Document G680M4EOQ6Q99d5eV4qrKwZM7

Koveober 28, 1972 Mr. J. H. Sally Besdix Corporation 1217 S. Walnut Street South Bend, Indiana 46621 Dear Jack: Thia concerns our discussion concerning labeling requirements where brake linings are being shipped tokens toners* .7- In attempting to determine what practice one oust use, OSHA haa stated that if one is meeting the-spirit~ef its regulations it vlH not becited for violations. As a result of this, it becomes ueces&ary to interpret soae of the OSHA regulations. I as enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association (AIA/KA). You will note on these reports that Mr. Armstrong, from Bendlx corporate headquarters, attended these meetings. There is absolutely no question concerning the requirements for labeling where loose asbestos is being shipped. The big problem develops where Desbers are shipping what the AXA and OSEA refer to as locked in asbestos products - brake linings, brake blocks, clutch facings, etc. When customers of yours drill linings, chsafer linings, cut linings, or grind linings, .they may very well-raise the asbestos concentrations In the atnospheretozabove the OSHA standard.!. Some membersThave indicated that" the drilUngrand grinding.operations are problem areas in .brake lining factories with existing exhaust systems. Therefore, if a customer of yours started drilling or grinding without hawing proper dust collectors, he would probZbly be in violation of the OSHA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to warn the customer of this possibility. The fora which the warning takes is still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for e violation. Therefore, '2 you ceuid'r put in every one of your skids, or cartons, or pallets, a warning notice to the effect: "?ouer tools without dust collectors should not be used for machining, cutting, or sanding this product." If a notice such as this were enclosed with every carton, or stenciled on the outside of the carton, it is likely that you would be meeting the spirit of the regulations. If you were to write your customer aad tell him about this with every shipment cade, you would probably be also meeting the spirit of the regulations. If you send a one time letter to your customer saying this, it is hard to say whether you would be meeting the spirit of the regulations.