Document dYqvaZBnqzZM9J857en9x7wB9

Kovenibar 28, 1972 Kr. J. E. Kelly Beudix Corporation 1217 S. Walnut Street South Bend, Indiana 66621 Dear Jack: This concerns our discus el on concerning labeling requirements where brake linings are being shipped to customers., la attempting to detera-ine whet practice one must use, OSHA has stated that if one is meeting the spirit of its regulations it will not be Cited for violations. As a result of this, it becomes necessary to interpret some of the OSHA regulations, 1 an enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association (AXA/HA), 7 ou will note on these reports that Hr. Armstrong, from Betdir. corporate headquarters, attended these meetings. There is absolutely no question concerning the requirements for labeling where loose asbestos is being shipped. Toe big problem, develops where members arc shipping what the ALA. and OSKA refer to as locked In asbestos products - brake Haines, brake blocks, clutch facings, etc. When custonete cf yours drill linings, chamfer linings, cut linings, or grind linings, they may very well raise the asbestos concentrations in tha atmosphere to above the OSHA. standard, Some members have indicated that the drilling end grinding operations are problem areas in brake lining factories with existing exhaust systems. Therefore., if a customer of yours started drilling or grinding without having proper dust .collectors,, he would probEbly be in violation of the OSBA standard. It therefore becomes your responsibility, as the supplier of the brake lining, to warn the custoner of this possibility. The form which the warning takes ie still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for e violation. Therefore, '.t you tsstrfcdhr put in every one of your skids, cr cartons, or pallets, a warning notice to the effect: "Power tools without dust collectors: should not be used for machining, cutting, or sanding this product," If a notice such as this were enclosed vith every carton, or stenciled on the outside of the carton, it is Likely that you would be meeting the spirit of the regulations, rf you were to write your customer sad tell hit# about this with every shipment made, you would probably be also meeting the spirit of the regulations. If you send a one time letter to your customer saying this, it is hard to say whether, you would be meetinj `` J-- " ... P-FMSI- 0020 SCF-ALLF-04270 P-EXHIBIT-037