Document GK97oKxDLgRkdbbd6MbNNQ4RN

Manufacturers of Quality-Controlled Asbestos Products TO AIL KICOLET CUSTOMERS August 7, 1972 ; Dear Customer: i On June 7, 1972 the Occupational Safety and Health Administration of the United States Department of Labor published regulations under the Hilliams-Steiger Occupational Safety and Health Act of 1970, covering the use of asbestos in* industry. A copy of the OSKA standards is attached. In our opinion, based in part upon-comments made by the members of the i'sbsstos Ir,for.nation-Association of North America, (our industry association), if not all, major United States asbestos manufacturers believe: * fh-it currently prescribed ierel of five fH'er*s (5 micro*'*? or more in length) per cc of air.can be achieved by better housekespinc, lireroved work practices, process modifications end engineering controls, (i.e., dust collection systems), i> .s. all segments of the asbestos manufacturing industry*, with th3 probable exception of asbestos textile carding and"spinning. That tiia prospective level of two fibers (S microns or more r length) per cc of air, which is indiscriminately made applicable to all types cf asbestos, (sdteduled to becoss effective in 1576 probably is unnecessary to protect the health of the'asbestos work force. i!a anticipate, therefore, that the major ccrbsr.iGs in the V. S. asbestos aar.u- facturing Industry, during the next four yr-^rs} will sponsor research to detenu ire which icii-ds of asbestos may be dsneerous, what fiber* configurations may be danger ous and ;,r<at levels and duration cf asbestos oust exposure can be experienced with out adverse effects upon he-alth. .If the .results of this research ere as oxpacteJ. the -.'otd gathered will be used .hopefully to povvuadc the Departront of Labor not to iea-.lerer.t the two fiber standard because we think it is bir.ecossary, sic, T.hcru- a waste of industry r-asr-urcss. 00059 6 Ic th~. nteantii!*. both you sr.ri wa fl-n'c tel:;: steps to csxsoiy with the-five finer .vt:n:iord urd certain other provision-; .cf t:vi rci.;s; Jr. ions. jJicoloi: <::,,%$* yet be expert in the genera*! *p;elo of is-ducr-'U'' l-yo?-:!;?; fn* v? have i-'-ido Just ccsrits, and we have cjccytsfuTly d*:;.- .......... We offer you our assistance within the limits of our resources in taking a first look at your situation. We will, at your request, at a-reasonable cost to voti. measure dust levels in certain areas of vour factory and try to define which portions of your manufacturing process may nose problems. You may find that you already are under the five fiber level. If you are not, you may wish to use our engineering staff to advise you on how to achieve the five fiber level. You will understand that, for this service, we will have to charge an additional fee. , It may still, however, be less costly for you to use Nicolet personnel than it would be to hire your own professionals on a full time basis. If a study of your dust problem should indicate that the capital cost of compliance is high, you may wish to consider having Hicolet perform some converting operations for you. It may be that we are already equipped effectively to handle your critical operations, (or v/e can equip ourselves at a nominal cost), so that it would be more economical for us to do your converting for you. If you would like to discuss any of these matters in greater detail, please contact one of our Marketing Managers or the undersigned. In sunmary, we are satisfied that most asbestos materials, (particularly those formulated with cnrysotiie), will continue to be valuable and safe Mien used by . methods which comply with the OSHA standards. Yery truly yours, HICOLET INDUSTRIES, INC CFW/emc.. C. FRED WORKMAN VICE PRESIDENT-MARKETING '