Document bBBN8d4yKm1RnN7VK04pbDrk

, O R A T E_____ D H W.. WASHINOTON. D. C. *OOOB MONT 20*-A62*6272 REGIONAL VICE PRESIDENTS NEW (NOLAND- C. TWANCl* LOUTOIL. ODOTON August 3, 1971 (AtTC*N-WILLIAM MAC KNIOHT. RHILAOtLfMIA (AOT CENTRAL - WOO INT W. OOOY. CLtVKLAND W|OT CINTRAL - H. C. MILLER. OT. LOUIS . lift*** *'f* AAl**TON OUTHERN - HUOH M. MAYBERRY. BRUNSWICK. OA. OUTHWMTtAN - HAROLD WCfMBCRB, DCNVK" ,U|fcN III IOt T WASHINGTON WKOTKRN - D. W. KENNEDY. LOO ANQtLIt * * Memorandum. * TO: ' .Selected Furniture Finishes ^ and Chemical Coatings Manufacturers FROM: Robert A. Roland, Executive Vice President SUBJECT: Lead Content in Children's Toys and Furniture Attached is a letter from Mr. Jensen of the Food and Drug Administration which I have received, pursuant to a meeting held with him some weeks ago. Mr. Jensen and his associates have main tained a constructive relationship with the Association in the pursuit of their responsibilities which, incidentally, may be greatly enhanced under recent proposals supported by the White House through Secretary Elliott Richardson of HEW, recommending on enlargement and consoli dation of product safety affairs within FDA. Mr. Jensen has requested industry to relate its best possible effort for reducing lead below the 1% level, currently recognized and accepted under the ANSI Z66.1 Standard. This approach has been taken as opposed to unilaterally promulgating a lower percentage of lead and requesting industry comment. Therefore, it is imperative that we give this matter our serious and immediate attention. The Bureau of FVoduct Safety is being subjected to considerable pressure from various quarters both inside and outside of government to reduce lead in products specifically designed for use by children. At this time they would prefer a voluntary industry approach as opposed to a government directive. ! ACTION REQUIRED: I would like your company to send me a letter responding to this Inquiry, detailing.not only your ability or inability to manufacture these coatings below the 1% lead level, but also specifying the difficulties which this might produce and the products which might be most affected. While economic considerations are not highly persuasive, they should be noted. Of greatest concern would be the impact on manufacturing process and any , possible effect on the efficacy of the coatings produced. It is our understanding thatleodper se,, either as pigments or in driers, etc. may not be essential in many of these coatings> but that the . . 1% level covers extraneous trace elements which find their way Into the finished product from the raw materials used. | would like your response in my hands by August 20, 1971, 1 ,v I V.: > ' 1 ; ;' GLD012448 V;i < ' ' ;r:.../.to> t V 1971 PROGRESS THROUOH COOPERATION ' . i.\-. . .1 '/ To: Selected Furniture Finishes and Chemicol Coatings Manufacturers Page 2. CAUTION There is substantial research being done at this time by government scientists, attempting to document the fact that even 1% lead poses a hazard to children. The Association has been successful in defending the Z66.1 Standard and this definition has been incorporated into the Lead Paint Poisoning Prevention Act of 1970. While wd have been assured that the concern of FDA at this time is limited to children's toys, etc. and there is no intention of extending any .reduction, voluntary or otherwise, to interior or exterior paints generally, we must be mindful of and concerned with the precedent that could be established by a substantial reduction in the area of this present inquiry. With kindest regards. I R AR/kah enclosure 0 t4 GLO 012449 4 > i V.l 'ii i. y t. v -t.