Document omaj6aj3RkewOg2wyd6gxomDX

/T*0 440^ d-OstzX July 18, 1990 Henry Forsyth ALTC SUBJECT: GEON 87628-136 FOR ELECTRICAL SWITCH BOXES The use of antimony oxide and tetrabromobisphenol A In Geon 87628-136 prevents its clearance for use under current FDA regulations, 21CFR "Food and Drugs". However, since this is a non-food contact application for use in kitchen restaurants, it would clearly fall out of the area of an "FDA" application. In fact, as stated in the legislative history; the Food, Drug and Cosmetic Act was not intended to regulate food contact articles for use in the household, food service establishments, or food dispensing equipment. Enclosed is a copy of correspondence with FDA regarding the "Housewares Exemption". The FDA has done nothing further to date on their 1974 proposal. Hence, the "Housewares Exemption" remains unchanged. I see no reason why, from a food adulteration basis, that Geon 87628-136 could not be used for the stated purpose, i.e., electrical switch boxes in commercial kitchens. I believe the electrical and flame retardant properties should take preference in such an application. W. C. Bachtel 0718-1/jp BFG07561 20S66001 J 'u -v. - 90 14:27 FROM BFGOODRICH GEON D5052 PAGE.001 THE BFGOODRICH COMPANY GEON PLASTICS TECHNOLOGY DEPARTMENT 5052 AVON LAKE TECHNICAL CENTER MOORE & WALKER ROADS AVON LAKE, OHIO 44012 EXTERNAL TELECOPY NUMBER: (216) 933-0132 INTERNAL TELECOPY NUMBER: 8-221-1132 DATE: 7/iLlfO TIME PLEASE DELIVER THE FOLLOWING PAGES TO: NAME:_ LOCATION:____________ IKn.'j'W________ B FAX NUMBER:2 Vig______________________ e><f FROM: NAME: 4J ' LOCATION: y -j---------r /' f * f/ Lf f 1 (sr-------------LL--------- TOTAL NUMBER OF PAGES INCLUDING THIS COVER LETTER. IF ALL PAGES ARE NOT RECEIVED, PLEASE CALL BACK IMMEDIATELY. NAME: INTERNAL -- 8-221EXTERNAL -- '(216) 933- BFG07562 Z009980C JU1, 4 6 '90 14:28 FROM BFGOODRICH GEON D5052 PAGE . 003