Document Jr1R4azw7N7aeLeNbjaj96eGa

Technical Service Department November ;2S,:. 1953- D. R. Carter CHEMICAL DIVISION Cincinnati, Ohio Dear Don: File: labeling Regulations Hational Paintj Varnish & Lacquer Ass'n. We-are in receipt of your letter of 19 November transmitting subject correspondence originating from the Chicago Paint, Varnish & Lacquer Association. Our comments on the proposal for a federal paint labeling act are made in the order of the questions raised. We certainly should subscribe to the promulgation of a, federal labeling act covering paint products insofar as; it should serve to insure uniformity of labeling., A warning label carrying a sufficient statement of hazard, should circumvent further legislation from being directed specifically to lead, which through the assiduous efforts of the paint industry, has been sacrificed to appease the pediatric societies and other do-gooders who apparently are-not aware of the relative toxicity of other compounds contained in paints. We would, suggest answering the questions raised, as follows: (a) The law should, apply to both retail and industrial . containers. The.paint manufacturer undoubtedly prefer, that industrial containers not be labeled, since the federal law should encompass rav.'raaterials. The labeling of industrial containers is .necessary if the law is, to .prove worthwhile. (b) The law should apply.to all substances tabulated since in the.non-solids: states all the tabulated ingredients / represent varying degrees of toxicity. (c) Pigment products of known toxicity should be included. NU698 (d) An Ingredients statement is apparently repulsive to the paint manufacturer but nonetheless, is needed if the federal law is to circumvent new legislation and supplent existing labeling regulations. In general the ingredients statement far tne labeling of hazardous compounds can be restricted to -"th naming of the toxic or hazardous compounds. The pediatric societies sponsoring lower regulatory groups will insist on a naming of the toxic compound on the basis of its necessity for prescribing the nroper antidote. Unfortunately the type of leoel that would satisfy the health department will not necessarily satisfy existing state legislations that are designed to classify quality of product, etc. such as Virginia or labels-'or the desire to obtain uniformity in labeling will undoubtedly be defeated. If a different precautionary label is prescribed by the governmental agency for each and every toxic compound or hazardous compound contained in the paint, the number of labels, even though uniform for a given product. wHi 'present a insur:tountafcle problem for the paint manufacturer. vg rather strongly that with the1 Concurrence of the paint industry, a simple, label could... be adopted bust would prove acceptable to all regulatory bodies, do-gbcdersy etc. Such a pv label ba drafted as follows: Contains hazardous ,compounds.Should not be taken internally or used on surfaces likely to be chewed by children. Pigment p by Wt. , ZnC - 35,f, TiG220$, etc. (typical label analysis by..weight) Lead chromate." 1Ce realize that this is rather . long-winded but felt, tha t you would want full comment in order that you can make the reply to the Association. Very truly yours, Paul. tvhitford