Document OBwx03NG4v5okMenb89e8p0w

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 ' ' |e - Textures Corporation Paco 1857 COMMERCIAL STREET CALIFORNIA 94070 = 415 582-8126 582-8126 SAN CARLOS August 22 1977 CSoencsruemtearryProduct Safety CommiCosmmisssioin on Washington D.C. 20207 RE PROPOSED RULES TO BAN ASBESTOS FROM PATCHING COMPOUNDS Dear Secretary letter is in regard to the proposed rules published This July 29 1977 in the Federal Register on states Patching compounds that are labeled The proposal sold solely for industrial use would not as marketed and of this ban However it is further be within the scope considers substantially all stated that the commission manufacturing wall We are a medium size company the rules would effect all Joint Compound As published even though it is almost Joint Compound business The commercial oefnto iu rr ely sold to the professional market of industry is already under the regulations O.S.E.A. small The retail or consumer portion of our business is but very identifiable not include material that If ban is required required it should In our use is made for commercial orprofessional between to distinquish distribution system it is very easy retail and the commercial sales But labeling USE the containing patching compound FOR COMMERCIAL ONLY and banning asbestos from containers under 20 pounds would further assure an effective control a zero level of asbestos in Technology has been appreaching reached the quality joint compounds However it has not yet market I have personally tested required by the commercial with little 236 different formula changes inatshb e els abtoorastoprryoducts of uccess I have also evaluated and found them also lacking in properties her manufacturers quired by the building industry The biggest problems being with shrinking and Lack of workability during application ven six months of further development I feel we could for the consumer who does not require a produce a product and who would normally use high production type product a product under more ideal climatic conditions MANUFACTURE OF JOINT CEMEN ' DRY WALL AND I 75 In summary I 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 commission hearing room with respect to the above matter Sincerely Douglas W. Merrill Research and Production Manager Manager DWM CC S. John Byington Chairman John Liskey Office of Program Management CPSC