Document 99zN4jVjbn4bbpJoyRbe1yd15

c November 13, 1963 Mr. L. T. G? miller! Technical Manager HOOKER CHEMICAL CORPORATION Ruco Division New South Road Hick3Ville, New York 11802 Deer Lou: A member of your staff, Mr. Fabrizio, telephoned last week regarding the PDA attitude on vinyl resins and more specifically, I believe, how the PDA policies might effect the use of bulk resins in specific applications. Our original PDA approvals were based on studies done many years ago on Geon resin. It is our attitude that FDA is not concerned about the manu facturing process used to make our different resins. We satisfy ourselves that a resin will present no hazard in a specific application by running the prescribed extraction tests. It is our present opinion that the manufacture of polyvinyl chloride by the bulk polymerization process will not require new toxologieal or feed ing studies. Ve do not now deem it necessary to initiate any discussions with PDA on resin mode by this process which, in our opinion, falls within the category of prior sanction resins. We hare been informed that Dow ran extraction studies on the following PSG resins: RB 8010 GB 9010 GB 1010 GB mo GB 1210 BFG04357 20653001 HOOKER CHEMICAL CGHP. Mr. L. T. Cemilleri c Page Two 11/13/68 Dow data indicated the above polymers can be used in food packaging applications and will comply with FDA requirements under the Food Additives Amendment. If Mr. Fabrizio wants to be informed on the FDA regulations, we suggest he get from the Food end Drug Administration their food additive regu lations that pertain to indirect additives. Mr. Fabrizio also inquired about the molecular weight of Geon resin 104 which is Just a shfde lover than Geon resin 103. The inherent viscosity, according to ASTM 1243-60, of our resins is as follows: Geon Resin 101 - 1.10 Geon Resin 103 - O.96 Geon Resin 104 - 0.86 If you have any further questions, please let us know. Cordially, James S. Wolff/jmm bcc: tX*. McCormick - Akron L.R. Jimenez E.B. Osborne B.M.G. Zwicker Salas Manager Monomers end Petrochemicals C 01 Cfl? Ci2 3 P BFG04358