Document Mad3nVL2Z8VxZB0RwYaRZbox

Minutes of the Meeting Asbestos Study Committee -5- October 24, 1975 Written consents concerning the proposal Bust be submitted in quadruplicate: Docket Officer, Docket H-033 US Department of Labor, Rood H3620 200 Constitution Avenue N.W. Washington, D.C. 20210 The question was asked as to what would be the most effective means of coEsnunieating with Washington to indicate the problems with this new numerical standard. Should the Institute comment? Should the individual members comment? It is not enough for the manufacturer to feel his views will be represented to the regulators by the Asbestos Information Association or FIISI. It was suggested that it would be best If both the Institute and individual members respond with points that are particular to t eir factories. It is felt that participation by the small manufacturer will be most meaningful. The Asbestos Study Committee will review the proposed standard and note some of the points that members may wish to conga* nt on. It should be pointed out that even if members comment to the effect that they support the ALA comments or they support the FHSI comments, at least they will be on record espousing their viewpoints. A comment wes made to the effect that everyone has been gearing to get their concentrations down to the 2 flber/cc limit by July 1, 1976. The technology necessary to take the count down to 0.5 fiber/cc is not known. Bow can consents be made on the cost impact, effects on competition, effects on employment, effects on energy supply, when the technology for getting to the 0.5 fiber/cc is not even known at this time? The least that can be done is to request an extension of time for comments past December 8, 1975. Upon notion duly made, seconded, unanimously passed it was RESOLVED: That the Institute will request the Department of Labor to delay the cut-off date for comment on those* proposed amendments to April I, 1976. The friction materials industry does not knot* whether the 0.5 flber/cc limit can be reached. Perhaps it will be necessary to go to materials with a material cost ten times that of asbestos in order to get the work place down to the proposed level. Industry is confronted with requirements for Standard 121 and Standard 105-75 from the National Highway Traffic Safety Administration with stringent friction materials requirements at the same time that they must evaluate whether they ***" still use asbestos in their products. There are several points in the 0SHA standard besides the 0.5 flber/cc limit. However, the main problem is the 0.5 fiber/cc limit. Some of the comments to follow concerned new problems that nay arise as a result of this proposed standard. These problems will be pointed out to the members so that they can look at these from their viewpoints with the aim of advising Washington on their individual problems with this standard. The reduction of the limit to the 0.5 level is going to effect processors such as the re-builder and the garages who were not really included in this standard before. Any outfit that handles friction materials may very well find airborne concentrations of asbestos fibers that exceed the 0.5 fiber/cc level. For example, a junk yard which might have a . 1 ` *" t. -- -1 -- -L W 1 <- - * e f 4 wa Ufw.faifaw