Document gdBnq4KZKQ6NJKGD0jgxzwV3

FILE NAME: Georgia Pacific (GP) DATE: 1977 July 6 DOC#: GP105 DOCUMENT DESCRIPTION: Letter to CPSC RE Asbestos - Spackling Compound & Proposed Ban Georgia-Pacific Corporation F90o0rllsa.uvdy,.OnrjeibgoAnm$7m20e4 Telephone (20%) 222-2261 PLAINTIFFS EXHIBIT GP-265 July 6, 1977 Mr. S. John Byington Chairman Consumer Product Safety Commission 1750 MX" Stroot, H. W. Washington, D.C, 20036 Subject: Asbestos - Snacklinn Compound Bear Chairman Byingtcu,j In the staff report presented to the Co: June.30, two issues were discussed on vl The issues wore: 1. A definition of consumer packaging as differentiated from an industrial size package, and 2. The effective date of the ben. First, I would like to point out that, on the date of your announced ban on speckling compound containing asbestos, we ceased using asbestos in our product and switched to a substitute. We have also worked closely with your contractor developing the environ ment and economic report on asbestos. In the course of our discussion with your contractor, ve focused on the issues mentioned above and would like to directly express our recommendations to you. V e support a total ban on spackllng compound containing acbeotos without regard to the packaging size. We package our speckling compound in both one-gallon and five-gallon containers. Although the smaller size is directed toward the "do-it-yourself" market, we bave no way of policing the salo of our five-gallon containers and keeping'those out of this market, A ban which differentiated the size of packaging would be difficult to enforce; and for that reason, we do not recommend you make the baa effective to different sizes of containers. Pago 2 Kr. S. John Byington Ju ly 6, 1977 Because w e no longer manufacture a opackling compound containing asbestos, w o support the 180-day effective date of the ben. Our pre-mix compound results in s minismm exporure which, based on your assessment analysis, presents an insignificant health hazard. Your risk assessment analysis wan based on a four-day, eight-hour exposure vliich is not typical of the nonprofessional use patterns In using gypsum board and applying joint compound. Yha one-tisio user is at the lowest end of the exposure curve. A ban of 180 days will provide sufficient time for any existing inventories to be depleted and replaced with asbestos-free speckling compound. W e will continue to work with your contractor, end if we con provide any direct information, please do not hesitate to contact me. Yours very truly. G. Wilson Vico President CEJ/ew be: Messrs. 0. E. Burch C. T. Hewlett, Jr. - Hash., DC - ExecJ Office C. W. Lehnert - Tigard Lab__________ / T. F. Mitchell - Wash., DC - Exec. Office T. E. Withycombe