Document N2qxd9p3EnpGXy9rzpoVeKkL8

FILE NAME Kelly Moore KM DATE 1977 May 27 DOC KM036 DOCUMENT DESCRIPTION Letter from Calidria Asbestos to KM RE Proposed CPSC Asbestos Ban UNION CARBIDE falCalidriaCalidria Calidria - NIAGARA FALLS, N.Y. 14302 . . p.0.B0X579 . ASBESTOS ASBESTOS Nin UNION CARBIDE TEL:718-278-3378 _ May 275 May Mr. 0. Mr. Moore Paint Kel 1015 Commercial 1015 Commercial San San Carlos CA Company 5/2/77 Merrill Product Safety Commission the Consumer Commission Dear Mr. aware recent action by Consumer Product Safety Commission Commission no You CPSC CPSC doubt ban consumer use by containing containing Product Safety propose a and and joint compounds compounds Their action asbestos was instigated containg - and 7/15/76 Resources Defense National the "Proposal on The by by 5/2/77 take action on the petpeittitiioonn vviiaa the Proposal take The Hearing procedure procedure months involves the following minimum minimum months a minimum of six }. Publish the proposed regulation 2. Accept written comments . and hold a public hearing 3. Publish CPSC a final regulation sale of of products the manufacture manufacture of products inadvertently , the proposed over depending its wording wording interpretation interpretation could inadvertently the inadvertently affect packaging sale of products products intended packaging industrial industrial pails is understanding understanding 25 bags the usual commercial stocked packaging packaging some gralelotnail outletpurcshased lreuadym-bemrix yards yardsyourselfhighighhlly y pdrroybabm le i proxbable tChPeSCse prsodoucmtse propductrs opdruicotrs could purchased taken ultra by do - approach actions has consumer ultra conservative conservative consumer prior can be approach any product wwhhiicchh their be and be covered resolved consumer obtained obtained consumer regulations This is question which woulb d e discussed discussed resolved type regulations public hearing hearing type of question could public hearing is the type CPSC has and and to product order order CPSC distribution consumers a product we we do to happen the further distribution activist groups AlthoughAlthough continuing continuing to press expect this type of action NRDC CPSC can any arechange change their their action plans pressure There There at present present time little little no counter counter from industry industry the main present letter you . Enclosed is copy @ copy information information sent information the CPSC last September by Asbestos Asbestos Information information September Information tion Association Association This This information information was developed Dr. H. Rhodes Rhodes our asbestos asbestos asbestos oped group to the developed developed of . sent was information devel by Dr. H. Rhodes This Association. group - 01093 01093 -2- do can see from the contents of the enclosure we do not believe that the use As you of asbestos in spackling and similar compounds presents a significant hazard to the consumer However do not feel that it would be prudent to oppose a ban on containing compounds in consumer packaging i.e. 1-5 pounds or 1-4 quarts The consumer does not need the performace products containionfg asbestos which are required by commercial applicators and the . protection your products for commercial use is much more important Also enclosed is a copy of our letter recently sent to members of the Consumer Product Safety Commission We felt that it was appropriate to take this action before asking you to become involved If you are concerned about the possibility of inadvertent and perhaps immediate ban on your asbestos products even thoaungh they are intended for commercial use we suggest the following action 1. Review the enclosure to determine the facts about the issue 2. Express your concern to the CPSC including the following points A. The effect on your commercial a ban on consumer products products which could result from B. Your preference for the proposal procedure rather than any immediate action which is unnecessary and could have a severe deleterious effect on your business C. A hearing is necessary to properly air the potentially harmful consequences of any CPSC action D. Suggest if you concur that your products be labeled with the regular OSHA asbestos warning plus For Commercial Use Only This would be based on the assumption that such products would then be exempt from CPSC regulations Your comments opinions etc. should be expressed directly to Mr. S. John Byington Chairman Consumer Product Safety Commission 1750 K Street N.W. Washington DC 20036 or that Union Carbide will take an active part in a hearing in Please be assured where such action is appropriate and neces- other phase of the CPSC procedure let know if you require additional any sary to assist our customers Please us information or wish to discuss this matter in more detail Very truly yours L. John L. Myers Marketing Manager KMX 01964 cjb Enclosures P.S. It is obviously at your discretiobunt we of correspondence between your company and would appreciate the CPSC receiving copies