Document p2v9bo69K6VZVOdXrGOZdGg0D

UNIDH GARB IDE AND CASBOH CORipRATlOH' 30 East Forty-second Street Hew York 17, Hew lark Mr. Manfred Sawditch Director of Sesltli and Safety Lead Industries Association U2Q Lexington Avenue Hew York 17, Usw York l$r dear Manfred: October 8, 195k You, asked ma to send you a note on the subject of the Sagla-Picher Company warning labels for lead products. The concern seems to be as to whether the labels, copxec of which you gent me, would be adequate and comply with the regulations In. New Fork State and Hew York City as I understand they do with the codes in California and Illinois. Iho codes referred to all 'follow essentially the principles for preeaationary labeling published by the Manufacturing Chemists1 Association in their Manual L--1, Earning Labels.a Naturally, it would be a question for the enforce ment agency to dotormino -idiothsr or not a given label is satisfactory under their coda, and. It .would not be a. function of tho H.C.A. to make such detarminatlorn. Obviously, if experienco indicates that the originally accepted label does not satisfactorily cover, the:situation, dt change night be required; by the enforce ment agency, In tho .present case, I understand, the. Eagle-Tichar Company Trishas to laam whether those- labels would be acceptable finder the Hew York diets and Hew York City codas.'.'' In the case of. Hew Toit City, I understand that they have stated that at eraseat these labels .would appear,to meet with their regulations. . ISLcther or not a given label is acceptable under a given coda seema to be readily answerable, yes or no, by the administering .agency of the cods# It would not seem that thora should be any need';to-';confer with tho II.C.A. os to intcrpretatioh of the code, even though t'iCh a coda might have evolved in collaboration with the M.C.A. Therefore, I am a little at a loss to undsrsuand why in tne case of the'Sew. York State code they, cannot give a- direct answer based on their own intorpretatioa of thair own code. As a disintsi-ested observer, it would seem to na than these labels prepared by the Eagle-Plcher Company should be satisfactory under any of 'the codes mentioned. Very truly yours. A. G. Craach, h Hs / -Jj n. - v j . c.i MEDICAL CONSULTANT N11697 LEAD INDUSTRIES ASSOCIATION 420 Lexington Avenue New York 17, N. Y. $ \ M A N F R E O BO W D ITC H DIRECTOR.OF HEALTH AND SAFETY Go tober 11, I95h Mr. 5. T. Barker Assistant Director Bureau of Environmental Sanitation How York State Department of Health Albany 11. Hew York Dear ttr.Barker; The references in your letter of 'September 27th to the llarnifsctud.ng Chemists" Association'and the. Chemical Specialties Bferrafaeturers Association led. me to.refer it to jDr. A. G> Cranch, nfco is active in the labeling work of,.'both these-.groups*. The fact that ! have only now received his\response* of which a copy is herewith^ accounts for this delayed acb^irlec^aent oh my part. The Mew York City Health Department, has indicated ap proval of the labels submitted with my\ letter of', September 2lst". and I gather from what yon have said that they Kill be acceptable'' to your Department also* \. // ' ", :-`V r'' /[ As.sbme of our member: companies are only, new learning ,of these new; regulations/ I'assume that -they. will have a reason-. -. able period in 'which to make proper compliance. wSinceraly yours, CvCi i0cc: I'r. '.raioiorc; ;r. jh-nrieh son , .A* o * c'd .J? iichlman: M11697.01