W. M. Deutsch to C. L. Sheckler on the New York Sanitary Code and Hazardous Product Labeling (1969)

A two-page memo of September 11, 1969, from Warren Max Deutsch at Johns-Manville's headquarters to C. L. Sheckler, copied to E. M. Fenner and D. B. Wingerter, on "Hazardous Product Labeling, Industrial Insulations Products." The next step, Deutsch wrote, was to decide which of the division's products containing asbestos fiber or crystalline silica were hazardous. He quoted the New York State Department of Health Sanitary Code, which required warning labels on "any substance which is a hazard" and defined hazard as the risk of illness from "any reasonably anticipated type of handling or use of a substance" by reason of inhalation, and suggested that definition as the general guide.

What it shows

Deutsch framed the question as which products "can be reasonably anticipated during handling or use to produce potentially harmful dust concentrations," and pointed to new federal safety and health standards for federal supply contracts that listed limits for asbestos and silica dust. Products found hazardous, he wrote, "should be appropriately labelled to caution the hazard involved," and he asked to review the final wording. He also restated his agreement with the legal principles in Sheckler's May 1968 memo on labeling insulation products (Sheckler to Wingerter, 1968). E. M. Fenner had already drafted guidelines sorting the products into those to be labeled and those not (Fenner to Wingerter, August 1969).

In Johns-Manville's chronology

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

Warren Max Deutsch memorandum to C.L. Sheckler, 9/11/69, discusses the requirement of the New York State Department of Health Sanitary Code on "any substance which is a hazard". "Hazard" is defined as:

". . . the risk of injury or illness which may be encountered during or as a result of any reasonably anticipated type of handling or use of a substance, or during its specified use, if any, be reason of . . . inhalation . . . ."

Deutsch suggests that the definition be used as a general guide to what a hazardous product is. "In the context of industrial insulation products, . . . consideration is which products, if any, can be reasonably anticipated during handling or use . . . ."

Related documents

• E. M. Fenner to D. B. Wingerter on Which Insulation Products to Label (1969)
• C. L. Sheckler to D. B. Wingerter on Caution Labels for Sil-O-Cel and Marinite Insulation Products (1968)