Document 3QndZ5OdVDj26p3vXBa0vY0Ly

ZONOLITE construction products division CONFIDENTIAL October 8, 1974 TO: R. M. V ing SUBJ: Monokot 3 In Canada CC: H- A. Brnun T. P. Felt J. L. Wright WRG 00055' RECEIVED OCT 8 1974 CONSTRUCTION ?00UB5 8IVIMM N. / PLAINTIFFS J{ EXHIBIT " WRG-722 A policy-type decision is needed on whether we continue to sell MR-3 in Canada unless or until its use is prohibited. It's my understanding that Jim McKague intends to continue with MK-3 and that there are no overall limitations by the Canadian government prohibiting its use, although certain local authorities have. Where it is prohibited, MR-S is being sold The case for MR-3 is the lower cost possible. The case against it is: 1. Grace could get critical publicity from selling an asbes tos containing material. 2. If there is legislation against MR-3 there can be a concern generated on asbestos content of vermiculite. (If MR-5 had totally replaced MR-3 prior to EPA's action I don't believe we would ever have had any question generated in the market about the asbestos in vermiculite. 3. Selling MR-3 in Canada could continue attention and confu sion on Monokote in the U.S. It will be necessary to list MR-3 at UL and face the kinds of Issues as in the attached correspondence.. 4. Mannfaf.tntlng- MRyl creates asbaatoa- problems.- iir otterplants^ If this is attacked by air agency,, there is a risk that, the investigation would continue to a concern on vermiculite. 5. Continuing MR-3 will require testing and evaluations at UL plus all other overhead expenses related to the management of this type of product. UL work alone could be a major cost item. The attached letter needs to be sent if we are to continue MR-3 In Canada. It's my recommendation that we cancel MK-3 Immediately and elimi nate the concerns listed above. BRW:cj Attachment 1 B. R. Williams ZONOLITE CONSTRUCTION PRODUCTS DIVISION 05 7? rnltht* T7T: October 1, 1974 L Hr. Robert M. Berhinig Engineering Group Leader Fire Protection Department Underwriters Laboratories Inc. 333 Pfingsten Road Northbrook, Illinois 60062 Dear Bob: Re: Subject 263 - Spray Applied Fireproofing Materials Containing Asbestos This is in response to your letter of September 20 on the above subject. Since mid-1973, Zonolite has discontinued manufacturing MONOKOTE Type MK3 fireproofing in the United States. Since that time, we have ex clusively produced MK4 and MK5. We have continued to maintain our UL listing for MK3 because this product is still marketed and sold in Canada. The affected Canadian companies--Grace Construction Materials, Ltd. and F. Hyde & Company, Ltd.--are multiple listees. Because it is my under standing* that the multiple listing must be identical to the listing for the parent company, keeping MK3 listed for Zonolite becomes necessary. All other listees of MK3 (Ari-Zonolite, Robinson Insulation, Texas Vermiculite, Vermiculite-Intermountain, and Vermiculite Products) would have no reason to continue their MK3 listing. Very truly yours, 7m/ Tnomas P. Feit Manager Fire Protection Products TPF/dz ccr T- V, McKague/Zono-Scarborough A. D. Webster/F. Hyde & Co., Ltd. J. B. Robinson/Robinson Insulation Co. L. K. Irvine/Vermiculite-Intermountain, Inc. J. H. Greer/Vermiculite Products, Inc. R. B. Moran/Texas Vermiculite R. K. Burnham/Ari-Zonolite Co. * UNDERWRITERS LABORATORIES, INC. 333 PFINGSTEN ROAD NORTHBROOK. ILLINOIS 60061 * an independent,not-for-profit organization testingfor public safety Subject 263 333 Pfingsten Road Northbrook, Illinois 60062 .September 20, 1974 TO: The Manufacturers of Classified Spray Applied Materials With Asbestos (CALV) SUBJECT: Spray Applied Fireproofing Materials Containing Asbestos. Gentlemen: The Federal Environmental Protection Agency has established that there shall be no visible emission to the outside from the spraying of materials containing more than one percent asbestos (by weight) which are used to insulate or fireproof buildings, pipes, conduits, etc. Attached is the wording from the Federal Register Vol. 38, No. 66, Paragraph 61.22 (e) dated April 6, 1973. In addition, some states and municipalities have even more stringent requirements. In view of the above, we propose to delete our Classification of fireproofing materials containing more than one percent asbestos. Before taking this action, we invite your comments and suggestions. Please address them to the undersigned at the Laboratories' Northbrook Office as soon as convenient and before November 15, 1974. UNDERWRITERS LABORATORIES INC. R. M. BERHINIG TTy Engineering Group Leader Fire Protection Department REVIEWED BY: T. CAS UNO Managing Engineer Pire Protection Department RMBrkh FP-3 Lstd. Mfgrs. .*. *. - n'- 312 272 &O0 Tils*: 72 4331 CbH: UUHC NOftTHMOOK 11* /V , object 263 September 20, 1974 Federal Register Volume 38, Number 66, Paragraph 61.22(e). "(e) Spraying: There shall be no visible emissions to the outside air from the spray-on application of materials con taining more than 1 percent asbestos, on a dry weight basis, used to insulate or fireproof equipment'and machinery, ex cept as provided in paragraph (f) of this section. Sprayon materials used to insulate or fireproof buildings, structures, pipes, and conduits shall contain less than 1 percent asbestos on a dry weight basis." V