Document 50kmDpJ62oZLVXL0QpxZ85z34
FILE NAME: Flooring (FLR)
DATE: 1980 Aug 22
DOC#: FLR101
DOCUMENT DESCRIPTION: Jack Clegg Memo Stating Strong Opposition Against the Necessity of Labeling
see distribution
PLAINTIFF'S EXHIBIT AMT-94
Jack Clegg
REj ASBESTOS REGULATIONS
August 22, 1980
The move by State and Federal Agencies to legislate mandatory labeling of asbestos containing products is of serious o o n o e m to our industry. In addition to the Connecticut House Bill #5607 and the pending New York State legislation (oopies Attached) CP8C considering a mandatory rule requiring manufacturers to inform con sumers by way of labeling about the presence of asbestos in the product and about proper installation and removal techniques. At the RFCI level, we are taking every avenue open to us to diauade CPSc from' instituting mandatory labeling of our products. Armstrong is also unilaterally taking a strong position against such labeling.
The Connecticut Bill has passed the House and Senate and is now pending Governor's approval. It Is not clearly defined that our products specifically will come under the Bill, but from the intent of the legislation, it would appear that they will. The snowball effect could spread rapidly to other States, each requiring different wording and become a labsling nightmare.
Beyond a strong position against the necessity for labeling, in view of wide discrimination of the "Recommended Work Procedures For Re silient Floor Coverings" by RFCI and member Companies and the warnings contained in individual manufacturer's literature, there is little other action we can take.
With respect to the "Comprehensive Asbestos Seminar" being held in New Haven on September 10 (copy of brochure enclosed), we should consider attendance by our Safety Director and/or others involved in 03HA compliance within the Company.
J C in n
CC DISTRIBUTION >
Mr. D* O'D. Kennedy Mr. J. L. KoIcyski Hr. R. G. oonohoe Mr. B. Gamble Mr. E. L. Uaiobleton
rack Clagg
SP001419
SP001419
NYCAL006208