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iNffER-OmCE LETTER Cleveland H. E. Spitzer ANSWERING tETTBl OF FROM Cleveland Laboratories OFFICE Development, PV&L OFFICE OATS January 14, 1971 subj ec t Trade Sales - Professional Coatings DICTATED BY Exterior Paints Lead Containing Attached is a discussion < the work and type of products to be worked on that will be required to remove lead from our exterior Trade Sales and Professional Coatings paints * This work is intended to reduce the lead content to leas than 1 per eut, based on the dry fila^ which is in compliance with the present legislation before Congress. Our initial estimate indicates this will require approximately 2,000 manhours of actual reformulating work. This assumes that no unusual or unexpected problems occur. There are three major areas included in this work. 1} Extensive testing of present formulas against the new Specification TT-P-00I02C. With the new HOD Programs , this could become a substantial item. 2) Removing lead type pigments from paint, particularly undarooaters. 3) Removing or reducing litharge and lead drier content in the exterior colors. This may require new vehicle concepts. We have already written to J. C. Weaver request!ig he consider investigating new vehicle types. The bills before the Hou3<a of Representatives and Senate do not specify a deadline. However, fchey do call for prompt elimination; Also, it appeara that both these laws will be funded through 1972 which suggests* that January 1973 may be the deadline. Since we would not expect to have this work completed for 1971 production, we would plan to be prepared for .1972 production. This work can ba done in Cleveland but we may prefer to have some little part done at another location. lriie first phase of this Project would cover a one-year period We will assign Rv S. T&ub to direct this work. On this basis, wa would request an allocation of $30,000 to cover this work. sL LJ Collins, Director Central Laboratories, FV&l RLC/ck V. Enc. > cc: ABH SAM GGS RGB JJL DFH RAT SST' JVP LLB N41526 0007-SWP-223968 r Confidential Cleveland Laboratories Development, PV&L Cleveland Tech Service Janaary 11, 1971 R. L, Collins Lead Containing Exterior Paint Products File #47 Per our recent discussion regarding the removal of lead from our exterior paint products, the following should be considered in attempting to pre dict man hours needed and possible difficulties that may be encountered in reduction of the lead to IX or less based on the dried film. ,V I. Proposed New Specification TT-P-00102C which is for a high HO2 alkyd paint and is Intended to displace white lead, leaded sine Iand sine oxide paints. Although we believe our Kem-l-Coat /^ k't y' Alkyd, A3 tf 16 will be a good candidate, conslderabel testing \ ' will have to be done to confirm this. Since the mildew resistance will probably be the toughest to meet economically, much ^ |r*-V' testing of various priced fungicides will have to be done, 'f0 ) " $ II. Formulas containing leaded sine: The following Cleveland controlled formulas contain leaded zinc, 68 22 00 which will have to be removed and replaced with straight zinc oxide. This will result in a few cents per gallon increase in cost but should not be technically difficult to accomplish. Limited testing will be required. However, if it it is desired to go completely lead free including elimination of lead driers for some advantage in fume resistance, then more work is required. Name Rex SWP Gloss White SWP Trim & Tinting White P/C Hi-Level Gloss Bouse Paint P/C Hi-Level White, Mildew Resisting Bxeello Oil Base Hout Paint SWP Chaises Gray SWP Beige SWP Raffia SWP Sage SWP Sandpiper SWP Peace Yellow A2 W 4 A2 W 8 B46 W 4 B46 W 14 B4 W 56 A2 A 20 A2 H 27 A2 H 39 A2 G 93 A2 A 47 A2 Y 50 III. Formulas containing lead carbonate: There are three undercoeters Involved using lead carbonate 68 06 22. Quantities vary from 1/2 to 1 pound per gallon. Name Rex SWF Undercoater A-100 Wood Undercoater Exeello House Faint Undercoater White A2 W 2 A6 W 32 B4 W 71 N41526.01 0007-SWP-223969 R. L. Collins 2- - January 11, 1971 The A6 W 32 is expected to b replaced by P.C. Hi-Level Undercoater B46 V 31 which is an alkyd with less than IX lead* The A2 W 2 Is difficult to rapines because of its low cost. Vs will haws to re view exposures to know if we can remove all lead carbonate from A2 W 2. BA V 71 is not as critical in its lower priced Market. IV. Formulas with special lead containing pigments: Hama Heme Lead Containing Pignent SWF Ardmore Green Leatharstocking Green King's Yellow Latex Vood Primer A2 G 12 A2 G 51 A2 Y 56 A17 V 2 Chrome Yellow 80 36 23 Chrome Yellow 80 08 21 Ghnoma Yellow 80 23 40 Lead Phoaphosilleate 68 03 21 Some of the above formulas also contain large amounts of lead driers as litharge and lead naphthenate. Complete reformulation will be necessary. Exposures will be neceseaty. V. Formulae with large amounts of lead driers i (From A to 10 pounds/100 gallons of litharge end up to 29 pounds lead naphthenate) Name SWP Ardmore Green SWP Charcoal Gray SWP Wastchaster Gray SWP Tricorn Black SWP Doeskin SWP Winthrop Red SWP Verdoe Green SWP Revere Green SWP Woodland Olive SWP Fairfax Brown SWP Solfast Red SWP Harvest Gold SWP Heritage Colors Leatherstock Green Colony Green Provincial Sage Cape Batteras Blue Olde Tavern Brown Plantation Brown Bucks County Gold King's Yellow Commonwealth Willow Green Colonial Barn Red Ranch Red Rust Control Primer #49 Beauty Lent Redwood Rogers House Paint Charcoal Rogers House Paint Shutter Green Rogers House Paint Chocolate Brown Rogers House Paint Redwood Rex A2 6 12 A2 A 38 A2 A 42 A2 B 18 A2 H 68 A2 & 44 A2 G 38 A2 G 94 A2 G 105 A2 N 70 A2 R 32 A2 T 52 A2 G 51 A2 G 54 A2 G 55 A2 L 52 A2 N 53 A2 N 56 A2 T 55 A2 T 56 All G 3 All R 15 All R 47 A57 R 17 A14 R 59 B4 A 3 BA G 2 B4 N 1 B4 R 1 Confidential 0007-SWP-223970 ^ i R. L. Collins -3- January 11, 1971 Name Fashion Right House Paint Deep Tinting White Antique Gold Tinting Base Mimosa Tinting Base A2 W 21 A2 7 18 A2 7 19 Formulas in Group 7 may be very difficult to reformulate with less lead. Special vehicles may be requited. Many of the formulas listed have parallels which have not been shown. The time involved in reformulating all of the above formulas Bhould be at least a minimum of 2000 hours end will be dependent on whatever success is achieved in different vehicle systems. RSTeub/cb L. L. Back, Assistant Director Cleveland Technical Service Confidential 0007-SWP-223971