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FILE NAME Manville JMA DATE 1980-1982 DOC JMA220 DOCUMENT DESCRIPTION M Customer Letters - Papers & Millboard Gaskets Brakes JM Manville Internal Correspondence To J.F. Reis - Denver 1-03 From G.E. Hughes - Mississauga Copies Date March 30 1982 Casbestos Papen Subject file Asbestos Paper and Millboard Customers - U.S.A. In compliance with your verbal request of March 25 1982 we enclose a copy of the letter which we sent to U.S. paper users in November 1981 as well as a list of the few people in the United States that have since purchased and millboard The products mentioned of asbestos paper course originate from Kingsey Falls P.Q. As you will notice in paragraph 4 we did mention to the re- cipients that a dust supressant was added at Kingsey and the warning label also appeared on the enclosed data sheet for the appropriate product As we indicated response to our to you letter we have been disappointed with the but keep hoping for an improvement Best regards CH dmw Encl PRODUCED JM U.S. PAPER AND MILLBOARD SALES 1 Bullough Insulation and Supply Inc. Salt Lake City UT 84116 2 Taylored Industries Inc. Pittsburg PA 15223 3 Walco Enterprises Warren MI 48089 4 FB Wright Co. of Pittsburgh Bridgeville PA 15017 Asbestos Rollboard Asbestos Paper Asbestos Millboard Asbestos Millboard PRODUCED JM - 83 JM Manville Canada Inc. Asbestos Fibre Division 2021 Cliff Road Suite 303 Mississauga Ontario 416 275-1442 Telex 06-960125 L5A 3N7 November 9 1981 Gentlemen We would like to bring to your attention the fact that Manville in Canada still produce Asbestos Paper Asbestos 106 Millboard and Asbestos Rollboard Data sheets detailing the various thicknesses and sizes are enclosed It should be realised that these Canadian produced materials differ slightly from the products formerly produced in the U.S. by Manville in that they comprise of 1/16 thick laminations The Canadian materials contain a small quantity of a dust supressant which may cause an odour for a brief period at elevated temperatures but are possessed of the same formance characteristics as the materials with which per- are familiar you Should you require further information or samples please contact us at this office Yours very truly G.E. Hughes Sales Manager - Canada GEH > dmwGEH > dmw Encl Manville JM Type Asbestos Paper and Rollboard Termal sulation Products M ASBESTOS PAPER AND ROLLBOARD @ DESCRIPTION A felted sheet material in thicknesses from .006 to .125 composed prin- cipally of asbestos fiber and a small percentage of binder Available in standard rolls of various widths and sizes also in tape form Manville makes a variety of types to fit the needs of home shop and industry Used where an insulation of minimum thickness is required to protect against fire heat or corrosion Many specialty uses @ AVAILABLE TYPES Commercial Asbestos Paper and Rollboard - A medium length fiber paper with high fiber content minimum 95 Satisfactory for most general purpose uses in plant shop or home A safety covering for heating ducts Good for temperatures up to 400F or to 800F where loss of strength is not critical Burn Asbestos Paper - A medium length fiber paper with high fiber content Suitable for continuous service at 400 F. Long Fiber Asbestos Made with high grade long asbestos fiber minimum fiber content 88 ) For use as a thermal insulation gasketing base sheet for saturating Special Long Fiber Asbestos Paper for Electrolytic Cells high quality paper uniform throughout for use as diaphragms in electrolytic cells Doublex Asbestos Paper - Completely inorganic will not burn char or smoke Has high wet strength Developed for use as neon sign pattern paper Also used as liner for foundry funnels and pouring gates Temperature limit 800F or 1200F where some embrittlement and loss of strength is not critical Asbestos Welding Paper A 32 paper 1/16 thick with low organic content used to protect adjacent parts from heat smoke sparks during welding Also used to control cooling rate in annealing process H@ ADVANTAGES Excellent Mechanical Properties Fast easy to apply and safe to handle amply strong for most needs Heat Resistant M Asbestos Paper will withstand high temperatures that would damage conventional papers and rollboards CAUTION CONTAINS ASBESTOS FIBERS AVOID CREATING DUST BREATHING ASBESTOS DUST MAY CAUSE SERIOUS BODILY HARM SMOKING GREATLY INCREASES THE RISK OF SERIOUS BODILY HARM PRODU Manville JM Millboard No. 106 Sheet Insulation Material Type Insulating Sheet Temp Limit 800F Description Manville Millboard is a dense rigid fireproof sheet or board material light gray in color Sheets are furnished in thicknesses ranging from 1/16 to 1/2 in standard sizes 36 x 48 Cut pieces can also be supplied Uses M Millboard is recommended for applications which require a sheet or board insulation for protection from fire heat acid fumes etc. It is frequently used as a resistant lining in floors partitions ceilings and firedoors and as an insulating barrier in stoves ovens and heated appliances Millboard has been found particularly valuable in the steel industry but can be adapted to scores of industrial applications Styles Available Number 106 Millboard - general purpose high utility Millboard suitable for most uses Will withstand tem- peratures to 800 Meets Federal Specification 351D Amendment 1. Size 36 x 48 No. 106 Millboard is treated with a dust suppressant in order to minimize the quantity of dust produced during cutting CAUTION Contains asbestos fibers Avoid creating dust Breathing asbestos dust may cause serious bodily harm Smoking greatly increases the risk of serious bodily harm Silicated Millboard - Millboard can be specially treated to increase surface hardness Where such sheets are required the word Silicated should appear before the Millboard type Weight of Silicated Millboard is approximately % higher than untreated board Special Millboard - for special purposes Millboard can be tailored to service requirements Consult your M representative for specific applications PRODUCED JM 7 JM Manville Caryl Ranch Denver Colorado 80217 303 979-1000 May 27 1982 Mr. A. J. Kyle Supervisor Standards Engineering Turbomachinery Division Ingersoll Company 942 Memorial Parkway Phillipsburg N. J. 08865 Dear Mr. Kyle Thank you for your April 7 1982 letter regarding our advertisement in Machine Design magazine I must apologize for not answering your letter sooner but an unusually heavy travel schedule has caused my correspondence to fall behind The containing products to which you refer in your letter have the asbestos encapsulated by elastomeric binders so that they can be used safely posing no health problem to the worker Once installed there is virtually no possibility of the asbestos fiber becoming airborne from these products The health effects of asbestos have been the subject of study for nearly 50 years These volumes of studies have provided a basis for conclusion as to what constitutes a safe level of exposure to asbestos Of the numerous asbestos products on the market which claim to be replacements for asbestos- containing products many are composed of relatively newly developed fibrous materials of which little is known about their potential health effects As an example of this I have attached a copy of the Material Safety Data Sheet for Garlock's Blue Guard gasket sheet As you will note in the Reactivity Data Section one of the hazardous decomposition products is acrylonitrile monomer and I have attached an OSHA booklet covering the hazards of acrylonitrile Realistically the likelihood of Blue Guard in normal use releasing hazardous levels of the noted agent is slim But as previously pointed out will during normal foreseeable use containing gasketing not release hazardous levels of asbestos either I have attached the following information on handling asbestos- containing gasketing materials for your review PRODUCED JM - 83 Mr. A. J. Kyle May 27 1982 Page 2 1 Mechanical ty, fe Packings and Gasketing Materials Containing Asbestos Fiber - Manville 2 ~ Asbestos Exposure from Gasket Naval Regional Medical Center Operations Bremerton WA 3. All You Need to Know About - Manville Gasket Materials 4 Disposal of Packings - Containing Gaskets and Manville Marketing Bulletin not Regarding replacing asbestos in joints I can comment gas turbine exhaust expansion on the Raybestos on Manville Q fiber but material Manville's as I'm not familiar with it 1 Q fiber is a high temperature 1800 F I hope that this information will be have additional questions helpful to you If you on asbestos and or would like to have a presentation to contact us containing at products please feel free anytime : Very truly yours . Steven Kuhn Market Manager Asbestos Fiber Division se bcc J. F. Reis - 1-03 T. P. Jackson - 3-09 C. W. Miles - 3-09 D. M. Kelleher - 2-13 INGERSOLL TURBO . TURBO MACHINERY Turbo Machinery Division Ingersoll Company 942 Memorial Parkway Phillipsburg NJ 08865 201-859-7000 201-859-7000 May 4 1982 Denis Kelleher M Asbestos Fiber Division Caryl Ranch Denver Colorado 80217 Subject Manville Advertisement Machine Design Magazine We would appreciate your response to our letter of April 7 1982 one copy attached Thank you for your cooperation Zale Supervisor Standards Engineering Turbomachinery Division AJK 5/4/82 Attachment CC S. S. Rajan File PRODUCPED RODUCED ALL AGREEMENTS CONTINGENT UPON STRIKES ACCIDENTS AND OTHER CONDITIONS BEYOND OUR CONTROL ALL CONTRACTS ARE SUBJECT TO APPROVAL BY AN OFFICER OF THE COMPANY QUOTATIONS SUBJECT TO CHANGE WITHOUT NOTICE INGERSOLL TURBO MACHINERY Denis Kelleher M Asbestos Fiber Division Caryl Ranch Denver Colorado 80217 Ingersoll 942 Memorial Parkway NJ Phillipsb0u8r86g5 April 7 1982 Subject Manville Advertisement Machine Design Magazine We refer to Manville advertisement appearing in March 25 1982 Machine Design magazine We are thinking about replacing asbestos in the following components used in our line of turbomachinery Component Asbestos Replacement Considered Pipe Flange Gaskets Flat Ring Gaskets Spiral Wound Gaskets Gas Turbine Exhaust Expansion Joints Garlock Guard Asbestos Garlock Guardian Style 555 Pyrofil asbestos Manville Q Fiber Raybestos Seal Safe Resin Treatment Please furnish us with @ Comments on these replacement materials @ Recommended safe handling good work practices and proper application particularly as applied to asbestos flange gaskets and gas turbine exhaust expansion joints More general information on asbestos replacement Supervisor Standards Engineering Turbomachinery Division CC S. S. Rajan File PRODUCED JM - 83 ALL CONTRACTS AGREEMENTS ARECONTINGENT UPON STRIKES ACCIDENTS AND OTHER CONDITIONS BEYOND OUR CONTROL SUBJECT TO APPROVAL BY AN OFFICER OF THE COMPANY QUOTATIONS SUBJECT TO CHANGE WITHOUT NOTICE INGERSOLL TURBO MACHINERY Denis Kelleher~ M Asbestos Fiber Division Caryl Ranch Denver Colorado 80217 Turbo Machinery Division Ingersoll Company 942 Memorial Parkway Phillipsburg NJ 08865 April 7 1982 Subject Manville Advertisement Machine Design Magazine We refer to Manville advertisement appearing in March 25 1982 Machine Design magazine We are thinking about replacing asbestos in the following components used in our line of turbomachinery Component Asbestos Replacement Considered Pipe Flange Gaskets Flat Ring Gaskets Spiral Wound Gaskets Garlock Guard Asbestos Garlock Guardian Style 555 Pyrofil asbestos Gas Turbine Exhaust Expansion Joints Manville Q Fiber Raybestos Seal Safe Resin Treatment Please furnish us with e Comments on these replacement materials @ Recommended safe handling good work practices and proper application particularly as applied to asbestos flange gaskets and gas turbine exhaust expansion joints @ More general information on asbestos replacement Kyle and Supervisor Standards Engineering Turbomachinery Division PRODUCED JM JM 23 CC S. S. Rajan File ALL AGREEMENTS CONTINGENT UPON STRIKES ACCIDENTS AND OTHER CONDITIONS BEYOND OUR CONTROL ALL CONTRACTS ARE SUBJECT TO APPROVAL BY AN OFFICER OF THE COMPANY QUOTATIONS SUBJECT TO CHANGE WITHOUT NOTICE ii Ai! " Manville Ranch 5108 Denver Colorado 80217 303 979-1000 May 11 1982 Mr. Daniel A. 686 Dill Road Severna Park Parvis MO 21146 Dear Mr. Parvis Thank you for your letter of April 4 1982 to Denis Kelleher about testing for the presence of asbestos in your ceiling First of all it is our understanding that there were very few ceiling tiles produced that contained asbestos fiber tile One reason for this was that the addition of asbestos increased the cost of the tile This increased cost was difficult to justify in little new the market benefit to because the the tile to asbestos contributed offset the increased very price Secondly you can have your tile tested to determine if it happens to be one that contains asbestos This testing should be done by a laboratory with the proper equipment and test procedure in order to obtain an accurate analysis There is a simple chemical testing kit being advertised which supposedly detects the presence of asbestos iron or magnesium We have been told that this simple type of test gives numerous false positive readings in other words it can confirm the presence of asbestos in products that do not contain asbestos Thus is by which the way to accurately determine the presence of asbestos testing with ray diffraction and electron microscopy can be done by numerous laboratories in the U.S. The closest one to you is Tabershaw Associates 6110 Executive Blvd. Rockville MD 20852-3980 Attn Dr. Keane 881-6920 I hope that this information will have additional questions please anytime be helpful to you If you feel free to contact us Yours very truly wT . Steven Kuhn Market Manager Asbestos Fiber Division se BCC D. M. Kelleher Chrono JM - 83 | | JM aa] g Manville Is Caryl Ranch Denver Colorado 80217 303 979-1000 May 24 1982 ; F . Mr. Jack Poteet Great Lakes Carbon Corp. P. O. Box 140 Morganton N. C. 28655 Dear Mr. Poteet Attached is the Friction Material Work Practices Guide was somehow left out of the packet of information that sent to you , that I As a result of our telephone conversation I have also attached the work practices booklets for asbestos pipe and asbestos sheet and a white and gasketing materials paper on packings If you need additional i from Manville to advise we discussed please information assist with or would like someone the asbestos presentation Very truly yours i Steven Kuhn | ees ;... Market Manager Asbestos Fibre Division a7 se rr. Enclosures bcc Hank Shad - Atlanda D. M. Kelleher PRODUCED Manville Sales Corporation O. BOX 5108 Caryl Ranch Denver Colorado 80217 303 97 978-2000 May 10 1982 704-437-3221 704-437-3221 Mr. Jack R. Poteet Production Superintendent Great Lakes Carbon Corporation P. O. Box 40 Morganton North Carolina 28655 Dear Mr. Poteet| Thank you for your letter of 4/2/82 to Denis Denis Kelleher In answer to your that cover the request I have enclosed an assortment use of asbestos in friction materials of reports and the decomposition products from lining wear follows The reports are as 1. Brake and Clutch Emissions Generated Generated Driving Vehicle Operations - Jacko M.G Ducharme , R.T Somers J.H. 2 Asbestos Emissions from Brake Dynamometer Tests Anderson A.E Gealer R.L McCuneMcCune R.C Sprys J.W. 3 Brake Lining Decomposition Products Products - Lynch J.R. 4 Asbestos and Health in the FrictionFriction Material Industry Asbestos International Association 5 Asbestos Friction Materials - Jacko M.G Brunhofer C.M Aldrich F.W. 6 Friction Materials - Technical Bulletin Bulletin from Manville 7 Friction Materials Work Practices Guide - Friction Materials Standards Institute Inc. PRODUCED Great Lakes Carbon Corp. - 2 - May 10 1982 If you have any questions about like other specific information us anytime the enclosed material or would please feel free to contact Very truly yours Steve Kuhn Steven Kuhn Market Manager Asbestos Fiber Division Encl Bcc Hank Shad - Atlanta D. M. Kelleher Chrono PRODUCED PRODUCED 83 EXECUTIVE OFFICES 299 PARK AVENUE NEW YORK N.Y. 10171 GLC PLEASE ADDRESS REPLY TO BOX 40 MORGANTON NORTH CAROLINA 28655 GRAPHITE PRODUCTS DIVISION April 2 1982 Mr. Denis Kelleher M Asbestos Fiber Division Caryl Ranch Denver Colorado 80217 Dear Mr. Kelleher Would you please send me any information you may have on asbestos especially concerning brake shoes Thank you JRP Sincerely Jack Pu Jack Jack Poteet Production Superintendent PRODUCED JM 73 JM 73 - HV HOLLINGSWORTH & VOSE COMPANY Technical and Industrial Papers Dile : CPSC CPSC CPSC East Walpole Massachusetts 02032 Telephone 617 668-0295 Telex 924470 May 8 1980 Mr. James Reis Director Policy Manville Corporation Caryl Ranch Denver Colorado 80217 Dear Jim Attached are copies of the letter I received Dr. Lipshutz and our response to that letter As can see we used Guy's definition because we felt be reasonable from you it to I appreciate your help in the struggle with the EPA and CPSC Yours truly HOLLINGSWORTH HOLLINGSWORTH & VOSE COMPANY ARW enclosures in Ann R. Wise Manager of Public Affairs PRODUCED PRODUCED REGULATORY RESEARCH CORPORATION Nelson R. Lipshutz PRESIDENT April 24 1980 Ms. Ann Wise Manager of Public Affairs Hollingsworth & Vose Company 112 Washington Street East Walpole Massachusetts 02032 Dear Ms. Wise As we discussed over the appreciate telephone today we would that receiving your should be suggestions as to the elements included in a simple useful of friable asbestos working definition papers from those which have which would distinguish such papers We appreciate a negligible probability of fiber release need the your desire information to respond in writing But since we appreciate it if as soon as possible we would greatly as soon as you havyeou twhoeumldtoaglestohecrall us with your suggestions Thank you for your help Sincerely yours NRL Nelson R. Lipshutz PRODUCED JM - 83 24 Radcliff Road Waban Massachusetts 02168 Telephone 617 964-6940 2 ba Dr. Nelson R. Lipshutz Regulatory Research Corp | 24 Radcliff Road . Waban MA 02168 _. May 2 1980 Dear Dr. Lipshutz .< In response to your letter of April 24 1980 we feel that the following is a reasonable definition of | commercial asbestos paper . Commercial asbestos paper a paper least 85 chrysotile asbestos fiber fibers usually kraft and a starch nesses of .0015 to .0625 consisting of at plus organic binder in thick- We cannot comment further on such products since we do not manufacture paper of this type| . Yours truly HOLLINGSWORTH & VOSE COMPANY Ann R. Wise . Manager of Public Affairs ARW 7 7 PRODUCED JM - 83 M M Manville Internal To P. Kotin M.D. Date March 19 1980 Froni Copics Subject CONSUMER PRODUCT SAFETY COMMISSION REQUEST DISCONTINUATION OF ASBESTOS PAPER SALE Manville announced on February 25 1950 sec attached Merchandise Bulletin the discontinuation Therefore it of Asbestos Paper and Rollboard Therefore appears we have already complied with part the CPSC request The major portion of distributors and our knowledge of the end Asbestos Paper was merchandise people use sold have through little I would anticipate however that very little of material ever became a consumer yourself the product I doubt very much that Manville would be willing to comply with CPSC request A or even if it is necessary to do so I would also anticipate the the information information requested in - would be virtually impossible impossible to provide ne ea E. M. Fenner EMF jh . Attach PRODUCED JM- * i M M M M Manville REFRACTORY PRODUCTS DEPARTMENT Merchandise Merchandise Merchandise Bulletin Bulletin Bulletin No Effective 80-35-8 During March 1986 Cancels ~--a conn - February 25 1980 ( DISCONTINUATION OF ASBESTOS PAPER AND ROLLBOARD MANVILLE AND WAUKEGAN PLANTS The Manville paper mill will shut down within approximately 30 days and all manufacture of Asbestos Paper and Rollboard will there Orders must be placed immediately to be considered for The Specialty Papers made only at Manville including Burn Long Fiber and Special Long Fiber will no longer be available the shut down cease acceptance after acceptance Effective May 30th Asbestos Paper and Rollboard from Waukegan will also be discontinued Waukegan will accept orders for these products through April 18th After that date delivery will be subject to availability of inventory Many of the applicatiofnosr Asbestos Papers asbestos Cerafiber and Cerawool Papers can be filled with A strong effort should be made to accomplish this conversion especially in view of the recent 15 price reduction on these products om Carl P. Weber Market Manager TO 10T 111T 1141T 1142T 116T 117T 119T 441 Waukegan & Manville Only 5211 Waukegan & Manville Only 5311T 5313T 731 D C CC G.E. Thompson 2-02 PRODUCED JM - 83 a JM Manville Merchandise Bulletin INDUSTRIAL PRODUCTS DIVISION / REFRACTORY PRODUCTS DEPARTMENT ANNOUNCING - CERAWOOL MILLBOARD A New Asbestos Millboard No Effective 80-35-10 May 1980 Cancels <-7 7777 * February 27 1980 466 On or about May 1 Cerawool Millboard will be available from Waukegan This is a new asbestos Millboard made in standard sizes of 42 x 48 inches and in thicknesses of 1/16 1/8 3/16 1/4 3/8 for temperatures to and 1/2 inches The product 1200 but can be used up to is suitable 1600 where loss of strength is not detrimental We shall accept orders for Asbestos Millboard only through March 7. Shortly after that date Waukegan will permanently discontinue its manufacture to avoid contamination of the new asbestos formulation Orders for Asbestos Millboard received after March 7 will be subject to availability of inventory After March 7 Waukegan will accept orders for Millboard subject to their future scheduling Cerawonl As stated we would expect availability on or about May 1 above List prices cartoning schedule and weights of F.O.B. Waukegan Illinois no freight allowed ment net 30 days after shipment are Cerawool Millboard with terms of pay- THICKNESS INCHES LIST PRICE / PER SHEET LTL NET WEIGHT LBS./SHEET LBS./SHEET NO OF SHEETS PER CARTON 1/16 $ 5.13 5.75 3.0 21 10.80 12.10 5.8 12 1/8 8 3/16 15.71 17.60 8.1 18.93 21.20 9.6 6 1/4 4 3/8 27.80 31.14 13.7 1/2 38.75 43.40 20.0 M A table of properties is appended Demand expressed been great The has for this new asbestos Cerawool Millboard moment has arrived --- it is now available We expect to be deluged with orders Carl Weber Carl P. Weber PRODUCED JM - 83 Market Manager TO 110T 111T 1141T 1142T 116T 117T 119T 5211 Waukegan Only 5611 Waukegan Only 441 Waukegan Only 5311T 5313T 731 C - MANVMI ANL VIL LLEE CERAWOOL MILLBOARD A New Asbestos Millboard PHYSICAL PROPERTIES Density Bending Radius Wetted Loss on Ignition 35 pcf 2 inches % at 1200 Modulus of Rupture psi AS RECEIVED 400 TEMPERATURE 600 850 OF 1000 275 275 130 135 140 Tensile Strength psi 200 --- 65 65 65 Compressive Strength % 45 45 55 55 58 Deformation at 500 psi Brinell Hardness No. Abrasion Resistance % of Loss 18 18 18 16 16 3 3 10 10 10 1200 120 65 59 16 13 JM - 83 File : CPSC ---- -- K--o,,tin MD . Pescewebe ~ 141 LANZA AVENUE Frank X. Werber Vice President Research and Development TECHNICAL CENTER GARFIELD NEW JERSEY 07026 AREA 201 - 772-7100 May 3 , 1981 5/11 Dr. Wm S. Durrell Vice President D Jim Walter Corporation 1500 North Dale Mabry Tampa FL 33607 Dr. James Ramey Director of Product Safety Celanese Corporation 1211 Ave of the Americas New York NY 10036 Dr. Stewart K. Kurtz Vice President Research & Engineering Clairol Appliance Division 2 Blachley Road Stamford CT 06902 Mr. James F. Reis Director Asbestos Policy Manville Corporation P.O. Box 5108 Denver CO 80217 Gentlemen I have been remiss in not sending you copies of the enclosed letter from Mr. Richard Gross Executive Director of the Consumer Product Safety Commission which reached me over three weeks ago Mr. Gross letter was a follow up to a previous meeting which I held with Mr. Gross and his assistant Mr. Andrew Zaikis on February 17. The purpose of the latter meeting was to explore whether a useful purpose might be served by organizing meetings between top technical people of Industrial Research Institute members and appropriate Consumer Product Safety Commission staff to deal with industry's efforts in the areas of CPSC concern Messrs Gross and Zaikis felt that industry had been generally involved in adversary discussions with CPSC and technical information exchange was very rare With his budget cut 30 with the future of the Commission under discussion in Congress and without a permanent Chairman Mr. Gross was anxious for such specific discussions and proposed to send us the attached letter detailing the Commission's current concerns PRODUCED - JM 83 Dr. Wm S. Durrell et al May 3 1981 Page 2 I look forward to discussing with you at Scottsdale and over the phone your reaction to the proposed exchanges of information In my view I think a follow with CPSC personnel may be fruitful in those areas where industry has a cogent body of facts to present To my knowledge this includes asbestos benzidine congener dyes and plastics flammability On the other hand certain of these topics have been discussed in the greatest detail with the CPSC staff and additional repeat may be a waste Sincerely FXW df CC Dr. Theodore L. Heying Director of Research Chemicals Group Olin Corporation 275 Winchester Ave. New Haven CT 06511 il il VenVkeer nVkeenkrerVenker F. X. Werber Dr. Sherman K. Reed Vice President Director Chemical Technology F M C Corporation 2000 Market St. Philadelphia PA 19103 Dr. Lewis H. Sarett Sr. Vice President Science and Technology Merck & Rahway Company NJ 07065 Inc. PRODUCED JM - 83 U.S. CONSUMER PRODUCT SAFETY COMMISSION WASHINGTON D.C. 20207 vhs - Frank X. Werber Vice President Research and Development J. P. Stevens and Company Inc. Technical Center 141 Lanza Avenue Garfield New Jersey 07026 . Jo, sos 34 Dear Mr. Werber Thank you for taking the time to meet with me and my staff to discuss the nature and purpose of the Industrial Research Institute The staff of the Consumer Product Safety Commission is very interested in the possibility of working with the Institute to coordinate our efforts in the area of technical research concerning consumer products Given our shared concern in providing consumers with the safest possible products I am confident that cooperation between us will prove to be most beneficial to all including especially consumers As requested at our meeting in February I am providing you a brief summary of some of our term research areas involving consumer products that may be of interest to the Institute members I would point out that most of these topics involve areas where the Commission staff have a general concern regarding safety and do not necessarily represent areas in which the Commission will be regulating in the future Since the Commission's mandate is to reduce unreasonable risks of injury associated with consumer products a substantial amount of research and effort is initially required in some of these areas to determine the exact nature and degree of a perceived risk within a particular consumer product In the course of such assessments we have always attempted to work closely with the segments of industry that might be affected and in many cases have been able to promote and assist industry efforts to address the issue on a voluntary basis thus pre- cluding any need for regulatory action by the Commission We expect be working together with industry in the areas that are listed below would welcome any additional cooperation that may be provided by the to and Institute or its members Some of the major areas of Commission activity for the upcoming year include the following PRODUCED JM - 83 Asbestos - Inhalable asbestos fibers associated with a risk of cancer in humans may be found in a number of consumer products The Commission has issued a general order to gather information on asbestos in certain consumer products Selected products will also be tested for asbestos release Exposure and risk will be determined and appropriate regulatory actions recommended to the Commission Benzidine Congener Dyes - Consumers may face a risk of cancer from exposure to consumer dye products and crafts dyes utilizing benzidine tolidine and dianisidine dyes referred to as benzidine congener dyes The Commission has granted a petition requesting that a ban be proposed for these products and has directed the staff to develop a draft proposed banning regulatifoonr Commission consideration The Commission will also examine the use of these dyes in clothing and other textiles and will consider whether action is necessary to reduce any hazard identified with this use Chain Saws- The Commission estimates that there were over 100,000 chain saw injuries requiring medical attention in 1979. About 23 of the injuries associated with chain saws result from a phenomenon known as kickback - the rearward and upward travel of the chain saw when the saw bucks kicks or otherwise unexpectedly jumps toward the operator The Commission will begin development of a mandatory consumer product safety standard for chain saws their components and replacement parts to address chain saw kickback hazards Electrical Hazards - Residential fires continue to take a significant toll in deaths and injuries electrical in nature Some involved in include efforts each year and many of these fires are of the projects that the Commission is to assess and determine the reliability and performance of circuit breakers investigation of the effects of thermal insulation upon wiring and electrical systems and evaluation of design changes in electric blankets and quartz heaters to reduce possible fire hazards Formaldehyde - Formaldehyde has been found to be a carcinogen in test animals and an independent federal panel of scientists believe it should be presumed to pose a cancer risk to humans Formaldehyde gas released from consumer products is also associated with irritation effects such as human respiratory problems headaches and eye and skin irritation The Commission will examine the extent of consumer exposure to formaldehyde from such products as plywood particle board and textiles as well as formaldehyde use in school laboratories Indoor Air Pollution - Various harmful pollutants - including radon formaldehyde carbon monoxide and nitrogen dioxide - have been found in the air of homes This problem may be made worse by current efforts to conserve energy by insulating or sealing air leaks and thereby creating a tighter thermal envelope Indoor air pollution may pose a more serious PRODUCED JM - 83 3 human health problem than outdoor pollution since Americans spend 70 to 80 percent of their time indoors The Commission is working with the Environmental Protection Agency the Department of Energy and other federal agencies to determine the health effects and environmental implications of major sources of home pollution and begin to develop data to determine acceptable levels of major pollutants Methylene Chloride - Animal studies indicate that methylene chloride may be carcinogenic and the Commission is concerned about its potential hazard in situations where consumers are exposed to the chemical The Commission will be investigating and evaluating the use of this chemical in aerosol propellants Phthalate Esters - Tests by the National Cancer Institute indicate that ethylhexyl is carcinogenic in rats and mice Phthalate esters are used in significant quantities in the synthesis of many plastics The Commission is concerned about reports which indicate that general there is gassing of plastic products that may expose the population to phthalate esters Plastics Flammability - With widespread use of many different types of plastics in consumer products certain such products containing plastics appear to be unusually flammable or produce very toxic gases when they burn The Commission plans to develop scale methods to evaluate the hazards of plastics in consumer products Upholstered Furniture - Every year upholstered furniture fires caused by smoldering cigarettes are estimated to kill at least 1,300 people and seriously injure another 3,700 The industry in an attempt to produce upholstered furniture that is more resistant to ignition from burning cigarettes has initiated a voluntary program that includes modifications of the materials used in the furniture and changes in the methods of furniture construction The Commission will complete its assessment of the effectiveness of the industry program and consider appropriate options both voluntary and mandatory Commission staff members are available to discuss in more detail each of the above areas as well as our existing and planned research efforts We also are willing and anxioutso explore areas of cooperation and coordination in our mutual research efforts It is my sincere hope that this letter will serve as the first step of a promising and rewarding effort towards increased consumer product safety I look forward to hearing from you and the Institute in the near future Sincerely Richard A. Gross Executive Director PRODUCED J-M 83 File : CPSC J. Stevens Co. Inc. - ~~ Stevens Center 400 EAST STONE AVENUE P.O BOX 2850 GRE2850GREENVILE NVILL2E850 GREENVILLES.C. TELETP ELHEO PHN ONE E 803/235 - 2581 March 31 1982 SUBJECT FROM Meeting with Ms. Nancy Steorts Chairman Consumer Product Safety Commission and Associates at Commission's HQs in Washington March 19 1982 F. X. Werber Dr. Dr. Dr. Mr. Mr. Frank X. Werber VP Research & Development J.P. Stevens Chairman Theodore L. Heying Director of Research Chemicals Gp Olin Corp. Stewart K. Kurtz VP Research & Engineering Clairol Appliance Div James Ramey Director of Product Safety Celanese Corporation James F. Reis Director Asbestos Policy Manville Corp. Meeting was above Mr. attended Reis was by the unable first four to attend subcommittee members listed From the Consumer Product Safety Commission besides Ms. Steorts attendance consisted of Ms. Katherine Cook Executive Assistant to the Chairman Dr. Peter Preuss Director of Health Sciences and two gentlemen who were assistants to Commissioners Sagoria and Pittle respectively In our presentation members of the subcommittee emphasized two main points 1 The Industrial Research Institute through its Federal and Science Technology Committee seeks to serve as an effective bridge between the industrial research community and agencies of the U.S. government whose work depends heavily on technical information from diverse sources 2 The companies and subcommittee have industries represented by the members of in depth D and technical organizations deal with safety of their products the to Response from Ms. Steorts generally emphasized in collaboration with industry Following are conclusions from the meeting her the strong interest specific 1 Ms. Steorts asked for a page summary of the organization and activities dealing with product safety in each of the companies represented on the subcommittee PRODUCED PRODUCED83 JM Page 2 2 Ms. Steorts suggested a series people from industry with CPSC three or four specific issues of seminars of D and technical staff each dealing with two The industry people would dis- cuss the technical factors and constraints surrounding their products of interest to the CPSC this suggestion has merit and we The plan subcommittee agreed that to discuss further whether and how this could be followed up In limited discussions with American Textile Manufacturers Institute staff it has already become clear to me that each company and industry will have to weigh the potential benefits against the risks in undertaking such meetings 3 The subcommittee suggested that a way CPSC staff to have access to balanced should be technical found for the advice from industry as well as academia at very early stages in their examination of potential hazards As it now stands Chronic Hazard Advisory Panels are convened only after a threat to consumer safety is suspected with all the attendant publicity that convening such a group generates There is a legal problem in trying to bring about panels at an earlier stage and Mrs. Katherine Cook was asked to examine what the possibilities were I know for a fact that others have suggested similar panels but sunshine guidelines impose some serious obstacles to setting up formal boards Members of the subcommittee agreed to consider point 1 quickly and provide the summaries to F. X. Werber CPSC if agreeable to their companies I for transmittal to the will discuss with the subcommittee members follow up action on ) F. X. Werber ce Dr. Dr. Mr. Mr. Mr. Mr. Mr. Mr. Theodore L. Heying Stewart K. Kurtz James Ramey James F. Reis Lewis H. Sarett S. G. Stearns E. Steinberg Charles F. Larson FXW3241 FXW3241 tm Manville Corporation Caryl Ranch Denver Colorado 80217 303 978-3039 James F. Reis Director Asbestos Policy April 8 1982 File CPSC Dr. F. X. Werber J. P. Stevens & Co. Inc. P. O. Box 2850 Greenville SC 29602 Dear Frank I have reviewed the minutes of your meeting with Nancy Steorts and am attaching a very brief summary of JohnsManville's activities dealing specifically with product safety and asbestos as they pertain to CPSC's areas of responsibility Again I apologize for not being able to attend the meeting Very truly yours James F. Reis MANVILLE PRODUCT SAFETY ACTIVITIES AND CPSC Manville is not considered to be a producer of consumer products However because of the concern expressed by the CPSC about risks to the health of the consumer from asbestos or asbestos products used in the manufacture of consumer products the company has attempted to work with the agency in identifying potentially hazardous situations Both independently and through participation in industry associations Manville has developed and tested work practices that will limit release of respirable asbestos during the fabrication of asbestos products Where it was not reasonable to assume that these work practices would be followed pro~ composition has been changed to encapsulate the asbestos in binders or to eliminate the asbestos from the product line uct Manville has a Health Safety and Environment Department staffed by health professionals and also maintains extensive Research facilities for evaluating all product lines CPSC CPSC CPSCCPSC J.P. Stevens Co. Inc. Stevens Center 400 EAST STONE AVENUE P.O. BOX ' 2850 GREENVILLE S.C. * 29602 TELEPHONE 803/235 - 2581 TECHNICAL CENTER February 15 1982 Ms. Nancy Steorts Chairman U.S. Consumer Products Safety Washington D. C. 20207 Commission Dear Ms. Steorts JH JH . Swenses Swenses Swenses B. Pigg - Aul | RTIZ RTIZ RTIZ I am writing Committee of to you on behalf of the the Industrial Research Federal Science and Technology Institute I am chairman of the Subcommittee for Consumer Products and Trade Regulation i.e. of the Federal Science and Technology Committee To capsulate briefly the Industrial Research Institute is an organization whose aims are to promote the benefits and impact of industrial research in the United States The organization is over 40 years old and approximately 300 of the largest corporations in the U.S. and a few overseas with private i.e. nongovernment research programs comprise the membership The Federal Science and Technology Committee has approximately 20 subcommittees which interface with the various branches of the Administration and the Congress in an effort to be of service My subcommittee has been loosely in existence for some years but our contacts with the CPSC have been sporadic Most recently I had a meeting with Mr. Richard Gross the former Executive Director and his assistant Mr. Andrew Zakis on February 17 1981 to explain to him that our membership includes companies in the building materials industry textile industry all the major chemical companies oil and electronic industry be pleased to meet as a group with members of the commission to explain our various philosophies of research as related to the safety of products which we manufacture some of which impact the consumer directly Mr. Gross expressed great interest in continued contact and wrote me a letter outlining interest of the commission copy enclosed the then areas of PRODUCED PRODUCED Page2 We did not because of immediately pursue the changes taking the meetings place at the suggested by Mr. Gross time which in part culmi- nated in your appointment I felt it was timely to resume contact since since you have had a perhaps it may period of many be of interest monthtso to you to become established and discuss with some of us how we might be of help to you in the work of your Commission Let me list for you briefly the names and connections of the subcommittee members Dr. Stewart K. Kurtz Vice President Research & Engineering Clairol Appliance Division Mr. James F. Reis Director Asbestos Policy Manville Corporation Dr. James Ramey Director of Product Safety Celanese Corporation Dr. Theodore L. Heying Director of Research Chemicals Group Olin Corporation In addition membership of IRI almost certainly includes companies in all the industries whose products your staff may deal with on occasion It may be of interest to yourself some of the other Commissioners and to your staff to meet with a number of us for perhaps 2 hours or so for us further and how we might be of help At the same at a time convenient to you to explain the role of IRI time we are most anxious to hear your concerns and interests These will most certainly have a bearing on the I plan to call meeting may be programs pursued in our various companies Accordingly your office in about a week or so to see when such a convenient Tentatively I would look to the week of March 8th if that suits your schedule We look forward to meeting with you Sincerely F. X. Werber Vice President Research and Development ce Dr. Stewart K. Kurtz Dr. James Ramey Mr. Jam RameyeResi Dr. Theodore L. Heying Dr. Lewis H. Sarrett jlg FXW2152 PRODUCED P.S. I am asking the office of the Executive Director of the Industrial Research Institute Mr. Charles Larson to send you a copy of the most recent annual report of the IRI which will provide a good rundown of the Institute's activities U.S. CONSUMER PRODUCT SAFETY COMMISSION WASHINGTON D.C. 20207 Frank X. Werber Vice President Research and Development J. P. Stevens and Company Inc. Technical Center 141 Lanza Avenue Garfield New Jersey 07026 t are rs Dear Mr. Werber Thank you for discuss the nature taking the time to and purpose of the meet with me and my Industrial Research staff to Institute The staff of the Consumer Product Safety Commission is very interested in the possibility of working with the Institute to coordinate our efforts in the area of technical research concerning consumer products Given our products shared concern I am confident in providing consumers with that cooperation between us the safest will prove possible to be most beneficial to all including especially consumers As requested at our meeting in February I am providing you a brief summary of some of our long research areas involving consumer products that may be of interest to the Institute members I would point out that most of these topics involve areas where the Commission staff have a general concern regarding safety and do not necessarily represent areas in which the Commission future Since the Commission's mandate will be regulating in the is to reduce unreasonable risks of injury associated with consumer products a substantial amount of research and effort is initially required in some of these areas to determine the exact nature and degree of a perceived risk within a particular consumer product In the course of such assessments we have always attempted to work closely with the segments of industry that might be affected and in many cases have been able to promote and assist industry efforts to address the issue on a voluntary basis thus pre- cluding any need for regulatory action by the Commission We expect to be working together with industry in the areas that are listed below and would welcome any additional cooperation that may be provided by the Institute or its members Some of the major areas of Commission activity for the upcoming year include the following Asbestos - Inhalable asbestos fibers associated with a risk of cancer in humans may be found in a number of consumer products The Commission has issued a general order to gather information on asbestos in certain consumer products Selected products will also be tested for asbestos release Exposure and risk will be determined and appropriate regulatory actions recommended to the Commission Benzidine Congener Dyes - Consumers may face a risk of cancer from exposure to consumer dye products and crafts dyes utilizing benzidine tolidine and dianisidine dyes referred to as benzidine congener dyes The Commission has granted a petition requesting that a ban be proposed for these products and has directed the staff to develop a draft proposed banning regulation for Commission consideration The Commission will also examine the use of these dyes in clothing and other textiles and will consider whether action is necessary to reduce any hazard identified with this use Chain Saws - The Commission estimates that there were over 100,000 chain saw injuries requiring medical attention in 1979. About 23 of the injuries associated with chain saws result from a phenomenon known as kickback - the rearward and upward travel of the chain saw when the saw bucks kicks or otherwise unexpectedly jumps toward the operator The Commission will begin development of a mandatory consumer product safety standard for chain saws their components and replacement parts to address chain saw kickback hazards Electrical Hazards > Residential fires continue to take a significant toll in deaths and injuries electrical in nature Some each year and many of these fires are of the projects that the Commission is involved in include efforts to assess and determine the reliability and performance of circuit breakers investigation of the effects of thermal insulation upon wiring and electrical systems and evaluation of design changes in electric blankets and quartz heaters to reduce possible fire hazards Formaldehyde - Formaldehyde has been found to be a carcinogen in test animals and an independent federal panel of scientists believe it should be presumed to pose a cancer risk to humans Formaldehyde gas released from consumer products is also associated with irritation effects such as human respiratory problems headaches and eye and skin irritation The Commission will examine the extent of consumer exposure to formaldehyde from such products as plywood particle board and textiles as well as formaldehyde use in school laboratories Indoor Air Pollution - Various harmful pollutants - including radon formaldehyde carbon monoxide and nitrogen dioxide - have been found in the air of homes This problem may be made worse by current efforts to conserve energy by insulating or sealing air leaks and thereby creating a tighter thermal envelope Indoor air pollution may pose a more serious PRODUCED PRODUCED - 83 3 human health problem than outdoor pollution since Americans spend 70 to 80 percent of their time indoors The Commission is working with the Environmental Protection Agency the Department of Energy and other federal agencies to determine the health effects and environmental implications of major sources of home pollution and begin to develop data to determine acceptable levels of major pollutants Methylene Chloride - Animal studies indicate that methylene chloride may be carcinogenic and the Commission is concerned about its potential hazard in situations where consumers are exposed to the chemical The Commission will be investigating and evaluating the use of this chemical in aerosol propellants Phthalate Esters - Tests by the National Cancer Institute indicate that ethylhexyl is carcinogenic in rats and mice Phthalate esters are used in significant quantities in the synthesis of many plastics The Commission is concerned about reports which indicate that there is gassing of plastic products that may expose the general population to phthalate esters Plastics Flammability - With widespread use of many different types of plastics in consumer products certain such products containing plastics appear to be unusually flammable or produce very toxic gases when they burn The Commission plans to develop scale methods to evaluate the hazards of plastics in consumer products Upholstered Furniture - Every year upholstered furniture fires caused by smoldering cigarettes are estimated to kill at least 1,300 people and seriously injure another 3,700 The industry in an attempt to produce upholstered furniture that is more resistant to ignition from burning cigarettes has initiated a voluntary program that includes modifications of the materials used in the furniture and changes in the methods of furniture construction The Commission will complete its assessment of the effectiveness of the industry program and consider appropriate options both voluntary and mandatory Commission staff members are available to discuss in more detail each of the above areas as well as our existing and planned research efforts We also are willing and anxious to explore areas of cooperation and coordination in our mutual research efforts It is my sincere hope that this letter will serve as the first step of a promising and rewarding effort towards increased consumer product safety I look forward to hearing from you and the Institute in the near future Sincerely kunn Milan Richard A. Gross Executive Director J.P. Stevens Co. Stevens Center 400 EAST STONE AVENUE P.O BOX 2850 GREENVILLE S.C. TELETPELHEO PHN ONE E 803/235 - 2581 March 11 1982 Ms. Ann Walker U.S. Consumer Products Safety Commission Washington D.C. 20207 Dear Ms. Walker Confirming our telephone conversation the members of my Subcommittee of Industrial Research Institute's Federal Science and Technology Steorts other of your staff Committee look forward Commissioners who have As discussed we plan to meeting with Chairman been invited and members to meet with you at 2:30 at your offices at 1111 18th Street Washington D.C. All the members of the Subcommittee named in my previous letter of March 2 1982 will be able to attend They include Messrs Heying Kurtz Ramey and Reis besides myself As discussed our plan is 1 To present informally aspects of D and technical work directed towards improved safety of our products in five different industries represented by members of our Committee 2 Discuss other ways in which the Industrial Research Institute and its members may interact effectively with the Consumer Products Safety Commission We look forward to seeing you on March 19 ' Sincerely a ol oY foo F. X. Werber bec Mr. Dr. Dr. Dr. Dr. Mr. Charles F. Larson Lewis H. Sarrett TheodorLe. Heying Stewart K. Kurtz James Ramey James F. Reis FXW3111 PRODUCED PRODUCED PRODUCED PRODJUCMED PRODUCED