Document a4qvqL8xVNM3daa8yMOyjqMzM

FILE NAME: Raybestos-Manhattan (RBM) DATE: 1975 May 5 DOC#: RBM084 DOCUMENT DESCRIPTION: Memo RE Area Where Industry is Especially Vulnerable to Third Party Suits 'p3 TO: Messrs. F. D. Bauce D. F. Calliari F. S. Daly R. M. Gordon R. A. Jann J. F. Maclachlan R. R. Moalii W. S. Simpson Many of you have probably seen the enclosed article distributed nationally by the Associated Press on April 27. I* should be given careful attention because it points to an area where industry is especially vulnerable to third party suits because of lack of knowledge on the part of workers of hazards associated with the materials they are handling. As workers in small business are more apt to use poor work practices because of lack of knowledge of occupational hazards, the liklihood of occurrence of injury or disease is greater than in larger and more sophisticated operations. The Borel Case established beyond question the duty of manufacturers to warn of hazards. Assistant Secretary Stender has repeatedly and forcefully stated that manufacturers have the obligation to educate their customers in the safe use of their products. This is not an CSHA responsibility. It is questionable whether a caution label such as that required by the COSiiA Asbestos Standard is sufficient warning in cases where a significant hazard can exist. We know from the results of our own field tests and those conducted by Mt. Sinai personnel that high dust levels can exist in brake service shops. Instruction sheets have been distributed to all Grey-Rock and Raybestos distributors of friction materials describing proper procedures but we should make certain that these instruction sheets get down to the small shops where they are most needed. We should also make certain we have adequately covered other areas where' asbestos-containing products may be processed in such a fashion as to cause unacceptable dust levels. Enclosure John H. Marsh jhm C30211