Document JN0OZLY4VEVNvmLB4a4dE1nm2

Sfatumal |Jautt 'Burnish unh jUnrqwr Ansurmtum I N C O R P O ,R A T E D 1500 RHODE ISLAND AVE., N.W., WASHINGTON 5, D. C. OFFICERS PRESIDENT-- JOSEPH F. BATTLEY, WASHINGTO: VICE PRESIDENTHERN HARD MAUTZ, MADISON TREASURER-- H. BRAETH DAVIS, BALTIMORE SECRETARY-- M. VANDENDRIESSCHE. WASHINGTON August 27, 1954 REGIONAL VICE PRESIDENTS NEW ENGLAND--WILBUR L. RICE, PROVIDENCE EASTERN--E. F. COX. PHILADELPHIA CENTRAL--LEO GUTHMAN, CHICAGO SOUTHERN-O. C. GREGORY, JR,. RICHMOND ' SOUTHWESTERN-R. W. BLAIR, JR., DALLAS WESTERN-JOHN V. VAUGHN, LOS ANGELES DIVISIONAL VICE PRESIDENT WHOLESALE DISTRIBUTORS DIVISION H. B. WEATHERFORD. RICHMOND ,T0: MEMBER'S OF THE . ' ; . SURCQidCEBTSE OF EHE MDDSIL LABELIHCr COMMlTIEE: You will find attached the following letters; and reports: Minutes of the August 12 meeting at the Hotel Hew Yorker . Approved Report of' the Subcommittee concerning : . . precautionary labels ASA Subcommittee Z66 proposed standard Letters from President Battley to Drs. Baumgardner, Commissioner of Health, Hew York City; and Bundesen, ' Chicago Board of Health Copy of letter we received August;26 from Health department, City of Hev; York. You will note that the requests and recommendations of the Subc.onnnitteee; are =being carried through to: completion. . . President Battley has written.to Mr. Jerome Brichter, ;: Assistant. Commissioner,, Board of Health, . Hevr York, requesting, a postponement of the meeting on proposed labeling regula- : tions..for. lead horitaining paint until their October meeting , so that some of our experts can be present. Ahy;comments :you may desire to make' concerning anyofthese 'matters .'will be appreciated. . Very truly yours, d. JCMisb ; "> V JOHH C. MOORS,. Director;';;^,: . ''': ^;;. ;/' ,:;..4./;:;'':'':.':,:irechnicalDivision' ' N11702 , MINUTES/OP KEEUlTG SUBGOMMIMEI 09. MODEL XABSLINCr Angust 12, 1954- Hotel New Yorker . ; New York,: NA.Y.-'. , : Present- B. ;J. ECHART, Chairman m/^DANIEL:: L A BOLAND ) y| A * - H WOLEE; Vice Chairmanzj^^ . PAUL" , hpEOLL YIH^t..fjZsM, (j&ttp - { .JOHN E. F0UL3SE iWw Dj ^ SAZFOED J. KILL'- Q^A$ffv5T~ L> ^ ^ Jed o s : h o ms D: ;&;R:j:r-Jc c d Dw el l . MOOEE .' ^/v3 -- ,.. ,, e-^- w. h . l u t s - C. c. Me IMPS -. Oa v i-u ^. fiWa ~%TZ, ~)\ ,\ & : AES'HuE MISITOH - ,cJ^_ 4,' C. .. SLOCUM - W - .uT\ HEEEY'- J:, vWHiTSOiM- <--^.0. Co -- ""B vt-OvcC*1 p a u l w e i#Did : for Mil e s m. zo l l er . Absent ,'9- :JEEOKE ,CEOWLEY EEANK E. PITI1. c* . , \Jt (r U^ Visitors 6i4v.es- U A. B. HOLTON DB. ';e o b t .v me l l in s (Chicago Board , of Health) The Chairmari; called\the meeting to order at 9:^5"-a.m. and asked Mr. Slocum to report on the August 11 meeting of American Standards Association (ASA) Sub committee Z66 relating to recommendations on paints suitable for application to cbiIdren1s:, tqys . and furniture. Mr. Slocum reported the meeting was well attended. The paint industry was repre sented by Messrs. Eckart, Eculger, Whitson,:. Kolto.n and Slocum. A. Si A.-was requested by tfhe American Academy, of Pediatrics to draw up health standards for obj ects with ivhich children may: come in contact. Paint is one of those objects. After much, discussion the following Z-66 Committee resolution was approved for submittal tp the A*S.A. Standards Committee: . "A liquid coatihg to be deemed suitable from a health standpoint for . use on articles such as furniture, toys, etc., or for interior use in dwelling units where it might be chewed by children. (1) Shall not contain lead compounds of which the lead con tent (calculated as Fb) is in excess of one per cent of .the total weight of the contained solids;(including pig ments and drier). (2) : Shall not contain compounds of antimony,- arsenic, cad- > : mium>;,:;mercury,l3elehium>,barium> (when; solubleiih^iluteA-bic" ? hydrocliloric acid) introduced as such .ia:;,thb>foririhlatlon-d>:^-v; of such coatings. Coatings, complying with articles 1 and 2 above, may be; marked "Conform with: American Standard Z66-1 for Use on, surfacesAwhich might; be chewed by children." .. Nl1702.01 As first proposed. Chromium compounds were, included Under;item 2, bi as no proof has been presented where.oral poisoning is caused by zii A. feii? members wanted the allowable maximum amount of lead reduced t|c this proposal was rejected by the Z-66 committee. The words;in-.iteift! soluble in dilute hydrochloric acid" refers only to Barium. Eoweve: of this test were hot discussed at the Z-66 meeting. The proposed -z~ ' fers' specifically "to;-'intentionalUsev'of 'the. desIgnated metals 'in:' .a:;,formula..!1/ : If these metals exist as impurities in paint raw materials they ai*e not included. P'articular-note of use of the words "deemed suitahle" in the proposed standard . was .made. /.A'llieproposal :fifst 'dtated "considered safe'1', ihere is a v/ids .differ ence as this change'produces a non-rigid standard.' Mr.. Slocum, upon completing this report, stated "We need to thoroughly discuss this proposed standard11. He also said, "'Ihe question is `Should we have a paint Industry standard*'1. Dr. Eoulger stated the procedure of voting on A.S.A. proposed standards on health matters gives 'every member: of fhe 'cbmittee one voteahd ;a'majority,rules. .-Alhis-, voBing; method 'mAt'erIdllyi^influihce's.L'.th,e-;hature'' 6f',;.st'aadapds>;. He ^pointed out . the A.S.A. can only suggest standards and cannot enforce them. Dr. Eoulger stased that the standard, as revised, is very innocuous. Considerable change from the original, proposal had resulted. He expressed the belief acceptance of the standard-would hot cause,the paint industry any trouble. His belief was partly -based on recognition of the fact that considerable toxocological work had been, performed by some of-the leading authorities in the country, and that work should not be discarded.. He stated tha: the question presented to the Subcommittee was what are the alternatives to the.A.S-.A. standard! Mr. Eckart remarked that -the paint Industry could follow the standard.but did not. have to refer to an A.S.A. standard. Mr. Boland expressed the belief the.A.S.A. standard, if adopted, would be made a part of legislation and official health, regulations. Mr. Hill;remarked'the A.S.A. proposal likely resulted from inaction of others to offer a better solution. Upon a request from Mr.. Slocum for, a statement, of Association policy on the sub ject, Mr . Boland explained that General Battley cbuld'not be present but had discussed the ..Association policy with, him the previous day. He then stated that the Association was opposed to standards and also to any proposals which might Have the effect of lav/ and thereby affect - the individual formulations of-products of the industry. He stated that the A.S.A. project was. directed, against a pro- blem which' could not be solved by labeling, but by education, of parents and other interested parties;and .advocated extreme cars in adoption:of the A.S.A. standard ' on the-ground that , it would not correct; the aitUatiqixi 'y'3Efa,e' problem is one for solution by the lead industries and,our industry and must be-considered' fully by the Association*s Executive Committee. If the A.3.A. standard resulted in blanket acceptance by public' bodies and:legislative groups it would be better to have the Industry take advantage of all'the work -done'by the: Z-66' : Committee: A . and the paint industry adopt its own. standard based on.- a workable .educational and legislative approach. - \ Dr. Foulger stated any action of this or:any Other committee does, not preclude our having the: opportunity to appear before . state or. local'; authorities. !Ehe . A.S.A.; action: is not the solution to the-problem: of keeping children from being ,: exposed to harmful: elements or from being poisoned for that matter. It will, take 50 years to corrected situation that has. taken hundredsof years to produce. . Mr. Slocum read a. clipping from the August 4 or 5 New York limes relating 'to" labeling regulations which referred to cooperation between the Manufacturing Chemists Association Inc., and local Health Authorities. Mr. Slocum further re marked we should arrive: at a decision to use. a s tandard of our own: or expect- EP! 000869 others to legislate one. Mr. Hill "believes the Hew York City regulations for labeling of dangerous substaiibss, can: :be "interpreted to "include .paint even though at; present we think paint will likely be excluded. ..We should take`the initiative, to <avoid. specific re gulations concerning-i-warning' labels for-. lead. True, ; the 'present: paint labels are certainly better than some the regulations are aimed at. He pointed out that many different government|divisions have authority to issue regulations which may affect labeling of our products. In Hew York City it is the Department of Health '"and'-in'-HeW PdPPeyi;ltii&;;tfii:;. :Dep:at'tkent.pf";;laibop.^'"/Ih^bthef;:;d^fM'^P*^i^'^:'^ 'Other agencies are proposing regulations. It seems ^Industry has not pointed the way and:.'produqed'-:.a ptissiblledgolufcipni '[ M.C.AtS hasipartiallyanswered'St&CsprOblem'- and. . their suggested.'lhb.ciing^ is receiving reoognitioni' ;,te,' ;:Eili,is!Ufg.e|ted;'iwe,shoiild. join, and"help ;:tiiem. : - Mr. Slociiit remarked that: i)r. Lanza, who is representing the paint industry, has been given until September 1:to produce an answer for the Hew York City health authorities. If no satisfactory reply is given the resulting regulations may be worse than now. contemplated. "Action must be taken how.in Hew. York City. Mr. Slocum further noted that Mr. Eabin of the Hew York health authorities proposed at the Z-86 meeting that paint containing lead in excess of lp:be labeled: "WARDING This paint contains more than percent of ..lead,-- HHSAIIj -* : POISONOUS. Should not be used for children's toys or furni ture, or on surfaces which may be chewed by children." .. Mr. Eckari said City ofChi cago desires, only interior paint of less than Ifa lead be allowed to be sold there. Mr. Minich remarked Dr -Lehman of the Pure Food & Drug Department at Washington, D. C., has; approved use of "Harmful if 'taken internally". ^ Mr. Eckart stated the discussion on the. A.S>A. standard had arrived at a point where Mr. Lutz, Chairman of the Task Group to prepare suggested precautionarylabels> should report. Mr.. Lutz stated that the Task Group selected to draft.suggestions for precautionary labels ..for industry's products had met at the Hotel Hew Yorker the preceding- day. Those present at this meeting, in addition to himself, were Dr. Fotilger, Mr. Hill, .Mr.; Homer, pid.-'-McInnes,;.Mr. .Moore, and. Mr. 3oland,. , tlr.: Lutz-stated the proposed labels should cover approximately 90>& of'[the industry's products and were submitted as a minumum requirement to comply with existing laws : and to specify the hazards if any.. He believes the proposals coulaserveas a basis for -an- Association program; concerning further, legislation and; could be sub- mi tt ed to members for .their:' individual consideration: and.' at:cept'^hGe.':if'-r5!hey are;.:. mere suggestions only.. d:. Mr. Lutz read the report of the Task Group and .moved the report bb:included. id the minutes, of'-the; meeting with any amendments. . Hiis was seconded by Mr, Croll and; . approved bjf the Committee. (See attached for approved suggested., precautionary ... labels)...'- Mr. Eckart inquired why Classes IA and 13 in the, report relating to flash point; could not be combined by using the words "Caution-Combustible". Dr. Foulger EPI 000870 replied:, .that : a haz^'d\-:yh;b,ul'd'''hev'er be;'-understated, or overstated. Mr. Boland :pola:ted>4u1*;such-:a;-:dpmbi;natip:a 'wo:vdi:/;cfliifli.ct;.,;,wl:ch. nxistirig lawsy :' ;MrV ':Sdii:: stated ltiiei,:a'.di7asi'''.''iibth.iDg..,to prevent -'.-anyone1 from over, labeling but he considered;,idlnMvisable:. Mr., 5ut'a;%'rem^rl:eci;:':tii.bse proposed precautionary labels state what ws are for not, what we are against, ho one is obligated to use these labels. They do conform to, IG' regulations-*. vsiSorae; discussion in, the', Task G-rPup^had .pentered; Sarotmd use of. words :!'Do-no t stake' internally,,:. The Group'believe such;, a 'statement;: should.:' not be included ...in the' proposals * Hr. Lutz believes; we should (1) alert' our industry to the potential dangers and (2). stem the tide of adverse legislation. At this point \Dr. Hellins; of the Chicago Board of Health arrived and. was request ed by Chairman lekart to discuss; the.attitude, of the Chicago health authorities regarding|precautionary labeling. Dr. Melllns first desired to know what the paint Association was. doing to help aid the health authorities. In reply, Mir. Boland pointed out President Battleyhad appointed this Subcommittee to consider the problem of/ lead poisoning and precautionary labeling. The Sub committee had met several times and had recommended action as follows: (1) An educational program conducted by the Association. (2) iShe Association prepare a list of paint raw materials.that: might be hazardous and distribute this information to members. : (3) She Association set up machinery to investigate.each poisoning lease: attributed to the. eating of paint, whether or not fatal. Mr. Boland described the various departments of the Association, which were being geared to intensive Work on an industr;- ,and nation-wide educational program. Ee p .referred to . the Publicity, Industry Relations, Clean Up-Paint Up*-Pix-Up Bureau, :' "Trade Sales|and Industrial Product Finishes Division, all.of which would function in some manner. Dr. Foulgdr- thought the best method of securing detailed .and, authentic-dhforma- :; .,: tionon each alleged child leadpoisoncase was to ask the Casuality and Liability ; Insurance Companies ,:to- handle.;;;: They are definitely interested-and"have; thei T ; , medical-;land other background to best secure the information desired:,byrus. -Iddv> Mr. SldcW:b'elieves;:the"public| school students' should be enlisted ia a campaign, to ; keep young|er brothers and sisters from cxiewing painted surfaces. Dr* Meilinis, in reply;to a question, said he had talked,to Mr. Trichter' of ;the-: City-bept . of Health. The H. T. health officials are not completely, satis- fied with the A.S.A. standard as drafted, but .realize it -would, be helpful in" : labeling rsquirements. ,In Chicago^ Dr. .Mellins, advised, there was considerable agitation,for action con cerning lekd poisoning and that Dr. Bundesen, Chicago Health' Commissioner,: had: PI chXj 87 1 been un^^rptesstirevfrpii the ^newspapers.:, and. .various groups., He said> he had suc ceeded in having :hetfoh:;heforred. in . view of ; the A.3vA. Z-66-!prbjecb: Eevpointe^ ' out that his main concern was with window sills and osher interior surfaces which might 'he hheiije^ 'hyinhildrehh Ee:expressed his gratification to hear' of the Association program and ashed to be placed on the mailing list for any of the Association releases relating to lead po'isbhdpg'. , ':d:. .. h hr. kellins belieTesl; it is hlghly ;important !to' learh: ail possible about eachalleged case of lead poisoning of children. It should be a reportable disease. The mere.fact that a child died from alleged lead poisoning is not sufficient. iVe must be sure of the, cause ;and determine how the child got the lead into its system S-nd, then use that information in an educational campaign. Dr.. Medians' further stated there has been an increased use of paints by the non-professional person and they are not familiar with all the hazards involved. The Paint Indus try should include on the labels.information of possible hazards. Another pro blem is a precautionary label for exterior paints containing lead. After examining, the proposed precautionary labels being considered by the. Sub committee. he; said the proposed label is good as far as it. goes but an additional precaution is needed - "Contains lead and do not apply on surfaces; that may .be chewed by .children" or words ;to that effect. After some discussion it was decided Messrs. Wolff and Mclnnes would work with < Dr. Bunaesen, head of the Chicago Board of Health, and Messrs. Slocum and Eckart would contact the Hew York City Health Authorities, and: explain the Association's activities! and our desire to. help the health authorities solve the problem of the alleged'lead poisoning of children. Respectfully submitted. JOS C* MOOSE, Director