Document emdEz37QG564kvg0kONXVGQRp

FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE //4, PARAMUS, NJ. 07652 October 30, 1972 TO: Delegates & Alternates Asbestos Study Committee SUBJECT: Interpretation of OSHA Labeling Requirements The Chairman of the Asbestos Study Committee is request Inc a survey of members on their interpretation of the labeling requirements for asbestos type Drake lining and clutch facing shipments. On June 20, 1972, the Institute distributed to all members a copy of the OSHA Standards for exposure to asbestos dust. - A key paragraph in the standards had to do with labeling requirements: (2) Caution labels--(i) Labeling. Caution labels shall be affixed to all raw materials, mixtures, Borap, waste, debris, and other produots contain ing asbestos fibers, or to their containers, exoept that no label is required where asbestos fibers . have been modified by a bonding agent, coating, binder, or other material so that during any reasonably foreseeable use, handling, storage, disposal, processing, or transportation,' no airborne concentrations of asbestos fibers in excess of the exposure limits prescribed in paragraph (b) of this section will be released. . The problem, in this case, is the shipment of asbestos containing brake linings or clutch facings where in many cases subsequent operations will be performed--cutting, grooving, drilling, and grinding. The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestoB fibers in excess of the current exposure limits (5 fibers/cc TWA, or 10 fibera/cc ceiling). The questions are: 1. Do you now label asbestos type friction materials with the label as specified In the OSHA Standards? 1.1 For replacement market shipments? 1.2 For original equipment shipments? 2. Do you plan to label asbestos type friction materials with this label? 2.1 For replacement market shipments? 2.1 For original equipment shipments? 3. Do vou Interpret the OSHA Regulations on labeling to require a manufacturer to label asbestos type friction materials where subsequent operations (drilling, grind ing, etc.) are likely to be performed? IVould you please complete this--or have it done by the individual responsible for implementation of the OSHA Standards--and return to me at the Institute Office. FMSI-0134 E. W. Drislane Executive Director fmsi 02805 SCF-ALLF-04230 T FRICTION MATERIALS STANDARDS INSTITUTE, INC., E-210 ROUTE &, PARAMUS, N.J. 07652 OSHA LABELING REQUIREMENTS 11 Current, Labelim_ Practigg 1.1 For replacement market friction material shipments, we now provide the OSHA caution label. 1.2 For original equipment friction material shipments, we now provide the OSHA caution label. PlannssLUbal ing,,.Prastifia 2.1 For replacement market friction material shipments, we plan to use the OSHA caution label. 2.2 For original equipment friction material shipments, we plan to provide the OSHA caution label. 3. Interpretation of OSHA Labelinp RbpuIatiflQS 3.1 We interpret the OSHA labeling regulations to require caution labels on friction material. shipments that will have subse-, quent working (drilling, grinding, etc.). o c=> (____) . , (> I) Ha (_) CH) CZD BY COMPANY. DATE. FMSI 02806