Document 4QJwd4o7oJgbMjDg19nyaa5wR

Vista Chemical Company 15990 N. Barker's landing Rd. Post Office Box 19029 Houstonjexas 77224 Phone (713) 531*3200 June 8, 1988 Mr. Ron MeEwan Sun Chemical 4526 Chickering Avenue Cincinnati, OH 42232 Dear Ron: As we discussed, attached is a Vista TSCA 8(c) form we are requesting you complete for our evaluation. I have summarized below what I believe to be the facts of the allegation. Please correct or add to this summary when completing the form. Specifically, any information regarding the medical evaluation and treatment, and "severity" of the irritation would be appreciated. Please call me at 713/531-3445 if you have questions. AT-I-EGATT ON SUMMARY After performing a routine color pigment flush operation utilizing Vista 47 a femalelaboratory worker exhibited a significant irritation in various body locations that were uncovered during the work. The Vista 47 was being handled at a temperature of approximately 120C. Chemical contact occurred as a result of exposure to a water/oil vapor or mist. The exposures occurred periodically over a 2-3 hour period. The employee saw a physician who diagnosed the irritation as a "chemical irritation". The employee was removed from exposure and the rash subsided in 3 to 4 days. Medical treatment consisted of application of a standard skin cream or medication. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo Attachment cc C. Pierson VVV 0000X4707 Visto Chemical Company June 7, 1988 15990 N. Barker's Landing Rd Post Office Bo* 19029 Houston,Texas 77224 Phone (713) 531-3200 Alan B. Ward, Esquire Baker & Hostetler 1050 Connecticut Avenue, NW Suite 1100 Washington, DC 20036 VIS1A Dear Alan: Following is Vista Chemical's response to SDA's Proposition 65 Survey. Vista Chemical is a manufacturer of raw materials for the soap and detergent industry. We do not manufacture in the State of California. The survey answers are based on these two facts. Vista is generally supportive of SDA activities addressing Proposition 65 issues but strongly urges an organized plan or strategy be developed and communicated. Specifically, close coordination of the various technical committees should be maintained. Part I Proposition 65 Compliance Exposure Warnings 1. a. None published b. None c. Multiple letters have been sent on request to customers. d. We have included a copy of letters received from Shell Oil Company. These are the only such letters we have received. 2. Not applicable 3. We have provided no warnings specifically for Proposition 65 on labels. a. Not applicable - we produce no consumer products. b. Not applicable 4. No labels received to submit 5. We are planning to modify our MSDS's to provide specific Proposition 65 warning separate from standard hazard communication information, but have not done this as yet. 6. Specific exposure assessment information was developed for ethylene oxide in 1984 to respond to the new 0SHA standard. Some assessment has been done for VCM in customers workplaces. Besides routine workplace monitoring, no other exposure or risk assessments have been done. YVV 0000X4708 Alan B. Page 2 June 7, Ward, 1988 Esquire 7. The requests we have received routinely ask for information on any chemical on the Proposition 65 in the products purchased. Requests have been for quantitative information on Proposition 65 chemical levels in the products. Only one request, for VCM content, was chemical specific. Sample copies of our response letters are enclosed. Although we have not kept exact data, we receive approximately 5-8 requests per week. 8. None 9. Not applicable Discharge and Other Questions 10. None 11. a. None b. 1-4 dioxane, multiple chlorinated hydrocarbons, polynuclear aromatic hydrocarbons (11 listed) 12. No 13. We don't manufacture consumer products - however, we do receive requests from feedstock or raw material customers on detergent intermediates such as ethoxylated alcohols and ether sulfates. 14. No 15. No 16. No, but we have committed financial support to a CSMA fund and effort which hasn't begun. Issues and parties concerned are undecided at this time. 17. Vista would consider financial support to fund industry efforts to litigate Proposition 65 issues. It is desirable the effort be coordinated with CSMA. a. Vista would consider joining as a financial supporter or party to a SDA or larger industry coalition. FDA and OSHA Hazard Communication preemption should be added to the list. 18. 1-4 dioxane Various chlorinated chemicals Polynuclear aromatic hydrocarbons (11 listed) VVV 000014709 Alan B. Ward, Page 3 June 7, 1988 Esquire 19. This question is difficult to answer at this time based on our current experience, or non-experience with compliance or enforcement litigation. PART II REGULATION LEGISLATION 1. a. Yes - believe to be too conservative b. Not sure of implications c. Yes - we need to clearly understand how they will operate d. Yes - as anon-operator it isn't directly applicable but is an important scientific principle. e. No comment f. No comment g. Yes - this is important as a supplier to the state h. Yes - need to be reasonably conservative i. If this means other states, then New York is important now based on a proposed Proposition 65. 2. a. Yes b. Yes - consistency across the board should be required c. No comment d. New York State; other states as proposed legislation occurs 3. See 2.d. 4. Yes PART III 1. A monitoring and dissemination of enforcement or compliance activity in California will greatly assist us in determining the validity or adequacy of our efforts. Sincerely, Thomas G. Grumbles, C.I.H. Environmental Quality Manager ajo bcc W, J. B. Vogel W. L. McClain 0. C. Kerfoot VVV 00001471