Document 8V2q0Q1p4524B9L3VzGBMZYYe

FILE NAME: Rockwell (RCK) DATE: 1975 Dec 5 DOC#: RCK014 DOCUMENT DESCRIPTION: Letter from Rockwell International to US Dept of Labor with Comments on Proposed Asbestos Standard Rockwell International 600 Grant Street Pittsburgh, Pennsylvania 15219 December 5, 1975 Docket Officer Docket H-033 D. S. Department Room N-3620 200 Constitution Washington, D.C. of Labor Avenue, N.W. 20210 Dear Sir: Pursuant to your request for comments on the proposed standard for occupational exposure to asbestos, published in the Federal Register, October 9, 1975, the following response is made on behalf of Rockwell International Corporation. Rockwell manufactures brake assemblies for highway and off-highway vehicles. In the manufacture of these units brake linings containing asbestos must be processed. These linings are bored, rivetted and subsequently ground to specified dimensions. At present, local exhaust ventilation systems are utilized to ensure that .employee exposures to airborne concentrations of asbestos fibers remain below the current permissible limit of 5 fibers/cc. As provided in the current standard, 1910.1001 (b)(2), the permissible limit is to be reduced to 2 fibers/cc, effective July 1, 1976. Our activities have been directed towards achieving this level by modification of our processes and elimination of as many dust producing activities as possible. With the proposed reduction in permissible exposure to an even lower limit, 0.5 fiber/cc, a redirection of these efforts will be required in an attempt to achieve this 10-fold reduction in acceptable levels. Accordingly, we request that the effective date for lowering the permissible limit be set no earlier than July 1, 1977. With respect to 1910.1001 (9)(3)(iv) which provides for job re-assignment of personnel found unable to utilize respiratory protective equipment, we submit that this is Docket Officer December 5 f 1975 Page Two not appropriate for regulation. This issue is more appropriate for individual company policy determination or as a bargaining issue, both within the constraints of the handicapped provisions of federal law. We respectfully request that consideration be given to these comments in the final rulemaking procedures. Sincerely, John Maciejczyk, Director Safety & Environmental Health JM: Is