Document 4JXxzo5vL7eB0LGQNr66Eb37x

. . . UXIOIST CARBIDS COKPOPLATXOjST '. . . Law DiPAnTJiEiiT . ` 270 PARK AVENUE NEW YORK, N, Y. 10017 ' . , ^ '. ' .* . \ ' October 31/ 1963 Food and Drug Administration Washington 23# D.C. _ 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 1 paper and paperboard does not result, and may not reasonably be expected to result, directly or indirectly, in its becoming a . component or otherwise affecting the characteristics 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 ex perts qualified by scientific training and experience to evaluate its safety. (3) If not, we ask you to file this letter as a petition ' for a regulation under Section 49 of the Federal Food, Drug and Cosmetic Act stating that this use of asbestos fiber is safe. We propose to coll aobcotoc fiber for this use. Responsible paper manufacturers tell us that it improves the quality of paper and paperboard for certain food contact use. We base this petition on the generally known physical characteristics of asbestos fiber. While we write in terms of "asbestos fiber" without limitation in view of your presumed interest in a broad regulation, our company's direct present interest lies in c'nrysotile asbestos (a magnesium silicate). We attach a table entitled "Solubility and Dissociation Data for.Chrysotile in Water" from The Journal of Physical Chemistry, Vol. LX (1556) page 1220, and our summary of "Properties of Chryso tile Asbestos Fiber". We respectfully propose the following regula- . tion: . <3121.__ Asbestos Fiber. * Asbestos fiber may be safely used as a component . of paper and paperboard intended for use in producing, . . manufacturing, packing, processing, preparing, treating, ' packaging, transporting/ or holding food. ' ' - * ` - Very truly yours, " UNION CARBIDE CORPORATION . . GTS:R enc. Bjr________________________ George T. Scriba A24322 UCC 024944 I'