Document oDd7p4ozye8n11Qd5bbKXyMVw

KCn n CTk * b a *v n M-a SC* Cw iCa SO 0bMA*lto| Th e Sh e r mn Wil u ams Ca I>|4> | ( 'VkA *C CHICAGO ILLINOIS f9C2t January 21, 1972 Aldarmen Thomas F. Fitzpatrick Chairman, Buildings and Zoning Committs* Chloago City Council City Hall Chicago, Illinois 60602 Dear Aldoman Fitzpatrick: It Is requested that representatives of The Shorwin-Villiams Co. and its subsidiary, Tha Martin-Sonour Company, ba grants! tha opportunity to maka a statamant regarding tha proposod ordinances dealing with lead-based paints which art to ba tha subject of a public bearing before your committee on January 27, 1972. The necessity for some legislation on the use of load compounds is recognised, and we support tha ordlnanoe celling for a reduction in lead content of palnta intended for Interior use or for uee on exterior surfaces accessible to children to 0,59$ on * weight basis, tfe do not feel, however, that the proposed further reduction to 0.035 lead by weight effective January 1, 1973, 1* either necessary or justified. ' ` Vo have not uaed load pigments or other lead compound# in Interior palate or in palnta intended for use on furniture or toys which might be chewed by children for many years. We do, however,, have certain lines of exterior palate which cannot bo formulated, ` ^ased on curront technology, without the uto of load drlars. For the moat part, these are tae oil typo palate which still represent a tube tantlal portion of the exterior paint market. These ean be euoeesefully formulated within tho 0.55 limit, but cannot bo pro duced at the 0.035 standard. Should tha latter figure beeone the standard, paints of this quality would bo unavailable to the Chicago market. The necessity for a limit of 0.035 lead by weight le not Indicated by any studies conducted to date. Charles C. Edvards, Commissioner of Food and Drugs, atates In the Uovember 2, 1971, Federal Register, Vol. 36, So. 211, page 20966, that he la unaware of any reports of eorlous Injury or death resulting from the ingeation of paints containing 1.0 load. Tha solution to tho problem 0007--SWP--036448 ~ N21809 Alderman Thomas P. Fitzpatrick 2 1/21/72 of lead polaonlnR, according to 3r. Stephen H. Kail of Southern Illinois CnlveraLfcy in an article in Znvlronrxntal Sctonco and Technology. Bseeaber, 1971, does not iio in nnpiyln.- load-free paint over old loaded paint, but in rar.oviDs leaded paint from substandard houaic. Objections are also ralsod to tho ordinance doalin? with labelin?. As currently written, this ordinance would require, prior to hareh 1, 1972, rolcbolln,* of almost ovary paint eontalnor on doalors' sholvos In Chicoro. At tho prosont tlao. there ere proposed regulations for epecial ltbollr.,- requirements for paints containing noro than 0$`X lead at tho Fedoral level. Thore are also parallel requirements for certain othor heavy motels at & level of 0.05-5 by weight. Thoso proposals are Included In tho issue of the Federal Pollster roferred to above. It Is our recoiT.:endation thnt action on tho Chicago labeling ordinance be held up tending final action by the Food and Drui; Coaslssion and that the Chlca-o ordinance adopt the wording re quired by the Federal regulation. It Is also su-costed thnt a nore reasonable nerlod of time be allowed, following the adontlon of tho ordinance In Its final fora, to aoeonpllah whatever rolaboltmj nay bo aeceaaary. The deadline date of Kerch 1, 1972, la not roalistle. Kith regard to the labeling roqulred for notarial* that do eonfora to the proposed 0,5*$ Unit, we do not fool that this will cerve any useful purpose. It is our recorderdation that the ordi nance bo anended to ollninate this requirement. At indicated, wo would nice the opnartunlty to present our S'tatenont to your corelittee and to further amplify the remarks eontalnod heroin. Vary truly yours. k :r KKdrJK Bidden copies to: HUB QOS CQ3 FCQ CJ3 BAM JJL RKU CBH O007-SWP-03 (5449 0007-SWP-000117774