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HELLER. EHRMAN, WHITE & McAULIFFE
ATTORNEYS
THIRTIETH FlOOR WELLS FARGO SUILOING 44 MONTGOMERY STREET SAM FRANCISCO. CALIFORNIA 94104
TCLCBMOMC (4151 991-9000 CABLE: MCLBOW
October 29, 1976
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PCNINSULA OFE:CS I BALO ALTO S3LAB,. BALO ALTO. CALIBOBNIA *4104
Mr. J. W. Austin Director, Safety Department California Chamber of Commerce 455 Capitol Mall Sacramento, California 95814
Re: CAL-OSHA, Asbestos Standards
Dear Jim:
I enjoyed meeting you yesterday at the CAL-OSHA Standards Board meeting on asbestos, and I look forward to receiving a copy of the Asbestos Information Association presentation to the Board, which you so kindly offered to furnish to me.
As I indicated to you yesterday, our client is very concerned with the present and proposed health and safety laws and regulations as they affect products with trace amounts of noncommercial asbestos contamination. In the case of our client's products, there is no likelihood that airborne asbestos concen trations will exceed or even approach the maximum amounts per mitted during the entire life cycle of the product, from applica tion and use through disposal. Further, even to the extent that minimal airborne concentrations of asbestos fiber appear, they are tremolite and/or actinolite, on which there is no evidence of harmful effect, even in fibrous forms. We believe that no labelling, reporting, or other regulatory requirements should apply to such products.
I am sure that our view is shared by many California businesses who are aware of asbestos contamination of their prod ucts, and probably would be shared by many, many more, who are presently unaware of the trace elements of asbestos minerals in their products, or are unaware of the applicability of the CAL-OSHA regulations to them. In this connection, I recommend to you the enclosed copy of "Asbestos in Your Future" by Dr. C. S. Thompson of the Research and Development Division of the R. T. Vanderbilt Company, Inc. (a talc producer) which provides a dramatic
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Mr. J. W. Austin
DATE 10/29/76 p. 2
description of the breadth and effect of current and proposed asbestos regulations.
I look forward to working with you in connection with these matters.
Very truly yours,
GEORGE H. CLYDE, JR,
George H. Clyde of Heller, Ehrman, White & McAuliffe
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Bcc: Mr. Robert H. Locke