Document YGVZwyeOapL347z5Emeg5QxpE

General Headquarters, Box 91 Uareh 6, 1952 J. C. Xelleher, A*F*D., Uontreal Buies k Beguletioos Heir ting to leveling in the Use, Handling and storage of sub stances Harmful to the E*alth k Safety of Employees We have examined the regulation of the State of Illinois with reference to labeling asbestos fibre and it is our opinion that in order to comply with the Illinois law, bags containing asbestos fibre should be labeled in the following Banneri CAUT2CS - ASBESTOS FIBPX Inhalation of asbestos fibre over long periods aay be harmful* The bp terlei should be so used as not to create dust or, if this is not possible, employees should be equipped with adequate pro tective devices* We have discussed this natter with Dr* Lanza and Ur* Vandiver Brown and it la the opinion of Dr. Lanza that as far as the medical angle is concerned the label la sufficient and it Is our opinion that the label eocplies with the legal requirements of the Illinois statute and the regulations Issued thereunder* Arthur I. Fish, Jr* ALFlS cc A, v Lindell, Asbestos Mine r /- v> General HeedQuarters. Box 91 April 3, 1952 W. H* flouter* Asbestos Uine Sections 3 sad A of the Health end Safety Act of the State of Illinois (211. Rew.fltat. Chapter AS, Sections 137.1-137*21) provide In pert as follows; "It shell be the duty of every employer under this Act to provide reasonable protection to the lives, health end safety of ell persons employed by such employer. The industrial caenisslcn shell, from time to time, make, promulgate and publish such reasonable riles as will effectuate such purposes.* To effectuate the purpose* stated in Section 3* the Industrial Commission shall sake such rules only fort (c) The prevention of personal injuries end diseases by contact with any poisonous or deleterious materials, dust, vapors, gases or fumes." Pursuant to and In accordance with this statutory author ity, the Industrial Commission of Illinois has Issued "Buies and Regulations Relating to labeling In the Use, Handling and Storage of Substances Harmful to the Health end Safety of Employees* A eopy of Part *J" of said regulations Is enclos ed herewith. ,a It Is our opinion that under Buie 2, subsection (f) . the definition of dust Includes asbestos fibre; that flection II, Buie 1 requires the labeling of such fibre and, as you will tee, i flections III end IT determine how the fibres shall be labeled. Arthur I. Risk, Jr. AtTtS Snc# A,F.B. MOKTKEM. April 23t 152. Arthur L* fisk, Jr# * Central Headquarters, Box 1 & Segulstioas Eelsting to Labelling in the Use, Handling tad Storage of sub stances Harmful to the Health A S&fety of Employees 3/6 Ve hive retd tad discussed your cement regarding the labelling of asbestos for shipment into the State of Illinois vith other producers interested. Before proceeding vith the troublesome task of complying vith these regula tions, ve vould like to be sure i That ve must label our bugs* Thit "Asbestos* is specifically referred to is the regulation# That a penalty exists if ve fail to comply* that other states have similar requirements * Xhat ve are really after ia a decision that it is compulsory to do the labelling job as a Canadian producer, tad thst there is no other v*y out* Can you help us further in this direction? J. C. *502823?/ JCK/T met K. Y. lindell * Asbestos 1500 i u- r'kJ J.4 : 44 P.? General Headquarters, Box 91 May 2, 1952 J. C. Kelleber, A.?&. Hontreal Rulea and Regulations Relating to Labeling In the tTae, Handling and Storage of Substances Harmful to the Health and Safety of Employees April 23, 1952 Answering the question contained In your letter, presumably as the State of Illinois does not have Juris diction over Canadian yofans-kanville, it could not require us to label our bags* On the other hand, it could require our customers to label the bags* The word Asbestos1 la not particularly referred to in the regulation but the following, In the opinion of the Legal Department, covers asbestos; *Pqt* Solid particles generated by handling, crushing, grinding, rapid impact, detonation and decrepitation of organic or inorganic materials such as rock, ore, metal, coal, wood, grain, etc* a dust does not tend to flocculate except under electrostatic forces; it does not diffuse In air but settles under the influences of gravity, tensity for failure to comply Is a fine of not leas than $25 and not more than $100 for the first failure and a fine of not less then $50 and not more than $200 for each subsequent failure* At the present time I do not know of any state having a similar statute, but swat probably similar statutes will be adopted by other:tates. Nl. Xn our opinion it is compulsory that the begsof asbestos fibre handled or stored In Illinois be labeled fin the manner described in ay letter of Karsh 6, 1952, Xf I we do not do it, our Illinois customers will have to do It. alfi a Arthur L Fisk, Jr. JUN 01 '90 09=41 CO DE 219 HOTELECOPY LOEWS CONFIDENTIAL l P.2 Harinite Dust Division Headquarters Jims IS, 1958 Attached is a letter by V* S. Padhsa in which he li calling to our Attention, a situation la vhieh JWi la the future have sons responsibility. 1 would appreciate 70ur rsTiew of this letter end give me the benefit of your thinking in regard to the company liability. It hee been suggested by Mr. flavin that possibly s statement could be made in our literature sailing attention to the potential hatard is confined quarters. ccj . D* flavin V. B. Padham Nashua fils T, H. Eaton JUN 01 '90 09^1 CO DE 219 HOTELECOPY LOEWS Ao 4-V - ' J 7 - M 33T.- P.3 A z'tbA $4x2* M \\r rCOWFIDDTTlAL July 1, 105B T. B. Eaton Harlnlte Dust X have discuss'd your memorandum of Jus* 18, 1658 vith Hugh Jackson. V. B. Fadbam la to be commend'd for his dis covery of the situation listing at the Newport Hews Shipbuilding Yard, X think this is a natter that may result In extensive legal liability in the future unleas_lt Is properly handled. The important feature ie that the employee mho is using a aaw on Harlnlte should know what the precautions are that must be taken. Placing a state ment la tbe literature does not carry to tbs employee the Information be should have. It Is suggested that e label be placed on tbe back of the sheets of Marlnlte Dugb Jackson and X mill be glad to give you tbe copy required for these labels, Te have had the earns ex perience in caution labeling on Cellte products* Xu sending copies of this letter to Hugh Jackson and A1 Schmidt of tbs Insurance Department Simps this Is a natter which mill increase our premiums on product liability insurance if any lav suits are brought against urn for failure to warn of the potential hash'd. Herbert Horten Ball cg E. D, Flavin V. B. Padbam, Nashua B. H. Jackeon A. V. Schmidt y ^`pQWIUEl.'TIAL L Herbert Morton Ball Division Headquarters July 7, 1958 Marinlta Dust 1 appreciate your appraisal of the situation in connection with our Company's exposure when Marinite aheets are cut on the job, resulting in a considerable amount of dust* In order that vc may give further consideration to the proper labeling of all Marinite producte# I would appreciate it if you would give me the copy required for these labels. Mr. Jackson is on vacation aai I would like to get this under way before his return. ccs E. D. Flavin J* B. Jobe V. 8, Fadham Nashua i-. Ho Jackses: X. H. Schmidt file I rr.n.i:s zlz&mi c -msiz ~ zzzmj or' t mjHflrha* m at; ------------ ZSJtEUXui hr-C^^LT'J?L>CX. T. Bv Baton The enclosed copy of I. I* Caithfs letter is uolf-explaaatorjr, Barb Ball and Z concur that the decision to u*e a label should be sade bj our gtAlor officers* >*KftRl .. ,, . rT--_ ^ oio^xjjcxrciicar. **hc ^Ua-Cuiijo,,eu.'jaoxcrac.a. * * ca J3 isi nSy M nt^lr n iiconni*iaa3 * u'u'ujvu'ocn Wllllaa P. * fireese Enel, cc; *. V, Sfcitb K D Flavin J* B* Jobo B. M, Jackson <1., F. Schmidt F* B. Padhaa - Kashua i i `V VW ' L July 9, 1958 W, P. S. Breese Caution Label Karlnite Following is the wording of the proposed caution label for Karlnite sheets which we discussed yesterday. Caution narinite is composed of asbestos fibre and calcium silicate. Inhalation of dust produced in saving* drilling or trimming this board may be harmful. Avoid breathing this dust. Dust should be kept at a safe minimum by proper controls. If tiis is impossible* respirators approved by the U. S. Bureau of Mines are recommended. In my opinion* the use of this label should be given very careful consideration. If ve apply it to one of our products such as Karlnite, 2 believe that we would have to apply It on several other products such as Transits* Flexboard and certain pipe covering materials. I believe that such a move should be a policy deeleion made by our Senior Officers. Kenneth V, Smith* H.D I JUN Q1 '90 09:43 CO DC 219 HOTELECOPY LOEWS P.7 copy uivi^on Headquarters July ?9, 1958 D.L. Hinmon MARINITE DUST The natter of i caution label on Marinite has been discussed with Dr. Smith and Mr* Ball. Our discussion covered all board products, not Just Marinite. Mr. Ball indicated in his letter of July 1, 1958 to T.H. Baton, the important thing for us to do is provide the employee who is sawing or sanding Marinite - or any board product for that natter with suitable information so that proper precautions can be taken* How do we disseminate this information? A label could be used. However, because sheets are sometimes faced with other materials after they leave our plant the label would be covered and not seen by the p**oa doing the fabricating* Where sheets are not faced or painted, nany labels would have to be used on both faces to make certain that all persons who cut, sanded and drilled the pieces were suitably warned. ' - We have nany competitors in the board products field. A caution label on our products - snd none on theirs would make our selling efforts nost difficult. Until the entire industry takes such action, we should consider other means of communicating with the users of our materials* Mr. Ball's letter of July 1 also indicates that placing a statement in literature does not carry to the employee the information he should have* On most sales promotion pieces and brochures this would be the case* In the case of board products, we have a different type of lit erature - namely, an instruction hook covering cutting, drilling and machining Transite and Ebony products. The purpose of this instruction book is to reach the thop foreman and the man doing the actual work to instruct them on the proper method of handling our aaterials* This has been in use for several years. It is now being revised to include 'i-9.M our o'her board product*. The old instructions car:: - ..3t co dry cutting - "in dry cutting there oust be available the proper equipment to remove duatV -7- When the instruction book is reissued, this statement will be expanded to cover all our board products and will read as follows: "During cutting! machining, drilling, and sanding operations adequate precautions must be taken to eliminate air contamination by dust resulting from these operations.*1 In ny opinion, the action we have already taken is the most direct meins available to warn the person handling our material of the potential danger which he may face if he continues to work in a very dusty atmosphere and breathes the dust. 1 believe that since our division has already taken some cognizance of this danger through the publication of an instruction of the need to remove dust plus the fact that we are enlarging on this statement in our new literature, represents all of the action which we need to tk thi tine. I recommend that Building Products Division be advised of the steps which we have already taken. Since we have taken what 2 think to be suitable steps on the matter of cautioning the users of our mat erial about dust, I don't believe that any proposal needs to be submitted to the Senior Officers. The only other division involved is Building Products w d once they know of our problem they can take similar steps if they feel it is necessary. cc: " " " 4 W.G. Hoffer w; frjMtS C3i sr: 2 Cu> : Cl ^ i:aj 53 *: c^.r jfz sr.cciLr :r?l:0 ai elzi *mk 2 zjtmaz -q V*ti'CT^^J'"JTLrcJj I i August 11# 1956 D. L. Hinaoa Mariaite Dust Tour letter Aug* $ to K* V* Ssith ` Ten and X reviewed thU natter with Kesars. V* O, Koffer and H. H. Ball and concur la the reeonendatlont Bade by Rr* Hoffar la his latter of July 29 to you* Tha statement la the Instruction book which will reach the Job foramen and the man doing; the actual work will place the desired Information la the hands of those for %fcoe it la Intended and la most important* .-.'agyfcaiK n miasuszu sxsca: i m :c uxxj: xac z a,mx 3 is u* i:c sfca .1 a a;; o-3Li >m.m m c:s o r: ! jX3 'wujva1 cct J B* Jobe He K Saift. X B* H* Jackson uc_ diy HO ISLLCOPY LOCUS P. 10 kV w. G. Hoffer Division Hesdquarters August 13, 1936 Marinite Dust Your Letter July 29, 1958 X concur with the recommendations Made in your letter of July ?9th on the sbove subject. Please proceed to esrry out these reeomaendations* cc: J. B. Jobe H. M* Ball' file Don L. Hinmon *`W r>-5^ *.  * *f /'^/ n ,,J?1X\ X. V. 2*iU A ` merm MmAci 9rU Be/ nt W?d far arrival ot* u. r-.i>--' -- - - - --. . -- !-fit "'- ,w. 10/1V6Q cw* m*. ..j ..- .H Yromittliu M***t_tqwrt of Art Ja>w, w aW data fof vaU< MiHfi oa bto of J-Sprijr, J-#' ubwtop i|rrr^o flraproeflci o*UrlU. HoUrUll iff . J Sji SI flb*n rffg^ndff ^ur*l wool. fr^totqtf u4 s-odlu* AdtfiU, aitrlts. XatTial appliod by ootfldf goctruftora through rpririag *o>-U ilmlltr to rock vaal bio*!*/ <qhlao Md far ha* ipaalaUa* oxo*pt flat vatar tpnr Itplogf on tbo >*tortl, ta ib *nrr* fro* ofiilf eaaniag vfttfd xi which fttfki oft atHlafi and axocl ort w bo flrtprocfod. So-- doitlay rwvlti threogh iaeowplot* tlxlag. ?!*-- viro year ljmwIi T.D. 11 --with i oovr tio 1. t.i Blo..k.....C..T.O..W""1 -r(r w ^ & n x. r7 foiKT oa mt. u m*A OIU illA 8H/F SIIN0I* ___ __ WHY FILE THIS! r. a. fob 000003 ........................ VL\ A ^^ lZ C \______ "~i O i'Oi'W t t i L" ( ;To^ ", ) \A' v A. Pocius - DnQ, Box 91 Division Headquarters, Toronto, Feb. 1, 1965 Be o\^------- - Vi CAUTION LABELS INDUSTRIAL INSULATION FRODUCTS YOUR LETTER JANUARY 29 ' We have been assured by Dr. K.W. Smith that it is not^necessary to us the caution label in Canada and, therefore, we obviously do not want it on any of our cartons* As you know, we import a large quantity of Theraobestos from Kanville and, to hold costs to a minimum, we reship out of Toronto Plant in the KanviHe cartons. I discussed this v " 'Vinet by rf* telephone and he informed me that it would be no the printed caution label by sanding. He was to cedure effective January 13 for new shipments bu* or in transit would have the label removed at To -C.;. '* We are reluctant to cover over the label becaus of having the protective covering removed on tt in complete agreement. oo,. `'ey;- -ty is I have been assured by the fiber Division tha' .pped in Canada will not carry the label. This leaves ttpe Covering imported from Waukegan. Since our volume very - 11, less than 45,000. per year, it would be appreciated if Waukegan Plai would remove the marking by sanding or some other means, on cartons being shipped into Canada* ' WliHsKW * cc; M.W. Burleson - DHQ, Box E.C* Lindstroa * DHQ, Box W.W. Acher - DHQ, 3ox . C.H. Jensen * Waukegan f quality control DEPT. JUN 04 '90 14 M2 P.3 / y? //* /. > (S' ' XA. s<rfrra--n 9* floor flUdoloo *o ' tiytulf li CAffTIflW T-mg^-g ASNESXQS PRODUCTS tom sggpga 9 Ploooo bo wtaU4 tbot to# caution labol laotltutod by thlo Plvioio* 1* bolds placed on tb High Toapornturo lino for cwr ewa protection* X noroly Mat you tbo letter to toll 70a this la cane you tested year product pbVired* X mitfgest you ebook tdtb Or* K*w* 5*itfc consenting tbo legal aepecto for any retuixeaeut on product* containing Aebeetoe* IUMiIa Mi .1# fiengb * *. fioltb - 90 floor - 2nd floor D** vxmsxxf