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AIA-56 APPEND!T L Document No. 15 ASBESTOS INFORMATION ASSOCIATION 1660LStfMt N-W. / WwAington. OC 200/(202) Z23-tdS . .. . 15 July 1974 - - . '* * . Dr. Daniel P. Boyd * - . . Director, Office of Standard Development Occupational Safety and Health Administration 1726 M Street, N.W. , Washington, D.C. 20036 Dear Dr. Boyd: ' ` V ; The Asbestos Information Association/North America consists of twenty-two member companies and associations which represent . three-quarters of the asbestos mining, milling, manufacturing, and importing industry of the United States. The Association maintains active liaison with trade and technical groups related to the industry. Over a period, of time and on numerous occasions, we have consulted with key representatives within the Occupational -Safety and Health- Adainis tration in a cooperative effort to ' develop sound safety and health regulations for the industry. Wo - - are -pleased to enjoy a close working relationship with OSHA. .. When the Association learned of plans to revise the Asbestos ' . Standard, as first published in the Federal Register. Vol. 37, . * ; No. 110, June 7, 1972, we spoke with Mr. Lewis Cox, Mr. Gerald - Scannel and Dr. John P. O'Neill to advise that we would be pleased to take on the task to recommend revisions and develop work prac-- ... tices. We submit, herewith; our recommendations for revising the . OSHA Asbestos Standard, as reprinted in the Federal Register. Vol. '. 39, No. 125, June' 27, 1974. We also enclose suggested work prac-- ' tices in the following areas: i/ '* * ' . -. , A. Unloading and Storing Bagged Asbestos Fiber. . *, . B. Introduction of Asbestos Fiber into Manufacturing Processes. . . . C. Asbestos Dust and Scrap Removal and Disposal. D. Housekeeping in the Asbestos Industry. ' Please note that we have addressed only those areas whers the Association feels the necessity for clarification or better- defined practical application in the interests of ready compliance within the spirit of the Act. Areas not addressed are considered _ reasonable and enforceable. . 01-0217898 AIA-56 l Page - 2 - '* .. ... The Association's Standards and Technical Conanittee, assigned to the task of preparing revisions and work practices, consists of environmental control engineers, industrial hygienists, and safety and health directors. The Committee has consulted extensively with medical, management, labor and othe:: disciplines within the industry. Edmund M. Fenner of the Johns-Manvilla Corporation serves as chairman of the Coraittee. Mr. Fenner is well known for his many years of experience in the occupational safety and health field. He is a regular member of the lecturing staff for NIOSH* and participates in numerous national technical programs on occupa tional safety and health as concerns the asbestos industry, a list of other members of the Committee is attached. *_ , > . The Association acknowledges the importance of disseminating information concerning asbestos regulations and work practices throughout the industry and is performing this function. Much has been done and much more will be done. We are proceeding with the development of work practice materials for member customers who are * fabricators and processors of asbestos fiber and fiber-containing products. We can report that there is an; industry-wide appreciation of the health problems associated with asbestos dust in the workplace, . requiring-realistic-understanding-and remedial action where necessary. We are indebted to Dr. O'Neill, and Mr. Barry Gilbert for their out standing assistance and professional guidance. He shall be pleased . to meet with you or representatives of your office to discuss our recommendations and any other matters at your pleasure and conven ience. . . * , . Sincerely yours. Vs R/ H. Mereness Executive Director HHM/cg Enclosures* ' ;. .. . * (1) Recommendations for Revision, OSHA Occupational and Bealth Standard for Exposure to Asbestos Dust (2) Suggested Workplace Practices in the -Asbestos Xndustry ` 4 01-0217099 AIA-56 ~ . STANDARDS AND TECHNICAL COMMITTEE ASBESTOS INFORMATION ASSOCIATION/NORTH AMERICA Edmund M, Fenner Chairman Director Environmental Control Johns-Kanville Corporation Denver# Colorado ... Harold L. Becker Chief Engineer Nicolet Industries Ambler, Pennsylvania . ' Charles C. Clarke Industrial Hygienist The Sendix Corporation Southfield, Michigan , ', - . 4~ ' * _,, .. - _ ' .`L. E. Moody Plant Engineer * Southern Asbestos Company Charlotte, North Carolina Fraser Morton Industrial Engineer ' Congoleum Industries, Inc. ' Finksburg, Maryland . C. Nelson Codding ' Corporate Environmental Control Jim Halter Research Corporation St* Petersburg, Florida * William H. Mortonson ' General Manufacturing Manager The Plintkote Company . East Rutherford, New Jersey Sudhakar Dixit f Dr. H. B. Rhodes * Industrial Engineer ! Area Manager * Garlock. Incorporated * Marketing and Tedhnology Palymyra, New York. * Union Carbide Corporation . Niagara Falls, New York William Fassuliotis "` Director Safety and Security Isaac H. Weaver ' GAF Corporation Director Environmental Control New York, New York Raybestos-Manhattan, Inc. . Hanheim, Pennsylvania - John P. McGinley Director of Manufacturing Frank B. Zimmerman *: Asbestos Cement Pipe and Plastics Corporate Director, Certain-teed Products Corporation Safety end Environmental Bealt Ambler, Pennsylvania - National Gypsum Company Buffalo, New York A 01-0217900