Document 7RoNdwNbK9Jyypg1z2Vy2gR1j

i dfl ft! 2. Regulation* -- MASSACHUSETTS t^CGr- (Hc/C t T'-y-Z? Due to tubstontfol practical marketing problem, Increased costs and inconvenience to customers, NPCA and its members hove questioned the requirement that certain products emiqpt from the Massachusetts lead regulations (automobile refinishet, industrial and commercial mainte nance products, etc.) be marketed only in containers of two gallons or more . Massachusetts author ities now are considering a revision to the Iced regulation to alleviate this problem. NPCA olso is continuing to question the Following issues raised by the Mossoehusetts lead regulations; 1 - The special labeling (e.g. Poison statement) required by the Mossoehusetts lead regulations, especially in light of Federal preemption of labeling for products covered by the Federal Haaordous Substances Act? The reporting requirements of the regulations (which wore to have been complied with by July 1, 1973) and the extent to which these provisions require lead content data for individual products?- 3 - The impact of the exemption for "original finish points" on coatings used in the original equipment manufacturing of appliances, air conditioning units, heating units, otc., which may be used in households? In on attempt to obtain some accommodation on these issues, NPCA has arranged a meeting on July 10, 1973, with appropriate Massachusetts officials Further developments will be reported as occurring 0007-SWP-036560 N21844