Document aBQ1OLwXZ27xL6dygDekeyvEB

STATEMENT OF ROBERT A. ROLAND EXECUTIVE VICE FRESIOENT NATIONAL FAINT AND COATINGS ASSOCIATION BEFORE THE SUBCOMMITTEE ON HEALTH OF THE SENATE LABOR AND FUBLJC WELFARE COMMITTEE ON AMENDMENTS TO THE LEAD-BASED FAINT POISONING PREVENTION ACT (5. 3080) MARCH f, \m ' * i 4 t 0007-SWP-036650 , -i Mr. Chairmen, members of fho Scnorc Laaor ana ?.blic >V fsr* j.sc:--!* * an Health. I appreciate this opportunity to be here today, accompanied by a repre!*-.'=?i*e grouo sf executives from our industry, to pretent the views of the National Paint and Coa'ir.g* Assacia!;on on the legislative propoial (S. 3080) which would amend the leod-Sated Paint ?oisoni-g ^ewention Aef (P. L. 91-495). We are here becouia our members are vitally concerned over the major impact which ona of the provisions of 5. 3080 would have on the paint and coatings industry. ) I refer to Section 2 of the bill before your Subcommittee today, which would change the definition of "lead-based paint" from the one-percent established by P. L. 91-695 to an arbitrary 0.04 percent. We deem such on amendment net only to be unnecessary end unreasonable, but -- as I shall discuss in some detail later -- highly inappropriate. The National Point and Coatings Association (formarly the Notional Point, Varnish and Lacquar Association) is a trade association representing the manufacturers of mor# than ninety .'90) percent of tha dollar volume of paints, varnbhas, lacquers and allied products produced in tha United States. In addition, tha National Paint and Coatings Association is a spokesman far tha major suppliers ef raw motorlaIs from which tha Industry's products are mods. Industry sales amount to mare than S5 billion dollars annually at retail level, providing employment far mere than 70,000 parson* at tha paint manufacturing level alone and mere than 200,000 at tha retail level. 4 r j r J At the outset, I want ta assure you that the Association and tha industry mambors wo ' ' represent share your concern over the sorioue problem of load poisoning ef children which is occurring today In most mtropolitan area*, end -- wo pledge our full support to continue to work to selva this serious problem. However, I would emphasise that the amendment -- proposed In*Section 2 ef S. 30K) -- will da nothing toward correcting tha present, Identified and reel causes of load pabon ing of children today. 0007--SWP-036651 _ -j I W i w a e i i S e i <d 0007-SWP-000117968 2- - THE PROBLEM OP OLD LEAD-BASED PAINTS In this regard, the major contribution of paint to the poitoni'-g of chiloren today wcj identified irony years ego at tha old leod-bcsed paint which it f!airing or peeling from t-e -oils of dilapidated housing in tha urban artat, particularly in the slum areas where mci-tcnance -os bean neglected. It it tha pre-World War II housing thrf it matt hazardous bacause, more 'hen 30 yaars ago, tha paint industry began eliminating that# old haavily-leadad paints, which of'en con tained 50% or more basic catbonota af lead (white load), a highly soluble and admittedly hazardous compound. Theta wete, of course, tha bait quality paints produced at that time, and -- the type prescribed by government specifications. At stated, tha paint Industry started phasing out white lead at a basic ingredient of interior paints more then 30 years ago, when titaniumdianida became commercially available. It is na longer necessary (or economical) to stsa white load in interior paints baeauta I pound of titanium dioxide will "cover" the equivalent of 5 to 7 pounds of white lead, depending on the formulation. Interior paints than ceased to ba a causa of load poisoning. Tharafe*a, with respect la old paint, tha term "leed-besed" is appropriate but, with regard to modern paints, this is hardly accurate 1 In theta diwallings, particularly slum hawing, where painting maintenance is minimal or even non-existent and where housekeeping is below standard, chips of paint or paint-Impregnated plaster may ba eaten by young chlldron. This b tecognized tow as o principal causa of childhood laod poisoning, and, according to modicol exparti, generally is associated with a condition known as "pica" -- a compulsion to oat non-food materials aids as dirt, wood, paint chip* and platter. Whan such children are living in aid pra-Warld War II hawing in tha inner citlos, they era exposed ta tha many coats of paint an tha walls and woodwork which frequently contain significant amounts of white load pigments. Additionally, these children ora exposed to greater load pollution in tha air and on tha ground. Under such circumtanoes, load poisoning is most likely te occur. 0007-SWP-036652 J 0007-SWP-000117969 -3- 'hot I am frying to highPght of this ooinf -- wlrraut =bcr'-g '-*,Lr or -3f oointj might caul* lead poisoning in fh distant future '"o wreern children af u>-carn oarenrj' i rhof fh* existing causes of lead poisoning of our children hooov .-nvt seen ise-tified. 7-eie be csrrecfed if adequate fundi are provided and if rhii effort it given priority ptfention ay au'barl* ei in thpie juriidictieni where tueh conditions are most prevalent. We recognize, of court*, `at lumi of money required to oceompliih thii task are vary groat; end, as afficialt of the Oeport-e't of Houiing end Oban Development have commented on several occasions, this is only on* af severe' problems of like magnitude in the housing field. Wo deem Federal financial assistance and technical guidance to local furisoietions to be vital in this matter; and, by public announcements and lottan to tha Secretaries of Health, Education end Welfare and Housing and Urban Development, this Assoc lotion has urged that maximum funds bo made available for these purposes. We strongly support the funding provisions of Section 3 af S. 3080 and concur that thase additional funds should be authorized. We will continue to urge the Secretaries of HEW and HUD ta include such funds In their budget requests end to utilize the funds so appropriated far the purposes intended. We consider it meet unfortunate, however, that the subfact of lead in modem oaints seena ta be getting more attention today from the Congress, the Federal agencies ond many public health officials than tha real problem. The record will thaw that, ever since hearings were conducted by tha House Banking and Currency Subcommittee on Housing in July 1970, the focus hat bean changed from tha detection and elimination of the eld lead*bosed paints to the question of what further reduction in tha amounts of lead used in modem paints should be made by the industry. t i j 1 0007-SWP-036653 t S A 5 0007-SWP-000117970 -4- LEAO IN MCOS3N PAINTS I turn now ro the motter of vital concern to the point Industry, portiej'crly *3 'a-; number of imoll manufacturer! in our industry. I refer again to Section 2 of 5. 3330 :ch ouid change the definition or "lead-based point" (a misnomer) from one sercenr ro "3.36 sor centum lead by weight (calculated as lead metal) in the total nonvolatile content of liauid paints or in the dried film of paint already applied. " Before proceeding, let me remind you that we no longer are talking about 'eod-bcied points, but wo reolly are talking about imoll quantities of lead in paints. The manufacture of "lead-based" paints, especially for interior surFoeet, was discontinued mere than thirty years ago. Lead pigments, such as lead chromates and lead molybdates, have been used to provide the papular bright colors -- reds, yellows, greens end oranges; and, of course, load compounds have been used, where appropriate, in corrosion-resistant coatings because they are especially valuable for such uses. The use of lead in corrosion-resistant coatings today is not being questioned because it it recognized that those are essential to preparty maintenance and no hazard to children exists from such uses. / I t i However, lead pigments for colon and most other uses already have boon largely dis continued in interior residential paints to ensure that these products would not exceed the ana percent lavol established soma years ago by o voluntary standard and recently incerparoted into f. L. 91-693. lit Is my understanding that the Implementing regulations -- maki- this one percent level mandatory at the federal level far the first time -- are being published this week by HEW, In accordance with Titla IV of f. L- 91-693.) t i 0007-SWP-036654 to 0007-SWP-000117971 The voluntary slondord, juit mentioned, USA Stondord Zi6. 1 *hien *ci ' > 555, under the ioontorihip of the Amoricon Academy of Pediatrics, to deal wirh *ka toxicity "otordi which may ba encountered through the ingestion of dried coofings an orriciei ar swtaces acmiibla to children. The itondard wai raviawad and approved by fha American Stondardi Association (ASA) Sectional Committee an Prevention or Control of Hazards to Children. The organization now it known os the American National Standards Institute. This standard served as o pattern far the several statutes, regulations and ordinances dealing with the subject, wnich were adopted by mere than twenty jurisdictions between 1955 ond 1970. However, a sampling by Now York City, under its Health Coda, in the Summer of 1971 indicated that not all manufacturers wero adhering pracisaly to either the voluntary standard or the stated previsions of that cade. Although we believe there has been substantial compliance with the voluntary iranderd and a related labeling program, sponsored by our Association, wa have cooperated to the fullest extent in proper discussions initiated by the Pood and Drug Administration, U. S. Department of Health, Education and Welfare, leaking to the establishment of regulations under the Federal Hazardous Substances Act. Such regulations would make mandatory the prescribed levels of lead in modern paints and provide far requisite procautionary labeling. Subsequently, on November 2, 1971, FDA published in the Fadaral Register a proposed regulation -- A PropesoI To Declare Certain Heavy Metal**Containing Faints and Other Surface-Coatings "Hazardous Substances" and To Require Special Labeling far Child Protection (21 CFR Pert 191). As proposed, this would establish a 0.5 percent standard far lead in paints, a fifty percent reduction from the ana percent voluntary standard , which wes incorporated in P.L. 91-595. * i --r------- t 0007--SWP--036655 I ! i 0007-SWP-000117972 -4 Our Industry considered this fo be o most importonr proposal and a progressive step by the Food and Drug Administration, an agency for which w* hav* the nighest regard and for which. In our opinion, lha record shows effective administration of its responsibilities under the Federal Hazardous Substances Act since its enactment in I960. Our Association announced publicly its support for this proposed regulation and urged membership support. This regulation is still awaiting final action by the Food and Drug Administration because of the pressures for even further reductions in the use of load in coatings for toys, children's furniture and interior surfaces of residential dwellings, which alio ara reflected by the amendmenr being considered today. This would operate to eliminate the one remaining intentional use of load in paints and coatings -- the load driers. I shall comment only briefly an this in my own statement be coma other industry witnesses, scheduled to testify before your Subcommittee, will discuss the state of the art, the setveh for sub stitutes for leod dtier^and other requirements whids must ba considered in paint reformulation today. They will comment also an the greet Impact, pa*tlcularly on small manufacturers, of pre cipitous action by legislatures or regulatory bodies which would deny the use of lead d'lers to them. Wo do not agree that this elimination is in any way necessary far the safety and health of children today, or yet unborn. It is our contention that neither human experience, records of the poison control canton, nor adequate reranehond animal-feeding studies have shown the need far such action. Houwvar, before turning to this mttlcal Issue of haw much lead can be safely used, I would Ithe to touch upon a common misconception often quoted by these not informed regarding the paint industry; namely, that all menufachwors can easily remove all lead new. 0007-SWP-036656 0007-SWP-000117973 -7` Perhaps, mm apparent credence wot given *a rnii '*ciiccy by recent jo-slings z-i ests conducted by the National Bureau of Standards on paint predwe`s in ?-e ra-<*`z'-ezt. work was conducted pursuant to the terms of Title III of P.L. ?UofS os o sreiininor/ stuOy paving the way for a broader national sampling program. The paint products were net selec*ed according to a statistically valid sampla of any kind -- nor were they supposed to be 'or this preliminary survey. The results of one part of this program showed that 74% of the paint pro ducts contained lea than 0.1% (+ 0.1%). While this may reflect to same degree the sincere desire of mast point manufacturers over the past decode to reduce lead content to the lowest possible level, it cannot be cited cs proof that oil paint manufacturers can eliminate all lead frontall product lines immediately. This is an unfair use of the NBS data, which was net intended to accurately test the present status of lead In paint products in the marketplace. It is typical of the questionable dota offered to justify the unreasonable standard desired by some. It is alia interesting to note that these analytical tests had a 100% margin of error at this lava I. fcoduets shown as 0.1% load could actually la 0.2% or 0. Analyses of this kind ere not easily conducted, have questionable repreducability, depending on sample preparation, and cannot be conducted routinely by the majority of paint companies. As we have shown the committee, through the letters from industry members forwarded to your offices, the problem of removing all but trace amounts of load from paint is a monumental ana indeed. A random sampling of ana or two market areas It certainly not a valid indication of the magnitude of the problem. 0007-SWP-036657 t 4 sBo * i i. * p t } 0007-SWP-000117974 -3- I would remind you that point* end coari'jJ era prodjc'i rot c;--> 'j, ss each manufacturer Farmulerei in ardor to produce what, in hii opinion, it tr o*tt ocn.se orscjf. Probably in 'e other industry or* brond noma* so important, and -- consumers re,, -esvily on - roputation of tho manufacturer whoso products rhay hove usod successfully in tho sesr. 3c:0'~.lations with substitutes art not simple, but quite complex because the interactions or s-e mg'td'ent with another must be determined* Adequate tests cannot be mode in the laboratory; only ocr-icl exposure experience can be completely reliable. WHAT IS A HAZARDOUS LEVEL OF LEAD IN PAINT? These who insist that all lead In paint should and can be eliminated (and the pro* penents oF the .06% level all ore In that category} bow this demand on the assumption that lead levels in excess of this amount would build up to a hasardous level over the years otter several layers of modern paints had been applied. This assumption includes consideration of the lead taken into the body from natural sources as well at lead pollution from automotive end all other industrial sources. I Feel constrained to comment briefly on this point for it Is being made such a vital issue in this end other legislative and regulatory proceedings today. The proponents of the .06% level of lead In paints base their conclusions principally on the work of Or. Robert A. Kehee at the Kettering laboratory, UnIvorsIty of Cincinnati. Tho validity of his work is not being challenged by us, but -- x* are challenging the assumptions mode end conclusions drown by such people as Dr. lorry King of the II. S. Public Health Service, Department of HtW, whose work (which is alsa the bash far the petition of the American Academy of Pediatrics), wo contend It based mere an methemetIeel extrapolations From Dr. tjeheo's work than an adequate research and appropriate onimel-feeding studies. . ________________________ 0007-SWP-036658 I 0007-SWP-000117975 -9- I would remind you *uat pai".'* crd caafi-.gs art oracjcu not eoi-vros>'es, -s **c* ocK monufoeturer formulates in order to oroduo* what, in nil ooinion, it fre oast oosslb'e sroc.eProbably in no ofu*r industry ora brand nomas so important, and -- consumers rely -eovily cn --a reputation of the manufacturer whose product* they have used successfully in the csst. lotions with substitute* are not simple, but quite complex because the interactions of one 'ngreo'err with another must be determined. Adequote test* cannot be made in tha laboratory; only actual exposure experience can be completely reliable. WHAT IS A HAZARDOUS LtVCL OF LEAP IN PAINT? Those who insist that all laad in paint should and can bo aliminatad (and tha pro ponents of tho .01% level all are In that category) base this demand on tha assumption that laad levels in excess of this amount would build up to a hasardoul level aver the years after several layers ef modern paints had bean applied. This assumption includes consideration of the laad taken into tha body from natural sources a* wall as load pollution from automotive and all other industrial sources. I fool constrained to comment briefly on this point for it is being mode such a vital issue in this and other legislative and regulatory preeeedinge today. Tha proponents of the .06% level of load In paints bow their conclusions principally on tha work of Or. Robert A. Kakoa at tha Kettering Laboratory, University of Cincinnati. Tha validity of his work is not being challenged by us, but -- wo ora challenging the assumptions made and eanchielani drawn by such people as Or, lorry King of the U, S, Asblic Health Service, Dopesfmoot of HCW, whose work (which is also the basis far tha position of tho American Academy of Ndiatries), wa eonsand is based more an mathematical axtrapolatlone from Or. t^ehae'i work than an adequate research end appropriate animal-feeding studios. 0007-SWP-036659 0007-SWP-000117976 -9- TMl is particularly important when ir is recognized twcr 3r. Sense's eone'.us.o-s were based on tSe use of lead aeetate, a very soluble leed compound, wr,ieh -as intros.eed inro rhe drinking water of the adulr human sub[ectt. The conclusions of Or. Zany <'ng so 3* take into consideration the fact that the load compounds used in paint ore 'or 'ess soluble *non lead acetate and, when ingested in the form of dried paint chips, should am absorbed by 'h human body at a much slower rote, if at all. A dried film of modern paint 7s a hard, fairly insoluble substance containing resins, pigments and other ingredients that are not easily dissolved in the human system. We do not know what amount, if any,of lead compounds -- encapsulated in point films -- is absorbed (made biologically available) into tho human systam. There is urgent need for anperimentol testing to make this determination, I believe the testimony of the witnesses who have preceded me confirm our very strong belief end contention that, at this timo, there is insufficient scientific data available showing the use of 0,5 percent (or even ana percent) lead in modern paints to be a hazard. To respond to reguests for further reduction in lead levels to ,06% would be condemning a product which has never been tested I In view of our vital responsibility in this regard, via in the paint and coatings industry would like to sea this issue resolved once and far all. To avoid claims of bias and ta insure that the proper research equipment and other resources are available, federal lyfunded, independent studios should be conducted ta mqha a responsible scientific finding as to what is a truly hazard ous content far lead in paints. We beI leva that P. L. 91*495 provides the authority to the Oapvtmants of Health, Education and Welfare and Housing and Urban Development ta make such studies. *We formal I y requested that this action be taken and offered our full support and co operation. * 0007-SWP-036660 0007-SWP-000117977 10- Until such definitive studies ora conducted on driad point r;|m con*oini-g --a types and amounts of load compounds actually used by the point industry todoy, t^a rosier ion of the 'aod cent*it in points to on exceedingly low level, such os the . 068i s*=-cc'd, would bo o precipitous ond totally unwarranted action. I repeat; We are confident ;ha* tuc- itua'ei and the related research will prove that the 1% level of lead in modern points is rot 0 hatard to children. We would welcome the support of your Subcommittee in recommending such studies and amending Title III of F. 1. 91*499 to provide far this specific action. Even if the industry were given the time and could provide the funds for these studies, the credibility of the results still could be questioned by thaw who blindly demand the elimina tion of all lead from paints. We believe this matter to be sufficiently in the public interest to justify the expenditure of federal funds. Again I assure you that the industry has offered what ever assistance and support might be considered appropriate -- and, I am confident that the industry would respond rapidly to conform with the findings of such studies, whatever they might be. fending the conduct of such studies, we ask that you not legislate to change the definition of "lead-based paints" as new proposed. We believe this is o matter that can be determined more properly and effectively by the government agencies who have such responsibl titles. loth Title IV of P.L. 91-499 end tha Federal Haeardous Substances Act delegate authority to the Socrotary of HEW to doslgnato the proper moans for protecting the consumer from the hazard of dangerous materials suds as lead. Right at this moment, the Feed and Drug Admini stration, DHEW, Is collecting date relating to this subject, with a view toward pamulgeting os soon as possible the regulations mentioned earlier. I strongly suggest that DHEW be permitted la act on this problem, In accordance with their statutory responsibilities, rather than being pre- j 1 0007-SWP-036661 0007-SWP-000117978 -n- empted by Congress. The maximum allawool* lead levels then could be irccllinca s/ implementing regulations without requiring rhof P. L. 91-695 again ba anenaed. in* need Fgr eoraful determination oF data upon which lews end 'eguie':an| or* baud hoi bacoma all Fee apparent in recent years. One need only meniion rhe phespneres and hexechlerephena fiascos and, more racenFly, She saccharin problem. Lead in eainr can easily become, and shows oil signs of doing so, an issue solved by emotion and half-done research rasher then Factual data. There is another important side to this matter that should ba considered, but unFortunotely it is often overlooked. Substantial harm would be done, not only to the paint industry, but to the overall public interest as well, by-unnecessarily limiting the use of lead levels in paints. As previously stated, small amounts of load are used In many interior and exterior coatings For drying purposes. Lead driers promote Firm, hard paint films. Also additives, which prevent Ion of drying of oil-type coatings during long storage, often contain same lead. These have become valuable tools for the coatings industry and the edatings chemist, and they have bean used effectively in quantities of less than 1% of the non-volatile content of the coating far many yoars. Now technological developments permit our Industry to consider a reduced standard (0.5%) and still maintain these uses. This, and the fact that it will provide an extra margin of safety, is the reason we supported the reduced standard (From 1% to 0.5%) proposed by FDA, even though adequate showing has yet to be made that a 1 percent standard is hoaerdous. t 3 1 0007"SWP--036662 0007-SWP-000117979 -12- The .06% standard proposed would preclude the uu af tkte treil e-a,,fs of lead compound*> In fiel, this exceedingly low iaval would forca iNnuloOurirt fa engoge in expensive and burdensome "pharmaceutical-type" analysis of oil their row rsfarlolt ra moka certain that the amount of lad allowad 1* not exceeded. As a matter of foc, the prablam of contaminant* during manufacture i moit lignificant and could include tubitantiol omounts of load from tho atmosphere, from the citjr water supply, and the air pollution raiulting from proximity to highways or urban eroas. In addition, it would bo difficult to got agreemant, among trained analyiti, e* to proeiioly how to determine if well minitcule amount* of load ore protont. (e.g. tho * . I in the NBS analysis.} What all this could eotlly add up to is hmdor-to-moko product*, coiling much mart to manufacture and, consequently, more to buy in tho marketplace. Step* leading to thii, whan thay hove not boon shown to be necessary for tho health end safety of children, definitely would not bo in tho public Interest end would penalise unnecessarily an Industry that has done so much to make our environment more attractive Incidentally, I should mention hero that the complato elimination of load drlori will seriously affect the through-dry of products, and m hove found that this can causa shrinking of tho film and evon a footer tendency to pool. Another footer, and perhaps tho most important ono, is that tho enforcement of a .06% standwd would bo difficult. If not impoeilblo. This Is portly duo to the difficulties of analysis, os wo have pointed out. A lot of time, money and effort would bo spent by Federal, state and local officials In trying to enforce an umeaMnable load limit that hasf in no instance, . boon shown to bo nseomary far safety. 0007--SWP--036663 A 5 III. Recommended limit le 1 recosaended thet the quantity of lid la surface coverings with single mJ multiple layers of pstnt, should r.ot exceed C 33 rg/c--. Where Chit Halt it excecdtd the surface covering should be covered, or ochervieo erected eo ensure ehsc the contained lead H no longer available eo children. IV. Rationale tor Recommended Limit KehoO establlehed that 0.6mg of lead par day waa the maxima that could be ingested by an adult with no Increase la blood lead level; at this level Input exceeded output with a slight accumulation f body lead burden. A corresponding value for the child was estimated to be 0.3m lead per day frnm alt sources by an ad hoc committee nf pediatricians end biological scientists qualified In the area of pre vention of lead peleentng In children.* A range of values for estlewted average intafce of lead per day in the dlac la O.lOOira to O.HOnn. Thus, the Ingestion of wore Chan 0.2 nggb/day from supplementary sources, such as paint chips, would result In an lneake in exeess of the Uniting value receewanded far children. The weight of one and aultlple layers of dried interior house paint chips have been Measured on prepared samples (Table 2.). * In the nanuserlpt of the report, the naxieein dally Halt fer Intake of lead frea all aowreee.la referred to at dally penlaelble Intake (DPI). 0007--SWP-036664 0007-SWP-000117981 -13- No iimninant hazard hoi boon claimad by tho proponent* of *ho .06% lava! in points, certainly nona hot boon shown. Tharaforo, thaio attack* an tho uto of tmall omoun** of lead in madam point! do not do ona thing to oliavlata tho tarioui problam of load pollen ing of children today. In fact, it actually hinder* progrou by clouding tho itiuo and taking tho focus off of tho haort of tho matter. Why do this to tho point industry and to tho comtiming public? Co I laterally, you hove another tarioui coraidorotion, namely -- the possible effects of untasted substitute materials. White wo urgo that your Subcommittee not take prematura action to reduce the permissible lead level in today's paints, wo do urge with equal vigor that tho responsible Fedorol agencies continue to study tho problem with utmost dispatch in order that they may develop and promulgate realistic end reasonable regulations -- with due consideration to all the facts and bated on proper and complete research and studies. In this regard and because of tie magnitude of the laris, wo ore hopeful that HEW and HUD will bo provided the necessary funds and manpower to accomplish this work. Wo support appropriations and staffing necessary to permit those Departments to carry out thair heavy schedule of statutory responsibilities. In Conclusion: It is our sincere belief, based an long and daap involvement in the problem, that onco those eld coatings ere removed or adequately seeled off, and so long at modem paints containing no more than 0.3% (or oven I percent) lead are applied to surfaces ac cessible to children, the lead paint pahoning problem will cease to ax ist. Records in some cities (such as Chicago) today support this claim far, onee effective screening programs have * bean established and children are denied access ta the old paints, tho incidence of high t 0007-SWP-036665 0007-SWP-000117982 14- blood laod levels in children hove shown a doelining trend. Th# Federal financial assistance, for which additional authorisations ore requested in S. 3060, will pormlt th# dodieatod public hoolth official! in tho local jurisdictions to carry out this work more effectively. We alio believe that continued funding of research projects under P. L. 91-695 is vital. This will permit not only the acceleration of current programs to develop moons for test ing interior surfaces of tub-liondard housing for the presence of lead end determining optimum measures for rehabilitating these dilapidated structures, but would provide the necessary answer to the major question as to whet lead levels In point film actually constitute a hotard or would build up to hasardous levels for future generations of children. Until such studies era conducted, ere do net believe that precipitous action should be token to change the definition of "lead-bosod paints* to the unrealistic level of .06%. Such action would eliminate the use of all lead in howto paints, resulting in product degradation, and would impose unnecessarily on the Industry the economic and liability burden of testing to ensure that the trace amounts of load Sn all raw materials used or contaminants from ether sources do a not exceed the arbitrary limit established. It should be noted that. If th# definition of * Iaid-based points* were to be changed to the .06% as proposed, she existing language of Title II of P.l. 91-695 would require the elimin ation of point from many additional interior surfaces end practically all *porches and exterior surfaces to which children may be commonly exposed of all residential housing" without regard to ago or condition. Obviously, this would bo on Impassible task for enforcement officials, end the costs of such an action wouldnatonly bo wastebl but completely unjustified. It also does net. In any way, reflect the hosard that actually exists in the country. * rhe i 0007-SWP-036666 0007-SWP-000117983 -15' Finally, wo regret that much-needed attention of the responsible officials and the limilad rasourcai of our government oganciat ora baing divartad from the prasanr and idanrifiod problem of old "leod-bosed* points to the question of lood in modarn points ond cootings where no imm inant hozord exists, nona baa baan cloimad, ond tha futura Hozord it only speculative and eonjocturol until odaquatoly researched. Wo tineoroly hopa that tha lottar inua eon be pul bock in perspective end that decisions can be made besed on facts rother than politics, emotion and unfounded claims. If you Have any questions. Gentlemen, I shell attempt to answer them new, or if you prefer, you may hold questions until the other Industry witnesses have testified. i ---------- 0007-SWP-036667 I V i 0007-SWP-000117984