Document Z7QygMQ6Ypob1b9Rk2y3EdeL

J O H N D . B R A O L E Y . PRESIDENT K. W . G R E E N . VICE PRESIDENT F. S. M U L O C K . VIC E PR ESIDENT F. E. W O R M S E R . VICE PRESIDENT R O B ER T L IN O L E Y Z IE G F E L O . S E C R E T A ftV -T R E A S U R E R ]Li i i i s t r i e s Assiiff:iMiL 60 E A S T 42nd S T R E E T N E W Y O R K 17,X.Y. MANFRED BOWDITCH D IR E C T O R O F H E A L T H A N D S A F E T Y February 23, I960 Robert A. Kehoe, M.D., Director Kettering Laboratory of Applied Physiology University of Cincinnati College of Medicine Eden Avenue Cincinnati 19, Ohio Dear Bob: By way of making a start on what you should have as a basis for formulating municipal regulations with regard to "paints that may be chewed by children," herewith are (l) a copy of a letter received from Dan Ring of the National Paint, Varnish and Lacquer Association on Friday, (2) copies of the three of his enclosures which I have in multiple, (3) a copy of a statement prepared for the February 2lith meeting of the ASA Z66.1 Subcommittee by Mr. Lyman P. Hunter of Salt Lake City, (U) a copy of the call for the meeting, to give you an idea of "what's cooking," and (3) a copy of the Z66.1 - 1953 Standard currently under revisionary discussion. You will, I think, find Mr. Ring's "Report on Precautionary Labeling" particularly worth reading. As he indicates, uniformity as between jurisdictions is vastly more important to the affected industries than is the actual wording of the precautionary labels themselves. Very much off the record, the particularly obnoxious fly in the ointment of uniformity is our friend H. Williams. For my money, Dan has a .broader and better understanding of this whole business than anyone else I know. I think he could be very helpful to you, and when I see him tomorrow, I will sound him out as to the chances of his getting out to Cincinnati. MB: es enc. /<'' 000260 N 7544 % .5r -i^ 'i^r--, ' " *^ 0M &WiiXf&SA `**"" L e a djy g 'r t; .->-. I n d u s t r i e A s s o c i a t i o n `j y pf? ' ^ - s * ; ;4 2 d a t j ^ Nsw York 17, N e w York, M y ''dear. old' DiaskSuasti ^ w * ; ' -- <>>:\r-\,: j . v/jr-*# ? Let we thank you for the suggestions in your letter Ofll February 15< Unless M r . Hoover disagrees, t h e s u b s t a i . ` of -the will be included in our report b e c a u s e l f s e l that they w i l l do a lot to i s p r o v e the ;w h o l e d o c u m e n t V i'- i- ' -'A'.**'3?-, I a taking the opportunity to enclose herewith an a n d two copies-of.my,-report o n precautionary..labeling Ou r m i m e o g r a p h 'sect i o n is j u s t jaawed' to''the'NHh";-degrw'eT!f^ S i at the present tine or I would have provided a m i m e o g r a p h e d - Bk." s e r i e s for e a c h e m b e r 'of the. cowaittee..;:'; I'a a e n c l o s i n g - ; ^ ' ' with the report sufficient copies of our presentrecommended-? p r e c a u t i o n a r y l a b e l s A W b i c h w e r e a p p r o v e d in 1 9 5 4 and^ytti^cty ^ h av been u s e d by the g reat m a j o r i t y o f our m e m b e r s ever',:!, s i n c e tha t time. A s ^ I say' in the repori;:v;wh^'"t h e rh s w ; | ^ ^ ^ ^ r e v i s i o n s ar e complete, w h i c h w i l l fb e w i t h i n 'the';he*tfi 6 0 l ^ ^ 4-'- <iays, I will be h a p p y to d i s t r i b u t e the..same "to'"all m e m b e r s ' o ou r s u b c o m m i t t e e . . . ..'V.fW.c'kM J--jr^ \ ; y *- I a l s o e o c l s * for u $ w i t h tfe r e p o r t 15 c o p i e s of p r o p o s e d h a z a r d o u s s u b s t a n c e b i l l i n t r o d u c e d in th e Senate>| by .Senator M a g n u s o a which, as l remarked.in; my:: T 9 p o r t y .M M ^ M h fTTr'SsPfe-t- ft: ;. foll o w s .closely1'the model- bill- of i;the-.t^M::ahd '* Everybody is short of copies of t > e m o d e l b i l l but 1 " *s=i-.; one we looks have like. here in'our This bill, office so that of course, was y o u o a y s e e sdiatij approved primarily,! : f o r use* in state legislatures. In the State, o f N e w Jea a bill has recently been Introduced that follows a mod*&j^?v:* :-bil'i:>hibh'X^lhad prepared' a n d w i l l 'use whenever^ 'thm ^ ^ ^ ^ P PM*..:'- .* l e g i s l a t u r e w i s h e s to r e s t r i c t its a t t e n t i o n t o p s i n a r a t i than hazardous substances generally. X e n c l o s e a copy: of; '-v; o u r B o d e l s t a t e p a i n - t l a b e l i n g a c t : : *- :> -> _ * 4 -S'*-.TM, tjf t - r v * V *" r t," ""**.* " ^ " k< -ijgBSS 1 1 ,i - ^i.ftv^ - r,j? .. v ... .. JV?.. A . 1-W/ -* V. #' -- *,:>.i i-^*f<>r^ '4 |^ p K t''i1^ ^'* ? *.'vi.r'^fSfKia^Sf*e?r 1 hope that X aanot becosiag too dlhliital ; :^4V'aiithis data;-. Xthinkyou a*;{tfcs; tary hould s h u e it in tb f i l i A t least, a n d you a h o u l d Q i s ow n d i s c r e t i o n alxittt ^ d i s t r i b u t i n g t h e p r e c a u t i o c a r y l a l w h i c h n o w k n o w w i l l s h o r t l y b e revised*.f a n d the' of the Senate Bill o n hazardous substances V . <- . TM --*> , --C , M ', J o h n F o u l g e r a n d I w i l l a r r i v e Tueeday.(n l g h t , F e b r u a r y ' W e .h a r e r e s e r v a t i o n s a t the W a l d o r f .-c<-j|^*<i * With very best wishes, I as V ' DSR:e* Enclosures " * ;. . 3 cc. Report on Precautionary Labeling. D.S.R., (typed) - iV`- 10 cc. Precautionary Label Becosssended by the I.P.VJ,,,___ _ Containing Metal Compounds, Solvents of Specified Flash - . ... - _____ 1166 CcOc.. Significant Amount of Other Materiel Which Key Be Harsfnli! Oct. 1, 1951*. (mimeo.) . ' . . ` ; : - ' / S.1283, 86th Congress, 1st Session. Magnnaon.. :.: ..- ' 1 0. Hazardous Substance Labeling Act. N.P.T.L.A.* Jen. 5, -- : ; .k - . ,* - Z 1 Ci State Paint Labeling Act. I.F.V.L.A., Jan.2$,~19$*.( . ,5 - K' f T:,, ^w a ; i ---?r i -f*"5*^Ji^a`. K Z 000-6262 1 * * r + * M ^ $ s* ^ t * !*?` -*, ~ .. r f ; . --.vi-v, . r : - , . ... w - .-*.'.. : . . - V '- - '* - -, - -s*'''-'-. ` 'i*' ' - '>. -.> --v .- fiv v i i . '. \ : .?- v.%. . . . . * ? . - a ' ' i e - ' */ *-r ; - ^ ' '-- ' , .*;| Vwis.V C. r :.* V^^Siirf-y , a ** `'SssSfe. ... Report on Precautionary Labeling General I have been requested by the Z66 subcommittee of the American Standards Association to summarize precautionary labeling legislation with respect to laws and regulations applicable to paint products on municipal, state and federal levels. Precautionary labels are one of the two large general divisions of labeling regulations that are in effect in the country. The other division is what is known as formula labeling. The distinction is that precautionary labels are aimed at protecting the public from harm through the improper use of products, while the formula labels protect retail purchasers against fraud and deceit with respect to the nature of the product bought and sold. Formula Labeling Formula labeling requires the statement of the ingredients of a product to be placed on the label. This informs the purchaser what he is buying and he can compare any particular can with any other. The states now requiring formula labeling are Alabama, Iowa, Minnesota, Mississippi, Montana, Nebraska, North Dakota, South Dakota, Vermont, Virginia and Wyoming. Precautionary Labeling Precautionary labels are subject to two large subdivisions. One applies to paints and paint products exclusively; the other applies to all hazardous household products, which includes but is not limited to paints and paint products. 0006263 ^ 7544.02 -2- States with laws on hazardous substances are California, Colorado, Hawaii, Illinois, Indiana, Kansas, Massachusetts, New Jersey, New York, Ohio, Oregon, Texas and Vermont. These hazardous products laws relate generally to retail sales and do not seek to bring under their juris diction industrial transactions which do not involve a marketing of the product as such to individual members of the public. The following states have labeling statutes limited to paint products as such: Alabama, California, Georgia, Illinois, Iowa, Kansas, Massachusetts, Minnesota, Mississippi, Nebraska, North Dakota, Olio, Pennsylvania, South Dakota, Vermont, Virginia and Wyoming. In many of the states there are both hazardous household products . laws and regulations as well as paint labeling laws. In some instances this overlap is taken care of by excluding paints from hazardous household product acts where special provisions have been made for paint. City Ordinances The cities of New York, Buffalo and Baltimore have special municipal ordinances relating to paint. The Fire Department in New York has one set of regulations to protect against the hazards of flammability and combustibility, while in the same city the Health Department has other regulations under its Sanitary Code to protect the health of its citizens. The Recommended Labels In 195k the National Paint, Varnish and Lacquer Association adopted recommendations for labels which followed, in marked degree, the American Standards Association Z66.1 standard on lead and other harmful substances in paint. The recommended labels of the National Association, however, went even further and embraced the hazards of flammability and combustibility 0006264 -3- even in paints -where there was no harmful ingredient present with respect to ingestion or inhalation. I append a set of these recommendations hereto with the general statement that they cover practically all states having both hazardous household products involved and special paint laws. Just this year, however, the National Paint, Varnish and Lacquer Association revised its re commendations by adding the recommended phrase "Keep Out of Reach of Children" for all labels and by emphasizing the requirement to use all products "with adequate ventilation". The new recommendations are not ready for distribution but as soon as they are, they will be distributed to each member of this subcommittee. Uniform Warning Wording He are currently engaged in a project to seek standardization and uniform wording for warnings in ordinances in New York, Baltimore and the rest of the country with respect to paints containing more than 1% lead. The Baltimore label required for paint containing more than 1% lead reads as follows: "WARNING - Contains Lead. Harmful if Eaten. Do not apply on any interior surfaces of a dwelling, or a place used for the care of children, or on window sills, toys, cribs and other furniture." The New York requirement for a lead paint warning label is: "Contains Lead. Harmful if Eaten. Do not apply on toys, furniture or interior surfaces which might be chewed by children." In the event that an agreement can be reached between the Baltimore and New York authorities as to the wording, the proposed recommended label for combustible paint products with a flash point above 80F. will read: H E 0006265 -u- "CAUTION, COMBUSTIBLE. Keep away from heat and open flame. Contains Lead or other compounds harmful if eaten. Do not apply on toys, furniture, window sills or other interior surfaces of rooms used by children. Avoid breathing vapor or spray mist. Avoid prolonged contact with skin. Wash thoroughly after handling and before eating or smoking. Keep container closed when not in use. Keep out of the reach of children. Use with adequate ventilation." This label takes care of both the requirements of the Health Department of New York City with respect to harmful ingredients, and with the requirements of the Fire Department of New York City with respect to combustibility or flammability. With the addition of the words "Keep out of reach of children", which is a new phrase, we believe that this label once cleared by Baltimore and New York will be acceptable in all states and other municipalities requiring lead paint warning labels as well as in all states with hazardous household product laws. Federal Legislation There is pending on Capitol Hill Senate Bill 1283, introduced by Mr. Magnuson, which closely follows the labeling requirements of the model bill prepared by the Manufacturing Chemists Association and the Chemical Specialties Manufacturers Association, copy of which is here enclosed. During the last few years, eight states have adopted in substance the provisions of this model bill. The American Medical Association participated in preparing the drhft. For use in states as distinguished from the federal government, our Association has approved its terms as being acceptable to the paint industry whenever a state legislature decides that a paint labeling law is desirable. K E 0006266 5- Conclusion We have SO states, the District of Columbia, Puerto Rico and the Virgin Islands which can each adopt precautionary labeling. We have dozens of cities who are interested in protecting their citizens by having products properly labeled, and now we have the federal government working on the same proposition. The paint industry asks only for an opportunity to cooperate in a practical, effective and reasonable way in labeling its products to protect the public against harm to its health and against fraud from "gyp" and "fly-by-night" entrepreneurs. Time and again I have heard manufacturers whose labeling cost them many, many thousands of dollars each year say: "We want strong and effective and truly protective labels. We want fully to cooperate with our public health authorities, our municipal authorities and our states in providing proper labels. There is only one thing that we ask, that to the extent humanly possible the-wording on labels be made uniform." It is only by reaching as far as possible toward the goal of uniformity in labeling that we can provide without undue hardship the protection to which the public is entitled. The converse would be a requirement in its worst sense of differing labels for SO states and as many cities. I hope that each of you can see his way clear to support us in our fight for uniformity in warning labels. Respectfully submitted, " ' .Daiiiel S. Ring National Paint, Varnish and Lacquer Association, Die. 000626? PRECAUTIONARY LAEELS EECOKMEEnSB BY THE RATIONAL PAINT, V A N I S H Aim LACQUER ASS^ CIATIOK FOR PAINTS CONTAINING PETAL COMPOUNDS, SOLVENTS OF SPECIFIED FLASH POINTS OR SIGNIFICANT AMOUNTS OF OTHER MATERIALS WHICH MAY b e Ha r m f u l The follovang precautionary labels are suggested for use by members of the paint,'varnish and lacquer industry* The principles set forth in the suggested labels apply to all types of containers, large and small. 0006268 Precautionary labeling for paints containing harmful metal compounds should be applied to groups as indicated. GROUP I - Products containing not more than 1 percent of lead, as metal (Fb), and not containing compounds of antimony, arsenic, cadmium, mercury, selenium, or barium (when soluble by stirring for 10 minutes with 5 percent hydrochloric acid at room temperature) introduced as such in the formulation of the-se products, and a solvent flashing below l50F. Flash Point above 80F. CAUTIOHl CCHBU3TIBLE Keep away from heat and open flame* Use with adequate ventilation. Avoid prolonged or re peated contact with skin. Avoid prolonged breath ing of vapor or spray mist. Keep container closed when not in use. Flash Point above 2GF, to 80F., inclusive WARNINGS FLAimjLS Keep away from heat, sparks, and open flame. Use with adeqviate ventilation. Avoid prolonged or repeated contact with skin. Avoid prolonged breath ing of vapor or spray mist. Keep container closed . when not in use. Flash Point 20F. or below DANGER! SkTREIELY FLAI-EABLE Keep away from heat, sparks, and open flame. Use with adequate ventilation. Avoid prolonged or repeated contact with skin. Avoid prolonged breath ing of vapor or spray mist. Keep container closed when not in use, .~ 0u062o9 -2- (a) "Bo not take internally" may be omitted from Group I except in the case of d e a r liquids, such as thinners. Regardless of flash point, these clear liquids should bear appropriate Group I label plus warning "Do not take internally", because clear liquids may be attractive nuisances or mistaken for beverages. (b) Flash point determinations, in all cases, refer to Tag. Open Cup Method, as specified in ASTM Method D 131k-5iiT. (c) Products classified in Group I which contain "odorless" solvents must be labeled with the appropriate Group I labels, but the warning worus "Use with adequate ventilation" must be in type two points larger than the type used for the rest of the appropriate caution label and the label placed in a prominent position on the container. (d) The percent of lead is determined as lead metal (Pb) based on the total solids of the paint. GROUP II - Products containing more than 1 percent of lead as metal (Pb) in a compound (see Rote (b) below), or containing a compound of antimony, arsenic, cad mium, mercury, selenium or barium (when soluble by stirring for 10 minutes with 5 percent hydrochloric acid at room temperature) introduced as such in the formula tion of these products, and containing solvents of the following flash points: Flash Point above 80F. CAUTION! COMBUSTIBLE Keep Away From Heat and Open Flame CONTAINS LEAD OR OTHER COMPOUNDS HARMFUL IF EATEN Do not apply on toys, furniture or interior surfaces which might be chewed by children. Use with adequate ventilation. Avoid breathing vapor or spray mist. Avoid prolonged contact with skin. Wash thoroughly after handling and before eating or smoking. Keep Flash Point above 20F. to 80F. Flash Point 20F. or below -3- WAF.NIHG FLAMMABLE Keep Away from Heat, Sparks, and Open Flame COIITAIKS IEAD OR OTHER COMPOUNDS HARMFUL IF EATEN Do not apply on toys, furniture or interior surfaces which might be chewed by children. Use with adequate ventilation. Avoid breathing vapor or spray mist. Avoid prolonged contact with skin. Wash thoroughly after handling and before eating or smoking. Keep container closed when not in use. DAIIGEFcl EXTREMELY FIAMAELE Keep Away from Heat, Sparks, and Open Flame CONTAINS LEAD Oi OTHER COMPOUHDS HARMFUL IF EATEN Do not apply on toys, furniture or interior surfaces which might be chewed by children. Use with adequate ventilation. Avoid breathing vapor or spray mist. Avoid prolonged contact with skin. Wash thoroughly after handling and before eating or smoking. Keep container closed when not in use. (a) The percent, of lead is determined as lead metal (Fb) based on the total solids of the paint. (b) When more than 1 percent of lead is the only harmful compound used in the product, the. words, "Contains lead or other compounds harmful if eaten" in the applicable Group II label may be changed to "Contains more than 1 percent lead (Fb)". Furthermore, when this wording is used, the words "Harmful if eaten" must appear in the text of the label. GROUP III - Products other than those included in Group Ir containing significant amounts of materials or solvents which may be harmful. K E 0006271 1 -ItWhen harmful substances, other than those included in Group II are used in paint, due to formulation variables, it is impossible to establish a general warning label. The paint manufacturer is cautioned to alert himself to such hazards and use an appropriate precautionary label. Es-tra vigilance should be the rule in labeling harmful Group III products. Label ing of Group III products containing hazardous chemicals to be guided by MCA Manual L--1 Warning Labels applying to those particular chemicals. (PGUP ITT - Fa hit and Varnish Removers (a) Ion-Flammable Remove rs, such as specified in Federal Specification TT-R-2>lc Eemoverj Paint and Varnish (organic Solvent Type), Type II. Such removers containing substantial amounts of Methylene Cliloride must bear labels materially as follows: CAUT10NI Contains Methylene Chloride Use with adequate ventilation. Avoid prolonged or repeated contact with shin. Avoid prolonged or repeated breathing of vapor. Do not take internally. (b) Flammable Removers, such as specified in Federal Specification TT-R-25lc Remover; Paint and Varnish (organic Solvent Type), Type I, Such removers containing substantial amounts of benzol must bear labels materially as follows: DAI'OERl EXTREIjELY FLAMMABLE VAPOR HXRiu-TIL - POISON Contains Benzol Keep away from heat, sparks, and open flame. Keep container closed. Use only with adequate ventilation. Avoid prolonged or repeated breathing of vapor. Avoid prolonged or repeated contact with skin. , . A n .'J f t rt i! HISTOldc n p E3AD XITOlCCCATXOiT S BJLP.T3D TO HODSRH Pi\HT FILMS" TShensver a hasard involving siaall children exists, prompt steps should he tahen to correct it. However, it is most desirable to pin point the hasard as cjcourately as possible in order- to be sure that correc tive efforts are nade in the right direction. in attempting to study the problem of lead intoxication in young children, our most reliable sources of information seem to be medical reports that have been published. Of these, three in particular have been brought to our attention as shoving effort and care in documen tation. These are as follows 1. "The Baltimore Study" by X. Julian Chisolm, Jr. 11.D., June 1553. 2 . "The Srposuro of Children to Lead" by J. Julian Chisolm Jr.. ii.D., and larol-d B. Harrison, H.!>.. pub7.ish.od in "'Pediatrics", *7ol. 13, Ho. 6 , Doc. 1955. 3. "Summary and Trcarpts from Passaic. County Grand Jury Present ment of January 1951". / There may be ocher equally me11 documented studios, but if so, they have not come to our attention. Three pa ocularly significant facts seem to be brought out by these reports: 1. The greatest hazard seemed to be with children under three years of age. 2 . The lead content of composite films 'There ingestion was sus pected or confirmed was usually over 5%. 3 . Host cases were from the urban, low income, slum areas. It is unfortunate that no mention is made in these reports of the form in which the lead was found. Perhaps this was not determined. Hevertheiaes, simple mathematics plus a knowledge of the history and corpora hicn of paint indicate that it would be highly improbable for idie waj or part of this lead to be anything other than "hhite Lead", Details on this point are discussed later. In any case where the \ analysta of composite films indicates more than 5% of lead, this vou Id .3 fch'C hita Load" ki-w: "' y 'Ti* t h a t i. . . . . y --_ involved in the cases -ediere lead conte is over e nearly all saoes} It would not te un asonarle s probably i:v.~olvee in the fey; similar ases '.-.-here < -2- tha lead content vas lens than 5b>. . Frcoia a technical point of vie-*, it does not saesa reasonable to accept the preraise that ail lead compounds are alihe, and will have equal tonicity, the lead content of glassware ana of porcelain glares is presumed to be free from liasard because of the fact that the lead is tightly held in an unavailable form. Ws would also expect that the lead content of paint vaiyht well be more available in some compounds than in others. An effort to determine v-metaar or not ail forms of load that are used in paint are equally hazardous would seem to be desirable. In iSdC, the U. S. Public Health Service published Public Health Bulletin ho. 253 entitled "The Relative Tori city of Load and Some of its Common Compounds'1. This teas an animal study, and is not claimed to be conclusive, nevertheless, we have the following statement on page 2?, "However, careful consideration of the data in the above ex perimental we::h indicates that while no enact numerical order can bo assigned to the tonicity, certain lead compounds may be sot apart as idoro tonic than others". It is recognised that animal studies may not lie directly applicable to problems connected with small hildran. The above is cited simply to support the statement that all lead oompoi'nds tire probably not alihe in tonicity, ho another example of hoc metallic compounds may vary in tonicity we slight contrast the effects of barium chloride and barium sulphate. There are three goner:;1 -classes of lead cosyounce used in the paint industry. One is "white lead". The second consists of a group of color pigments whose essential lead component is lead chromate. A third possible classification is that of lead driers. Hcrsver, the concentration of driers in paint films is probably too lor to be significant. Although "white lead" probably should only refer to basic Lead car" bonato, basic lead sulfate is also used in exterior paints and is often called "white lead". Both of these compounds carry lead in an easily available form. The "Basic" portions of both compounds as well as the carbonate portion of the "Basic Carbonate" tiro easily converted to lead chloride by stomach acids. As stated "Whits Load" is used in exterior paints at the present time. Its concentration may vary all the way from 0 to 2C% (in rare instances even higher} based on dried film. At one Lime i was a cowman practice for painters to buy pure white lead in pasta form and mix their c m paint. This painter mined product m x v h t c o n t a i n as much as 10 to 12 pounds of load per gallon of paint. f ~ *? w Such painter mimed finishes were! used not only on exteriors, but on interiors as well* "his practice has been discontinued for many years because of high cost and because acre suitable interior finishes were developed for the trade. Although it has been re?orte& that some rasnufacturers used moderate amounts of white lead in a few interior finishes possibly as late as the year l4i, even this use, as far as we know', was discontinued because of high cost. It is reasonable to state that for all practical purposes, with the development of iithopone and titanium pigments in the lS2G*s the manufacturers of most ready mixed paints discontinued the use of white load in interior finishes. Many painters continued to use Paste Vihite Lead for inferior finishes until shortages developed at the beginning of the last world war. It is easy to see how an occasional coat of this high lead content paint could produce an analysis of a composite film of over 5% lead. On the other hand, lead chromate in one form or another is now used in the paint trade as a color pigment in both interior as well as ex terior finishes. For many of its uses there is not a satisfactory lead free replacement. However, from a chemical point of view, the lead in lead chromate is much loss available than the lead in `"Hhite Lead". Hie amounts of load chromate usee in paint production have two limit ing factors. One is cost. Since these colors are expensive, no manufacturer will use mors than he feels is necessary, Th is other limiting factor is the quantity that can be put into a gallon of finished product. For example, it would not be practically possible to grind more than approximately 3 pounds of chrome yellow, contain ing approximately 2 pounds of load into a gallon of enamel. To do so would seriously interfere with gloss and gloss retention. However, while it might be roseisle to use 3 pounds of chrome yellow, the practice is to use lesser amounts and make up the differen.ee in hiding power with less expensive pigments that would contain no lead. It would be reasonable to state that the maximum amount of lead that might be introduced into a yellow enamel would be between 1% and 2 pounds par gallon. Contrast this with the 10 to 12 pounds introduced into an old time painter white lead finish: And also bear in mind that no this I'a pounds of lead is in a relatively unavailable form compared r- with that in the white lead of the old time finish. cu to co A yellow enamel such as is discussed above might be used on gasoline CO o pumps, highway signs, earth moving equipment, etc. but would not be used for decorating the interior of homes. The experience of the W paint industry has been that where more than 4$S of lead (based on dried film) is introduced as tinting color, who public does not buy such finishes farc inferior work on homes, since the colors are not acceptable, when ; tk oral sales will ho verv low. In the rare bean used in the interiors of lot* income or slum homes. If they had been used, they could have been readily identified by their color. It is known as a practical fact that the public does not buy interior finishes where the tinting color has introduced more than 49 lead as lead chromate. Ke can also state that most probably, where such a color has been used, for the sabs of variety, a different color using less, or no lead will be used on the nest repaint job. Thus the average lead content of several coats of interior paint on such a home would move steadily downward from 4%. If vre return now to the three reports mentioned earlier in this paper, we find the following in Dr. Chisolm's Baltimore statement, on page 2 "In most cases of intoxication source samples have been found to contain `greater than 5% lead' by the method used". In "Pediatrics" Volume 18, Ho. 6, referring to Baltimore studies we f5.net the following statement "For each of the 105 exposed children, from one to five different sources containing greater than i? of lead were identified among the various items each child was thought to have chewed. For 102 of then there was at least one source containing greater than 5% of lead. The lead was contained in the paint on the surfaces. The paint was old and flaring and frequently contained xaany layers, one or 'more of which may have been 30 to 705 of the total solids in the paint". In the "Summary <i Excerpts from the XS5S Passaic County Grand Jury PresentiViCnt", at the bottom of Page 1 we naive the following: "The paint from the x'indow sill in Case Ho. 1 contained load in an amount of 6.15%". "The paint in the exterior f3.ahir.gs in Case Ho. 3 contained lead in an amount of 5.285" . "The paint in the Interior walls of the house in Case Ho. 4 contained lead in jdva amount of 9 .45". Although there is no mention in any of the above cases of the form in which the lead existed, it is almost a mathematical certainty that all except -very minor amounts would have been `TJhite Lead" . If by any chance, even minor amounts of lead chromate had been present, it could have beer, easily identified and estimated by the color. This raises the question, have we ever identified any cases of load intoxication in small children due to lead chromate? if a3.1 such cases are clue to white load, we should bear in mind that the manufacture of interior finishes containing this pigment was descentiaued many K F 0006276 > years ago. co problem not? er.istS as far as nianufaetaring is coneernscl. Oar real problem trould lie in odv.cat5.ng people not to use exterior paint on interior surfaces. There is also the need to prevent children from chirring painted surfaces out of doors. Close records of future cases should be kept, if possible, in order to determine rhether or not lead chromate is involved. ` lend free replaceracnfs for chroma yellow are sensitive to heat and light., are rack in hiding porer, lack eemenence in pale tints, and are unreliable with respect to color uniformity at the point of applies iron of the paint. rn the meanwhilef if re are not able to discover any cases involving lead chromate, it -would seen unreasonable to force upon the nubile the heavy or/ponsa rorui.rcd to replace the chrome colors no*? used for interior work, This v: uld involve not only heavy exponsa, but *?oulel also result in a loss satisfactory product for the public. Presented to h.S.h. Suh-oonn.iifcta ESS-i at :.r./ 2o, 1360, by Lyraan P. Euntsr. k cit sbrucrv K Z 0006277 60 East li2nd St. New York 17, N.Y. February 10, I960 To the Members and Alternates of the A.S.A. Z66.1 Subcommittee: Dr. M, R. Mayers Dr. Charles Abler Mr. H. G. Lamb Dr. H. M. Cann Dr. T. W. Nale Mr. R. J. Eckart Mr. D. S. Ring Dr. J. H. Foulger Dr. Maxwell Stillerman Mr. Stuart Hoover Mr. H. J. Whitson A meeting of the Subcommittee will be held at 2:00 p.m. on Wednesday, February 2Uth, in Room 291+6 of the American Standards Association, 70 East lth Street, New York City. Business to come before this meeting will include: Consideration of a statement relative to the Z66.1-1955 American Standard by Mr. Lyman P. Hunter of Salt Lake City, who will attend the meeting by invitation. (See report of November 11, 1959 meeting.) Consideration of a report by Mr. Ring and Mr. Hoover relative to paint coatings on metal toys. Consideration of a report by Mr. Ring on the current status of precautionary labeling regulations applicable to paints on municipal, state and federal levels. Discussion of possible amendments of the Standard (a) as proposed at the November 11, 1959 meeting, and (b) in the light of the above. NOTES: 1. We have been notified by Dr. Foulger that the investigation undertaken at his suggestion cannot be completed for some months. HE 0 0 6 2 78 -2- 2. Invitations to attend the meeting have also been extended (a) to Dr. L. C. McGee, Medical Director of the Hercules Powder Company (now associated with the Imperial Paper and Color Corporation), (b) to Mr. R. L. Ziegfeld, Secretary-Treasurer of the Lead Industries Association, and (c) through Mr. Hunter, to such other representative of the Federation of Paint and Varnish Production Clubs as he may select. THE IMPORTANCE OF FULL ATTENDANCE IS STRESSED. cc: Mr. L. P. Hunter Dr. L. C. McGee Dr. Edward Press Dr. G. M. Wheatley Mr. R. L. Ziegfeld $/ -'-1\ & Manfred Bowditch Secretary H E 0006279