(2/2/2012) NATIONAL GYPSUM COMPANY: Response of New NGC, Inc., d/b/a National Gypsum Company, to Report # 20120106-A878B-2147471577
To Whom It May Concern at CPSC:
New NGC, Inc. d/b/a National Gypsum Company (“National Gypsum Company”) received on January 17, 2012 a report dated January 6, 2012 and bearing Report number 20120106-A878B-2147471577 (the “Report”) concerning a property located at [REDACTED] (the “Property”). The Report indicates that it was submitted to CPCS by [REDACTED](the “Consumer”). National Gypsum respectfully offers the following comments on the Report, which contains and is based upon materially inaccurate information.
The Report states that the Consumer purchased a home November 1, 2004 in [REDACTED] and asserts that the Consumer, her son and her dog have experienced certain physical symptoms since living in the home and also that the “drywall started making wholes [sic] in it by the air conditioner/air handler system. The Consumer states that “CCA green board was also placed around the air handler/air conditioner in the attic” and that such board was “put all throughout the house/garage/attic/bathrooms/bedrooms/windows/doors” and that it “has biohazard materials in this house and is unsafe”. The Consumer also states that “a friend suggested I see if the house has Chinese drywall” and that the “drywall in this house was made by National Gympsum [sic].”
First, it appears that the Report is claiming that the physical symptoms are being caused by “CCA green board”, which National Gypsum has not manufactured or sold, and the Consumer also indicates he/she was advised to “see if the house has Chinese drywall,” which National Gypsum has not manufactured or sold. It is not clear precisely what product the Consumer claims is causing or has caused the symptoms described in the Report. In any event, the Report notes the mere presence of one or more sheets of National Gypsum Company drywall, but it does not contain information that could substantiate a conclusion that any National Gypsum Company drywall present at the Property was defective or caused the reported characteristics at the Property, or that other causative factors such as corrosive Chinese drywall or other building materials have been eliminated. In fact, many of the complaints asserted in the Report have been associated with defective Chinese drywall and numerous sources unrelated to drywall.
National Gypsum Company Has Never Produced, Handled or sold “CCA green board” and Therefore Takes No Responsibility for Any Effects of Such Product. “CCA Green Board” is a pressure treated wood product containing chromated copper arsenate (“CCA”), a chemical wood preservative containing chromium, copper and arsenic. See the United States Environmental Protection Agency article on this subject at www.epa.gov/oppad001/reregistration/cca/. National Gypsum Company does not produce or sell and has never produced or sold such a product. Furthermore, National Gypsum Company drywall does not contain and has never contained any CCA material. Consequently, any assertion that “CCA green board” was produced by National Gypsum Company, that such a product is installed in this Consumer’s home, and that it is the cause of the physical symptoms described in the report, is on its face false, misleading and materially inaccurate.
The statements in the Report, describing symptoms that may be associated with defective Chinese drywall or possibly “CCA green board”, and indicating that “National Gypsum” is one brand of drywall in the home, DO NOT IN ANY WAY implicate National Gypsum’s product as the cause of those symptoms. When a homeowner or someone inspecting a home suspects that it might contain defective drywall, the easiest place to start looking for the brand or source of manufacture is in an attic or closet ceiling, or sometimes a garage area, rather than to pull or cut out wall panels in the living spaces of the home. It is most common, particularly in homes in Florida or in other Southern, humid climates, to find National Gypsum wallboard in the ceilings and attic spaces of such homes, since National Gypsum makes a “High Strength” gypsum board that is resistant to sagging and is often preferred, indeed specified, for residential ceiling applications. Also, usually National Gypsum’s fire-resistant 5/8” Fire-Shield® drywall product (or a similar U.S. competitor’s product) is used and typically required by code for garage applications. To the best of our knowledge, the Chinese manufacturers did not import either such products, rather only ½” regular wallboard was imported. Thus, if a person complains of the characteristics or symptoms associated with defective Chinese drywall, and they find National Gypsum drywall in their attic or in their garage, they may have defective Chinese drywall in their living area, or other causes for such symptoms may exist in the home (such as, per the Consumer’s claim, “CCA green board” produced by some other manufacturer of building materials). The mere existence of National Gypsum’s product in an attic, garage or other specific area in the home where the “National Gypsum Company” brand name may be visible in no way indicates that such product is defective or is the cause of the reported problems, any more than any other building material or furnishing (e.g., carpet, furniture, draperies, lumber) installed in the home might be claimed as the cause.
To the Extent “Chinese Drywall” is claimed to be installed in this home, National Gypsum Company Has Not Manufactured, Imported or Otherwise Distributed Chinese-Manufactured Drywall and Therefore Takes No Responsibility for Any Effects of Such Drywall. All drywall sold by National Gypsum is produced at its own manufacturing plants in the United States. National Gypsum has produced billions of square feet of drywall, and none of it has been shown to cause the types of characteristics reportedly present at the Property. As a practical matter, it is not uncommon for a property to contain two or more types of drywall, possibly including both benign U.S.-made drywall and problematic Chinese drywall.
As indicated below in the independent, government-sponsored reports, analytical testing of the drywall in a particular property is necessary to determine whether the drywall in the property is problematic. In addition, a thorough investigation of the particular property is necessary to determine whether any of the numerous other sources of odors and corrosion can be ruled out.
CPSC-Sponsored Report Identifies Elemental Sulfur (S8) as “Sensitive and Specific Marker of Problem Drywall”; Elemental Sulfur Not Detected in National Gypsum Company Drywall. A report sponsored by the Consumer Product Safety Commission states that “the presence of elemental sulfur (S8) in concentrations greater than 10 mg/kg in drywall has been found to be a sensitive and specific marker of problem drywall.” EH&E Report 17402, Problem Drywall Assessment and Indoor Environmental Quality Evaluation,144 Groesbeek Street and 4 Darden Street, Fort Bragg, North Carolina, at p. 73 (Feb. 7, 2011), available at http://www.cpsc.gov/info/drywall/ehefeb2011.pdf. As tests by various agencies (such as the U.S. EPA, the CPSC and Florida Department of Health) have confirmed, elemental sulfur is regularly detected in problematic Chinese drywall and has not been detected in National Gypsum’s drywall. For example,
[F]our samples of U S -manufactured drywall were purchased by EPA from local stores in Edison, New Jersey and included in the analysis . . . Sulfur was detected at 83 parts per million (ppm) and 119 ppm in the Chinese drywall samples. Sulfur was not detected in the four US-manufactured drywall samples . . . The drywall sample manufacturers and product names are as follows: US Gypsum/Hamilton (US); PROROC/Certainteed (US); National Gypsum/Gold Bond (US); GP/Tough Rock (US); Knauf/33928-2005 (China); and MIC/33966-12077 (China).
U.S. EPA, Drywall Sample Analysis (May 7, 2009), available at http://www.epa.gov/oswer/docs/chinesedrywall.pdf.
A study commissioned by the Florida Department of Health reiterated the “distinct difference” between problematic Chinese drywall and American-made drywall:
In summary, the odor that has been described by investigators and homeowners in Florida residences originated from the emission of volatile sulfur compounds. There is a distinct difference in drywall that was manufactured in the United States and those that were manufactured in China. The Chinese samples contained traces of strontium sulfide inclusions and more organic material than the [National Gypsum] Gridmarx sample (United States). However, it is not yet known if either contributed to the odor. The Chinese samples give off a sulfur odor when exposed to extreme heat and moisture.
Unified Engineering, Inc., Report on Florida Drywall Samples (Mar. 17, 2009) (Commissioned by Florida Dep’t of Health), at 5 (emphases added), available at http://www.myfloridaeh.com/community/indoor-air/drywall.html.
The CPSC reported additional testing results showing a “clear distinction” between problematic Chinese-manufactured drywall and American-made drywall:
U.S. Consumer Product Safety Commission (CPSC) staff contracted with Lawrence Berkeley National Laboratory (LBNL) for measurement of chemical emissions from 30 samples of drywall products obtained as part of an investigation of imported (Chinese) drywall. In this report, non-Chinese drywall is referred to as North American or NA. . . . .
While the data provided by LBNL to date are limited and the sample size is small, these data provide important information about chemicals that may be emitted from older Chinese drywall but are not released from NA drywall. Based on these preliminary results, the most salient difference between older Chinese and NA drywall is in the number and amount of reactive sulfur compounds emitted.
CPSC Staff Preliminary Evaluation of Drywall Chamber Test Results – Reactive Sulfur Gases (March 2010), at 2-3 (emphasis added), available at http://www.cpsc.gov/info/drywall/index.html; see also Garland & Greene, Division of Hazard Analysis, CPSC, Statistical Analysis of the Chemical Screening of a Small Sample of Unused Chinese and Non-Chinese Drywall (10/28/09 Draft), at 10, available at http://www.cpsc.gov/info/drywall/TabA.pdf (“[A]ll the measurements of elemental sulfur in non-Chinese drywall samples were non-detects, while in contrast, only one measurement in the Chinese drywall gypsum samples and one in the Chinese drywall paper samples was a non-detect.”) (emphasis added).
Each Property Is Unique and May Have Various Causes of Physical Symptoms, Odors or Corrosion Unrelated to Drywall. As the CPSC has explained, “[a]n elevated rate of corrosion in homes is not sufficient, by itself, to conclude that the corrosion is associated with problem drywall in the home. Outdoor corrosion rates may be the source of indoor corrosion in some of these homes. . . . Or, the corrosion source might originate from something other than the drywall.” CPSC Staff, Summary of Contractor’s Evaluation of Homes Reported to Be Constructed with Domestic Drywall, at 4 (Apr. 15, 2011). “It is possible to misclassify homes because of other possible sources of metal corrosion such as volatile sulfur compounds from sewer gas, well water, and outdoor contaminants that may enter the home independent of the drywall in the home.” Summary of Revision 1 to the Interim Guidance – Identification of Homes With Corrosion from Problem Drywall, August 27, 2010, available at http://www.cpsc.gov/info/drywall/guidance0827.pdf. (Emphasis added).
In summary, National Gypsum Company has not seen any reliable scientific evidence to support speculation, if any, that National Gypsum Company drywall can cause the characteristics that have been associated with problematic Chinese-manufactured drywall and other sources of physical symptoms, odors or corrosion unrelated to drywall, including but not limited to “CCA green board”. In addition, National Gypsum Company has never sold any “CCA green board” and none of its drywall products have ever contained CCA. Although the Report regarding the Property notes the mere presence of one or more sheets of National Gypsum Company drywall in the Property, the Report does not contain information that would in any way or to any degree substantiate a conclusion that National Gypsum Company drywall was defective or caused the reported characteristics at the Property or the physical problems of which the Consumer complains. Without more, the Report is simply a report by the Consumer of physical symptoms on the part of occupants and of possible corrosion, in each case from an unidentified source. If the Property owner has drywall in the Property that bears a National Gypsum Company brand name (all National Gypsum Company drywall is branded), and any information regarding that product that the Property owner believes indicates that the drywall product is problematic, National Gypsum Company encourages the Property owner to contact the company and share the information. National Gypsum Company’s contact information is located at
http://www.drywallfacts.com/contact.htm
and http://www.nationalgypsum.com/contact/default.aspx.