Document qkZE3zzz5qXBVEkgRG42ORrjq

GAP OOOlCi FROM: HR Hughes, Senior Chemist Chemical Laboratory RE: Material Safety Data Sheets General Motors Corporation cc> ps Hank* JD Lynn G8 LeRoy WF O'Brien December 1, 1977 This has reference to our recent conversation regarding the detailed Information requested by General Motors on the attached Material Safety Data Sheets. As I pointed out to you, General Motors has modified Section 2 of the standard OSBA form to require complete disclosure of all in gredients in the product rather than listing only so-called hazard ous ingredients. 2 am attaching as Item *1 a copy of the standard OSHA Fora 20 and as Item #2, a copy of the Material Safety Data Sheet used by the supplier of our aerosol products. Note the difference in the Section 2 requirements between these forms and the General Motors fora. Attached as Xtsn 13 is the type of ingredient listing we would have to provide to fully eoaply with Section 2 of the General Motors form. This particular listing is for Style 604 as raquested by L.R. Sementilli1 a latter of 10/17/77. 1 seriously doubt that we want to dlaclose to this extant. Also, information la requested on Style 681 which we purchese and resell and I don't know how much formulation information they will disclose to ua. It appears to me that there ere several courses of action we can taka in handling these General Motors forms: 1. Disclose ell ingredienta aa requested on the form. 2. Refuse to fill out the forms at all on the basis that we are not required to by law. 3. Fill out and submit e standard OSHA Form 20 (see Item #1, attached) which would require only disclosure of hasardous ingredients like asbestos. ---------continued December 1, 1977 Page 2 minimum information on composition, perhaps a general description of the product. For Style 604, instead of the lilting shown on Item #3, attached we might aay: 'Style 604 consists of brass wire inserted commercial grade asbestos impregnated with a white natural rubber compound. Exact composition is considered confidential. Style 604 contains about 42% asbestos by weight*. Please note that on the reverse side of the General Motors forms' there is a statement that we give General Motors per mission to use or disclose any data provided in any way. I have discussed this with J. Lynn and he advises that, if we do fill out the General Motors form, we should cross out this statement. Please advise action you wish taken. Harold R. Hughes:nw Attachments