Document ZnyYjdMGYKOmjGq9DJLD4503J

Background Information ^ The Lead-in-Paint Issues NiUonii Paint and Costings Association (NPCA) 1500 flhodt liiartd Avenue. N.W. Washington, D C., 20005 (202) 4*2-6272 The \anonal Patrti and Coatings Association iSPCA J il a trod* association representing the menu'acturencf mote than 90 percent or the dollar vol ume of pawls, varnishes. !.ecourrs and jibed products produced in the 'Jntted States. It itorestnts motor suppliers Of raw materials from which Iht industry's products ore made. Industry lain amount to more than S3 billion annually at retail level, providing employment for more than 70.000 persons at the paint manufacturing level alone and more than ZOQ.OOOat the.retail level. In addition, the number of union painters whose livelihood is dependent on the industry j # 2 20.000. The industry's products protect, beautify or con tribute to the usefulness of hundreds of thousands of products manufactured nationwide. Although the monetary value of pawl for a house. automobile or appliance ts a very small pert of the total monetary value of any of the items, the "value added" by paint is extraordinarily high. There is probably no single component in all these products that contributes as much protective value and aesthetic appeal per dollar as paints and coatings. The National Taint and Coatings Association and .its industry members have a serious concern over the problems of lead poisoning in children which it occurring today in most metropolitan areas. NPCA has pledged its full support to continue to work to soive this senous problem. Tht health of the public, particularly our children, must now and always be tht paramount consideration. T1i Problem ol OM l*>4-Bated Palm* The major refariomhip of paint to the lead poisoning problem of today was identified Man ago t the o*d ead-based paint which <i flaking or peeling from iht walls of dilapidated hooting m the urban areas, par ticularly in iht slum areas where maintenance has been negiecred. H lathe pre-World War II housing that is mo hazardous. More Than 30 rear* ago. the paint industry . begin eliminating these old heavily-leaded paints which oien contained at mu<n 4% SO* oaiic caroorui* o> exd .wmie 'eadi. a mchiv ^oiuoie. 'eac co^oounc. These "ere me oeu q u j ih v pjmis gnown 10 man at mat time, jno me type pre><f*e<J o> $ovmmenr specifications in mnei-citv dwellings, parncuUriv slum nousmg wnere mamierunce is minimal or non-existent and where Housekeeping it oeiow stanoara. cruos or oami or paint* moregnated piaster mav oe eaten ov voung cniiaren. This n recognized now as one or me causes of cmldhood lead poisoning, and. according to medical exoem. gen erally is associated wuh a condition known as "pica'#a compulsion to eat non-iood materials such as dirt, wood, paim Chios, paper, and piaster, when children are living m old. dilapidated, ere*World War 11 housing, they are exposed to me many coats of old paint on me walls and woodwork. The paint irequently contains significant amounrs of old white lead pigments. Additionally, inner-city children are generally exposed to greater lead pollution m the air and on me ground caused m part by combustion sources. Under suen orcumsunces-ieacL poisoning is likely to occur. The National Paint and Coatings Association considers it most unfortunate, however, that the suoiect of lead in modem paints seems to be getting more attention today than me real problem --the old paint m me inner cmes. The focus seems to have changed from the detec tion and'elimination o) the old lead-based paints to me question or wnat further reduction n me amounts of lead used n modem paints snouid be made bv the industry. This does not suggest that the pamt industry n opposed to laws or regulations on lead content, it has actively supported those wmeft are accurate and m the public interest- It does not support laws and regulations which are arbitrary or misrepresent mo problem. Lead in Modem Paint* Of sarttcular concern to th* saint mduatry are refulauom and/or ieftaUtion which would reduce the iead-conttni lundard lor houtehold Damn io8.0*eer~ctm lead in the total non-olaule content of Houtd paint* or in the dried Him of patnt aireadr applied. TH* term "leid-baaed" paint ha* been ued -very looteir- It h more accurate id ditfuu verr *m*U quant)-- tin of lead in patmv The induatry narted phaainf out - . white tead a> a banc infredlent ol interior paint more - : than.JO year* a*o> when utamum diotude became com-. . uV.-SiV; "ecir pvip.-.e. * X-. 0007-SWP-036827 N22948 z-* .ttz >4 *> -c ^' -'"> " uues +r>c <ao '"Ci-rSxMiev -w>e ,wo :> pTowao OOfUjJj/ b*>gnt COdO'S -HKJV. rVviOw'V gre^ni *nd Ofan*v; arid. otf course. fead comoounoi lav* ooerv used. whero ', *Ptwopnac#^frCOrrn*oA-<vunt coatings beeauv# th#r - *re e*iecuJly vauabo fO' Sven us*v The us or lead m cmrovo#vfanl coawigt today n nor oe*ng que*Of>*d because it s recograzod iH-*t those are essential ro prooerty maintenance ind no hazard to cmidren e*ats Irom sods u*e*. Lead pigments ior color* and most omer uses already had been largely discontinued m interior resioe0*'*1 wmu to ensure tbit tnete product* would nor exceed use 1 percent level esraolahed some tears ago ov a voluntary stanoard ana mcoroorated into me leadbased Paint f*osonina P-etennon ac t n $7l. Elective January K 1973. noutenoid paints now must compiv with ;ne order or he Food and Drug Aommiviranon wnttn /unher lowered me :eag-conicnt sianoard to 5 ,. . The small Quantities of lead comoounos used m some modern residential paint* are aodea tor drying proper ties. Thev are used so tne paint will dry properly *nhn> reasonacle times to a tacit -tree. bare, durable surface. Paints without driers remjm tackv for aavs. ana weens <n some cases. Lead driers are unique m rnat tnev have a svnergfsnc effect in me action ot other 'ngreaenti; ihev promote proper Mm drvmg with oetrer adhesion, and ihev prevent lost of orying properties dunng storage of the paint. A 06 percent lead limit means thai no fead mav be added during the manuiacrurtng process. The me or lead dners would thereiore be eliminated. NPCA does not agree that reducing the lead content to .06% is in any wav necessary for the saiety and health of children today, or vet unborn. It is ivPCA's contention that neither human experience, records of rhe poison control centers, nor adeouaie research and animalfeeding studies have shown the need for such action. The primary problem to be resolved, then, is whai is a sale standard, or said another way, what ii the hazard ous level of lead in paint, and How is this level to be determined? Whai ii a Hazardous Level of Lead in Paint! There are fhose who suggest that all fead m paint should and can be eliminated. As indicated previously, other groups have suggested mat lead levels m pamt be reduced to a .06% level. 9oih situations would consti tute a ban. m both cases tne asiumption has been made mar lead levels m excess of these amounts would build up to a hazardous level over the years after several Iarea of modern punts had been applied. The proponents of The .06% level base their conclusion principally on the work of Dr. Robert A. Kchoe ai the Kettenng Laboratory, University of Cincinnati. The valid-' iiv of Kehot's work is not being questioned by NPCA. However. NPCA it questioning the assumptions made and conclusions drawn from Kehoe t resaarcb by others, included is Dr. tarry King of tho U-l Public Health Serv ice. Department of Health, education and Welfare, whose work (which it alio the basis for the position of the Amencan Academy of PvdiarrfcD, n *CA contends i* baaed more on mathematical extrapolations lrm Or. Ktftoe's worfc than on researdryon dry paint filmi and appropriate animal-feeding studies incorporating thete * -2.. - ***jV * PJ`~ / "OO'-jrw : \ - ;rui Of. *efloe ' j co'^ocijno aiK e*a acetate, a ef> so*uo*e lead co<v-oowq. wr%.cn *** v>- tiodoced mto tne drirt*in* water oi irve adult homxi jecr*. He dd ac h wofrwnh the smos or ie*d <om- pounm used m pamt todav and ncanemot was maoe :o >eetf paint cn/o> to ho subirco. The conouuons or Dr. tmg do not ukr into comideranon ih tan mat me lead compounds actually used ,n oanr a/e *< solu ble Than lead serrate and. nen maesiea *n me \otm of dned paint cnps, snoud be aoio'oed bv me numan body at a much slower *ae. n at all. K onec tilm oi "*od- ern oami is a hard, tairlv insoluble suostance containing 'runs, pifmems and omer ingredients mai are not eas>v dissolved m me numan system it is not nonn wnai amount, it any. oi *ead c3fT,oou',c> - encaosv. ated m pami himy->* ao>orued ^m*de 3*0'0gica:w ava. #o*ei mo me numan sv>iem in comrasi to Dr K.ne s worn, omer more 'ecent :t vearen oavec on ammai-'eeO'ng studies o< actual oam< turns indicates a muen nigner ifvei oi >eao <o oe sate. This u ihe mo h oone ov Da. Cage ano Lucniietd. *no puohshed their hndings m Engtanc m 1969 in orte sum mary. this research indicates tead limits mat are con servatively rrom 4Vj to g times nener. Fy/tnermore. tnese limits are based on a dailv *nue over a oenod of vears. a much more oramauc situation tnan is rne case today with young entiaren. Considgnng mai these are sate -aiues tor daily feeding, then ine hazardous levei must oe very much higher than tne proposed .06*> ead ievei. in fact. Drs. Cage and litcruietd snowed mji the danger oose is SO limes tne sate dose. In October. 1971, the Director. Division oi Hazardous Substances and Poison Control ol me Food ana Drug Administration, commented on me absence or naro sci entific data. He wrote: "there is no data from scientific studies to show how much lead m me form or pamt chips a child might ingest per dav. nor what iracnort of such daily "dose" will be aosorbed although several scientists have used assumption on the quantities m developing their models Wt have never seen anv eodemioiogicai evidence mat lead poaomng has resulted from ingestion of pamt chips containing 0.3% lead, nor can we produce toxicological data to support a rinding; that such a concentration will result in poisoning, in fact, we are unable lo produce epidemiological evidence of lead poisoning even at 1% in dried paint filmi or doc umentary scientifK evidences to support a finding that this level if enough to result in overt symptoms of tead pOMOfting." (emphasis orovided). There is an absence of empirical data and to impose an arbitrary standard at this time s. n effect, condemnmg a useful consumer proouci which has not been tau-ly tested. Rtuirrh is Underway RcMirdt i underwir which will provide t sound ,nd reasonable basts for iftslatton. if needed. NPCA he* undertaken a research sroffw*. bemf conducted bv an indtpendtnt laboratory, invoivirt| anitnal-iaedinfs ol paint chip* with the ingredient* used in modem Damn. The test protocol* have Been established, with the amirlance and advice ol FDA. the bureau ol Community En> vtroomental Manafcment IIClM).-both pan of the Depanmem ol Health, Education and Walfare-laadinf . medical-authorities, and others. The protecthonioinf.. =<% L7.K>c g9^ Q007-SWP-036828 0007-SWP-000112773 ^e*mnsfrui resufn 0 4*a..ao;e pynng -<)T3. prop*Oty wiihin 6 10 months. Mso, tr< institute o' Environmental Medicine o New vonc Lnivcrvwv Medcat Cenre' nas * 'oearcn proe'an-> jnoe^wjy. fvn0e<3 bv the Citv O' Nf* rot*. in addition, : -s understood mat fDA jno 8CEM have .mocrfaven retear<n Qrogramioi ?ny* own Ccnaimv. tne \oentiiic .nowiedee oemg oeveiooed Pv mose studies w*l o'o* ae many 01 me ambers to tne Cutrsi'cm .-.men exist :caav. ^nnl these studies arc como'C'es on cred samr ?im containing me t>pes anc jnsouni * or eao < o'nouuffls actually useo ov rne oami -nowM/k 'Oda* '*c 'eduction or .me <eao content n ojmrs to jn c<ceeameiv -ow mvet. v.itn as an> proposal to cstaonsn a 06*. sianuard. wouid oe a greco'ious ano unnecessary action sPCA is con-.cent mat research wni prove 'n*i ;ne I 0*. ieve ot >cad n modern oamis is not a na;aro :o crmqren. However, as evidence Ot Its real concern and io provide an aoui- onai margin ot saietv, .NPO nas act'veu -w o p o ^'CC a reduction to -cao <n household oamis ctiecnve >mce Oeeemoer 21 1972 Toe 5eaa ujnqa'd allows q i amned use ot lead oners n environmental and aw material contaminants. Contamination can occur oe- reuse iead is suen a common e>em*nf. General Impact on Paint Industry M Deviously stated, a 06* . evc> mrans tor all prac tical purposes mat the manufacturer can aod no lead during she manuiactunng process. vianv rnmuiacturerv do not have available any "oft the shell" suosutute. Therefore, at the very outset, extensive ano costiv testing and rermuJaton o' entire product unes would be nec essary. Any \ubstiuie> or ijc tomuounc-* would them selves h>ve to be tested. not on> tor effectiveness. but aiso IpliOty in addition, it would oe necessary, m order io prevent an maovertenr vtounon. to/ me manutacture'' to install verv expensive ohjrmafeuticaMvDe analysis and lestmg eampment into me profluCtton ime or nave each proouci Datcn tested bv ourvde laboratories oetore marketmg. Ouisiae testing is prohibitively exoensivi*. particu* any tor small companies. The immediate 'csuii or a .06* lead level would be a complete disruption or an industry with doubt as to the joihtv or many manutacturers to survive, The ultimate 'esuit is a moce costtv. levs vatmactorv product. If this ii r'ecessarv from a health standpoint, the trujusirv will <Jo t However. n ?Ca urge* only mat the necessity be established mot assumed! bv competent, thorough re search. fodmi Preemption * SP^,A urges one attyt imoocrant provUton >r nw laws, it asks that a full federal preemption prowion oe nserieo. s<mna/ to mat in me fede*at Haaaroous >uoxances ac t . /eoerji preemption it e*<fem?,v mooriini 0 manutacturers to avoid the undue and -nnecessarv Ouroen or Oemg required to compiv witn ihe OfOtiterat* mg jnp varying state and locaiiv-estaomned suncaras. viapy oi meve a>n<r m .eac level standards, effective oatev. jno laoeimg reQuiremems. resulting m contusion ano oostacies <ot tnose manufacru'e'S movng :ne>r products *n interstate commerce. The federal are* emotion would esuousn a uniform sianoarp 'Q< en tire Country. in vummafv. NPCA l 'tailr ccnce,neu w*in me :eao poisoning piooiem ot toaav and strongiv suOporrs e'torrs ro eradicate it. This can oe accomoittnea ov me removal or masking ot me oid paint oeenng .'rom ?ne surfaces or dilapidated housing. The generations cu to morrow. vet unborn, must be protected ov me produc tion q i sate products tooav The sate :ead :e>ei men <s me nev and snooid be finally ana conclusive^ oetermned by adequate scientific 'esearen. This teve*. once deiermmed. vnouid oecome our nauonwioe staocard. s^CA has urged mar mese oaiectives De accomonsned as follows: a. Incorporation of a requirement lor research ov HW to destfmtne the sate level oi io <n resi dential pamt producis with ihe addthonal redutrement of a umely reoon to Congre**. This research requirement should be parr ot federal law. b. Deferral of any further reduction below the cur rently effective .5"* lead sranaard unless and until the need for such reduction is exaoirsned by tne ongoing research. c. Provison tor federal preemption which ers a uni form, national standard lor lead fvei n pamt. d. Aggressive detection, and correction programs it rhe state and local levels re eliminate me njiaro of old lead pamt.' The programs should be soon>ored and funded bv the Federal Government to tne maximum degree possible. This is a medical as well as housing problem, and programs to etimmate the haaard must be directed io both aspects. -S-*2 0007-SWP-035829 0007-SWP-000112774