Document eveGnkLXyJzv4x9K3zRpNZY9m

IB INOUSTflies Hwunrno. mum armer wrru/pmawMM. k n ms y l w mu itm/Mt* sriu.i?t Oecenber 27, 1*71 , btrinf Clark Department of Mealth, Education and Welfare IBM MOO ttahera Lana hockville, Md. 20032 rc is awhre of Repreaeatativa hyaa'a petition u tha m which propoaea that laad in paint produeta ba reduced to traee* amount*; that painta oaatalnlng praatar than "trace* anounta of laad ha banned aa haaardoua oubataneea. It la further ondaratood that tha intant of thia patltion la to aupplant tha poaitlon of tha Motional Paint and Coating* hsaoeiation and tha ourrant PM opinion which ia, that laad ahould ha contcollad to 0*3 pareaat in tha dried paint filn. No atrougly object to Naproaantatlve Kyan'a poaition fren both a manufacturing and an anairnnnantal baalth etaadpoint, especially ia view of the foot that hia petition ia directed to all ooatinya rathar than to coatings applied to aorfaeaa nocaaaibla to children. with raapaet to aaaufacturiaa, it la inportant to note that coafreaaaaa Ryan's propoaal would roault ia a ropalatlon with which we oowld not ooaply hecaeae tha tarn `trace * baa not bean defined in a quantitative aaaaer. haawing tha tea* "trace* ware defined at a level each aa t.d* percent `lead bp weight ia the dried point filn aa aupyaated by Dr. Chiahola of the American headany of Pediatrics, it ia atill anreaaoaabla to apart that wo could eonalatently pradoea uaaful oeonereial deaoratlvu and protective ooatinga for the following reaaooai (1) At protect, the atate of ooatinga technology doea not perait reformulation of all ooatinga to essentially lead-free pcoductai (2) ear auppliera will net geareatee the lead content of pignanta, drier*, alia, coaiaa, and inert raw material!; and (3) providing that aaaentially lead-free coatinge could ho formulated, thia would aacaaaitate the aaalysia of each coapleted hatch of product ia tha aaaaer and accuracy of a pharmaceutical product--a patently lapoaaibla proeadura. 0007-SWP-03657B N21853 2- M far u anvironaental health la ooneernad, fK'i nodical and enviroaasntal personnel have reviewed tlia evidence upon which Congresaaan Ryan and ofehora Hava haaad thaiz reeaanendations. Tha haale latent of protecting children, taw generations raaoved, by considering anltiple layers of load containing paint and ralating thia to tha buaan aatabolie capacity to abaorb and alininata laad, la wall-founded Iowawar. tha aosuaptien open which tha rationale la bnaad uy wall be in error and oartaialy cannot ha oupported by any type or analytical experlanes. Thia aaaunption, which la baaed on tha work of Or. Robert Rehoe of the xattarinc laboratory, University of Cincinnati, bold# that eha variooe laad bo mg w Ii oontainod in the dried paint file are abaorbod by tha bawan body eaaotly an a water aolotion of load acetate takan with weals would be abaorbod. thia type of extrapolation la not valid and la goita unacceptable in the scientific coawunity, oepoelally in natters of hunan toxicology and the public health. it is also inportant to know that at thia tine there la no epideniolopical evidence to indicate that load at a lavel as high as one percent by weifht ia the dry paint fila has resulted in lead poisoning la ohlldran. The well-doeuwanted eases involve inaastion of paint produced prior to World Mar SZ when eha asjor plgaonts used la foraulating paint wnra laad coapounda such as idiite lead and lithopono. Those paint products hnd load eontant in tha driad fila as high at IS paroant. Thaaa plpwanta ara no longer in nan and hnwn baan raplacad by titaniun dioxide. Since there ie no ovldeaoe that paint prodoeta with laad content as high as one percent ia tha dried fila are hasardous to huwsna, there is no legni bneie for declaring that paint containing nore then traces of lead be banned as bessrdeus substances. Me therefore reepeotfully request that through the offieo of the national Paint and Coatings association, 1300 Rhode Island Avenue, n.u., Washington, D. c. SMOS, rosponcihlo experts be contacted for two purposed fleet, to oenweat on cnagresaaan Ryan's basic sasunptient aad ascend, to oeadnet tbo type of study that will provide the proper scientific evidence upon which to finalise on e lead value ia the dried paint fila at a level which will not bo e source of aoocora to future generations. Sincerely, Elaer c. Larsen .R. A. Reland - RPCA 0 Ring NPCA R. A. Arson - RPCA 0007-SWP-036579 0007-SWP-000117904