Document NG4YGZVbx5JQREbGGwZ2jYrnw

-mfCTION MATERI-S STAN"`?DS INSTITUTE, INC., E-210 R(XFC /?4, PARAMUS, N; J. 07652 October 30, 1972 TO; Delegates Alternates Asbestos Study Committee SU3JECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is requesting a survey of members on their interpretation of the labeling requirements for asbestos type brake" lining and clutch facing shipments. On Jline 20, 1972, the Institute distributed to all members a copy of tha--' OSHA Standards for exposure to asbestos dust.- A key paragraph in the standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, scrap, waste, debris, and other products containing asbestos fibers, or to their containers, except that no label is required where asbestos fibers have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation, no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. __ --------- The problem, in this case, is the shipment of asbestos containing brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos cfibeeilirnsg)\in. excess of the current exposure limits (5 fibe--r--s- /cc TVTA, or 10 fibe----rs/cc - The questions are: 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do vcu clan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3. Zo vcu interpret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grindirg, etc.) are likely to be performed? uould you cl ease complete this--or have it done by the individual responsible for implementation of the CSHA Standards--anc return to me at the Institute Office. E. IV i* Dr islane 0