Document KRnKnKbonMy2yNBYk1LBko2nQ

I Roveaber 28, 1972 Hr. J. H. Rally bendUt Corporation 1217 S. Walnut Street South Bend, Indiana 66621 Dear Jade3 This concerns our discussion concerning labelIns requirements where brake lining* are being shipped to easterners. In attempting to determine what practice one oust use, OSSA be# stated that If one is nesting the spirit of its regulations it will not be cited for violations. As a result of this, it becomes necessary to interpret mm of the OSH& regulations, X am enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association (AIA/HA). You will note on these reports diet Hr. Armstrong, iron bendix 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 when mashers are shipping vbat the A2A and OSHA refer to as locked io asbestos products - brake linings, brake blocks, dutch facings, etc. When cuetuners of' yours drill linings, chamfer linings, cut linings, or grind linings, they stay very veil raise the asbestos concentrations la the atmosphere to above the OSBA standard. Some acafeeta heve indicated thst the drlllieg end grinding operations are problem areas in brake lining factories with existing ea&aust systems. Therefore, if e customer of youzs started drilling or grinding without having proper dust collectors, -fae^would >yrehCaly-be~ia -*aoijrrlrm -nf .the Q5BA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to vara the customer of this possibility. Tbs form which tbs warning takes is still not definite but the beet guidance seems to be If you meet the spirit of the regulations yea will not be cited for e violation. Therefore, yon oeefcdcr put in srvery one of your eklds, or cartons, or pallets, a warning notice to Che affect: "Power tools without dust collectors should not be used for mAchingng, cutting, or sanding this product.** If a notice such aa this were enclosed with every carton, cr stenciled on the outside of the carton. It is likely chat you would be meeting the spirit of the regulation*. If you were to write your customer sad tell him shout this with every shipment made, you would probably be alee meeting the spirit of the regulations. If you send a one else latter to your customer saying this, it is hard to aay whathar you would be meeting the spfrit _of_the_rmgulatioas. P-FMSh 0C20 WV-06025 hr. J. E. Eelly Bcndir Corporation 2- - Sovsaiber 28, 1972 I am enclosing a copy of the vetoing label sussested In the Q5BA regulations where loose ashestea fibers are being shipped, sad the "Instruction Sheet" suggested where e cuiunr is te do further eacMnleg on dutch fadags, brake lining, etc, X hope this ia enough Information for you. >m Stone extended our boss recent asbestos Study Cotmittee Maeting where the subject of labeling was brought up. lour Kr. Armstrong is aware of some of the controversy concerning labeling. The current survey indicates that no neabers are now labeling shipments. A slight majority of those responding to date indicate that they interpret the OSSA regulations to require ease Usd of a versing where subsequent work is to be done on brake linings. This Is controversial Itsa for the Institute In that some mornsera feel that one or two companies are trying to railroad then into labeling. Another group of companies feel that we should comply with the spirit of the law sow and It is not fair If they do the proper labeling ad their competition does not. Sincerely, FRICTION MATERIALS STANDARDS INSTITUTE 55:liz E. W. Drislane Esscutlve Director