March 4, 1996

Mr. Daniel McBride
General Manager
Finger Lakes Chemical, Inc.
420 St. Paul Street
Rochester, New York 14605-1797

Dear Mr. McBride:

Thank you for your letter of February 5, concerning the Occupational Safety and Health Administration's (OSHA) Asbestos Standard (29 CFR 1910.1001).

You requested specific clarification on three issues related to the asbestos standard, which will be addressed in the order in which they were presented.

Your first question referenced the June 29, 1995, Federal Register page 33983. The reference to .016 f/cc refers to asbestos fibers.

Your second question referenced the August 10, 1994, Federal Register page 33983. You are correct, in that the reference to 0.1 f/cc does represent the eight (8) hour permissible exposure level.

Your third and last question also referenced the August 10, 1994, Federal Register, page 40987, regarding the labeling requirement for disposal bags. Labels are not required when the fibers have been bonded by some agent that prevents the release of fibers above the eight (8) hour permissible exposure level, and/or the excursion limit. Also when the concentration of asbestos is less than 1.0%. You will find this reference under section (j), paragraph (6)(i) of the General Industry Standard (1910.1001).

We hope this information is helpful. If you have any further questions please contact us at (202) 219-8036.

Sincerely,



Ruth McCully, Director
Office of Health Compliance Assistance




February 5, 1996

Ms. McCully
Occupational Safety and
Health Admin.
Frances Perkins Building
Room N-3467
200 Constitution Ave., NW
Washington, D.C. 20210

Dear Ms. McCully;

On December 13, 1995, Wal Blatter, Andrew Simms (NIB) and I (Dan McBride, General Manager of Finger Lakes Chemical) visited your offices in Washington D.C. We discussed our Wet Kit concept that contains a Terpene based aerosol, direction sheet, disposable towels, and a zip lock type bag, with header.

We are in the final stages of having all of the pieces we need to introduce the program to all of our Distributors. However, we still have three questions that we need more specific answers to. First Vol. 60 No-125 June 29 Federal Register page 33983, it says the equivalent method must not exceed .016 f/cc. Our question is: Does this mean fibers, or asbestos fibers?

Second question: Is Vol. 59 No-153 August 10, 1994 page 33983, you refer to 0.1 f/cc. Are we to assume this is also asbestos and is the amount allowed in an 8 hour work day?

Our third and final question is in reference to Vol-59 No-153 page 40987. It reads the bag for disposal must be marked showing it may contain asbestos. Our tests show that we are averaging .001377 of asbestos, well below the .016 f/cc. Are we still required to mark the disposal bag, showing that it may contain asbestos, when we are well below the 1% weight limit?

Please respond as soon as possible.

Sincerely,



Daniel McBride
General Manager
Finger Lakes Chemical, Inc.