Document om1GYd1w8GY6Rn1wj8RoZn747

NUBB-0034099 From wm : Bate : Sutlject: R & D CENTER - #601 DESIGN AND MANUFACTURING CENTER 236-5435 November 9, 1979 * - rS To : ALL DIVISION AND DIVISION'S GENERAL MANAGERS There Is an announced intention by several government agencies, primarily the Consumer Products Safety Commission (CPSC) and the Environmental Protection Agency (EPA) to res trict the use of asbestos in "non-essential" applications. They have published an extensive list of products containing asbestos on which they are beginning a formal Investigation in order to determine if this asbestos presents a substantial product hazard. At present, the CPSC and EPA are soliciting comments by means of an Advance Notice of Proposed Rule Making. The EPA is considering either: 1) The traditional regulatory approach restricting the manufacture of asbestos by product categories, or '.) limiting the amount of asbestos available and allowing the marketplace to determine the use and application of asbestos. The two agencies are combining forces on this issue in order to coordinate their actions and not duplicate efforts. This letter is written to accomplish the following: 1) Let you be aware of the situation, if you are not already, in order that you may evaluate the impact on your division. 2) Request your review for additional products which are not included in the attached lists. These lists were supplied as part of the CPSC's and EPA's Advance Notice of Proposed Rule Making. 3) To solicit your comments on this proposed rule. Comments should be sent to me for compilation, review for consistency and for clearing with the law department. Further details on the areas in which they are soliciting comments are given in the attachment. This is our opportunity to influence the direction of the government policies before they become fixed. Therefore it is imperative that you make comments that will help us Influence the government agencies and that these comments be sent to me by Decanter 3, 1979. gmc Discard Oatr. Attachment $*4 * ".John F. Gormley, Director Product Safety & Integrity  % HHBB-0034100 5=3 fel Attachment Issues highlighted for comment (Federal Register/Vol. 44, N0202/Wednesday, October 17, 1979, pp. 60056 - 60068). 1) How can the agencies (CPSC & EPA) obtain information necessary to make informed decisions concerning asbestos while considering industry's and the general public's interest in avoiding unnecessary reporting burdens? How can the agencies needs for information be met while protecting industry's legitimate interest for preserving confidentiality? 2) The CPSC initially proposes to seek elimination of all non-essential uses of asbestos in consumer products from which asbestos fibers are released during reasonably forseeable use or misuse. They are asking, la their approach sound, and under what circumstances should the commission consider action to address essential uses of asbestos in consumer products from which fibers are released. 3) How should the CPSC determine what constitutes an essential use of asbestos? How much weight should be given to cost, availability, utility or safety of substitutes for asbestos? 4) The CPSC believes it can take action on the basis that asbestos fibers are being emitted from a product. Comments are solicited on what situations should quantitative measurements of asbestos fiber emission be attempted. 5) The Commission intends to consider regulation of asbestos on a generic basis (classes of consumer products, etc.) rather than on a case-by-case basis. What are the advantages and disadvantages of this approach? 6) The CPSC does not intend to employ quantitative estimates of cancer risks posed by exposure to asbestos fibers in making regulatory decisions con cerning consumer products. Is this approach appropriate to the regulation of the risks posed to the public? The CPSC requests more Information con cerning qualitative or quantitative studies of asbestos fiber emission from particular consumer products. Any such information available would help to identify products which should receive priority attention. 7) What categories or individual products and uses containing asbestos do not present a health hazard to users? Why? 8) What asbestos-containing individual products or categories might be con sidered essential because of significant benefits and/or lack of reasonable substitutes? What are the specific benefits and costs? CPSC LIST ' Asbestos neper products Acoustical ceiling tile Lamp sockets Burner mats for gas stoves Roofing felts (outer layers) Pipe and boiler covering Vinly sheet flooring backing Radiator top insulation Appliance heating shielding (paper) Slow cookers Hair dryers Paper sheets for heat insulation Millboard TV & other electronic switch plates Electric switch boxes Metal reinforced gaskets (for air-cooled engines) Electrical washers Linings for ovens, kilns, safes, safety boxes, incinerators Millboard sheet Vail protection behind heat-generating products Floor protection under wood and coal stoves Soldering and welding blocks Iron rests Appliance heat shielding (millboard) Toasters Rotisserle broilers Fireproof wallboard Metal-clad fire doors & partitions Tent grommets Stove pipe rings Cloth and woven products Flexible air conductor for heating, cooling & ventilating equipment Appliance wiring Barbecue fire starters Broilers Curling irons Electric blankets Bair dryers Heating pads . Ranges Toasters Irons m Deep fat fryers EPA LIST Automotive Repair Mufflers Brake linings Clutch facings Custom auto body filler Metal deadener Household Materials Appliance wiring Counter surfaces Electrical cord Filler for shoe soles Floor tile Hair dryers Heat protective mats Ironing board pads & covers Lamp mantles Lamp sockets Potters kilns Slow cookers Toasters Safety Equipment Aprons Arm protectors Blankets ... Boots Caps Clothing Curtains Draperies Gloves Hats Helmets Hoods Mittens Overgaiters Sleeves Suits Umbrellas Aerial distress flares Ammunition shell wadding Catalytic heater mantles Tent gromets TV sets & projector equipment Home Building repairs Latex paints ~~ Texture paints Commercial applications KNBB-0034101  HHBB-0034102 O 5=3 H n *^S) .--j CPSC LIST (Cont.) Electric fry pans Awnings Candlesticks Catalytic heater mantles Cigarette lighter wicks Cord Seals for high temperature gaskets Valve steam packings Insulation for glass handling tools Reinforcing for braided wall stem hose Theater curtains Felt Reinforcements in plastics Gaskets Reinforcement in asbestos tapes Secondary insulation in high tempera ture wire and cable Asphalt impregnated roofing felts Plano & organ felts Heating pads (element insulation) Ironing board pads and covers Lamp and lantern mantles Pipe and boiler covering Pot holders and oven mitts 'Flame resistant garments Gloves Hats Helmets Hoods Mittens Overgaiters Sleeves Suits Umbrellas Aprons Arm protectors Flame-resistant blankets Boots Caps Smokers bibs Stoves - Coal & wood burning Tape for pipe insulation Braid and rope for packing Motion picture screens Tent grommets EPA LIST (Cont.) Aluminized cloth Bags bearings Belting Blocks . Boards . Braid ^ Buffing & polishing compounds Cloth Cord Diaphragms Drier felt Drilling fluids Fabrics Felt Filtering material Metallic cloth Millboard Paper Pipe & boiler covers Pottery Clay Plywood patch Sheet flooring Table tops Tape Textiles Welding electrodes Asbestos cement products A/C air duct A/C pipe A/C sheet Baking sheets Cement boards Clapboard Roofing Shingles Siding Tile Molded products Gun grips Filler & reinforcement in plastic Pond liners Phenolic laminates Resins Rheostat backing Roofing Materials * NUBB-08341B3 k * CFSC LIST (Cont.) Asbestos cement products Water, sever & septic drain field pipe Airduct pipe Sheet products Roofing clapboard Siding Shingles . Interior walls Boiler & furnace baffles Bulk sheeting Welding shields Baking sheets Blackborads Laboratory table tops Linings for vaults, safes, humidifiers & filing cabinets Viscous Matrix Products Adhesives (glues & epoxies) Air duct cement for asbestos-cement air duct Buffing & polishing compounds Caulks and putties Floor tile cement & mastic Auto body filler Flashing cement Furnace cement Glazing compound for ceramics Flpe and boiler coverings Roof and driveway coatings Stains and varnishes Automotive metal deadener Automotive undercoating Refrigerator cements Automotive muffler repair compounds Products, subject to inadvertent asbestos contamination ~ Driveway gravel Fertilizer & lawn care products Potting materials (vermiculite) Talcs for noncosmetic or food use applications Acoustical & thermal insulation material sprayed Ammunition shell wadding EPA LIST (Cont,) Aluminum roof coating Roof patch Roofing felts Roof preservative Sealants fr mastics for Conatmar ^.commercial -use ^ A/C pipe joint sealant Adhesives Caulking compounds and putty Furnace cement Glazing confound Radiator sealant Varnish r S=3 & 5^ *j wJ CPSC LIST (Cont.) Automotive mufflers Barbecue firebed materials in gas barbecue grills Boat hull repair kits Hover pots friction materials dutch plates Brake linings ' Potters kilns (home hobby) Pottery clay Povder (asbestos) Bulk fiber Reinforcement in molded plastics and rubber Automotive radiator sealant Vinyl asbestos floor tiles Abrasive wheels Aerial distress flares Molded plastics and Phenolic laminates Paint Textured paint Cement, dryvall & plaster patching compounds Artificial gas fireplace emberizing material Phonograph records Consumer products possibly con* tainlng asbestos Air conditioners Dishwashers Eand>held mixers Portable electric heaters Popcorn poppers Refrigerators Vacuum cleaners Waffle makers Carpet padding fireplaces Instant Light fixtures on railroad passenger cars Welding masks file cabinets 4B18EB8-88KH