Document Qgkar5q4zOgxZ8YYENVw6mpJk

I MESSRS. B. W. DUNBAR R. E. JOYNER, M.D. R. F. NRSON J. U. PITTMAN FEBRUARY 2, 1976 DEPARTMENT OF OCCUPATIONAL SAFETY AND HEALTH STAFF INDUSTRIAL HYGIENIST ASBESTOS - 0. C. PENNEY AUTO REPAIR CENTERS I had a telephone conversation with Mr. Neff of J. C.#enney's legal office In New York. The discussion concerned OSHA's citations for J. C. Penney's failure to nonltor for asbestos and to provide aedlcal examinations for employees working with automotive brake linings. They have reviewed several citations In their repair centers In Wisconsin and Illinois. J. C. Penney only removes and replaces brake linings; they do not grind or otherwise work the brake lining materials. It Is Mr. Reff's opinion that the law Is very specific In this matter, and there Is no question that It applies to any and all facilities repairing brakes. J. C. Penney Is currently evaluating the business Intact with the possible result being their withdrawal from the brake repair business. Original Signed By F. M. Parker HI F. M. Parker III FMPrjts LAM 030357 ABS-012412 i