Document 7O1X65zLxzGpOy68LaeD3m4je

WFVLA, Washington Nr. w. D. Kinasll Nr. J. K. Ntri Nr. e. Ivehtal Nr. S. T. Sowell, MW Nr. B. 1. Buchnsr W. Tone *r FEB i i .. \N- 'to'aC., r V B l\ W2- February IS, 1977 Or. Charl*o C Bdwards Commissioner F.D.A., Dept. R.I.V. St')) Flehars Lane Rockville, Naryland 1381) Dear Or. Kdwardai bast week Z had ths privilege to be present at dissuasions which included PDA personnel. Dm subject s( this meeting centered around lead contant in scchitsctnral finishes* Zt was My impression that sons aspects or ths situation were not entirely clear and other# have not been made as evident aa they night be. Chic company support! the objective# of the VDA proposal ss published In the Woeaaber 7, 1971 Federal Register and has expressed this attitude before the Nearing Clerk in the Department of Health, Bducation I Welfare, Zt le the company*# longstanding positl that the O.St lend level ie proper ee it present# no hisnrd to the public, end ve have reformulated our interior architectural product# to Meet the h.f* load content restriction, Zn nesting this regulation ve have renoved all lead-baaed pigmenta which conetItute the major lead-bearing constituents of such coatings. This reformulation program has resulted in e position that we now manufacture over 71* of our Interior architectural coatings gallonsg# with ne added lead content other than inadvertent contaminant# In rev Materials* Ths remaining i'M of our gallonage contain# J|&X **** 4jr*#r compounds resulting in less than 9,9* load content but mors than O.OS* contant. Freeent alkyd rosin and drying oil based eontings srs those which still requirs the nee of email amounts of lead driers to adequately perform oftor Shelf-aging end under cool, humid condition#. In this group are floor enamele, and general purpose interior elkyd costings. Xn view of pending legislation before several state and local governments which we believe is an attempt to coerce GLD012602 Dr. Charles C. fidvirAi coautlas loner P.D.A. - a February 19, 1972 or force the Industry to accept a standard eernewhere between Congressmen ltyan*e OH level and tha .5* level proposed by tht VDA, we viah to asoara you that a diligent and concerned major effort la la progress to raforMilata thla remaining portion of oar architectural products. Our objective la loot than 0t>9* lead content bat to at 111 provide an ade<|uate product to the cooeaner. Aa obvious objective here la refereolation with lead substitute drier compounds la vhieh we have complete confidence of proven non-toxic qualities. be respectfully seek your consideration and anpoort in obtaining a year in which to accomplish this objective of reducing the lead content of theso Interior architec tural products to less then O.iif* lead content. Yours very truly* HJXlefer Director of Research end Development Coatings end It*a ins group fUDOM^HOKKIV Division of fCM Corporation GL0012603