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I NCORPORATED
OFFI CERS PRESI D ENT* JOSEPH F. BATTLEY. Wa s h i n g t o n
V I CE- PRES I D EN T- W M . C. D ABNEY, L o u i s v i l l e TREASURER- E. A. f OY. JR. . C i n c i n n a t i EXECUTI VE ASSI STANT TO PRESI DENT*
GEORGE H. PRI EST. JR ..Wa s h i n g t o n
SECRETARY- T.S.MOULTON. Wa s h i n g t o n GENERAL COUNSEL-
M. Q. MACDONALD, Wa s h i n g t o n
1 5 0 0 RH O D E I S LA N D AVE..N.W .
W ASH I N GTO N 5 . D.C.
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Juris 1 ? , 1 9 ^ 9
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REGI ONAL VI CE- PRESI DENTS
N E W E N G L A N D - W I L B U R L. RI CE, PRO V I D EN CE E A S T E R N - H O T W. L I N D S A Y, B U F F A L O C E N T R A L - J. MARRY LAW SON, CHI CAGO S O U T H E R N - N O R M A N W. K EL LEY. R O A N O K E S O U T H W E S T E R N - H A R R Y M. K U H N , H O U STO N W E S T E R N - R A Y M O N O T. C A R E Y, L O S A N G E L E S
DI VI SI ONAL VI CE- PRESI DENT
w h o l e s a l e-d is t r ib u t o r s d iv is io n GEO RGE D .G ETTEM U LLER, BALTI MORE
IS. ROBES? A KEHOE Zetfcering Laboratory of Applied. Physiology University of Cincinnati Cincinnati 19, Ohio
Sear Dr. Relicel
Once again I write to you for help, this time in connection with the. new ilaryland Sonic Finishes Law (H.B. 102, June 1, 19'>p) which states in partJ
"It shall he unlawful for any person to manufacture, sell or offer to sell, any toy or plaything, including children's furniture, decorated or covered with paint or ary other rat erial containing lead or other substance of a poisonous nature,
fro;i goafcaai..with..3&lch childrenypy injuriously.. affectyl,
unless such article shall contain a label affixed thereto stating in clear and unambiguous language that the said paint, or other material contains lead or other substance of a poisonous nature."
Cur industry.is faced with the proper interpretation of this law, the crux of which nay lie in the underlined phrase. Unfortunately, no state administrative agency lias been established to which we can turn for state ments of policy or authentic information on tolerances. It seems that each case will depend on the whim of a court or jury.
Our intention is to locate, if possible, authoritative estimates cf singla des e, ingestion tolerances for small children. The list of potential!toxic materials that may find their way into paint and related products is undoubtedly large, but an a beginning we would like to be able to suggest tolerances for bright colored pigments based on lead, chromium, cadmium, arsenic, antimony, mercury, barium, iron (Prussian; blue and organic toners.
We would also appreciate a reprint of your publication "Ssperimental Studies on the Ingestion of Lead Compounds'1, and any other information that will heln us to advise our anxious members.
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K f OOV 5 8 < 2
AT TH E START. CONSI DER THE FI NI SH
I T ALW AYS COSTS MORE NOT TO PAI NT
June 30, 192^9
Mr* Mark . Vestgate,
national Paint> Varnish and Lacquer Assn., Inc.,
1500 Rhode Island Avenue, H.W.,
Washington 5 # D. C.
Dear Mr. Westgatei
.
Your letter of June 17a concerning the Maryland Toxic Finishes Lav, poses a problem vhich is difficult indeed. You may veil vonder hov to Interpret a lav vhich is so phrased. I think I am reasonably familiar vith the conditions vhich brought this lav into existence. I may be mistaken, but I strongly suspect that the attention given to lead poisoning among children*in your state and in the City of Baltimore lias been responsible for this lav. Unfortunately, this lav, like many others, does not go straight to the point, but tries to cover the universe, thereby creating difficulties of interpretation and administration. As you are probably avare, there is no sound basis at the present time for the establishment of tolerances, on a percentage basis, in paints and finishes, or on any other basic. Actually one is not concerned here, in the r*ase of children, vith the size of a single toxic dose of pigments or other substances in paints-. Rather the problem relates to the d03e of material taken over a period of days or veeks or perhaps months, vhich vill induce ill ness . The physiologic background of this problem has been vorked out adequately only in the case of lead, it can'properly be said that the dosage of lead taken in per day over a period of a fev months must not exceed'something of the order of magnitude of onemilligram. In determining the extent of the risk, one has to consider both the size of the dose and the duration of time over vhich it is taSen. In the case.of children one has also to consider a factor of susceptibility, and therefore the sise of the dose indicated above has a rather large safety factor. I
have been asked repeatedly to make a statement concerning the concentration of lead that might safely be used In paints used on furniture and on interior surfaces. So far as I knov, there is no evidence that vould enable us to say hov much lead could be ingested by a child in cheving the paint from the surface of furniture and toys. For this reason I should be disposed to make sure that painted articles of this type have no more than traces of lead in their composition. It might be suspected that cadmium and mercury were in a similar situation. This is almost certainly true of meieury, vhile cadmium is. definitely less-toxic. So far as I knov, the barium compounds used in paint are quite insoluble and do not present any problem.' tic :presents no problem at all. I have neither seen nor heard of any evidence of hazard from chromium in itself, but the lead salts of chromic or chromom acid vould be expected to present somovhat the same problem as the other lead pigments, with perhaps sons- reduction in the hazard because of the relative insolubility of these salts.
Ox) 0 i b'S3
Mr, Mark W. Westgate - (2) - June JO , 1949
This is a r a t her difficult problem, Its solution would require a very thorough study of the literature, vith a careful inter pretation of scattered and somevhat irrelevant experimental data. In the final analysis it could only be solved by rather extensive experimentation > My statements above are the best I can give you without prolonged study, and I trust they may be of some help to you.
I am very glad to forward to you certain reprints vhich may be helpful. If I can be of any further assistance to you, please do not hesitate to let me know.
Very truly yours,
RolSe rt A .' 'iLe hoe , M. D .
R A K el*
Reprints under separate cover. C e r t a i n r e le v a n t -oararvra-ohr a r e