this case, is J ^ 8 oper!!tions will b* linings or clutch facings where " many cas *Jdj,Jj ^ Chairman ,ndicates perfornved-- cutting, r w v *"fj ^ `^ ^ o ^ e ^ i r b o r n e concentrations of "bes^ that these s u b s e ^ e n l i m i t s (5 fibera/cc TWA, or 10 fibers/ fibers in excess of the currenx exp ceiling). The questions are: . i nshestos type friction materials with 2* M ^ o H y p * fr* t M "ttfrials For e ^ tn T ^ iP ^ M r*** 3. l!Sl#Ub!5toi type VrPotion^ d r U l , n s ' *ri for ^ z & T T r s r s s a ss 1^ - E^. tWil. DTLr.i3s1laannea Executive Director F M S I-0 1 35 FMSI02808 T ROUTE # 4 , PARAMUS, N . . 07652 FR IC TIO N M ATERIALS STANDARDS IN STITU TE, IN C ., E -2 1 0 OSHA IABELI^ REQUIREMENTS 1 - Current labeling Practi-SS 1 1 For replacement market friction material shipments, we now provide the OSHA caution label. 1 2 For original equipment friction Serial shipments, we now provide the OSHA caution label. o panned Label inp Prwaa- 2 1 For replacement market friction ` material shipments, we plan to use the OSHA caution label. 2.2 For original equipment fiction material shipments, we P*" provide the OSHA caution label. OSHA 3 1 We interpret the OSHA labeling 3' relations to retire caution labels on friction material. shipments that will have aubse-. quent working (drilling, grinding, _iA \ . Yes CD CD lg C) (. ) CCD BY_ COMPANY. DATE, FM SI02809 FRICTION MATERIALS STANDARDS INSTITUTE, IN C ., E . 210 ROUTE 4 , PARAMUS, N . J . 07652 June 20, 1972 TOs MEMBERS OF ASBESTOS STUDY COMMITTEE SUBJECT OSHA STANDARD - POSITION OF INDUSTRY, NIOSH AND ADVISORY COMMITTEE _________________ Mr. I. H. Weaver, Chairman of the Committee, felt the attached tabulation proposed by AIA/NA comparing items in the OSHA Standard against the Inudstry position and the recommendations of NIOSH and the Advisory Committee on Asbestos Dust would be of interest to all members of this Committee. Copies of this tabulation are attached for your information. EWDtllz E. W. Drislane Executive Secretary FM SI-0 1 1 9 FM SI02833 Subioct 1. Numerical Standard OSILI XBIILAi1:1 Industry Position Five fillers with. no automatic reduction to two fibers. 2. Labeling 3- Monitoring Frequency Ho label on lockod-in asbestos containing products. The words "cancer" or "danger" should not be used on labels. Monitoring should be conducted at a frequency necessary to assure compliance with the environmental standards. Management should decide frequency. 4 Protective Clothing Ho protective clo tiling required below 5-10 times 7.1A, FMSI 02834 5 'faste Disposal Only wastes tint generate dust in cneons of limits should bo br.ygod. :u;k; on .i;;-. iotoa HIOSH/Ailvisory Connittoo Recommendation Five fibers with an automatic reduction to two fibers in two years. F in a l OSltn 3t.-tidor1 Five fibers with an autan-, reduction to two fibers ir. four years. All asbestos-containing products should be labeled. Label should carry words "cancer" and "danger." Ho label on locked-in a3b containing products. Vfords "cancer" and "danger" will not be used. ITIOdlls Annual monitoring at stations below OTA. Quarterly monitoring at stations above OTA. A D V I S O R CO;3ilTTini: Tid.ceyearly monitoring at stations below OTA. Iloathly monitoring at stations above OTA. Monitoring every si;: nanti at stations above OTA. Monitoring r.t other static at a frequency to assure compliance with environner, standards. Management to decide frequency. MI03II: Protective clothing required in all areas above limit. ADVX.iGAr CG!J:ITZ21: Ho protective clothing below 10 times OTA. Protective clothing requir only where peal: exposures above limit ClO fibers) occur. All waste should, be bagged. Only wastes that generate dust in excess of limits rmst be bagged. Subject Industry Position 6. Prequenoy of Medical Sxaninc.tions 7* Medical Surveillance ihcans every two years for workers with loss than 10 years exposure, lienns every year for workers with uox-e than 10 years exposure, or with symptoms of disease. Mriployor should "provide or make available" medical e x a m as required. 8. Medical Records knployer shall maintain records and have access to them as required to comply with regulations. 9 Wearing of Respirators- No specific recommendations. FMSI 02835 IK mmmi ;'lC.S.'C/.`.f1vi;;crv Committee Kecorwonrtntion HI31I: Sane as industry position. Advisory Committee : Sans as industry position. Final OoHA 3t-.n-.-r.rd Annual exams required of all employees exposed to asbestos dust, regardless of length of employment. HICSH: No specific recommenda tion-. Advisory Committee:. Hnployoe should select physician to perforn exam. Snployer to pay cost of exam. Sene as industry position. HICSH: Ho specific recommenda tion. Advisory Committee: 2raployer shall not Maintain records nor have access to them. Sane as industry position. HIQSH; Ho specific, reccraaendation. Advisory Committee: No employee shall be required to wear a respirator if he has any of a long list of symptoms of disease. Physicinn selected by employer to conduct medical surveillance program shall decide if employee can or cannot wear respirator.