Document NMv54ppaDpM4JyYMpN2Egq6b

GRACE *3*908 CvnitrwctUn PrWucti Civilian TO: FROM: R. C. Erlcson CC: 0. M. Fevorlto R. Frohllch 5. Venutl R. M. Vlnlng J. W. Woltcr DATE: T55X SUBJECf: AAssbbeessttoosi Warning Labels V^on CCoonncci entrate Shipments FILE: Tremolite Fibers PLAINTIFF'S , EXHIBIT WRG-1690 ] This will make record of the decisions reached In our meeting of 5/26th, In which the attached memo of 5/12/83 was used as the Agenda. In reaching our decision, we took note of the following applicable documents: e DOT 49 CFRf173.1090. e California Labor Code Division 5, Chapter 2.5 "Hazardous Substances Information & Training" and other existing State "Right To Know" Legislation. e OSHA 29 CFRf1910.1001. e CPO Quality Control Instruction A-19 "Disclosure of Hazardous Substances Information". Sbec*r114^c-notfmwgtHn^yneseot^rMclicajcR94Gdlafl^JUcard ipg concentratewnsto<RO^pandtmg^1 ants. This Is based on the expectation that plant level Implementation of Instruction A-19 will satisfy both the Right To Know and the Duty to Warn employees handling concentrate. With reference to the applicability of DOT Section 173.1090, this specifically addresses commercial asbestos (material having commercial value because of Its asbestos content). Our concentrate Is not classified as connerclal asbestos under this definition. With reference to the applicability of OSHA Section 1910.1001, we will review our In-plant airborne fiber survey data at concentrate unloading points. With reference to exposures In connection with clean-up of spills resulting for rail accidents, our emergency response procedures provide the means to fully Inform authorities In charge of on-site clean-up activities. RCE:dm Attachment R. C. Erlcson