Document 152opaRMxo7Y4z9bKYrmdaz1q

THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 230 PARK AVENUE NEW YORK. NEW YORK 10017 212/687-2673 MINUTES AD HOC NITRILE BARRIER RESIN COMMITTEE Airport Hotel Philadelphia, Pa. June 14, 1973 11:00 A. M. Attendees: George Berry, Borg-Warner Co. P.O. Box 68, Washington, W.Va. 26181 Ken Burgess, Dow Chemical Co., Midland, Mich. 48640 Jim Coleman, ICI America, Inc., Wilmington, Del. 19899 Roland DiLeone, American Cyanamid, 1937 West Main St., Stamord, Conn. 06904 A. J. Haefner, Ethyl Corp., Box 391, Baton Rouge, La. 70821 R. L. Harding, SPI, 250 Park Ave., New York, N.Y. 10017 Jerome H. Heckman, Keller & Heckman, 1150 17th St., M.W., Washington, D. C. 2003 Gordon Klddoo, Vistron Corp., 1608 Midland Bldg., Cleveland, Ohio 44115 J. R. Lawrence, SPI, 250 Park Ave., New York, N.Y. 10017 Clarence Neher, Ethyl Corp., Baton Rouge, La. 70801 W. T. Nelson, E. I. DuPont, Plastics Dept., Wilmington, Del. 19898 H. J. Schneider, Rohm end Haae Co., Independence Mall West, Phllsdelphle, Pa. 19105 Ell Schwartz, Uniroyal Chemical, Elm St., Naugatuck, Conn. 06511 Fred Shlmmere, Borg-Warner, P.O. Box 68, Washington, W. Ve. 26181 F. D. Wharton,Jr., Monsanto Co., 800 N. Llndberg Blvd., St. Louis, Mo. 63166 1. Mr. Klddoo, as Chairman of the Ad Hoc Nitrile Barrier Realn Consittee, collet the meeting to order at 11:00 A.M. and asked for self introdmetiomm of thoso in attendance. 2- ttov Harding gave some background on the organisation of this Committee msetlng and the role that Gordon Klddoo had played in initiating the action. Mr. Heckman than brought tha group up to data on the action by FDA to require'an environmental Impact analytic report on plastics food packaging natarlala. In addition to rafarrlng to tha FDA order published in tha Federal Register on March 15, 1973, Mr. Heckman re ferred to the proposal balng made by Mr. Hutt of FDA to make an en vironmental impact analysis report requirement retroactive for materials cleared or exempted in some way by FDA prior to March 15, 1973. Mr. Heckman's analysis of tUa proposed requirement is covered In the SPI-23882 Ad Hoc Nitrile Barrier Resin Committee P2 attached memorandum of May 22, Co the SPI Food, Drug and Cosmetic Packaging Materials Coonittee. Mr. Heckman indicated his belief that, at least as a starter, It can be assumed Mr. Hutt appears most concerned about soft drink and beer bottles. Therefore, in a discussion with Mr. Hutt on June 11, It was Indicated that FDA would consider a proposal to hold back on requiring environmental impact analysis reports on other bottle resins, most of which are regulated or prior sanctioned materials if the industry will pro ceed with an environmental impact analysis report on materials used to make carbonated soft drink and beer bottles as the first in a series of analyses that might eventually Include all packaging. Mr. Heckman indicated that Mr. Hutt appears to be inclined to pro ceed in this fashion if the Industry could respond with an environ mental impact analysis report on such bottles within a period of 90 days after FDA Issues such a regulation. He further indicated that he had promised Mr. Hutt that ha would talk with him on June 19 to indicate what action this coonittee would be in position to Cake with respect to developing en environmental impact analysis report on carbonated soft drink and beer bottles. 3. Mr. Harding Indicated that there hed been e precedent In the Public Affelrs Council of SPI covering the expenses Involved in petitioning the Bureeu of Alcohol, Tobacco and Firearms on PVC for liquor bottles. He indlceted thet he would review this matter with PAC to determine its willingness to cover the extra legal end staff expenses required to develop such e report for FDA. 4. Mr. Klddoo suggested thet the definition of the resins to be Included in this environmental impact report be made sufficiently broad to cover ell the reelne thet currently sees to be candidates for this epplicetion. 5. Mr. Klddoo Indicated that Vlstron would be willing to share the in formation It has developed that might be useful in developing the mnvixonmentai impact report. He further explained that hie company's voetr qoo covers a number of outside studies on the incineration end environmental waste aspects of their nitrile reelne systems. 6. A consensus poll was taken on the concept of a cooperative effort to develop an environmental impact analysis report on nitrile type resins. The following companies Indicated their willingness to cooperate in such en effort: Dow, Uniroyal, Rchs end Haas, DuPont, American Cyenemid, Monsanto, Ethyl end Borg-Vamer. Mr. Coleman, representing ICI America, said that ha wee not In a position to make e statement on consensus since he represented the interest of ICI In England for whom he wee not authorized to speak. Of those co^eniee Indicating willing ness to cooperate in the development of en environmental Impact SPI-23883 Ad Hoe Nitrile Barrier Resin Coganttteft p. 3 analysis report the following companies indicated that thay have information that they think would be directly applicable and that they would be willing to share this information in the cooperative effort: Borg-Warner, DuPont (an environmental Impact analysis report had already been prepared on their resin and submitted to EPA), Monsanto and Vistron, 7. On the basis of the response of the companies present, Mr. Heckman feels that we may have sufficient background Information on these resins to innediately proceed in the preparation of a draft report for review. Therefore, it was agreed that those companies having such information would make it available to Mr. Heckman for the preparation of a draft report. He anticipated that he could have such a draft report ready for review some time in August, or within 45 days of the Issuance of a notice by FDA that such an environmental impact analysis report would be required on plastics bottles for soft drinks and beer. It was further anticipated that the final report might be ready to submit to FDA by the end of September if this would be the deadline of their 90 day notice period. The working conn* ittee Chat will meet with Mr. Heckman to review his draft will in clude the following: Borg-Warner DuPont Monsanto Vistron SPI Fred shlnnera D. E. Maloney Fred Wharton Larry Wenta John Lawrence The working committee would meet with Mr. Heckman to ravlaw hla Initial draft within a week of its issuance. After the working comeittee completes its work on the draft it will be circulated to the full committee represented by the companies attending this meeting. Broader circulation of thla draft to other intereated parties would be held up pending review of the report by the Ad Hoc Nitrile Barrier Resin Coortttae. 8. It warn agreed that coplee of the Mlnutee of today'e meeting would be mad*available to SPI members with an interest In molding such bottles. Tftaan seme companies would be given an opportunity to review the en vironmental impact analysis report prior to Its submission to PDA. Respectfully submitted, John R. Lawrence Director, Technical Liaison JRL:mJh SP1-23884