Document dnqoK7Nm8zYXNemrQoVYoLpd6

INTERNAL CORRESPONDENT METALS DIVISION P. 0. BOX 579 -4625 ROYAL AVE., NIAGARA FALLS. NEW YORK 1430? To (Nim) Mr. T. R. Alexander D'vition UCC-Corp. Distr Location 6th Floor 270 Park Avenue New York, NY 10017 cooy to r. e. Byrne, Jr. w/encl . J. H. Cleveland W. B. DeAtley w/encl. T. J. Kagetsu w/encl. W. G. Kahler R. W. Rebholz w/encl. H. B. Rhodes J. J. Sibley w/encl. File Dale onomjt.ngDept. October 6, 1980 "Calidria" Asbestos Answering letttr dale subi> Export Packaging for Asbestos Thank you for sending me the information on IMC0 requirements for packaging asbestos for export. I have some questions and am routing the information to others for any comments and/or questions they may have. 1. Can you clarify exactly who or what IMC0 is, what they do, how and where they enforce, etc? 2. The drop tests seem simple enough but the strict humidity and temperature control for bag conditioning prior to testing may be a problem. (a) Can you advise where these tests could be conducted and how much they would cost? (b) Some of our bags only hold 10 lbs. of product and we don't use 3 plies of kraft paper or equivalent - is this a violation? (c) I assume we are to test every different bag we use. Is re-testing required periodically and/or when we change bag suppliers? (d) Can we perform the tests or must they be performed by the supplier or a certified laboratory? If the tests are performed on the ''outside", the presence of asbestos may cuase some problems. If we use substitute materials, it may be difficult to match the densities of our various products, which range from 5 to 45 lbs/ft3. (e) Are there penalties for not conducting the drop tests? 3. Paragraph 3.6 "Marking" has me confused. (a) Can you provide a sketch of the markings which are required on our bags? X 418537 Mr. T. R. Alexander -2- October 6, 1980 (b) Are there any specifications on the markings: size, color, location, etc? (c) When were or are the markings required? (d) Are there penalties for not using the prescribed markings? 4. We have the same problem meeting IMC0`s "sift-proof" requirements as we do with DOT'S "dust and sift-proof." I assume they mean the same thing. We solve the DOT requirement by double shrink-filming each bag, but we do not have the physical capacity to do this in an optimum manner for domestic requirements let alone for all of our export shipments (we do single shrinkfilm all bags for export). An engineering study is nearing completion to decide how best to resolve the problem, but new equipment installation could not be completed until well into 1981. (a) When were the IMCO regulations enacted? (b) Is there a compliance period or effective date? (c) Should we apply for an extension? (Perhaps Mr. Sibley should comment on this.) (d) Can the single shrink-film meet the IMCO requirement? (Dr. DeAtley should comment here.) (e) What are the penalties for non-compliance? The extent of the IMCO regulations has obviously caught us by surprise and we cannot comply with them immediately. If non-compliance is a serious matter, I would appreciate your advice on how we should proceed. Jrthn L. Myers JLM:dal Enclosure X 41 8 5 3 B