Document 0Jrrm0ekzj2XxL7N8N4DrEjjd

agenda PVC SAFETY GROUP STEERING COMMITTEE Tuesday, February 28, 1978 8:30 A.M. The Sheraton Hopkins Hotel Cleveland, OHIO I. EPA Activities Status of Proposed VC Amendments Cancer Policy Review . Hearing (March 23) . Other industry response (MCA, AIHC, SOCMA, SPI Toxicity Committee) . Enforcement Manual II. Committee Activities . Health Committee . Communications Committee . PVC Fire Safety Committee . Nominating Committee Financial Report III. Risk-Benefit Concepts Open discussion including comments by Professor Richard Wilson IV. Other Business V. Next Meeting of the Steering Committee VI. Adj ournment THE SOCIETY OF THE PLASTICS INDUSTRY. INC 355 Lexington Avenue Ne>.\ York. N.Y. 10017 (212; 573-9400 SPI-08648 The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York. New York 10017 (212) 573 9400 March 10, 1978 TO: THE PVC SAFETY GROUP Gentlemen: Please note as indicated in the Minutes of the PVC Steering and Communications Committees, it is planned that the PVC Safety Group will take part in the EPA meeting scheduled for March 23 at the EPA offices, Waterside Mall, 410 M. Street, S.W. Washington, D.C. Room 3906 at 8:30 A.M. It would be advisable to have a representative from your company attend this meeting if at all possible. You can expect that a draft of the presentation material will be sent to your attention about March 20. Very truly yours. John R. Lawrence Technical Director JRL:gm SPI-08649 Beveridge. Fairbanks 6. Diamond 2/24/78 Proposed Work Plan for the SPI Presentation at the EPA March 23 Hearing on Generic Regulation of Carcinogenic Air Pollutants I. Overall Approach EPA has announced that it intends in its March 23 hearing to solicit recommendations leading to possible development of a proposed generic cancer policy for airborne carcinogens. It may be desirable simply to put EPA on notice that SPI intends to be heard force fully on EPA's cancer policy, address the eight questions EPA posed in its amendment, and then raise the literally dozens of questions posed by EDF's petition. We should indicate that the Agency needs far more time and addi tional meetings before it could possibly consider pro posing any new scheme. II. Committee Work Needed Before March 23. A. Policy Considerations 1. Whether to seek a delay of the March 23 hearing or to press for prompt EPA action because EPA's current policy is acceptable. 2. Development of an approach to EDF's proposal for a classifi cation scheme for airborne carcinogens; consider how to distinguish EPA concerns from OSHA. 3. Coordinate approach of the AIHC proposal with prior industry position at EPA. 4. How to challenge EDF's presen tation of the "Vinyl Chloride Story." How to treat EDF's statistics and such issues as substitutes, threshold, zero emissions, extrapolation of animal data to humans, repli cation, and offset. SPI-08650 2 B. Technical and Health By March 10, 1978, SPI should have papers pre pared analyzing the EDF proposal in detail (state ment by statement), raise all of the questions necessary to challenge that proposal, and consider an appropriate answer or alternative to the EDF proposal. Among the overriding issues are: 1. To what degree and in what manner should EDF cancer statistics be . challenged? 2. V.'hat information is available to rebut, correct, supplement the studies relied upon by EDF? 3. What position should be taken with re gard to EDF's non-threshold and zero emission theories? 4. What implications are there to the off-set policy? 5. What assumptions/facts does EDF rely upon which are erroneous? 6. What is wrong with EDF's proposed regulatory scheme both theoretically and, assuming implementation, from a practical standpoint? C. Legal The Legal Committee should March 10 a review of the legal arc posed by the EDF petition. issues are: complete by questions which Among the 1. What is the interrelationship of EPA's authority under the Clean Air Act and the Toxic Substances Control Act, the Federal Insecticide, Fungicide and Hodontici.de Act, the Federal Water Pollution Control Act and related laws and regula tions? SI'I-08651 3 2. Can EDF's scheme of relying on Section 111 to regulate new sources of Category II substances be effectuated? 3. What procedural safeguards are necessary under any regulatory scheme? III. Presentation at Hearing A. Background. Establish setting for the hearing; identify the key parties; establish SPI stature, experience and standing. B. Present policy statement, consistent with overall approach outlined above. C. Consider having technical, medical, scientific and legal experts available to testify. D. Consider submission of key policy, factual and legal issues and questions raised by EDF petition and the prospect of EPA action. E. Call for further informal meetings before decision on whether to even propose regulations. F. Establish groundrules if regulations are proposed, such as right of cross-examination. IV. Other Issues A. Consider filing a Freedom of Information Act request to obtain (a) all EPA cancer policy docu ments which led to its May 1976, statement, and any new information the Agency lias received on this subject relevant to the EDF proposal. B. Establish procedures for liaison with AIHC. C. Schedule of meetings. D. Establishment of committees and selection of chairpi' rsons. E. Coordination of expert witnesses with A1IIC. 1. Oral presentation. 2. Written submission. . SPI-08652 SPI-PVC & VCM PRODUCERS GROUP SOURCE & DISPOSITION OF FUNDS AS OF 12-31-77 SOURCE: AMOUNT 1. Carryover (Loss) From 1976/77 Operations-Per Ledger Print-Out Plus: Duplicate Entry of Allied Chem.Payment Less: Assessments Paid-Not Recorded on Ledger Great American Chemical Hooker Chemical Net (Loss) Carryover from 1976-1977 $(28784.58) ( 2460.00) 912.00 --1.67.1 5Q $(30165.08) 2. Assessments: Total Assmt. Assmt._____ Paid Net Assmt. Due Si 1976/77 Assessment No.3 Si00000.00 Si00000.00 b. 1977/78 Assessment No.1 250000.00 244512.50 c. 1977/78 Assessment No.2 394100.00 - Total Assessment Income $3^512.50 Net Assessments Receivable Per Attached Detail $5487.50 394100.00 344512.50 $399587.50 399587.50 3. Meeting Income: 380.00 Total Funds Available - 12-31-77 $714314.92 DISPOSITION: 1. Current Year Expenses: * Legal Expense - Paid thru 12-31-77 $204711.76 - Accrued for December 12366.80 Public Relations Expense-Paid thru 12-31-77 S 95076.52 -Accrued for December 10756.73 Meeting Expense (Incl. Travel) Research & Development Expense Office Supplies & Expense Telephone & Telegraph Expense Total Expense thru 12-31-77 $217078.56 105833.25 6777.92 33018.67 896.47 1502.45 $365107.32 Net Funds Available at 12-31-77 $349207.60 SPI-08653