Document r71ab4ZaYGge5gQRe64zwxpG

FILE NAME Allied Signal Bendix ASB DATE 1972 Nov 6 DOC ASB077 DOCUMENT DESCRIPTION Memo - Interpretation of OSHA Labeling Requirements FRICTION MATERIALS STANDARDS INSTITUTE INC 210 ROUTE 4 PARAMUS N.J. 07652 November 6 1972 TO Delegates & Alternates Asbestos Study Committee SUBJECT Interpretation of OSHA Labeling Requirements type brake The Chairman of the Asbestos Study Committee is requesting a survey on their interpretation of the labeling requirements for asbestos of members brake lining and clutch facing shipments On June 20 1972 the Institute distributed OSHA Standards for exposure to asbestos dust A had to do with labeling requirements to all members a key paragraph in copy of the the standards labels all 2 Caution shall be affixed to all Labeling Caution labels raw materials mixtures scrap waste debris and other products contain- ing asbestos fibers or to their containers except 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 fibers in 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 grooving drilling and grinding The Chairman indicates that these subsequent operations can produce airborne concentrations of asbestos excess of the current exposure limits 5 fibers TWA or 10 fibers ceiling The questions are 1. Do you now label asbestos type friction materials with the label as specified in the OSHA Standar reelscoment shipments original 1.1 For reelscoment market 1.2 For original equipment shipments 2. Do plan withyou label asbestosasbestostype type friction materials this label 2,1 For replacement market shipments ? original replacemnt equipment shipments 2.1 For interpret 3. 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 Would you please complete this have it done by the individual responsible for implementation of the OSHA Standarda return to me at the Institute Office E. W. Drislane Executive Director FMSI FMSI 02808 FRICTION MATERIALS STANDARDS INSTITUTE INC 210 ROUTE 4 PARAMUS N.J. 07652 OSHA LABELING LABELING REQUIREMENTS 1. Current Labeling Practice 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 2. Labeling Practice Practice 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 Labeling Labeling Regulations 3.1 We interpret the OSHA labeling regulations to require caution labels on friction material shipments that will have subse quent working etc. drilling grinding 000000 0000 0000 0 0 0000 t ) BY COMPANY DATE FMSI 02809