Document oD14BQz51NmV3dzd3Ozk0VrN7
In t er -Of f ic e Le t t er
"* Cl eland J. J. Linntti
ere* t o umrtii or
IHH (IlD .
Cleveland____________ --* Executive
d o t i December 10, 1970
uMti Lead Paint Poisoning Prevention Act S 3216
WCT.TCO *
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As you will .aee (n the attached, ve have reaponded to the request froa Mr. Boland by writing individually to oaeh of the neabers of the Senate CoMittee on labor and fablie Welfare.
Also encloaed for your background knowledge ia a copy of intonation received froa Mr. Boland, including the proponed bills.S 3216 and UB 19172. The present aeaaion of Congreaa ia expected to paan legislation requiring a naxiaua of 1% Pb on interior paints and exterior paints on porches, railings, etc.
Ve should be prepared to renove lead pignento iron all our ajor trade sales and painter products proaptly if the need arises.
Fortunately, our Kr-1--Coat Alkyd ean be used for porch railings, . etc.
The proposed Federal Specification Paint TT-P-00102C presently patterned soaevhat like our K*s>-1--Coat Alkyd is another nanifestation of the drive to get the lead out of exterior paints.
AWolton:AN To - HES KLC(2) 00S JJL DfB* BE1PADC
AS 12-6-70 letter to Senate Conadttee on Labor and Public Welfare only.
NU937
0007-SWP-000005881
"Anv paint ..... intended,--rpackaged in a fora suitable includes
1) Industrial Maintenance primers containing lead-based corrosion-inhibitiye pigments agSeh are used to protect tt and/or maintain structural steel, fire escapes, filter presses, pumps, equipment,, pipes, tanks, machinery, motors, metal fences, metal roof decks, ianks and vessels including potable water tanks, floor grating, transmission towers, bridgeo and other iron and steel. These primers are used to protect the surfaces stated in and around chemical plants, packing houses, paper mills, textile mills, pharaaceutical plants, filtration plants, laundries, locker rooms, distilleries, petroleum refineries, steel mills, etc. These are typically packaged in one and five gallon containers for maintenance use.
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N11937.01
0007-SWP-000005882
considering thif informstIf.r, the Conaiissi oricr find* that lend can be eliminated Iron paints and ether surface-coating materials more rapidly
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than the iraplcinintu tion dares specified in the following order, an
appropriate amendment "will- be made.
Therefore, the Coneniss loner finds that, notwithstanding such cautionary
labeling as in or nay?be required1' under the Federal Hazardous Substances Act,
the degree or nature of the hazard involved in- the presence or use of lead in
paints and other surface-coating materials in households ia such that the
objective of the, protection of the public health and aafaty can be
adequately served only by keeping such substances, when so intended or
packaged, out of the channels of interstate commerce. Under section
2(9)0) of the act, this will have the additional effect of banning such
product# from use on any toy tr other article intended for use by children,
Sincc^lead_may he a necessary component of products^intcndcclfor
particular uses, as suggested by several comments, the Commissioner is
prepared to consider petition* proposing amendment of the regulation.
ill:
Pursuant to 21 C.FR 191.201, petitions shoving rentenable grounds will
be pmbHr.hcd in llu- FOIL)RAT. REGISTER. Consideration will also be
givien in late 1-97-3 to^peti tiuns for-
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flit
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0007-SWP-000005883
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coneidcrfng
information, the Coiguisgloner flntU that lead can b
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cllniuated trim palms on-J ether curf|Ce^coating material* wore rapidly
than the itiplcnr.tMiUirion da rev specifi eO in the following order, an
appropriate amendment will he made.
*
Therefore, the Corliss,ioner finds that, notwithstanding such cautionary
labeling as is or nay'be required under the Federal Hazardous Substances Act,
the degree or nature of the hazard Involved in the presence or use of lead in
paints and other surface-coating materials in households is such that the
objective of the protection of the public health and safety can be
adequately served only by keeping such substances, when ao Intended or
packaged, out of the channels of interstate commerce. Under section
2(q)(l) of the act, this will have the additional effect of banning such
products from use on any toy cr other article intended for use by children.
Since lend way he a necessary component of products Intended tor
particular uses, as suggested by Severn 1 conwcnts, the Conwissioner is
^pr e pair. ed : |:n consider petition* proposin--g- amendment -o--f---t-h--e-- -regulatio-n. Pursuant to 21 CKR 191.201, petitions showing reasonable grounds will
be published in il- FHDKRAl. MXISTKli/ Consideration wfTl Also be
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given' i-n latfc'1973 to- petititns for--
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0007-swp-000005884