Document 1gG0Y9Dgqgdpmw6w5g0D1oG8o

TO: Rick Johnson eTf ^joTrf lt(HXF: ______ Interoffice Communication FROM: DATE: SUBJ: E. R. Taylor November 22, 1989 SARA 313 CUSTOMER NOTIFICATIONS VISIA The EPA, under Section 313 of SARA Title III, requires manufacturers (SIC codes 20-39) to notify customers (SIC codes 20-39) on products containing SARA 313 chemicals with the first shipment of each calendar year. Vista is subject to this regulation. Attached is an updated list of Vista products that contains SARA 313 chemicals and a sample notification letter. After talking to the EPA today, I have the following responses to your questions. If we sell Vista products to distributors, then it is up to the distributors to send the SARA 313 information that we supply on to their customers. Customers in Puerto Rico, Guam, etc. and all other U. S. territories and possessions must receive notifications. - To stay within the intent of the law, we should plan to send all sices a notification. I believe that by sending the notices out before 1/1/90, we will meet the intent of the regulation. we need to develop a listing of all customers using the attached products as soon as possible and determine the best way of informing these customers by 1/1/90. cc: M. H. Horowitz D. L. Cohen VVV 000023021 ALFOL 4 ALCOHOL AQUEOUS ALUMINUM CHLORIDE BLANE PVC COMPOUNDS BUTADIENE CONCENTRATE CATAPAL G AND GST ALUMINA EDC/VCM HEAVY ENDS ETHYLENE ETHYLENE DICHLORIDE (EDC) HEAVY AROMATIC DISTILLATE (HAD) LIGHT AROMATIC CONCENTRATE (LAC) MURIATIC ACID PREMIERE PVC COMPOUNDS ROTOFLEX RIGID COMPOUNDS (LEAD STABILIZED) RIGID DRYBLENDS (LEAD STABILIZED) PROPYLENE SPENT SULFURIC ACID VINYL CHLORIDE VINYL CHLORIDE LIGHT ENDS VISTA PVC COMPOUNDS VISTA 610 PLASTICIZER vvv 000023022