Document vVaaJBaEzLYXBoZw4vEXm1jBE

FILE NAME DuPont DUP DATE 1974 June 18 DOC DUP156 DOCUMENT DESCRIPTION Letter from N.K. Walters from the Engineering Service Division RE Employee Relations - Safety & Fire Protection Occupational Environmental Control - Asbestos - Dust T ae oe ; . QU PONT Nemours ; ' E. I. Du Pont de Nemours & Company . WILMINGTON DELAWARE 19898 ENGINEERING DEPARTMENT | June 18 1974 CC1 B. 2 G. R. ., : W. N11400 F. Reinhardt A. Christian S. Pease HE Lab apt . EXHEIBXITHIEXBHIITBIT # Punha Punha DATE 9/5/16 MASTROLAMINI MASTROLAMINI MASTROLAMINI FORMABOLI MISS CERTIFIED SHORTHAND REPORTE fundit ee . - file file N. K. WALTERS EMPLOYER RELATIONS DEPARTMENT WILMINGTON N12430A EMPLOYEE RELATIONS SAFETY & FIRE PROTECTION OCCUPATIONAL ENVIRONMENTAL CONTROL - ASBESTOS - DUST materials questions During our recent Company conference on thermal insulating were raised as to what constitutes exposure to asbestos As you know OSHA requires certain medical examinations for workers who are exposed to asbestos Unfortunately the OSHA regulation does not define exposure At the conference one of the NIOSH personnel stated his interpretation of exposure to asbestos to be exposures greater than 2 fibers vs. the time weighted average TLV of 5 fibers On the other hand the NIOSH criteria ; for a recommended standard defines exposure to asbestos to be time 5 fwiberseightcecd exposures above 1 fiber or peak exposures above , . wo Because of the confusion I called Mr. C. Ray McClure Chief of the Division of Occupational Health Department of Labor Washington D. C. His office has responsibility for interpreting OSHA regulations This letter is to inform you of DOL's interpretations for your consideration use . r : 1. According to McClure an occupational exposure to asbestos is ; interpreted by DOL to be any measurable level above clean outside ' : air DOL cannot hold the employer responsible for clean air levels i.e. levels over which the employer has no control McClure added that the reason for this interpretation is that ve do not know what a hazardous concentration of asbestos really is Hs went - on to say that DOL in taking this stand disagrees with the NIOSH interpretation which of course has no legal status . 2. McClure had no knowledge whether or not DOL's interpretation had been tested solicitor solicitor in the courts but it has been cleared by the DOL . 3. In light of DOL's interpretation McClure states that medical examinations specified in the OSHA standard are to be given to every employee who is regularly exposed to asbestos in the course of his work , BETTER THINGS FOR BETTER LIVING ... THROUGH CHEMISTRY June 18 1974 N. K. Walters If there are any questions please call me ENGINEERING SERVICE DIVISION Frank H. Fuller Consultant Heat Stress Dust and Fume Abatement Control Occupational Environmental Control Group FHF ctb RECEIVED JUN 20 1974 HASKELL LAB