Document qmQkV6Ez9NJNnn0ogDM7Vb7YE

CertainTeed Corporation P.O. Box 860 Valley Forge, PA 19482 (215)687-5000 CertainTeed E! February 11, 1982 Mr. B. J. Pigg Executive Director Asbestos Information Association of North America 1745 Jefferson Davis Highway Crystal Square 4, Suite 509 Arlington, Virginia 22202 Dear Bob: As requested at the last Executive Committee Meeting I have reviewed the proposed CPSC booklet. Asbestos in the Home, and I offer the following comments: First, I question the need or desirability of such a booklet at all, however, if CPSC is determined to issue one this revised version is much better than the original proposal and, with a few exceptions, I would consider it acceptable. The areas which concern me and which I think should be recon sidered are: 1. On page 1, fourth question, I don't like the wording of the second sentence. I would like to see it changed to something like the following: However, health studies of asbestos workers and others have shown that inhalation of asbestos fibers can increase the chances of adverse health effects. 2. On Page 2, in the first paragraph under APPLIANCES, I strongly object to the last three sentences. I think they are extremely misleading and any reference to the hair dryer fiasco should be left out unless it is stated factually. Mr. B. J. Pigg February 11, 1982 Page two 3. On page 3, under FURNACES AND STOVES, ETC. in the second paragraph I think the sentence "CHILDREN SHOULD NOT PLAY IN THE DUSTY AREA" is unnecessarily alarming. I think it should be revised to something like the following: All unnecessary activities in the dusty area should be avoided. 4. On page 4, last paragraph, I think the words "should" and "most" should be eliminated from the third sentence. 5. On page 5, are roofing, shingles, and siding considered consumer products? I wouldn't put them in that category. 6. Again on page 5, assuming that roofing is a consumer product, I think that the second sentence is misleading and could create much unnecessary concern. While it is true that some asphalt shingles were manufactured in the 1940's with small amounts of asbestos fibers in the asphalt coating to improve their fire resistance, those shingles represented a very small percentage of asphalt shingles sold and risk of exposure from them is practically nil. I am not aware of any actual asbestos based asphalt shingles although there could have been some. True asbestos based asphalt roofing was made in roll form rather than in shingles and was usued in built-up roofing systems on commerical and industrial buildings which would not fall into the consumer area as I understand it. I think these observations are accurate, but if Jim Reis or someone else does not agree with them, I will stand corrected. Mr. B. J. Pigg February 11, 1982 Page three 7. On page 6, in the second "CAUTION" paragraph, the word "with" in the first sentence should not be there. I hope that these comments will be helpful to you in respond ing to CPSC. Best regards, Thomas A. Dougherty Vice President Industrial Relations TAD/cml cc J. Rei^ J. Marsh J. Myers A. Wise K. Schwarz D. Poutiatine