Document 1QXR3YXxoewp0YpJvxEdepYj5

w/gThe IW#mgInVsintiytul te A Division of The Society of The Plastics industry, Inc. NOTED KAY 2 5 1990 JGL May 21, 1990 TO: The VI Health, safety & Environment committee RE: Standardization on Tank Car Valves At the May 10th committee meeting, a number of issues were noted during the discussion of a mutual aid response program. The attached letter from Peter de la Cruz of Keller and HecJcman to Committee Chairman Frank Borrelli clearly reviews SPI policy as it relates to the promulgation of standards. If you have any questions, please let me know. RTG/pmb cc: P. de la Cruz BOR 014327 Wayne Interchange Plaza II 155 Route 46 Wes/ Wayne, NJ 07470 (201) 890-9299 Fax #(201) 890-7029 JOBCHM c KCLLCft jCPOhCH HtCKMAN wiwuH h bohohebaml >. MALCOLM o watmcv black tCHMCMCC B. JOMCt MABTIM W. BCBCOviCt JOMH B. CLB*CO cabqlc c. ha<i U*T MATMA H*AMAA HlCHAtL HODAOMC MAN rOK EVCMS JOHN NtCHAAClt JOHN U, DUBCCK CTC* L. kA CftVt r.MftlfTlMC M. BILL MCLVIH S. DBOZEN SHINLCV B. fWIMOTO lawkcmcc a. nalamn ALMM A. tIHHONI PITCH A. BUSBEH e. oouolab hot AOMITTC0 tH 0,C. IHflkA A MILLAP PwTPlCK J huaq BCOPQC O MICRO mcBCBiCK j oat. j" MAflCIA A CONAN s cn*ic tautnmt haDN a. BICVCPB MlCHACL - BCHMCT a. PAAWKLtH MOOMT* CATHCPIMC H ftOCMC* ICNAND A. JAPPC* jcprpCT s ninn KRIS AHHC mOHTCITH CLLIOT IEULOI IhannOnL OChmAH CUBAN t POK* MAIN l_ ITZKOPP cEdwin Mount' MAlC BCHCJKA UUBTin P mcCAHTMT kcmmctn a, olbcn jcpppct b lamb* LAW OFFICES Keller and Heckman 115 0 17TM STREET. K.w. SUITE lOOO WASHINGTON. D.C. 20030 (202) eso-ssoo May 15, 1990 vO SCIENTIFIC STAPP t oahicl s oixlcp. p- ft ChaPLCS v BBCOCB. P- O BOBCHt A maTmCWS. Ih JOHN p MODOCBMAN. In, O MOLLY MUTMIKE rOLCT JUSTIN c. POWtLL. I- O TELECOMMUNICATION* cnginec* enables p yubncb telex MB BBBBI TCLCCOPIC* <ZOS> ?** -- CABLE AOOHESO "KCLMAW WBlTE*'* INECT Dial NUMBER (202) 956-5641 Mr. Frank E. Borrelli Georgia Gulf Corporation 42C Read's Way New Castle Corporate Commons New Castle, Delaware 19720 Re: Standardization on Tank Car Valves Dear Frank: At the Vinyl Institute Health Safety and Environment committee meeting on May 10, 1990, the Committee discussed rail safety issues. Among other things, the Committee noted that different valves are used on tank cars that transport vinyl chloride. To facilitate the work of emergency response teams, it was suggested that the same valves might be used uniformly. No formal action was taken at the Committee meeting, but it was anticipated that interested companies would explore the formation of a mutual aid response program. The emergency response activity would not be an SPI function but rather under the auspices of the Chemical Manufacturers Association (CMA) or an independent collaborative effort by participating vinyl chloride producers. In your capacity as Committee Chairman, I wanted to remind you that SPI has a long-standing policy of not promulgating standards. When members agree that a standard is needed in a particular area, the concerned SPI group may develop a guideline or recommended practice following procedures that provide for wide notice and opportunity for comment. The guidelines are then submitted as a proposal to a recognized standards-making organization such as ASTM, Inc. or the American National Standards Institute (ANSI). Conceivably, this might ultimately become a Department of Transportation regulation or guideline. BOR 014328 , Mr. Frank E. Borrelli May 15, 1990 Page Two Keller and Heckhan Obviously, member company interest in this matter is motivated solely by public safety concerns and is to be applauded. However, I did want you to be sensitive to the potential antitrust ramifications. If you have any comments or questions or if 1 can be of any assistance, please feel free to call. Cordially yours, cc: Robert D. Luss, Esq. Larry Thomas Robert W. Sherman Meredith Scheck Peter L. de la Cruz BOR 014329