Document zdLqGj5gXyg8Y2rOY53p0LeGa

( (j)(H) 0 C_ Inter CMc. Hr. D. T. Axon Supply SUfl July 2.7, 1977 co B. B. Murray Subject: Proposed OSHA Rule of .5 Airborne Asbestos Fiber/cc _ - M. R. Lower's July 14 Communication to L. M. Chieoine In response to your request, the following are comments relating to M. R. Lower's July 14 communication to L. M. Chieoine pertaining to airborne aabefltos: . Brake linings, gaskets, seals, and raw asbestos were referenced by Lower, Clutch facings were not mentioned tit offer development cbalienee2 which may exceed brake lininga development challenges. - Th letter does cot mention the NIOSH .1 fiber/ee recommendation which would effectively put us out of the asbestos business. . The communication does not have a recommendation to proceed wtth " programs to develop non-asbestos parts which is not consistent with NAAQ forward plans which state: "Proposed new OSHA standards (.05 to 1,0 fiber/cc) for ( airborne asbestos exposure may force suppliers to cease production of asbestos broke and clutch linings and gasket materials, MAAO Purchasing established a program ta expedite development of alternate materials'1 (see attached D. P, Cratty to D. T. Axon note). . Lower concludee the letter by saying, "It, therefore, is unlikely that vs would encounter a sudden and unpredictable cutoff in the supply of asbestos bearing products" which implies that further action is not required. As Engineering activities estimate that three to five years are required to develop asbestos-free parts, what will the Company do if we are given one year, or two years (which is not "a sudden unpredictable cutoff"), to meet the NIOSH .1 fiber/cc proposal? Mr. Lower's conclusion tends to leave the impression that we need not concern ourselves with the asbestos problem which is probably not his intent. . 1' .. J" . i1 - A3 all suppliers contacted stated there will probably be e program by OSHA tc continually lower allowable airborne asbestos contaminants and as a major supplier (Raybestos) hae a published policy to phase out of asbestos. Supply Staff should encourage budgeting funds for asbestos-free parts development programs. It is not necessary to proceed with ernoh programs, but we should " be aware that within an undefined period of time, possibly two-five years, . that we will likely have extreme controls relating to the manufacture of asbestos containing parta. ___ ^ ~ D. P, Crutly 003114 J1 PRODUCED BY FORD 105511