E. M. Fenner to H. B. Moreno on Plant Dust Sampling and Records Under the Emergency Standard (1971)

A two-page memo of December 27, 1971, from E. M. Fenner of J-M's Environmental Control Department in Denver to H. B. Moreno, answering his proposal, after the OSHA emergency standard, to train a salaried employee at each of four plants to take personal air samples. Fenner replied that the industrial hygiene laboratories at Manville and Waukegan, where "approximately 90% of your problems exist," could already serve the plants, and that "to whatever extent we attempt to use data obtained by local plant people, our credibility would be impaired particularly insofar as OSHA is concerned." He added that "The practice of having complete Industrial Hygiene Survey permanent record books at each location was discontinued approximately two years ago at the request of the legal department."

What it shows

Each plant still had a master list of its stations and a history of those that had been over the limit, Fenner wrote, while the complete books were on file at headquarters; "Special reports are now provided each plant for discussion with OSHA inspectors whenever necessary." The memo shows J-M's full dust records being kept centrally, at the legal department's request, from about 1969, and the company weighing how its sampling would look to OSHA. Fenner offered faster service to the Billerica Plant and the Laurinburg plant as well.

In Johns-Manville's chronology

Johns-Manville's own chronology of what the company knew describes this document as follows:

Fenner writes to Moreno, 12/27/71, that each plant has a master list of all stations and "a history going back to the base survey of all stations." The practice of maintaining permanent record books at each plant was discontinued 2 years ago at the request of the legal department.

Related documents

• OSHA Emergency Standard for Exposure to Asbestos Dust (1971)