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