Document Jrm3DBOrED3g7mZXvo0pyRzNv

t=^ V. Georgia-Pacific Corporation 900 s. w. Fifth Portland, Ortftm 91204 1 tUpbont (iOi) 222-iifil PLAINTIFFS I ^EXHIBIT 1 GP-265 July 6, 1977 * J) J) V Kr. S. John Byington Chairman Consumer Produce Safety Commission 1750 "K" Street, H. W. Washington, D.C, 20036. ' Subject: Anbnstoc - gpacklinft Cpropound Dear Chairman Eyingtcvj . In the staff report presented to the Convalesloa at your meeting on June.30, tvo issues were dlccucsed on which I would lilco to comment. The issues were: 1. A definition of consumer packaging as differentiated from an Industrial size package, and 2. The effective date of the ban. First, Z would like to point out that, on the date of your cnnouncod ban on speckling compound containing asbestos, we ceased using asbestos in our product and switched to a substitute. We have also worked closely with your contractor developing the environ ment and economic report on asbestos. In the course of our discussion with your contractor, ve focused on the issues mentioned above and would like to directly express our recommendations to you. We support a total ban on-spackling compound containing acbectos without regard to the packaging size. Wo package our speckling compound in both one-gallon and five-galldn containers. Although the smaller oize is directed toward the "do-it-yourself" market, we have no way of policing the salo of our five-gallon containers and keeping those out of thie mrlcot, A ban which differentiated the size of packaging would ha difficult to enforce; and for that reason, we do not reewnmend you mko the ban effectivo to different sizes of containers. // .( Kr. S. John Eyington Pc.72 2 July 6, 1977 .I Decausa we no longer manufacture a speckling compound containing . ccbccto3 we support the 180-day effective date of the ban. Our pre-mis: compound results in a minimum exposure which, based on your aaccT.rment analysis, presents an insignificant health hazard. Your risk assessment analysis wan based on a four-day, eight-hour exposure`vliich is not typical of the nonprofessional use patterns in using gyp3ua board and applying joint compound, l'ha one-time user is at the lowest end of the exposure curve. A ban of IDO days will provide sufficient time for any existing inventories to be depleted and replaced with asbestos-free speckling compound. VTe will continue to work with your contractor, end if we can provide any direct information, please do not hesitate to contact ms. Yours very truly. cm/m G. E. Wilson Vico President be: Messrs. 0. E. Burch - C. T. Hewlett, Jr. - Wash., DC - ExecJ Office C, W. Lehnert - Tigard Lab/ T. F. Mitchell - Wash.. DC - Exec. Office T. E.-Withycombe .