Document vVORYjnQJybpgxNx7ZJ7Rm1dE

3^atumal ;f3autt, IBnmisti artit Uacqu^r ^kssariattan I n c o r po r at ed OFFICERS FRESIOENTB A.MALM. DES Pl a in e s VICE PRESIDENTr a l p h j b a u o h u in .Ro c k f o r d EXECUTIVE VICE PFESlOENTROBERT A.ROLAND, Wa s h in g t o n TREASURERC A. 8RETHEN. JR .Wy a n d o t t e SECRETARYALLAN W GATES. Wa s h in g t o n FIELD SECRETARYJAMES N ELLIOTT. Wa s h in g t o n 1500 RHODE ISLAND AVE .N W . WASHINGTON. D C 20005 PHONE 202-462-6272 December 21, 1971 REGIONAL VICE PRESIDENTS NEW ENGLAND-C FRANCIS LOUT REL. SO ST O N EASTERN-WILLIAM Ma c KNIGh T. Oh il AOELPw ia EAST CENTRAL-ROBERT w BOOT CLEvCLAf WEST CENTRa l -h C MILLER, s t l Ou iS SOUTHERN-HUGH H MAYBERRY. BRUNSWICK. G SOUTHWESTERN-HAROlD WEINBERG DENY' WESTERN-D W KENNEDY. l OS ANGELES MR. J. F. COLE, Sc . D. Director, Environmental Health Lead Industries Association 292 Madison Avenue New York, New York 10017 % Dear Mr. Cole:- Roy Brown indicated that you had expressed some interest in our reaction to Pennsylvania's House Bill No. 1574. Needless to say, we feel rather strongly about it. A copy of our comments, directed to the Chairman of the Pennsylvania House Committee on Labor Relations, is enclosed. We hope this is consistent with the position LIA has or will be expressing. If not, let us know and perhaps we can develop a combined statement to unite the strength of our mutual interests. Moreover, we would be most interested in receiving a copy of the LIA statement for any additional insights and to temper our future comments accordingly. Thank you for your interest. Sincerely, BH:rw Enel. L\ Bruce Hamill Counsel N 850 LIA-76139 National Point, Varnish and Lacquer Association, Inc. 1500 r.hoda Island Avenue Northwest Washington, D. C. 20005 December 3, 1971 Honorable Andrew T. Fenrlch, Chairman House Committee on Labor Relations Pennsylvania General Assembly Harrisburg, Pennsylvania Dear Mr. Fenrich: Cn behalf of the National Point and Coatings Association, we wish to convey our comments with respect to House Bill No. 1574 which, v/e understand/, is presently pending before your Committee. j As you are aware, House Bill No. 1574 would profTTbtAjhs usa of hazardous paints for the purpose of safeguarding the hea!H)>ecl3scife'N of prcctrs/ion workers. The National Paint and Coatings Association (forr^riy knov/n as\fhe National Paint, Varnish end Lacquer Association) Includes crr.ong its mombership a substantial number of com panies who market their productSxttTma"nufacturir\g into reste/within the Siufe of Pennsyl vania. As a national trade association, fhis\rga)Hza>sm represents manufacturers of better than ninety (90) percent of the annual c'plIcfWclums of paints, varnishes, lac quers and alliecJ^sTodocts produced in the Unitld States and also includes many suppliers of raw materials. Needless fi.say, we are deeply concerned with the issues addressed in House Bi/l No. 1574 and hope our specic^rknov/Iedge and experience can bs of assistance |n its consideration. ------ We want to assure>you at the outset that the health and safety of workers coming into contact v/HKour^p-rdaucts is of paramount concern to us. Where our remarks con cerning the proposal at hand would tend to compromise that highly desirable objective, we stand corrected. Nevertheless, sharing the Pennsylvania Legislature^ concern, v/e are unable to support House Bill No. 1574 as the best approach toward attaining that goal. We call your attention to Section 3(a) of the proposal, which states "No person oshall us hazardous paints in any establishment." Section 3(c) further precludes the manufacture of such paints. The tenor of this language imposes an undue burden upon manufacturing interests within the State of Pennsylvania, with consequent impact upon the general citizenry. V/e submit that a reasoned program of safety regulations Is a better solution to the problem, rather than total annihilation. Some of the ingredients contained in modern paints may pose a hazard if basic safety rules are ignored -- where precautionary and safety procedures are observed the danger is eliminated. LIA-76140 N 850.01 2- - Roughly half of the products manufactured by this Industry are for industrial and commercial purposes. While we cannot be certain what percent of these would be deemed "hazardous paints" under House Bill No. 1574, we do know that substitute ingredients would result in inferior coatings, reflecting adversely upon the finished products being manufactured in the State of Pennsylvania. Relatively few articles are manufactured today without receiving some sort of coating. We do not think the Legislature intends to place a competitive burden on manu facturers situated in Pennsylvania by preventing them from producing a finished product of as good a quality permitted in neighboring States. An alternative means of attaining the same objective already exists in the Federal "Occupational Safety & Health Act of 1970", P.L. 91-596. The Federal Administration is enthusiastic in its ability to carry out the principal objective of the Act -- to cssure safe ond healthful working conditions for all workers. This Association has been active in cooperating with representatives of the U.S. Department cf Labor toward the establishment and enforcement of effective safety regulations surrounding the use of our products. The introduction of House Bill No. 1574 was surprising to us -- we were aware that the Stcte of Pennsylvania had made tentative arrangements under Section 18(b) of the "Occupational Safety and Health Act of 1970" to develop a "State plan.. .of such standards and their enforcement." Frankly, we are at a loss in attempting to identify inadequacies of the Federal Program of sufficient magnitude to warrant substitution by House Bill No. 1574. We stand ready to cooperate fully with appropriate State officials in resolving any short comings in the present law that would jeopardize the health and safety of workers dealing with our products. You may be assured that the facilities and professional talents of this Association are available to the Committee in its consideration of House Bill No. 1574. Moreover, if there ore to be public hearings, we would appreciate being advised so that represen tation can be supplied to elaborate further the views of the Industry, if appropriate. Sincere ly, BHH/sc Bruce Hamil! Counsel LlA-76141