Document wD8ByJwrjwLZDQVwMz21nr2k3
FILE NAME: Montello (MNT)
DATE: 1975 Oct 2
DOC#: MNT003
DOCUMENT DESCRIPTION: Letter RE Information of Super Visbestos in the Drilling Industry
October 2 , 1975
M A w n r r s EXHIBIT DMA.IW7
M r. Tom U ttre ll
MoQcobcr O ilfie ld Products Division
.
Dresser Industries, Ine.
2501 Northwest Expressway
Suite 501
Oklahoma C ity, Oklahoma 73112
Deer M r. U ttre lli
Thanks far your time by telephone yesterday. The purpose of this le tte r Is to offer In formation which we hope w ill be uiefal to you, regarding the application o f our Super Visbestoe in the d rillin g Industry.
A file folder is enclosed which includes double copies o f the followings
1. A resume o f the monitoring tests performed during the fa ll of 1972. 2 . A one sheet flye r which recaps the major paints concerning those tests. 3 . Three separate sets of monitoring test results run In March of this yocr cut of
Woodward, O kla . CA representative from Dresser-Safety In Houston participated.) 4 . A cita tio n form covering monitoring tests in Utah, where no excess fiber counts
ware detected.
The problem you describe appcrently stems from a flu rry o f Inspections during November, 1974, In West Texas and the Panhandle. The compliance officer* were operating out of the Lubbock area OSHA o ffic e . Small citations were levied far non-posting o f caution signs, however no iS h ltcrln g was performed. Our feeling was that the citations were improper, since signs ore only required In areas "containing excessive olrbcme concentra tions of asbestos fib e rs". We do not believe It Is possible to ascertain whether such en excess exists, w ithout monitoring tests, further, our years o f experience In such testing have failed to produce evidence o f such excesses in d rillin g opesetlons.
Following the Incidents in November, 1974, we pursued the matter through the Oklahoma Area office in Tulsa to the Regional office In Dallas. The result was Indecisive, w ith the exception of two points)
Mr. Tom Uttrell October 2, 1975
Page 2
1. In tholr rotponM to M, OSHA it*t*d that th* eompllone, officer,
lodgement wutt bo backed up with documentation, In nch cow *
(No dooumontotlon of ony kind wo, produeod In th* Novwnbor
citation*, o far m w# or* owero.)
-
'
2 . Th* Im pocton hovo, to our knowlodgo, tud no^furthor citation to oror, o f Supor Vhberto, In thot oroo Inc* th * Novwnbor flu rry .
A . to th . quotlon o f cita tio n , whon urlng S u p ^ V ld to ^ vto know o f ~ W TM * n * *
U .S. where any have boon laued on th * barf, of *xee flb w count,
m o n lto rln o c ic lffa d in th * r e la tio n ,. ^ ^
fa lfa d fa
for ov*r thro* yean. (Th. form from Utah I, on ew m pl* o f monitoring which fa !l*d to
rov*al any excois fib e r count*.)
A, to th . qooitlon of the hwrlth hotafa whon Ming Super V I* .* , ^ n ' monltori6
data In d icia , o rof.ty In of opproxlmat.ly 5 to 1 In
rp\
Thl, w fo ty margin, the porodlc and >hart Mm*
1
a ir work place, and th * to ll pounda*, required, or* d l plu** * *
\Zltb*Wor Ve b * li* v * thor* 1, no recwmobl# expectation of exceeding th * regulation,
when Ming Supor Vllbedo*.
PIoom lot w know If you hov* further question,, or wh.novw w* can b* of * " ! ln V
P way. W* appreciate your bmlneu and w ill look forward to applying you gain soon. Slncoroly,
MONTEOD, IN C.
Kenneth N . Campboli KNC/w) Enci (folder) cu Mr. H. R. M otley, >
cs