Document regK9jJaknv7zaL8OLzGJgqRq

CHICAGO PAINT, VARNISH AND LACQUER ASSOCIATION l 6 0 7 Ho w a r d St r e e t Ch i c a g o 2 6, Il l i n o i s President J. P. Jo r d a n Vice President Ha r r y D. Wr ig h t Secretary K. A. Co a t e Treasurer Lin u s O. Smit h Executive Committee R. G. Da h l b e r g E. O. Ro b s o n R. H. Cl in t o n Ka r l a J. Ho w e L. R. Reed A. P. St r e s e n -Re u t e r Executive Secretary Ra y J. Vo n e s h August 10, 19^1 Mr. Paul Whitford Technical Service Dept. Pigment Division Eagle-Picher Co. American Building Cincinnati 1, Ohio Dean Mr. Whitford: Here is a summary of what's happened in re: the labeling rules and regulations. 1. Th.e rules as enacted are contained in "Part J" a copy of which can be obtained by calling the Depart ment of Labor - Room 1300 - at Financial 6-2000. 2. After several conferences with the enforcement department of the Illinois Dept, of Labor the attached two page summary was agreed upon by the Department of Labor as being what they wanted as full compliance with the rules. 3. At a later meeting of our Trade Sales Committee the trade sales manufacturers unofficially agreed to go along with the suggested label for outside housepaints, to use a special label on varnish removers, stains and other materials containing "acute poison" and to use the socalled DuPont Label for all other lines. 1}.. At a similar meeting the industrial finishes manu facturers unofficially agreed to use a special label for varnish removers, stains and other materials, containing "acute poison" and to use the DuPont Label for all other lines. I enclose some sample stickers for your information.. Albany Press Label Printers here in Chicago (Mr. Carter Holmberg - W. Grand Ave., Chicago 39>" Berkshire 7- , 1373). Has them in stock. N11708 RJVtdt Lncs. ... . '*> LEAD INDUSTRIES ASSOCIATION 420 LEXINGTON AVENUE NEW YORK 17, N. Y. 1 s t a t s a n d :t e r h it o :iia l p a r k in g l a b e l in g l aw s ,:, Hie follovdngririquiry has been sent to health and labor departments of all states and territories: .:`T6rCth$b.l)rfLormatibn'''bx^out,V.'iae2ibefship> which includes many manufacturing;:companies; engaged in interstate .commerce/ we. are seeking to: acquaint ourselves rath all statutes or regulations . '-of .'the. several states which require warning, labeling of products which may be. hazardous .to health from the viewpoint of toxicity. We are, of !course>: principally interested in lead products, including lead .paints, and, we are not concerned, with drugs , . or pharmaceuticals." : Replies have been received as follows: Alabama. Economic' Poisons, law, covering insecticides, etc. Letter from Director, Division, of Industrial Hygiene: "As far as I know, the state of Alabama has no laws regarding the. labeling, of any products with reference to their toxicity. I. personally am interested in Seeing Teaming labels of some type on lead paints,- since .there are a considerable number of cases of: lead poisoning among children and are not correctly diagnosed by the attending physician.. If warning labels of some sort helped to diminish a number of these cases I would be very much in favor of it."- Alaska No warning labeling laws, Arizona Economic Poisons law, Arkansas Ho warning labeling lavra.: Letter from Director, Division of Industrial Hygiene: "We would like ..to inform you that:we have received information concerning apparent., epidemics of la ad :poiSohing...among children which have: occurred in .the Baltimore City. area . : We, intend: to inform all . our state and county , health -.`workers, and. our, physicians, . to bring : to the: attention of the. public the. po tentiai hazard i of,using, lead base:paints on children's furniture, and toys, and on the/lw .:/ interior of homes. . You: may be interested to know that our State Plumbing Code v permits the ..use of . le ad piping for vrater distribution lines. " California General Industrial Safety Orders,issued by the Division of. Industrial Safety of the Department of Industrial Relations. : require warning labeling.of 111 substances or groups of substances, of which ; S- A h .-- - ' -ass#/ N11708.01 WWW :pp?,; 00092 CO 2~ two are IfLend[Ac etath"':' artcL"Lead Compounds (Nano Compound)." In addition to these: orders y;ayalLabie at 25 cents^mper. copy,, an illustrative le aflet -with the : titled ["ihe;' LabelfMush Tell the Etory," is issued by/the: Division*,, Colorado ^^^'No''''.warning,'^labeling!!lav/ s'. Connecticut: ? .-'Warning? labels required for: containers1 of Ethyl Fluid or' tetraethyl ;jhleady thdtin6i,ezaC:t:'cohtent and dangerj 'label also: to 'state con- tainers to - be closed-tightly immediately when' emptied^ without [cleansing, and returned'to-,-plant*' : "'.-5 k: y -[ [ Delaware: No warning labeling- lavs. District of Columbia . Laws and regulations as promulgated by the Interstate Commerce Commission and Pure Food and Drug Division of ' the Department of Agriculture apply to District of Columbia. Florida -Economic Poisons law. Georgia. . Economic.Poisons law. , Letter from Director, Division of Industrial Hygiene:, '"I do not. believe the State of Georgia:has a. labeling 1 aw applying particularly to paints. Of course, the manufacturers in the State comply more or less with the voluntary , policing of the manufacture of baby cribs,' toys, etc." Hawaii. Regulations.-with the title "Preparation and Use of Warning Labels for Containers of Hazardous Substances" promulgated by the Department of .Health list I98 substances or groups of substances required to bear such lables, tyro of which are "Lead Acetate" and "Lead Compounds (Name Compound),": Detailed ..requirements as to the nature, of. the: labels are included. Idaho :No warning' labeling laws. Commissioner. of Labor} "We make every: effort tx). have such articles : properly labeled," .Illinois P.ules and Regulations Relating to: Labeling in Cthe Use, ..Handling, and. v ,f ; V Storage of Substances Hamfill .to the Health and Safety of Employees have beenpromulgated;byithe' Industrial' Commission .and became .effective:; June lEyll , d.95>l;[ These require .warning [labeling of ten1classes of, hazardous" substances,, of: [ ;-which.:: twq are"Materials[in Dust Form. Hazardous. from' Inhalation - or Coritact" arid .[[^Materials Toxic if Sv/allowed." A .seemingly absurd in -erpretation of these regulations is that all outside house paints, : whether or not they contain lead, : shall: bear the warning: y [."Kay contain lead, compound. V.rash thoroughly after handling end before eating or smoking. Avoid breathing dust. Do not take internally." ,. ' v Indiana No[warning labeling laws. EPI 000929- -3" lor,-a Economic : Poisons law. of ingredients on labels is the chief factor,- witii;prevention ox . adulteratioriV'as primary aim; Kansas '-U No warning labeling laws . Kentiiclcy; .^No, %arning labeling la tvs.- Department recommends-the use.of warning labels in accordance with 'the [recommendations of the Manufacturing Chemists ' Association. Louisiana Labeling of tetraethyl lead is done through agreement between menu- ; ' : facturer and IT, S. Public Health Service. No:warning labeling: Haws. Maine Economic Poisons 'law. Maryland . No warning labeling laws.' Massachusjetts learning. 3a beling laws , and regulations applicable only to benzol, carbon tetrachloride, DDT, methyl alcohol, and "dangerous caustic op corrosive substances in packages for household use." Michigan , Hdalth Departments- "'Then the necessity, arises we follow '..the require- j., -ments .of- the-: Interstate Commerce Commission and the Manufacturing Chemists 1 Association. , . Minnesotat Economic Poisons law. Paint labeling, lava aimed at proper listing of ingredients and pre-- . vention :of adulteration* .; ; V.V- Mississippi - ' No Warning labeling viaws Missouri, .- No warning labeling'laws: Montana ' iEconomic/Poisons law." Nebraska : Economic Poisoxis- law. p'-vb -.Mb : Nevada No yrarning labeling laws. :b Letter from Labor Commissioner: "However, - we would' appreciate your ;co~ operation in suggesting : to your niembership ; that .they place ,a'|; warning label'on : ' v' their products to be shipped in to ...Nevada,,-even .though we do-not have a statute t requiring it'.-TCNeva'da has an Occupational Diseases Act, but unfortunately we do not have statutes 'which- help to prevent occupational .diseases, ^ Therefore, if the manufacturing companies would:cooperate with us'voluntarily it would certainly be-appreciated, . New Hampshire No warning labeling lavra. EPI 000930 Newtjersey EconoraxC''E*6iso:iis 'law.. ' fe;r^;{GKj^'::;y;^'HovwarriIng;,'labeling vy y. ' ' ,./ New York No warning labeling laws. North .patbllhd :^V;^Ecb'n6^nlb;:^blsdnsl; 2aw.::J'''V^ y'. ^ 1\;. :>; North .Dakota iEcoribniic ..Poisons law. Ohio : Oeheral Code S ec tion 6333 of 1 aws acininistered by the Department'. of Agriculture requires that paint labels shall "show the name or names of any` sub stance or substances used in quantities sufficient,to be dangerous or injurious to human life or health whether through absorption, contact, or inhalation.11 Oklahoma Economic Poisons law. Oregon Economic Poisons law. Pennsylvania No warning labeling laws. Puerto Pico Economic Poisons law, . ; Rhode Island : No warning labeling laws. Soyth Carolina No warning labelinglaws. South Dakota No warning labeling laws.. Tennessee Economic Poisons law. Texas No warninglabeling lavs,. : Utah Economic Poisons law. Vermont Economic Poisons. law! . y Virgin Islands ' ; (No reply received.) - : ' Virginia Economic: Poisons law. Paint law requires proper labeling as to ingredients, etc., but no pro-1 vision for 'warning labeling,. Washington y; No warning labeling Haws. West Virginia No -warning labeling laws. . letter from Associate IN,rector; .Department, of Health: : , ;V7e do- not . in rest Virginia have any" requirements for warning labeling of -products ''which may . be hazardous to health, although I would be ready .to. 'agree with{.-you that'.'such .-label ing would be desirable. This matter has at various times been considered both by I . EFT 005932 -5 the .Department' of Laborj but no", definite action has- ever been takeh by etb'e?-iDeparitienti; due,i;I: would say, primarily to the: staf.f limitations, "of o^rl individuai;.,depart^lents. ,, Wisconsin' No vrarning labeling laws. Wyoming , Pure( Paint Law," Labeling provisions are for protection of: purchaser i<3hi^reghrdf;tok^dliiy^,^xiP--warning^labeling-'requirements.'' It t/ill> be observed that, apart from the Connecticut regulations noted, the only jurisdictions thus far requiring warning 'labeling of - the.- types with which we are principally concerned are.California, Hawaii, Illinois, and Ohio. The references to childhood lead poisoning in the letters from state officials in Alabama, Arkansas, and Georgia are of interest. lANFRDD BORTllCH w EFT 000932