Document mpD1e77bjDNL6XGrym9L025wO

METALS DIVISION P.O. BOX 579 4625 ROYAL AVE., NIAGARA FALLS, NEW YORK 1430 TO (Namoj Mr. Frank Twitty Olvislon UCC - Metals Location Niagara Falls, NY Dato Origtnatino Dept, March 23, 1978 "Calidria" Asbestos Copy to Messrs. C. R. Allenbach R. E. Byrne, Jr. L. A. Crisorio J. L. Myers-^* E. W. Shortridge W. C. Thurber B. L. Ingalls R. G. Woolery File Answering tetter date Subject TOSCA Registration This confirms our recent discussion of the registration of our asbestos products under TOSCA. Since failure to register a product can cause serious delays and may result in very large costs for animal testing while the penalties for registering a product that should not be included are minimal. It seems most appropriate to resolve all reasonable doubts in fayor of registration. A copy of paragraph 710.4 of the regulation showing the scope of the inventory is attached for reference. It seems quite clear that all of our regular asbestos products would fall under 710.4(b) and are automatically included in the inventory, i.e, we do not have to list them. Our seyeral combined products, however, are not as clearly defined and present a series of judgment decisions of increasing complexity as follows; 1. T-135 is a coflocculated mixture of our asbestos and anatase or rutile titanium dioxide. The TiO? is either an exempt, naturally-occurring substance which we purchase in the United States or will be reported by its manufacturers. While there is clearly some sintering of the TiOp to the asbestos fibers during drying, this product is really a mixture of two substances and should not be reported by us. 2. The RG-244 product is the result of a chemical reaction when a purchased material, sodium silicate (reported by its manufacturer), interacts with asbestos as a result of the action of acetic acid (also purchased) as a pH neutralizer. This appears to fall under 710.4(c)(7) and the product should not be reported. 3. The RG-600 product results from a chemical reaction between asbestos and dimethylol-t-butyl phenol (DMBP). It is postulated that an acid-base reaction between the Mg(0H)o surface of the asbestos and the phenol group on the DMBP attaches it to the surface via a Mg-O-C bond. It is suggested that we make certain that the DMBP is included in the Bound Brook report and the RG-600 should be reported as a product by us. A08 74b UCC 014196