EXHIBIT 8.01

                    [LETTERHEAD OF GIBSON, DUNN & CRUTCHER LLP]

                               August 27, 1997
                                       



(212) 351-4000                                                C 30620-00004

Falcon Building Products, Inc.
Hart & Cooley, Inc.
Mansfield Plumbing Products, Inc.
DeVilbiss Air Power Company
SWC Industries, Inc.
Ex-Cell Manufacturing Company, Inc.
Two North Riverside Plaza, Suite 1100
Chicago, Illinois 60606


      Re:  FALCON BUILDING PRODUCTS, INC.

Ladies and Gentlemen:

     At your request, we have examined the Registration Statement on Form S-4 
(the "Registration Statement") of Falcon Building Products, Inc., a Delaware 
corporation (the "Company") to be filed in connection with the registration 
under the Securities Act of 1933. as amended (the "Securities Act"), of the 
proposed issuance of up to $145,000,000 aggregate principal amount of its 
outstanding 9 1/2% Series A Senior Subordinated Notes Due 2007, for a like 
principal amount of its 9 1/2% Series B Senior Subordinated Notes Due 2007 
and up to $169,317,000 aggregate principal amount at maturity of its 
outstanding 10 1/2% Series A Senior Subordinated Discount Notes Due 2007, for 
a like principal amount of its 10 1/2% Series B Senior Subordinated Discount 
Notes Due 2007.

     We hereby confirm our opinions set forth in the Registration Statement 
under the caption "Certain Federal Income Tax Consequences." Furthermore, it 
is our opinion that the discussion under the caption "Certain Federal Income 
Tax Consequences," to the extent it discusses matters of law or legal 
conclusions, is correct in all material respects.


Falcon Building Products, Inc.
August 27, 1997
Page 2

     We hereby consent to the filing of this opinion as an exhibit to the 
Registration Statement, and we further consent to the use of our name under 
the caption "Certain Federal Income Tax Consequences." In giving this 
consent, we do not thereby admit that we are within the category of persons 
whose consent is required under Section 7 of the Securities Act or the rules 
and regulations promulgated thereunder.

                                       Very truly yours,

                                       /s/ GIBSON, DUNN & CRUTCHER LLP

                                       GIBSON, DUNN & CRUTCHER LLP