Document MgQDK3qJOj5M7QNJ2njXV84j

FILE NAME Allied Signal Bendix ASB DATE 1972 July 5 DOC ASB082 DOCUMENT DESCRIPTION Memo from Asbestos Information Association RE AIA OSHA Standards Meeting _\ . Asbestos Information AssociatcOWERh America at ub) 22 East 40th Street 3, New York N. 10016 212 661-8206 : JUL 10 1972 ARMSTRONG J. W. W. ARMSTRONG 5 J. \ INITIAL INITIANAD L| FORWARD : KWN | July 5 1972 TO . AIA MEMBER COMPANIES AIA ENVIRONMENTAL CONTROL COMMITTEE AIA LEGAL COUNSEL ~ James Armstrong E. C. Bratt - Bendix Corporation - H. K. Porter Company Inc. G. G. Gabrielson Jr. - Nicolet Industries Inc. ; -. Bernard Gross - H. M. Jacksom ; W. Johnson - American Bilt Rite Rubber Company - Johns Corporation Manville Corporation - Union Carbide Corporation A. R. Hooker - C. A. Neumann - - Flintkate Company - Kentile Floors Incorporated. G. W. Nickel - Armstrong Com Cop rk a Con mpay ny Clifford Seymour ; J. R. Stetson - The Carborundum Company - Congoleum Industries Inc a Philip Weinstein - Evertex Incorporated G. W. Wright M.D. _ - St. Luke's Hospital Gentlemen: A meeting was held in Washington last Thursday between the . ie AIA and representatives of the OSHA and compliance sections Attending standards development behalf of the AIA were John Marsh Raybestos Paul Weiner GAF Hugh Jackson Manville Frank Zimmerman Bradley Walls AIA Legal Counsel Zimmerman M. M. National Gypsum Swetonic AIA Executive Secretary OSHA was John O'Neill and Harry Gilbert of Standards Development and Ray McClure of Compliance The purpose of the meeting as was discussed discussed at the Association meeting on June 22 was to clarify a number of points with regard to the interpretation and enforcement of the asbestos standards Because the standards are to go into effect this it week we considered imperative to provide you with the basic points of interpretation and compliance established at the meeting A more complete report on the meeting will be forthcoming in the near future 800-631-6989 800-631-6989 80-631-6989 PLAINTIFF'S EXHIBIT 80 -631-6989 80 -631-6989 800-631-6989 800-631-6989 766 800-631-6989 PENGAD PENGAD Sponsored Asbestos by Atlas Co Cement Asbestos Products Co Certain Products Corp , Flintkote Co GAF Corp. Manville Corp. National Gypsum Co. Panacon Corp. and Raybestos Inc. WCK006895 LETS aE The following reached are the main areas discussed and the decisions . hte, _ . 1. LABELING The AIA is applying for a temporary industry variance on the exact wording of the labeling requirements of the - standards in order that existing supplies of boxes cartons bags etc. containing a label with wording somewhat different than that called for in the standards will be permitted until they are used up As long as the label currently being used contains basically the same information as the required one it will be acceptable to OSHA until stocks are ; used up oe we _ ae . me Fo ee ae , . ~ ' Products to be labeled should the list- sio ng submittebdy Dr. Pundsack of Manville to OSHA follotw heiMn arg ch hearings A copy of Dr. Pundsack's list with minor alterations is attac foh r e yod ur information oe a OS 33 No product which requires labeling will be permitted to be used without any label until existing stocks of labeled bags etc. are used up A stick label of some type would be satisfactory ae The size color placement etc. of the label : of = is left to the discretion the employer as long as the Label is readily visible and .. legible A good rule to follow would be if you are trying to hide the label OSHA will probably not accept it 2. CLOTHES LOCKERS Separate clothes lockers are required only for employees working at levels in excess of the five fiber TWA 30 It was the intention of OSHA to require Type C supplied respirators and protective clothing only for insulation and fireproofing spray applications AIA will apply for a modification of the law to exclude other types of asbestos applications from these requirements -More- WCK006896 RESPIRATORS There is a mistake in the standards in paragraph d ii Powered Air Purifying Respirators The first sentence of that paragraph now reads . A full facepiece powered air purifying respirator or a powere aidr purifying respirator or a respirator etc. | The sentence should read A full facepiece powered airpurifying respiratoorr a respirator etc. etc. The phrase powered delbe e d t ele etd ed air purifying respirator * MONITORING ANDANDPHYSICAL EXAMINATIONS Company examai nd n phya sict al i exao minn atis ons should conducotnealdl employees who regularly work with asbestos and are exposed to airborne fiber as well as on maintenance men company industrial hygienists and other employees that the company _ feels require monitoring and physical work or of because their close proximity to dusty asbestos operations This would exclude office personnel most people working in asbestos asbestos using sections of an - manufacturing operation etc. ; . . ; of : i : : -& E ; CITATIONS A company's own monitoring or other records will not be used as evidence to issure citationsnor will they be used to give a plant a clean bill of health OSHA INSPECTIONS OSHA industrial hygienists will take dust samples for a full eight hours if at all possible perhaps divided into two four hour samples In addition samples will be taken on more than one day so that a more accurate count can be produced Ceiling sampling periods will be at the discretion of the OSHA hygienist Ceiling samples as short as five minutes may be taken if deemed appropriate Under some circumstances -More- WCK006897 an obviously very heavy dust concentration only ceiling samples may be taken but this would not be normal practice Employers will be given specific dust counts only if they are in excess of the standard Counts taken by NIOSH but will hygienists will be reported to OSHA not be used by OSHA for purposes of issuing citations 8 EMPLOYEE NOTIFICATION On the question of notifying employees if they are found to be working in dust concentrations above the neither O'Neill or McClure would make a decision whether the notification clause limit in the standard would be satisfied by the posting on a plant bulletin board of stations above TWA or whether more individualized approach such as sending the employee a registered letter would be required To answer this question we were asked to write to the solicitors office in OSHA for a ruling Unfortunately a prior informal conversation between Paul Weiner of GAF and a member of the legal staff of OSHA indicated that the answer to such a would be in favor of the registered question letter approach Asa result we have decided not each for ruling in to submit this question but will leave it up to company in theindustry to decide what manner it wishes to abide by this requirement and wait to see if bulletin board notification will be challenged by OSHA regional inspectors In general the concensus of the AIA group that attended the Washington meeting was that the industry could expect reasonable treatment from OSHA as long as the industry did not try to circumvent the intent of the regulations For example the various requirements in the standard for protective clothing change rooms separate lockers etc. have as their purpose the preventing of excessive amounts of asbestos dust being carried home on an employee's clothes from work As long as this purpose is achieved the industry will be given wide latitude as to the types of protective clothing footwear and headgear required the location and size of change rooms -More- WCK006898