Document 6BvKpxnbBON6rGzz9XyRvx0G1

AIHC V-W-i-D 1075 CENTRAL PARK AVENUE SCARSDALE, NEW YORK >0583 (9t4) 725-1492 TO: AIHC MEMBERS RECEIVED MAR 13 1977 LAW DEPT. March 8, 1978 hfcUuiVED f.'AR i U 1978 J. T. BARR PLANS FOR DISTRIBUTION OF AIHC TESTIMONY Gent!emen: As you know, February 28th was the deadline for filing written comments and oral testimony of more than 15 minutes in connection with OSHA's proposed generic standard on carcinogenicity, the public hearings for which begin on May 16th. Attached for your information is a copy of AIHCs request to present testimony along with a list of its witnesses. Also attached is the AIHC paper which was filed last week with regard to the legal aspects of OSHA's proposal. Copies of the full AIHC testimony, which includes the final. Alternatives document, the full economic study by Foster 0. Snell and the testimony of its scientific witnesses, will be provided to the designated contacts of each AIHC supporting company as well as to all of the trade associations with which AIHC has been working for the past few months. . In addition, members of all AIHC Committees and other involved individuals will receive a copy of both the AIHC Alternatives document and the Executive Summary of the Snell study. Members of Committees particularly involved in certain areas will also receive the full documents in their areas of Interest, i.e. the full scientific testimony to the Scientific Committee, the full Snell study to the Economics Committee, etc. Additional copies of these materials will be available fninuAIHCat the cost of reproduction, i.e. approximately SI.00 each for th^AlternatTvgrand for the_SnelT~Executw&--> Summary and $5.00 each for the full SneTV sjtudy alnd the^ful 1 testimony^T scientific witnesses. --------- r~------- - b ~2-- Mailings of this material will be provided as soon as it is available from the printer with the first distribution expected to be on its way by Monday, March 13th, and all copies in the mails by Thursday, March 16th. AIHC has also made arrangements to copy virtually all of the papers submitted to OSHA on February 28th (with only a few exceptions). This record approximates 25,000 pages. One copy of this record will be available at the offices of AIHC's Counsel, Cleary, Gottlieb, Steen & Hamilton, V- AP00049557 1250 Connecticut Avenue, NW, Washington, DC, for use by the AIHC Committees. A second copy will be maintained at the AIHC Document Center at the Manufacturing Chemists Association* 1825 Connecticut Avenue, NW, Washington, DC, for use by AIHC participating companies. A third copy has been provided to the Society of the Plastics Industry and will be maintained at the offices of their Counsel, Keller and Heckman, 1150 17th, NW, Washington, DC, for use by AIHC participating associations. AIHC will also shortly be mailing out to all designated contacts and participating associations information kits which will be useful in discussing the OSHA issue within your companies, with customers and suppliers and with labor unions and hourly-paid employees. The initial mailing of these kits will be to designated contacts and a few other individuals within each company, but quantities of the kits will be available shortly thereafter for wide distribution. Sincerely, Enel. Executive Director AP00049558 *v RQaC RT C.HBHAPO rRCO 0 ruRNAOC B, MICHAEL 6UNSAN OONAI.0 I.M0P0AN CHAB^Ct D- MAHArriC, JR. J. EUGENE MARAN* OOUOUI E.XLCVCR DANIEL , SILVER KENNETH L. BACHMAN, JR. CHARLES P. LtTTOW RICHARD SIC. HINDS tJlOIMT PARTMCH* MATTHEW HALE HASuiNOTON COUNCIL KARA D.SCHOTLAND ERIC SCHWARTZ JOHN >. MA6NCY hCNMY J. ."'LOG. VP. EDWARD O.UDDCLL P1CHAPO R.OAROHCH LEE C. B UCHHEIT JOHN w.WILMCR.JR. EUGENE M.OOOTT THOMAS e. HILL JOSEPH ISCNSCROU Cleary, Gottlieb. Steen & Hamilton 12 5 0 CONNECTICUT AVENUE.N.W. WASHINGTON, O. C. 20039 1*0*1 **J-ISI Cmli. Clcaisolaw Waihiuotom Twx 7IOBCCOIOB February 28, 1978 OEORCC W. BALL COUNSEL hew YORK orricc ONE STATE STREET PLAZA HCW.VORK 10004 Paris orricc At,AVENUE DC PRICBLAMO 7SOOS PARIS,FRANCE BRUSSELS OPPICr RUC OK LA LOI, CO 1040 BRUSSELS, BELGIUM LONDON OFFICE WINCHESTER HOUSE rr LONDON WALL LONOON CCSN IOA.CNOLANO BY HAND OSHA Division of Consumer Affairs Docket No. H-090 Room N 3635 U. S. Department of Labor Third Street & Constitution Ave,, Washington, D. C. 20210 N.W. Re t Generic Carcinogen Proposal Dear Sirs: In accordance with the procedures outlined in the Federal Register of October 7, 1977 {42 Fed. Reg. 54147) as amended, we are filing herewith in quadruplicate on behalf of our client, the American Industrial Health Council (AIHC), the following: (1) Notices of intent (notice) to appear, testimonies and support ing documents for the following witnesses as follows: (a) Introductory witness (1) Paul Oreffice - Notice and testimony (b) Scientific Witnesses (1) Robert E. Olson - Notice and testimony (2) Francis J. C. Roe - Notice and testimony (3) Richard Wilson - Notice and testimony (4) David Brusick - Notice and testimony (5) Ronald W. Hart - Notice and testimony (6) R. F. Craiupton - Notice and testimony AP00049S59 'V 2- - (7) Paul Grasso - Notice and testimony (8) George Claus - Notice and testimony (9) A. E. M. McLean - Notice and testimony (10) Bernard L. Oser ~ Notice and testimony (11) Leonard Goldwater - Notice and testimony (12) Johannes Clemmesen - Notice and testimony (13) Frank C. Lu - Notice and testimony (14) Robert Murray - Notice and testimony (15) James H. Jandl - Notice and testimony (16) H. G. S. Van Raalte - Notice and testimony (17) T. Colin Campbell - Notice and testimony (c) Alternatives Panel (1) Elwood P. Blanchard and Fred Hoerger will lead the panel -- Notice and "AIHC Recommended Alternatives to OSHA's Generic Carcinogen Pro posal (Alternatives)" (d) Economics Panel (1) George Dominguez will lead the panel - Notice and report by Foster D. Snell entitled "Preliminary Estimates of Direct Compliance Costs and Other Economic Effects of OSHA's Generic Carcinogen Proposal on Substance Pro ducing and Using Industries" The above-referenced AIHC Alternatives and the Snell report contain the full text of the testimonies of the Alternatives and Economics Panels. The panels will draw from them in their oral presentations. (2) J^egal jobjection-s to the JDSHA proposal oand procedures. AP00049560 For your convenience attached hereto is a summary sheet of AIHC witnesses and the amounts of time requested for them. Respectfully, Robert C. Barnard Counsel to the American Industrial Health Council P.S. Due to mailing and other delays, the Notice of Intent to Appear for James Jandl and his testimony is not available for filing prior to the close of business at OSHA today. Copies will, however, be mailed and postmarked prior to the end of the day. Attachments AP00049561 aCleary, Gottlieb, Steen Hamilton 12 50 CONNECTICUT AVENUE, N.W. WASHINGTON, O-C. 20036 (*0*1 **3-*'*l Summary Sheet of AIHC Witnesses Introductory Remarks Paul Oreffice Scientific Witnesses Robert E. Olson Francis JL..C- Roe Richard Wilson David Brusick Ronald W. Hart R. P. Crampton Paul Grasso George Claus A.E.M. McLean Bernard Oser Leonard Goldwater Johannes Clemmesen Frank C. Lu Robert Murray James H. Jandl H.G.S. Van Raalte T. Colin Campbell Alternatives Panel Elwood P. Blanchard and Fred Hoerger will lead the panel Economics Panel George Dominguez will lead the panel 1/2 hour 1-1/2 hours 1-3/4 hours 1-1/2 hours 3/4 hour 3/4 hour 1/4 hour 1/4 hour 1-1/2 hours 3/4 hour 1/2 1/2 3/4 1/4 hour hour hour hour 1/2 hour 3/4 hour 1 hour 1/4 hour 2-1/2 hours 3 hours AP00049562