Document wg8L9JDKy3Jv5yxxJ98Xdng56

i4>ex An 1C Industries Company ' X November 7, 1975 C & M Axle Division P.O. Drawer 9269 Highway 80 West Montgomery, Alabama 36108 Attention: Mr. W. Kroell Dear Sir: . ! Have you been alerted to the Department of Labor Docket IH-033 which appeared in the October 9, 1975, Federal Register? This proposed revision to OSHA Asbestos Standard (29CFR1910.1000) covers a broad field, such as adequate cautioning to users.of asbestos, employee information and training, signs and labels, medical records, etc. The present level of asbestos exposure is five (5) fibers . per cubic centimeter. On July 1, 1976, the limit will be dropped to two (2) fibers per cubic centimeter. We already meet or exceed this level at our various plants and consistently support Improved regulations for the health and safety of our employees. We are concerned about many of the individual proposals covered in Docket tH-033. However, our primary concern is with the proposed reduction to .5 fibers per cubic centimeter. This is such a drastic reduction that we feel you should be alerted to the far reaching effects such a regulation would have on your business. At this time, we simply do not know if .5 fibers per 'cubic '.centimeter is attainable, . Considerable investigation and time will be required to determine this. - We must * proceed cautiously. If the industry determines that .5 fibers per cubic centimeter-is unattainable, it could mean the demise of the asbestos friction material industry. Over 95% of the automotive applications in the United States today use asbestos friction materials. The implications of the possibility of shutting down our transportation system are very real. \ We, feel that ' utmost caution must be used by this potentially over- zealous regulatory agency in establishing any new asbestos fiber limit. . Atopy of the proposal is attached for your information and use in the preparation of an urgent response. An ' expression of your concern is specifically requested to be submitted in quadruplicate to the: - VPD-153-0000975 DANA-322 Mr. Kroell 2 11/7/75 Docket Officer Docket IH-033 U.S. Department of Labor Room N-3620 200 Constitution. Avenue, N.W. Washington, D.C.- 20210 This must be postmarked on or before December 8, 1975. It would be most appreciated if you would forward a copy of your response to my office. Thank you for your usual fine consideration and cooperation. Very truly yours. L. Earle Bretz, Jr. Manager - Original Equipment Sales /ph Attachment VPD-153-0000976 6 Engineering controls arc required to reduce the exposure* even if they won't result in asbestos levels within the allowable limits. Periodic exhaust system checks are required. 7. A medical control program with preplaccment* annual and tormi-- * nation exams is required. . .. a. Sprays* pulmonary function.tests* sputum cytology and medical history arc included. . . b. There are- provisions made for an employee's refusal to ' take the examination. '. * 8. A compliance program must be developed and made available* on request* to 0S1IA. The program must be revised and updated every six months. . # 9. Employees whom the doctor 6aye' cannot function normally while using's respirator 6hall be, to the maximum extent possible:. a. Rotated to another job. ' ' b. Given the opportunity to transfer to another job, subject to the following requirements: __ -. 1. Duties he can perform. .. -` "* ** . - 11. Same employer. ** *. -` as ` ill. Same geographical*area. - -- ;> 'z *? - * iv. Same seniority, status and rate of pay. .. 10. Danger signs end labels, housekeeping end waste disposal provisions are included. - 11. Extensive recordkeeping requirements'are included with respect to asbestos monitoring and medical examinations. Monitoring records must bs made available to employees upon request. Medi-- ti>l records muse be made available to employees1 doctors upon request. All records must be made available to OSHA upon re- ' ' * quest. Records must be maintained for 40 years or an employee's ' emj&bymsnt interval plus 20 years, whichever is longer. - ' 12. Bfgpyee training programs, both preplacement and annual* are _ ' required. The. programs are to include the bow and why of - '' . operating procedures, medical examinations* etc. Employees - are to have access to the asbestos standard and training materials. 2- VPD-1J3-0000977 PROPOSED OSHA ASBESTOS STANDARD October 9, 1975 Oa October 9, 1975, a new proposed OSHA asbestos standard was published In the Federal Register. The proposed standard has stricter requirements than the present OSHA scandard'. A summary of the proposed scandard follows. 1. The Cemscruetion Industry is excluded. * 2. Applies to ali locations where asbestos or products*'cointain- * ing asbestos is manufactured, processed, packaged, stored, . applied, used or otherwise handled. 3. The allowable eight-hour time-weighted average concentration is 0.5 fibers/cc and the allowable ceiling concentration is 5 fibers/cc. ' (The present standard calls for a 2.0 fiber/cc average and 10 flbcr/ce ceiling effective on 7-1-76.) 4. Regulated areas must be established where the allowable con- centratlons are exceeded. .. a. * Only au tho. rizetd employees may. ente*r ar.e. a* ' 1 : b. A daily roster of all persons entering the area must - be maintained* c. Respirators and respirator programs are required. . - . d* Employees must be allowed to leave the area .to wash \ their face end clean their respirator. . e. Ho eating, drinking, smoking or chewing is allowed In the area. *. ' , f. Change rooms axe required with separate lockers, showers, ` ' etc. .. * . g. Employees must "be provided daily with clean and dry protective clothing to include coveralls, head covering, , gloves and foot covering. ' . *, ~- 5. Monitoring la required in ell exposure areas. -a a. Monthly if greater than the allowance exposure. ' * e. ', I b. Quarterly if within the allowable exposure.* c. Can'be discontinued if two consecutive samples within a certain time frame are within the allowable levels. `d. Hoc every employee need be monitored. e. Required after every procese change. -1-- VPD-133-0000978 , --