Document 06ej9QjLRB6Rrnw8zqz3rQGXd

Society of The Plastics Industry, Inc. September 1, 1994 TO: Vinyl Institute Executive Board Enclosed is the agenda and briefing book for the next meeting of the Vinyl Institute Executive Board being held at the Headquarters Plaza Hotel in Morristown on September 13th. The reception on September 12th will be held at the Vinyl Institute offices and the dinner will be at The Grand Cafe in Morristown. The following are directions from the airport you might need depending on your arrival time: Directions To The VI Office From Newark Airport take Route 78 West to Route 124 in the direction of Chatham. Follow the new Route 24 expressway to the end and take Route 287 South. Take Exit 35 (Route 124/24 Madison Avenue) and turn left at the top of the ramp onto Madison Avenue. Our office is on the first floor of the second building on the right. Visitor parking is in the rear of the building. Directions To the Grand Cafe (201)-540-9444 Follow directions above to 287 South/Exit 35. Make a right at the top of the ramp. Then make a right onto South Street. Take South Street to the Morristown Green (the Square). Go around the square 3/4 of the way and make a right onto Washington Street. The Grand Cafe is #42 on the left side. Directions to Headquarters Plaza Hotel (201)-898-9100 Follow directions to 287 South. Take Exit 35 and turn right at the top of the ramp onto Madison Avenue. Go through the next light (Madison Avenue turns into South Street/124 West). Follow South Street until you come to the Morristown Green (square). Circle the "green" approximately halfway and bear to the right onto Speedwell Avenue. The hotel is approximately 1/2 mile on your right. I look forward to seeing you in Morristown, NJ. /pmb Pat Benkner CTL014235 65 Madison Avenue Morristown, NJ 07960 (201) 898-6699 Fax # (201) 898-6633 Thf ongnt copy ot9m docurmnt pnrnd on ncydmt pap* % September 6,1994 Robert H. Burnett Executive Director MEMORANDUM TO: VI Executive Board Members VI Issues Management Committee Members FROM: Bob Burnett SUBJECT: Crisis Management Plans for the Dioxin Reassessment In anticipation of the U.S. Environmental Protection Agency's release of its draft report reassessing the effects of dioxin, a special VI working group has prepared the attached crisis management plan and communications protocol. While we believe our activities to date should serve to mitigate any potential problems relating to this report, the crisis communications plan is preparation for worst case scenarios that may occur on September 13. The plan will be executed by a special crisis management team that will assess the situation as it unfolds and assign appropriate strategies and tactics in response. These are outlined in the protocol. Additionally, key messages and potential media questions have been prepared to assist industry spokespersons in their response to media inquiries. We will also provide by the end of the week a two-page communications plan outlining key messages and talking points for distribution to VI member company employees, particularly plant managers who may field local media questions. Please do not hesitate to call if you have questions or comments. cc: Peter de la Cruz/Frank Torres Lew Freeman Marion Axsmith John Svalander Mr. Matsui CTL014236 65 Madison Avenue Morristown, NJ 07960 (201) 898-6699 Fax # (201) 898-6633 Tht ongnat copy at fm doatmrt prrUtfon ncydrt ptptf Crisis communications protocol for the vinyl institute September 1994 I. Situa tion analysis On September 13, 1994, the US Environmental Protection Agency will release the much anticipated Dioxin Reassessment. The Agency plans a national roll out of the report, initiated by a press conference in Washington, D.C. and supported by technical briefings at regional offices in New York City, Chicago, Dallas, Denver, San Francisco and Seattle. Based on current intelligence and the leak of an early version of the report, we know that EPA will find dioxin to be a public health hazard, including findings that show dioxin to be a suspected carcinogen as well as a reproductive and developmental toxin. EPA will also highlight known sources of dioxin for further study or potential regulation. Chlorine chemistry in general will be blamed as the largest source of dioxin production and specific uses of chlorine in particular singled out. EPA will likely conclude that the incineration of chlorinated compounds is the single largest known contributor of dioxin. We anticipate that EPA will also state that this problem has been addressed and all but solved with the pending release of MACT regulations for modem incinerators. Therefore, from a communications perspective, it is highly likely that EPA will point to other specific sources of dioxin as culprits due to political pressures to do so. Because of the aggressive tactics of Greenpeace and others pointing to PVC as a primary source of dioxin, we believe that PVC will be specifically mentioned, and potentially slated for further regulation. This belief is supported by recent conversations with EPA officials by Bob Burnett on behalf of The Vinyl Institute and members of the VI on behalf of their individual companies. This draft document is not intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 1 CTL014237 N D strongly believes that The Vinyl Institute must formalize a crisis communications plan to address potential scenarios that may result from the report and to protect PVC in the market place. The long term goals of the crisis communications program, in conjunction with other VI communications initiatives, are: To avoid deselection of PVC by major customers, and To prevent punitive regulation of PVC by EPA, Congress, or the state legislatures; The short term objective of the plan is: To mitigate the effects ofpotential negative press coverage by positioning the vinyl industry as a proactive and cooperative entity, working in tandem with EPA to characterize and minimize sources of dioxin. The following crisis action plan addresses specifically the release of the dioxin report and the media that is likely to surround the release. Longer term strategies to work with EPA and Congress to prevent onerous regulation are already underway, through: Proactive liaison with EPA in relation to the ongoing study of dioxin. Aggressive grassroots communications and mobilization to educate and inform policy influentials about the benefits of PVC. Active communications with customer trade groups to positively position vinyl in order to preempt consideration of product deselection. Media relations and communications activities to support the positive positioning on PVC in the marketplace, with customers and ultimately with issueattentive consumers. This draft document is ]]Q1 intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 2 CTL014238 ii. Basic rules of crisis communications l) Once an industry is widely perceived to be the source of a PROBLEM (THE CRISIS CATALYST), IT HAS LITTLE CHOICE BUT TO POSITION ITSELF AS THE SOURCE OF THE SOLUTION. If our intelligence is correct, it is highly likely that EPA's dioxin reassessment will single out PVC as a primary source of dioxin throughout its life cycle. Because PVC is ubiquitous and easily found in homes and offices, the media are likely to highlight its alleged role as a dioxin contributor. Therefore, the vinyl industry must actively and aggressively communicate with the media its commitment to working with EPA to characterize and minimize any dioxin in the PVC life cycle, while at the same time asserting that based on reliable data available to date, the industry believes its contribution is minimal. Cooperative positioning is the key element; solely asserting that PVC is a minor contributor to the problem will only serve to misposition the industry as uncaring and unresponsive in the minds of targeted audiences. 2) NEVER ALLOW INACCURATE OR MISLEADING CLAIMS ABOUT A PRODUCT, SERVICE, OR CORPORATION TO GO UNCHALLENGED. LEFT UNCHALLENGED OVER TIME, BOGUS CLAIMS WILL BE PERCEIVED AS TRUE -- REGARDLESS OF THE SOURCE. While it is highly likely that Greenpeace will be seeking to position PVC as a primary villain in the dioxin debate and that they will use data quoted in "Achieving Zero Dioxin" to support their claims, we do not recommend that the data be refuted on a caseby-case, data point-by-data point basis. We do strongly urge VI to aggressively defend the industry's credibility through the use of third party sources to debunk Greenpeace's -- or even EPA's -- misleading claims. Allegations against vinyl can be debunked through a number of tactics; however, engaging in a data point by data point debate is not an effective means of challenging misinformation. This draft document is not intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezcnhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United Slates of America. 3 CTL014239 3) WHEN EVALUATING THE MARKET RISK POTENTIAL OF A CRISIS CATALYST INVOLVING A QUANTIFIABLE HAZARD, ALWAYS REMEMBER THAT WHILE THE HAZARD MAY BE STATISTICALLY INSIGNIFICANT, IF IT AFFECTS VULNERABLE POPULATIONS, THE POTENTIAL FOR MARKET RISK IS SIGNIFICANT. While we know that the data Greenpeace uses to categorize the vinyl industry's dioxin contribution is inaccurate, any statistic that shows a link between PVC and dioxin, no matter how insignificant, is damaging in the sense that dioxin harms ihs most vulnerable population -- unborn children. Therefore, the industry must not discount the dioxin problem as statistically insignificant and therefore a non-issue, but must be positioned as a responsive and proactive player working with EPA towards a solution. The most effective message VI can deliver to respond to Greenpeace and leverage its own position in the dioxin debate is the following: The vinyl industry supports EPA's objective of identifying and reducing dioxin emissions and is working with EPA to determine the best means ofachieving that goal. Available data indicates that our dioxin emissions are very minimal today and we will work with EPA to further reduce them. Through this key message, to be reiterated in all media communications, VI gains credibility and therefore, can position itself as a responsive, responsible participant in the debate. Without stating its position to support EPA and respond to potential dioxin problems, VI will be perceived as insensitive at best given the effects of dioxin. 4) IF A CRISIS CATALYST HAS THE POTENTIAL FOR SIGNIFICANT MEDIA EXPOSURE, THE PRIMARY OBJECTIVE MUST BE TO REDUCE THE HALF-LIFE This draft document is uqI intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 4 CTL014240 OF MEDIA COVERAGE, AVOIDING ANY ACTION THAT EXTENDS THE LIFE OF THE STORY. This draft document is uqi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 5 CTLO14241 Victims of adversarial attacks often compound the damage they SUSTAIN IN THE MARKETPLACE BY VENTING THEIR ANGER AT ADVERSARIES THROUGH THE MEDIA. THE RESULT IS EXTENDED COVERAGE THAT INCREASES THE MAGNITUDE OF AUDIENCE RESPONSE. All communications with the media must be geared towards addressing the dioxin issue and positioning the vinyl industry as responsive and cooperative. The temptation will be to attack Greenpeace's position on the issue and to question their motivation, data and tactics. To do so, however, could raise the media coverage of the Dioxin Reassessment and threaten the credibility of the vinyl industry. VI cannot be seen as waging war with Greenpeace through the media. While bogus claims must be challenged, Greenpeace must be challenged by third party sources that are respected and credible. 5. AUDIENCES TAKE PERCEIVED BENEFITS INTO ACCOUNT WHEN REACTING TO CONTROVERSY ABOUT A PRODUCT OR INDUSTRY. Supporting messages in all communications must drive up the benefits of PVC products. Targeted audiences are less likely to react irrationally to negative media coverage if the benefits of PVC are clearly stated and universally recognized. For example, a policy maker is less likely to support Greenpeace's position of "ban PVC" if he or she understands the economic benefits of vinyl to his/her constituents. Therefore, when responding to media inquiries, all spokespersons should be urged to weave in a benefits message to support the key message in their response. This draft document is noi intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 6 CTL014242 ill. Messages A. KEY MESSAGE The vinyl industry supports EPA's objective of identifying and cutting dioxin emissions and is working with EPA to determine the best means of achieving that goal. Available data indicates that our dioxin emissions are minimal today and we will work with EPA to further reduce them. B. Supporting Messages Vinyl is an environmentally safe material, from production through use and disposal. The vinyl industry and its direct customers employ more than 100,000 people. The sales value of vinyl products is more than $3.8 billion. PVC in most applications is the safest, most cost-efficient product available. PVC is everywhere, used in a wide range of applications PVC is used in everything from toys to Venetian blinds, from wire insulation to floor and wall coverings, from automotive parts, refrigerators and air conditioners to disposable hospital gloves and blood bags. PVC is used in construction, packaging, automotive, furniture, medical and other industries because of its durability, ease of processing and intrinsically safe nature. This draft document is hqi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United Stales of America. 7 CTL014243 rv. Crisis a ction team Bill Carroll, oxychem and the Chlorine chemistry Council Margaret Rogers, Dow Chemical Fred Krause, the Geon Company Mike Reynolds, vista Chemical bob Burnett, The vinyl Institute Nora Jacobs, Edward Howard THERESA TERMINE, NICHOLS DEZENHALL primary Spokespersons: bob Burnett, Executive Director, VI bill patient, Chairman & CEO, Geon The Role of the Crisis action Team A. The Crisis Action Team will be responsible for. 1. Determining when a crisis situation exists. 2. Evaluating crisis management strategies and tactics appropriate to specific crisis situations. 3. Marshaling the VI resources needed to effectively respond to crisis scenarios. 4. Managing the day-to-day execution of crisis communications strategies and tactics. The crisis communications team must have the complete authority to make minute-by-minute decisions; to determine what messages to relay to targeted media; to activate third party sources and to authorize customer communications to educate and inform targeted audiences about the Dioxin Reassessment and VI activities. This draft document is na intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 8 CTL014244 B. Speak with One Voice To the extent possible within the framework of the Vinyl Institute and the other industry players in the PVC/Chlorine debate (the Chlorine Chemistry Council, the Society of the Plastics Industries, the American Plastics Council, etc.), an industry spokesperson should be designated as the "official" industry information source on dioxin and PVC. In the event of extended media coverage, member companies and allied trade associations should be urged to refer all vinyl-specific inquiries to the designated VI spokesperson. Efforts should be made to selectively inform the media of the identity/location of the designated spokesperson. This strategy limits the potential for miscommunication and ensures the delivery of appropriate messages. Key messages and talking points should be forwarded well in advance of September 13th to member companies to prepare their headquarters and local plant managers for potential calls from local media. Local response to local media inquiry is important, and must be consistent with Vi's national media strategy. C. Deliver a Consistent Message In a crisis situation, adversaries and reporters often apply a divide-and-conquer strategy, aimed at fragmenting industry and compromising their credibility. News correspondents relish the opportunity to report that factions of an industry coalition disagree on the facts and differ on major policy considerations. Thus, immediate action must be taken to inform all members of VI of key message points and strategies, as well as the role of the industry spokesperson in addressing media inquiries. Member companies should be encouraged to inform key employees of the messages as well. This draft document is uqi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dczenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 9 CTL014245 V. Pre-Event tactics In order to be best prepared for media coverage and inquiries surrounding the September 13th EPA release, several communications tactics must be implemented immediately. (Most of the following are already underway be either Edward Howard, Nichols Dezenhall or both.) A. Intelligence Gathering All resources should be employed to gather information regarding Greenpeace's activities prior to the release and immediately after the release. Additionally, early information regarding the contents of the EPA report should be obtained, if at all possible, to assist in structuring VI message points in response. B. Media Monitoring Major media and the day books should be closely monitored for advance information about the report and any planned media events by Greenpeace. Additionally, the crisis action team may want to consider briefing targeted reporters likely to cover the EPA release prior to September 13th if information indicates PVC will be addressed in detail. C. Customer Communications Customers -- both PVC fabricators (processors) and the trade groups representing major end users -- should be informed well in advance of the release of the EPA report of its expected conclusions, relevance to the industry and ramifications. The purpose of these communications is to educate and reassure, and all communications should be followed up after the report is released at the discretion of the crisis action team. Copies of all customer communications should be distributed to all VI members. This draft document is noi intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dc/.cnhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 10 CTL014246 D. Intra-Industry Communications VI member companies and their employees, as well as allied trade associations (particularly CCC and SPI), should also be informed well in advance of VI positions and activities in relation to the release of the Reassessment. Particular care should be taken to inform allied associations of key messages to be communicated by VI to ensure that VI is recognized as the sole spokesperson on PVC as it relates to the report. Members company and employee communications should be directed at educating and informing targeted audiences of the claims likely to be made in the report and by Greenpeace, VI response to those claims and VI activities to protect PVC in the media and the marketplace. E. Media Advisory A carefully worded media advisory should be prepared and disseminated to targeted media on September 9th, the Friday before the EPA's release. The media advisory should briefly identify the VI spokespersons and their locations/phone numbers in the event of inquiries relating to vinyl and the EPA report. The advisory clearly establishes VI spokespersons as the official source for the industry and establishes Vi's leadership role for the industry. This draft document is uoi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dczenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United Slates of America. 11 CTL014247 VI. Crisis Scenarios A. SCENARIO One Report is released with wide press coverage. EPA states that dioxin IS A HEALTH HAZARD, CONCLUDES THAT PVC IS A PRIMARY SOURCE OF DIOXIN AND THAT EPA WILL STUDY PVC FROM CRADLE TO GRAVE FOR FUTURE POLICY RECOMMENDATIONS. Responses Main Strategy: To embrace the EPA recommendations of characterization and minimization, positioning VI as working cooperatively with EPA. The primary spokespersons in this scenario are VI officials responding directly. In this scenario, EPA stimulates the coverage of the dioxin report, rather than Greenpeace or another advocacy group. VI must, therefore, position itself as a cooperative and responsive working in tandem with EPA. The steps to communicate this message are as follows: 1. Media Relations -- Every attempt should be made by VI to respond to all media inquiries through an official spokesperson. Additionally, if the content of the EPA report indicates a need, a brief media statement should be widely circulated. Supporting messages include: While we don't agree with everything that EPA has stated in its report, we share EPA's concern that dioxin may be a serious problem and will work with EPA to seek means of reducing dioxin. Note: This message point is likely to beg the question "What don't you agree with in the EPA report" and allows the VI to challenge inaccurate information. We do not recommend that specific data should be challenged, rather, that two or three overall questions be raised if appropriate. This draft document is uqi intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dczenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 12 CTL014248  We believe EPA has acted responsibly in beginning to research this matter and agree that further study is needed. We disagree with Greenpeace that EPA has not gone far enough. More data must be gathered before EPA can; industry will work with EPA to do so. 3. Third Party Support -- While we strongly recommend that VI not challenge the EPA science in the report, we do believe third party sources should be used to do so. Industry spokespersons should have a list of sources available to supply reporters to ensure that non-industry scientists address the accuracy of the science. 4. Customer Communications Follow-Up -- The crisis action team should determine the talking points for a mailing to PVC fabricators and trade groups post the release of the report, along with a statement of VI activities and position in relation to dioxin. This mailing should be sent by September 19th at the latest. 5. Intra-Industry Follow-Up -- The crisis action team should directly inform allied trade associations of the media coverage and VI response, as well as VI future actions to be taken with EPA and others in relation to the dioxin issue. Communications should underscore Vi's role as sole spokesperson for the industry, but keep allies in the communications process. Member companies and employees should also be provided with a summary of the coverage and VI activities in order to educate, highlight key messages and reassure employees on the issues. This draft document is uqi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 13 CTL014249 B. SCENARIO TWO Greenpeace, in conjunction with other environmental and health GROUPS, PREEMPTS THE EPA RELEASE WITH A PRESS CONFERENCE THE DAY BEFORE, SUMMARIZING THE RESULTS OF "ACHIEVING ZERO DIOXIN", TAKING EPA TO TASK FOR NOT GOING FAR ENOUGH WITH THE DIOXIN REPORT AND CALLING FOR A ZERO EMISSIONS POLICY ALONG WITH A BAN ON PVC. Responses: Main strategy: VI must provide EPA with support for acting responsibly in its report while at the same time unleashing a number of third party scientists to attack Greenpeace's science and allegations. The primary spokepersons in this scenario should be third party sources. In this scenario, it is Greenpeace that stimulates the coverage by preempting EPA's release of the Dioxin Reassessment. In all likelihood, Greenpeace will attack EPA for not going far enough, which may have the result of driving EPA towards industry. Tactics to implement this strategy include: 1. Issue a Media Statement -- The vinyl industry can capitalize on this by positioning itself in support of the EPA's efforts by stating: We believe EPA has acted responsibly in beginning to research this matter and agree that further study is needed. We disagree with Greenpeace that EPA has not gone far enough. More data must be gathered before EPA can effectively respond to a potential dioxin problem; industry will work with EPA to gather those data. 2. Media Relations -- Aggressive media relations efforts should be undertaken to direct reporters to third party sources that will refute Greenpeace's claims, providing reporters with sources and more information. This draft document is noi intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dczenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 14 CTL014250 3. Third Party Support -- A high-profile third party source (CATO Institute, etc.) should be used to counter Greenpeace claims, either directly on September 13th and/or immediately thereafter through op-ed coverage. 4. Customer Communications Follow-Up -- The crisis action team should determine the talking points for a mailing to PVC fabricators and trade groups post the release of the report, along with a statement of VI activities and position in relation to dioxin. This mailing should be sent by September 19th at the latest. 5. Intra-Industry Follow-Up -- The crisis action team should directly inform allied trade associations of the media coverage and VI response, as well as VI future actions to be taken with EPA and others in relation to the dioxin issue. Communications should underscore Vi's role as sole spokesperson for the industry, but keep allies in the communications process. Member companies and employees should also be provided with a summary of the coverage and VI activities in order to educate, highlight key messages and reassure employees on the issues. This draft document is qq! intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 15 CTL0l425i c. Scenario Three EPA RELEASE STATES THAT DIOXIN IS A PROBLEM AND THE FUTURE STUDY IS NEEDED TO CHARACTERIZE SOURCES OF DIOXIN. INCINERATION WILL BE HIGHLIGHTED AS THE MAJOR SOURCE, WITH PVC BRIEFLY MENTIONED. Responses: Main strategy: Do nothing. Because the EPA release does not target PVC as a primary source of dioxin, nothing should be done to raise the industry's profile in the debate. 1. Responsive Media Relations -- However, the crisis action team must be prepared to respond to any media inquiries, reiterating the key message: The vinyl industry supports EPA's objective of characterizing and minimizing dioxin emissions to the greatest extent feasible and is working with EPA to determine the best means of achieving that goal. We believe our contribution to the dioxin problem to be minimal, and we will strive to significantly reduce those levels. 2. Prepare a Media Statement -- A brief statement should be prepared and disseminated to reporters upon inquiry to ensure that the industry's voice is heard if the PVC angle is played in any media coverage. 3. Third Party Support -- The crisis action team should be prepared to direct reporters towards third party sources to address issues relating to the science. Intelligence gathering efforts should be made to assess the direction media might take in covering the report and responses prepared for any Greenpeace allegations made in response to the release. If Greenpeace attacks the release after-the-fact in a news release, the crisis action team should utilize third party sources to refute their claims. (See scenario two). 4. Customer Communications Follow-Up -- The crisis action team should determine the talking points for a mailing to PVC fabricators and trade groups post the This draft document is not intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezcnhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 16 CTL014252 release of the report, along with a statement of VI activities and position in relation to dioxin. This mailing should be sent by September 19th at the latest. 5. Intra-Industry Follow-Up -- The crisis action team should directly inform allied trade associations of the media coverage and VI response, as well as VI future actions to be taken with EPA and others in relation to the dioxin issue. Communications should underscore Vi's role as sole spokesperson for the industry, but keep allies in the communications process. Member companies and employees should also be provided with a summary of the coverage and VI activities in order to educate, highlight key messages and reassure employees on the issues. This draft document is not intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United Slates of America. 17 CTL014253 Media Questions and answers Q. Greenpeace claims that vinyl is the largest source of dioxin. What are you doing to eliminate dioxin in your production process and in your products? Q. Greenpeace claims that the only solution to the dioxin problem is a zero emissions policy and a complete phase-out of PVC. How do your respond to this? Q. Greenpeace alleges that PVC may account for up to one-third of all dioxin foimed. What data does the industry have to refute this allegation? Q. It has been reported that a recent Swedish study indicated that PVC plastic itself is contaminated with measurable quantities of dioxins and furans, which may leach into our food and water. What levels have been found in U.S. produced PVC? Q. PVC is the largest waste source associated with dioxin emissions in hospital waste incinerators. Shouldn't PVC be banned from hospital incinerators at a minimum and phased-out of use in pharmaceuticals ultimately? Q. How much dioxin is in chlorine? In the monomer? In PVC plastic? Q. Doesn't PVC produce dioxin in incineration? Q. Does dioxin leach from PVC in landfills? Q. Are fabricators and their employees at risk from processing fumes? Q. How much dioxin leaches from food packaging? Q. Does dioxin from PVC contaminate other recyclable commodities? Q. Doesn't PVC cause cancer in its own right anyway? This draft document is bqi intended for publication. This document does not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 18 CTL014254 Q. Are estrogenic chemicals other than dioxin involved with PVC? Q. What do your members do with their toxic waste sites that contain PVC, and therefore, dioxin? Q. How much dioxin is produced from member companies' onsite incinerators? Isn't this a risk for neighboring communities? Q. You say that industry does not have data for a number of these issues. Why is industry afraid to collect the data? Shouldn't you have this information on hand? Q. How long have you known that PVC has a problem with dioxin? Q. EPA wants to study PVC from "cradle to grave." Doesn't this mean that PVC is dangerous in all aspects of production, use and disposal? Q. Since PVC is just a dump for accumulated chlorine, is it also just a sink for nondisposable dioxin? Q. What other toxic products are made in the EDC/VCM/PVC process? Q. Burning PVC kills house occupants. Since fire is a larger risk in poor areas, isn't the long term threat from accumulated dioxin an environmental equity issue? The following are incendiary questions that could be raised by antagonistic reporters: Q. You say that dioxin emissions linked to your industry are minimal. Do you have any evidence to back-up that claim? Q. If dioxin emissions linked to your industry are minimal, why do you suppose that the EPA and numerous environmental groups are targeting PVC as a major source of dioxin? This draft document is not intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 19 CTL014255 Q. Have you shared your evidence that your industry only produces minimal dioxin emissions with EPA and the environmental groups? Q. If you haven't, why? Q. If you have, than it follows that either the EPA does not believe your research or that it is misleading the public about your industry -- which is it? Q. Isn't it a fact that there are viable substitutes for PVC available in all applications and if that is true, doesn't it make sense to ban PVC until scientists determine whether you have a dioxin problem? Q. If you find our that you have a significant problem with dioxin, will you agree to have your product banned or severely restricted in the marketplace until the problem is solved? Q. If dioxin is as bad as the EPA claims, why don't you support Greenpeace's zero emissions goal? Q. By not supporting a zero emissions goal, you imply that some dioxin emissions are O.K. How much dioxin released to the environment is O.K. from your perspective? Q. The EPA and environmental groups say there are no tolerable levels of dioxin, that any amount of dioxin is dangerous to human health. Your industry does not support a zero emissions goal. This suggests you are prepared to accept some dioxin casualties. How many injuries from dioxin are acceptable to your industry? Q. Your industry has worked miracles with plastics, why can't you reduce emissions of dioxin to zero by 2005? Q. Does your industry agree or disagree that dioxin is a threat to human health? This draft document is not intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dczenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 20 CTL014256 Q. If dioxin is a threat to human health, why has it taken you so long to get involved in finding a solution? This draft document is noi intended for publication. This document docs not necessarily reflect the views or policies of the Vinyl Institute. Nichols Dezenhall Communications Management Group, Ltd., is solely responsible for the information contained in this document. Any unauthorized release, publication or distribution of this document may violate the copyright laws of the United States of America. 21 CTL014257