Document Yr6749zX4GYkBM019N0zZvR2K

FILE NAME: Drywall Spackling Compounds (DWSC) DATE: 1977 Sept 6 DOC#: DWSC057 DOCUMENT DESCRIPTION: Letter from R.T. Vanderbilt Co. to the Consumer Product Safety Commission C c / C -7 7 - ^ (L, R . T. V A N D E R B IL T CO M PA N Y, INC,); 3 0 W IN FIELD S T R E E T N O RW ALK, C O N N E C T IC U T O o tP r- ^ w f i CC m : ' o m j . , ; CABLE ADDRESS , ,, /' BILTVAN " N O R W A LK , C O N N E C T I C U T `; * TW X 7 IO --4 6 6 -2 9 A O ' 1203) 5 3 -IA O O September 6, 1977 Secretary Consumer Product Safety Commission 1111 18th Street N.W. Washington, D. C. 20207 Dear Sir: We have become aware of the comment submitted August 20, 1977, by Peter Greene of Public.Citizen group in response to the C.PSC proposed ban of consumer patching compounds containing respirable free-form asbestos (part 1304). In view of the many inaccuracies in this comment and because it seems directed specifically at the R. T. Vanderbilt Company, we feel compelled to respond and we request that our correspondence be made part of the official record. Our comments on Mr. Greenes letter are as follows: Page 1, Paragraph 4 (1) Definition of asbestos is out-of-date and scientifically imprecise. The qualifying word "asbestos" must be used with the names anthophyllite, tremolite and actinollite. (see Mining Enforcement and Safety Administration publications 41 F.R. 10223, March 10, 1976 and 42 F.R. 35000, July 7, 1977; and U. S. Bureau of Mines publication 39 F.R. 24316, July 1, 1974). (2) Mr. Greenes definition on Asbestos fiber is also out-of-date in view of National Bureau of Standards report of analysis of 80 industrial talcs (Reported May, 1977) and proceedings of joint NBS-OSHA Workshop on Asbestos: Defini tions and Measurement Methods, and all respon sible authorities on this subject. Page 1, Paragraph 7 Peter Greene has never presented data to substantiate his inference that Vanderbilt talcs contain asbestos. His reference to Vanderbilt's "fighting a losing battle" is mere rhetoric and without validity in fact. D ie recommendations fo r use o f our m aterials are based upon teste b e fe e d to be reliable Howwer we do not guarantee the results to be obtained Page 2, Paragraph 1 All or almost all of the VanderJoil-fc talcs which have been used for s p a c k l i n g compounds have consisted of one of o u r FIBERTAL products. These products c o n t a j ^ fibrous talc and anthophyllite a s b e s t o s . J Accordingly we have been labelling t h e m with the official OSHA Asbestos W a r n i n g label since the fall of 1974 when w e a c q u ^ i this business from the International Talc Company. Mr. Greene is in obvious e r r o r when he states that Vanderbilt " c o n c e d e s , for now" that the tremolitic talc it s e l i ^ for spackling compounds does contain a s bestos. The company indeed always m a d e that concession and sees no reason to change. Page 2, Paragraph 2 Page 2 , Paragraph 3 The NBS report of analysis of t a l c s states in its conclusions on page 17 "It is the opinion at NBS that, even under favorable circumstances, the existing O S H A procedure is useful only for determining "fiber" content and not "asbestos" content., Obviously Mr. Greene does not understand th^ NBS report. He is confused over the terms fiber and asbestos. He obviously believes those fibers are asbestos whether they are asbestos minerals or not. Mr. Greene is correct in postulating that the nation's largest producer of tremolitic talc will dispute the presence of asbestos in many of its brands. Sincerely, AMHrlsm A l j . a u i'j . u a i. v c j; , I'ic u ia v f c i Technical Development Department