Document LxE9Mn4pqmZ215kpKz3LJXmb

FILE NAME: Kelly Moore (KM) DATE: 1977 Aug 22 DOC#: KM037 DOCUMENT DESCRIPTION: Letter from Paco Textures Corp. to the Consumer Product Safety Commission RE Proposed Asbestos Ban Paco Textures Corporation H D CQMMtRCIAL IT H ttT JAR 6 * < L 0 $ . C * l> fO * * w *A00 H t*) M l- tt August 22, 1977 Secretary Consumer Product Safety commission Washington, D.C. 20207 SUSi PROPOSED ffjs TO BAS ASBESTOS FROM PATCHING COMPOUNDS Dear Secretary: This letter is in regard to the proposed rules published in the Federal Register on JUly 29, 1977, The proposal states, "Patching confounds that are labeled as, marketed, and sold solely far industrial use would not be within the scope of this ban." However, it is further stated that the conmissian considers substantially all consumer products under the CPSA. We are a medium sine company, manufacturing Dry-wall Joint compound. As published, the rules would effect all of our Joint Compound business w e n though it is almost entirely sold to the professional market. The commercial industry is already under the regulations of O.S.E.A. The retail or consumer portion of our business is small, but very identifiable. If a ban is required, it should not include material that is made~for commercial or professional use . In our distribution system it is very easy to distinquish between the retail and the commercial sales. But labeling ___ asbestos-containing patching compound "FOR COMMERCIAL USE QHLJf" and banning asbestos from containers under 20 pounds would further assure an effective control. Technology has been approaching a zero level of asbestos in joint compounds. However, it has not yet reached the quality required by the commercial market. I have, personally, tested 236 different, formula changes in the laboratory with little ccess. i have also evaluated non-asbestos products of er manufacturers and found them also lacking in properties ed by the building industry. The biggest problems being ek of workability during application with shrinking and eking after drying. en six months of further development, I feel we could uce a product for the consumer who does not require a high production type product and who would normally use a product under more ideal climatic conditions. M ANUFACTURERS OR JOINT CEMENT ODY HALL ANO : s Is summary, Z feel that the commission should clearly exclude the commercial (professional) market and that if a ban is determined to be required for the consumer market, that it be effective 180 days after publication of the final rule. I would also like to request a copy of the hearing held August 15. 1977 at the conrnission hearing room, with respect to the above matter. Sincerely. .JULA* Douglas K. Merrill Research and production Manager DWM/jlb cc: S. John Byington, Chairman-CPSC John Liskey, Office of Program Management. CPSC