Document dayERDMjrvJ8L4yp6gReMzzr0

FILE NAME Manville JMA DATE 1977 Sept 21 DOC JMA018 DOCUMENT DESCRIPTION Letter from M to A Pipe Producers Association RE Warning Labels for A Pipe UM UM Manville Sales Corporation Caryl Ranch Denver Colorado 80217 303 979-1000 Cal OSHA OSHA Mr. J. C. Jackson A Pipe Producers Association 1600 Wilson Blvd. Suite 1308 Arlington VA 22209 September 21 1977 Dear Joe . WARNING LABELS FOR A PIPE At the Market Development Committee Meeting the subject of putting some type of warning label on our pipe was discussed It was the consensus of the committee that we should not do so but if required the label should be similar to page 19 of the Work Practice Manual As you know Jay Baker and I were in Los Angeles on Friday and spoke to the California OSHA inspectors regarding steps being taken by the AC Industry to protect the health of workers who install A Pipe At this meeting we asked their opinion on whether or not we should put a sticker similar to page 19 on our pipe and if we did would it infer that / Pipe would be considered a labeled product and one that would require reporting etc. Generally the inspectors thought it would be a good idea but that Not recommended should read Do Not Use Dr. Fred Ottoboni was unable to be present at the meeting but I spoke to him today to get his opinion regarding the advisability of such a notice on our pipe and if we put it on would he advise us in writing that this act on our part would not be interpreted as labeling our pipe Dr. Ottoboni was of the opinion a label of this type was not necessary and wondered why we wanted to put it on He said he would not consider it a label in the OSHA sense of the word but would not care to put this opinion in writing at this time In about 30 or 60 days after there was time to evaluate the situation further he said he would be in a better position to make such a comment and also to possibly issue an administrative interpretation on the California OSHA Asbestos regulation stating compliance with the ACPPA Work Practice Manual would be considered as being in compliance with the California OSHA Asbestos regulation Page 2 Mr. J. C. September Jackson 21 1977 He also stated he had received some communications from an C Pipe producer that they planned to label their pipe in some manner My interpretation of conversations with Dr. Ottoboni is that he is confused as to why we are so anxious to label our pipe in some manner It is my opinion that we wait the 30 or 60 days that Dr. Ottoboni suggested before we take any action in this regard Let's see what Dr. Ottoboni California OSHA do before we act CC A. C. Boush Lloyd Ambler Lee Taylor John Beals Ed Fenner Denis Kelleher Art Kahn ~