Document V3JRxmD4m9aNVdvarz809nd2w
FILE NAME: Union Carbide (UC)
DATE: 1972 June 22
DOC#: UC150
DOCUMENT DESCRIPTION: Memo RE - Suggested Format for Handling Inquires from Customers Concerting the New OSHA Regulations
P'S
June 22, 1972
MEMORANDUM
c*zr
TO: R. E. Byrne G. L. Oickson E. J . Klc-ber J . L. Myers T. P. Norris
H. B. R hodes"''''"
From: B. L. In g a lls
The follow ing is suggested as a basic format fo r handling in q u irie s from customers concerning the new OSHA regulations.
I. Set the mood.
C on trolling the conversation is paramount. Assure the customer th at the new law
Is reasonable end w ith in the lim its of p r a c t ic a lit y . C ite the e ffo r ts by our own
plant and that we have experienced no health problems with our employees. The
f i r s t paragraph of B i l l Johnson's le tte r to the O ffic e of Safety and Health Standards
6/9/72 summarize our positio n and a ttitu d e . I t also seems to have a soothing e ffe c t
on the em otionally ir a te . Po int cut the vast numbers of customers su ccessfu lly using
asbestos without problem.
"
If the customer is p ers is te n t and threatens to elim inate asbestos - a c e rta in amount of aggressiveness may be e ffe c tiv e . Words and catch phrases such as "premature", " ir r a t io n a l" or "avoiding the In e v ita b le " w ill sometimes turn the ta b le .
The main o b je c tiv e is to keep the customer on the defensive, make him j u s t if y his p ositio n . Most customers who c a ll are on the o ffe n s iv e , often prepared with "Toideti" questions and expecting an argument. Change the mood before discussing anything p ertinent about the new reg u latio ns. A lte rn a tin g between an aggressive and sub m issive a ttitu d e is confusing and allows you to bide your time. Refuse to argue, be humble and when they are s u f f ic ie n t ly calm, sometimes even embarrasses, make your point f o r c e fu lly . Don't cover too much ground in one co nfrontatio n. Even rabies shots are spaced a t moderate in te rv a ls .
I I. Pertinent points of issue.
( I ) Refer to the new OSKA Regulations Section 1910 and suggest the customer
UCC 013847
A08 697
himself with i t . Quote - " I t c l a r if ie s much of the issue and puts things n th e ir proper perspective" .
(2) _Cite the need for an in it ia l survey and recommend it be conducted fo r th e ir e d ific a tio n and compliance of the law.
(3) It is obvious by the tone of new le g is la tio n and regulations th a t in it ia l
survey and p erio dic monitoring are the way of the future for most raw m aterials,
probably a ll u ltim ately, e sp ecially s i l i c a , etc.
`
(4) S i l i c a Is due for review by the OSHA as a Target Hazard In September 1972. The TLV for resp ira b le nuisance dust Is 15 MPFCF and 50 MPPCF for to ta l cust ' s i l i c a TLV Is 20 i/FRCF,
(5) Medical examination is required if any asbestos dust is generated.
exami nations ^sre the p olicy of conscientious companies. Again th is wi l l become a basic requirement in the not too d ista n t future.
Medical probably
/cvb
.^08698
iiCC 013848