Document qmyMkKjQEO6NYdJVdzGbDQ6VK

ZONOLITE CONSTRUCTION PRODUCTS DIVISION August 14, 1978 TO: E. S. Wood SUBJ: M.S.D.S.-- Monokote cc: B. i.. Blessington H. 6. Duecker R. CKEricson W. R. Hanlon R. A. Merther J. W. Wolter \ Our experience in California provides a basis for using Ericson's Option #1 on the M.S.D.S. Cal/OSHA officials agreed with our position on 3 important considerations: 1. The asbestos content in Monokote was de minimus and far below levels that they felt justified any concern or regulation. 2. The concept of having a maximum allowable quantity of any hazardous material was essential since ever-improving analytical techniques continually lowered "detectable levels". 3. Reducing by 50% the EPA recommended maximum asbestos content of a material (from .5% to .25%) provided adequate safety. (Monokote has levels from 0 to .002%.) Based .on this, we are justified in treating the de minimus level of tremolite in Monokote in the same manner that the gypsum companies treat free silica, i.e., make no mention of tremolite and mention only nuisance dust. BRW/cj B. R. Williams grace] [---- -- D009395 15193135