Document 3QMO0MaJDBLoGRORed733YQ0a

FILE NAME: Union Carbide (UC) DATE: 1963 DOC#: UC086 DOCUMENT DESCRIPTION: Letters between Union Carbide and the FDA RE Asbestos Fiber DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE FOOD AND DRUG ADMINISTRATION W ASHINGTON 25; D .C . 20204 . December 6, 1963 Hr.- George T. Scriba Union Carbide Corporation 270 Pari; Avenue New York, New York 10017 Dear Mr. Scriba: Deference is made to your letter of October 31, 1963, relative to the status of an asbestos fiber as a component of paper and paperboard. * He concur that when used consistent with the principles of good manufacturing practice asbestos as an inert filler in paper and paperboard does not have food additive status. Therefore, there is no necessity for a regulation to prescribe the use of such asbestos fiber as an inert filler in such paper and paperboard. Sincerely yours, ff/U W :A A. -63. Frederick A. Cassidy Food and Drug Officer UCC 000083 4 '035 W.'3" v UHICXN* C A R B I D E C O H P O R A T I O N 270 PARK AVENUE NEW YORK, N. Y. 10017 Law De p a r t jis October 31i 19^3 WPoaosdhianngdtonDru2g5>ADd.mC.inistration Re: Asbestos Fiber Gentlemen: . (1) This is to inquire whether you are in agreement with- us that the use of asbestos fiber as an integral component of Daner and paperboard does not result, and may not reasonably be bisected to Result, directly or indirectly, in its oecoming a . component or otherwise affecting the characteristic3 of the food when the paper or paperboard is employed in contact with food. (2) If not, whether you are in agreement with us that this use of asbestos fiber is generally recognized as. safe among perts qualified by scientific training and experience to evaluate - its safety. _ (r ) If not, vie ask you to file this letter as a petition for a regulation under Section 409 of the Federal Food, Drug and Cosmetic^Act stating that this use of asbestos fiber is safe We propose to sell asbestos fiber for this use. Responsible paper manufacturers tell us that it improves the 0n / paperboard for certain food contact use. We base unis petition on / the generally known physical characteristics of asbestos loer. Sill vrriL i H e L i of "asbestos fiber" without limitation in view of your presumed interest In a broad regulation, our company s. direct present interest lies in chrysotile asoesuos (a magnesium silicate). Vie attach a table entitled Soluoility ana Dissociation Data for Chrysotile in Water" from The Journal of Physical Chemistry,. Vol LX (1956) page 1220, and our summary of Properties of Chryso- llle Asbestos Fiber". We respectfully propose the following regula tion: ' <J121. Asbestos Fiber. . A'sFestos fiber may be safely used as a component of pacer and paperboard intended for use in producing, . manufacturing, packing, processing, preparing, treating, packaging, transporting, or holding food. ' Very truly yours, UNION CARBIDE CORPORATION GeTnSc:. R By_ George T. Scriba UCC 000084 x r o 359