Document zQnL9G3agomo034BGzG07vjd3

FILE NAME Allied Signal Bendix ASB DATE 1972 Nov 28 DOC ASB051 DOCUMENT DESCRIPTION Letter to Bendix from The Friction Materials Standards Industry RE Warning Labels 55 November 28 1972 Mr. J. H. Kelly Belix Corporation 121 S. Walnut Sort South Bend Indian 46621 De Jack This concerns brake linings out are discussion concerning labeling being shipped to customera requirements where In attempting to determine what practice one must use OSBA has stated that if one is meeting the spirit of its regulations it will not be cited for violations As a result of this it becomes necessary to interpret some of the OSHA regulations I am enclosing with this letter copies of letters written by the Executive Secretary for the Asbestos Information Association AIA You will note on these reports that Mr. Armstrong from Bendix corporate headquarters attended there meetings There is absolutely no question concerning the requirements for labeling where loose asbestos is being shipped The big problem develops where Dembers are shipping what the AIA and OSHA refer to as locked in asbestos products - brake linings brake blocks clutch facings etc. When customers of yours drill linings chamfer linings cut linings or grind linings they may very well raise the asbestos concentrations in the atmosphere to above the OSHA standard Some members have indicated that the drilling and grinding operations are problem areas in brake lining factories with existing exhaust systems Therefore if a customer of yours started drilling or grinding without having proper dust collectors he would probably be in vaslation of the OSHA standard It therefore becomes your responsibility as the supplier of the brake lining warning to warn the customer of this possibility The form which the takes is still not definite but the best guidance seems to be if you meet the spirit of the regulations you will not be cited for a violation or cartons Therefore " or pallets a you sem^pd utein every one of your skids warning notice to the effect Power tools without dust collectors should not be used for machingng cutting or sanding this product If a notice such as this were enclosed with every carton or stenciled on the outside of the carton it is likely that you would be meeting the spirit of the regulations If you were to write your customer and tell him about this with every shipment made you would probably be also meeting the spirit of the regulations If you send a one time letter to your customer saying this it is hard to say whether you would be meeting the spirit of the regulations T s) Bendix Corporation -2- November 29 1972 I am enclosing a copy of the warning label suggested in the OSEA regulations where loose asbestos fibers are being shipped and the Instruction Sheet auggested where a customer is to do further machining on clutch facings brake lining etc. I hope this is enough information for you Dave Stone attended our Dost recent Asbestos Study Committee Meeting where the subject of labeling was brought up Your Mr. Armstrong is aware of some of the controversy concerning labeling The current survey indicates that no members are now labeling shipments A slight majority of those responding to date indicate that they interpret the OSEA " regulations to require some kind of a warning where subsequent work is to be done on brake linings This is controversial item for the Institute in that some members feel that one or two companies are tryintgo railroad them into labeling Another group of companies feel that we should comply with the spirit of the law now and it is not fair if they do the proper labeling and their competition does not Sincerely FRICTION MATERIALS STANDARDS INSTITUTE EWD 11z Loc E. W. Drislane Executive Director IN,e