Document 7M8V60Qy6eqd8V0xL3God5MMB

CHAIRMAN'S REPORT August, September, October 1978 Introduction Attachment D The close of the 95th Congress in October brought a mass of legislation Which we are still studying for its relevance to the chemical industry. The National Energy program, of course, is the most important of these last-minute bills because of the wide-ranging and continuing impact it will have. But amid the closing rush were other signal successes for MCA and the industry. They were treated extensively in a special Federal Legislative Bulletin and a special insert to MCA News, but their names bear repeating here: Section 311, "superfund," TSCA amendments, energy-reporting. The successes were the result of close cooperation among all staff members. It is this kind of cooperation, this kind of activity that will mark the spirit of the new ad vocacy role MCA has begun to play. The agenda for the next quarter is full. The Resource Cons rvation and Recovery Act, certain aspects of the Toxic Substances control Act, pretreatment regulations, preven tion of significant deterioration regulations, state implem entation plans on air pollution, product liability legislation. And more. Never, it seems, has there been so much to do, and never has the Association been in better condition to do it. The reorganization is working, and the more tightly structured committees and staff are responding with renewed spirit to the tasks facing them. JOHN M. HENSKE Chairman of the Executive committee CMA 039014 TECHNICAL DEPARTMENT CHEMICAL REGULATIONS ADVISORY COMMITTEE. MCA has made every eff rt to make clear to EPA that overly strict rules under section 5 (premanufacturing and Processing Notices) can obstruct innovation if demands for health, safety and marketing information go beyond the statutory need to establish that there is no unreasonable risk. Economic impacts Task Group. A one-year, $300,000 pilot study on the economic impact of the Toxic Substances control Act (TSCA) was begun with the signing of an agreement with National Economic Research Associates, inc. The primary objectives are to establish a method for measuring the economic impact of TSCA on the chemical industry and the U.S. economy, to impact EPA during the regulatory development process and to impact Congress for regulatory reform. Over the next few months, the actual survey questionnaire will be developed and pretested on a small group of member companies. DISTRIBUTION COMMITTEE. MCA is asking appropriate member compani s if they accept the railroad's proposal for a new tank car mileage allowance system that would increase compensation by almost twothirds in three years. Approval by MCA member companies and other parties to the proceeding seems certain. MCA will file a statement noting that a proposal to change truck drivers' hours f service might actually increase accidents. The proposal of the Transportation Department's Bureau of Motor Carrier Safety will increase costs by 25 percent. In an interstate commerce commission proceeding on increased freight rates and charges, MCA has filed a statement contending that the rail rates on six chemical product groups were already too high. MCA plans to file a similar state ment on future railroad freight rate increase proposals that would raise chemical freight rates. ENERGY CONSERVATION COMMITTEE. The latest energy conservation report (for the period June 1977 to June 1978) to the Department of Energy was presented to the press at a luncheon on November 6, with Robert A. Roland as host. Also distributed to the press were MCA replies to the General Accounting Offices' reporting program and the Energy Information Administration's report to Congress that could give Congress the impression that a more' legislation and regulation are needed to accomplish what already is being accomplished. The committee is working on tentative industry positions on the National Energy Act and has discussed coal conversion regulations with the DOE's economic regulatory CMA 039016 -2- administrator. On December 7, the committee will conduct a seminar for DOE on cost determination in the chemical industry. ENGINEERING ADVISORY COMMITTEE. The Engineering Advisory Committee (EAC) National Electrical code Task Group met in August to recommend MCA proposals for revision of the National Electrical Code. The EAC's Task Group on Electrical Motors met in August to finish a proposed MCA guide entitled "Recommended Specifi cation Guide for NEMA-Frame Size Totally-Enclosed Fan-Cooled Horizontal Induction Motors for Chemical industry Service". ENVIRONMENTAL MANAGEMENT COMMITTEE. During August through October, the Environmental Management Committee and its task groups met more than 30 times on its present major programs: solid waste regulations, hazardous chemical spills, pretreatment regulations, pr vention of significant deterioration regulations, content of pending revisions to state implementation plans, health effects of air quality, water quality ariteria, toxic pollutant sampling and new economic perspectives on environmental regulations. Th committee also developed a program for combined technical and legal actions to prepare the bases for responding to 25 critical regulations, among 87 identified of importance, scheduled to be issued by the end of 1979. In structuring this program, the EMC established 15 task groups, compared to 47 under the "old" committer structure, and reduced task group members to about 80 from more than 250. INSURANCE COMMITTEE. On September 28, Robert L. Mitchell of Celan se Corporation presented a statement before the Sub committee on Miscellaneous Revenue Measures of the House Ways and M ans Committee supporting the tax deductibility of reserves to pay product liability claims, congress failed to act on legislation for reserve deductibility but instead enacted tax "carry-back" provisions which will do little to alleviate pro duct liability claim problems. OCCUPATIONAL SAFETY AND HEALTH COMMITTEE. In a statement for MCA before the Subcommittee on Labor of the Senate Committee on Human Resources on October 5, Dr. Bruce W. Karrh, medical director of th DuPont Company, called on OSHA to work cooperatively with industry rather than taking punitive action to secure an injury- free workplace. ; CMA039016 3- r In a post-hearing brief submitted to OSHA, MCA said the agency exceeded its statutory authority in issuing its much debated e'a carcinogen regulation proposal. Also reviewed were the need for risk/benefit analysis and points in support of the American Industrial Health Council position. A Task Group on Chronic Hazard Labeling is drafting recommended guidelines for use in preparing exemplary labels in MCA chemical safety data sheets. At its meeting September 13. the Occupational Safety and Health C mmittee recommended that MCA challenge the "access to records" portion of the final (interim) regulation promulgated by OSHA r garding exposure and medical records. Guidelines are being developed by a task group on this subject for the collection of h alth and industrial hygiene information to be used in epidemi ologic studies. The use of such guidelines by member companies would help assure compatibility of the data when such studies are undertaken. Guidelines also are being developed on the "evaluation, classifi cation, risk assessment and control of chemical teratogens," as well as "control of embryotoxic agents in the workplace," by still another task group of the committee. SPECIAL PROJECTS. Fluorocarbons. Significant progress has be n made in the fluorocarbon research program administered by MCA towards its goal of determining the effects of these materials upon the atmosphere. Sufficient data and knowledge of the chemistry involved from studies completed to date have made it possible to begin development of a multidimensional computer model of the role of fluorocarbons in the atmosphere. At its September 28 meeting, the Technical Panel on Fluorocarbon Research approved proposals for the continued operation of the Atmospheric Lifetimes Experiment. This project is designed to determine the residence time of fluorocarbons in the troposphere, and, in combination with the computer modeling activity, will yield valuable information about the lifetimes of fluorocarbons in the atmosphere. Four stations analyze ambient air continu ously for species of interest. The fluorocarbon research program provided $420,000 to establish these stations and to begin operations in early 1978. The program provided an additional CMA 039017 -4 $335,000 on September 28 to operate the stations and to analyze data for the second year of the experiment. Other ongoing studies of particular importance are the develop ment of a method of analysis for total chlorine in the stratos phere and catalytic destruction of fluorocarbons in the troposphere by air-borne dust and sand particles. Proposals for trend analysis of ozone concentration, joining the relativ ly new satellite observations with an extensive set of ground-based data, are presently under consideration in the pan 1. Phosgene. The Technical Panel on Phosgene Safety met on Octo ber 31 to complete action on 14 agenda items. Among the more important of these were six investigative proposals. Five of these are concerned with retrospective mortality studies, retro spective pulmonary studies and a prospective on-site study in a member company wherein the phosgene unit is relatively isolated from other suspect exposures. The sixth project under considera tion is a long-term, low-level inhalation study. Titanium Dioxide. The Tabershaw Occupational Medicine Associates P.A., have in progress a feasibility analysis for an epidemiolog ical study of titanium dioxide workers. On-site visits have fee ntly been completed. A draft of the final report is to be submitted in November. Depending on the findings evolving from the feasibility study, a full-scale epidemiological investigation might be conducted. Trichloroethylene. The Trichloroethylene Task Group on the Audit of the chronic Inhalation Study met in November to prepare a final report on this research program, which was conducted by Industrial BIO-TEST Laboratories, Decatur, 111. Two important actions must be completed by the audit task group prior to its final report: A comprehensive review of and critique on the air concentration report or the exposure chamber concentration report. Review of a critique on a draft of the final report covering a histopath ologic study conducted by Experimental pathology Laboratories, Inc. CMA 039018 I Epichlorohydrin. The Technical panel on Epichlorohydrin will meet on November 21 to review the findings of the 90-day inhalation prob . Also attending will be Dr. A. R. Sellakumar, who will discuss his research at the New York University Medical Center. On October 12 a Current intelligence Bulletin was issued advising that epichlorohydrin should be treated in the workplace as if it were a human carcinogen. Ethylene Dichloride. Research on the effects of long-term inhala tion is not yet complete, although preliminary results do not show any excess carcinogenicity. The National Cancer Institute recently issued its report on the carcinogenesis bioassay of ethylene dichloride, stating that oral administration of the com pound produced cancers in rats and mice. Vinylidene Chloride. On September 21, a joint NIOSH/OSHA Current Intelligence Bulletin was issued on the carcinogenicity of vinyl halides -- including vinylidene chloride. Citing the NIOSH Crit ria Document and Dr. C. Maltoni's work, the bulletin says vinylidene chloride caused angiosarcoma of the liver in animals. The bulletin is currently being reviewed by the technical panel, especially in light of the extensive research program MCA has administered. Benzene, in mid-summer 1978, MCA entered into a contract with Tabershaw Occupational Medicine Associates for a mortality study of workers exposed to benzene at nine operating plants of member companies. This epidemiological work is expected to be completed about the Spring of 1980. Butylated Hydroxytoluene (BHT). Additional funds have been approved for an expert's review of the Franklin institute's report on a literature survey. TECHNICAL PUBLICATIONS. Procedures to establish and maintain other technical publications in addition to Chemical Safety Data Sheets in an up-to-date condition were recommended by outside counsel in September. Steps to implement the recommendations are being taken. The MCA film, "Safety in the Chemical Laboratory" was found to be out-of-date, has been withdrawn from distribution and purchasers of the film advised. Drafts of 11 revised Chemical Safety Data Sheets are being prepared; eight drafts are now in the edit/review stage; two drafts are in final form, awaiting resolu- CMA 038019 tion of chronic hazard question before publication, and one draft-- on phosgene--has been published. Revised drafts of eight Safety Guides are in various states of completion, four are in final draft and one has been published. CHEMTREC. One CHEMTREC workshop was held in Cleveland in October. One is scheduled for Atlanta in November. The manager of CHEMTREC made the following presentations: Detroit -- 1978 Mid-Continent Conference & Exhibition on Control of Chemical & Oil Spills; Cincinnati -- international Association of Fire Chiefs; Maryland -- University of Maryland - Fire & Rescue Services; Delaware -- Chemical Industry Council and New Castle County Fire Chiefs Association. CHEMTREC Statistics: Total inbound calls Emergency calls 3,087 877 (28%) Total Emergencies Transportation Non-transportation 739 665 74 GOVERNMENT RELATIONS DEPARTMENT LEGISLATIVE COMMUNICATIONS: Energy. In connection with the National Energy Plan legislation proposed by the administration, MCA worked in close concert with Washington representatives of member companies and members of the Energy Conservation committee. Congressional developments were monitored closely to insure that nacted bills were compatible with industry interests, particular attention was given to energy tax proposals which might have produced user taxes or a crude oil equalization tax. Environment. Superfund. MCA took the leading role in an inter industry effort to block enactment of this highly objectionable piece of legislation. We were joined by petroleum, waterways, trucking, railroad and other interests. CMA 039020 ____ l -7- Section 311* MCA was the principal industry organization responsibl for enactment of a vastly improved Section 311 of the Clean Water Act. The section now. clearly distinguishes between discharges associated with routine operations and spills from non-routine causes. The Association, working closely with EPA and several other industry groups and Congressional staff, was able to help to steer the industry bill through both Senate and House in the final hours of the 95th congress. The Government Relations Department has begun evaluation of legislative prospects for the coming year in the environmental area, with particular attention to the likelihood of amendments to RCRA. OSHA. MCA testified before the Senate Labor Subcommittee during its oversight hearings on OSHA in early October. Our staff participated in polishing of Association testimony, gathered useful background material on Subcommittee members., helped to brief and prepare the witness team and handled all logistical communications before and after the hearings. MCA monitored and reported in detail on the OSHA oversight hear ings conducted by the House Manpower Subcommittee in mid-Septemb r. AIHC. In support of AIHC programs, the staff participated in a number of meetings with Washington representatives and with communications specialists handling the AIHC media campaign. A number of advisory communications have been sent to all member companies keeping them abreast of developments. Special attention is being given to constructive contacts with members of congress to explain the AIHC alternatives package. Taxation, in connection with MCA testimony in late August on th tax reduction bill, the staff worked closely with the Association witness in preparing him for his appearance before the Senate Finance Committee. We coordinated development and submission of an Association statement on the "sunset" review of taxation issu s which was filed September 1. A letter to the House Ways and Means Committee was prepared in early September which expresses our vi ws on the tax treatment of employee fringe benefits. On the 31st of October there was a general meeting of the MCA Tax Policy Committee. CMA 039021 -8- Toxic Substances Control Act. The staff lead industry efforts to communicate with Congress regarding the impending amendments to TSCA, a version of which passed the Senate containing an objection able indemnification provision. The measure died in the House of Representatives. Transportation. MCA continues to monitor closely the .increased Congressional interest and attention to emergency response capa bilities in connection with transportation accidents. We worked closely with Congressional staff and participated in the MCA Emergency Response Workshop conducted in Cleveland in October. W monitored congressional attention to the Norfolk and Western rail strike, which was causing concern for many chemical shippers. Trade/Tariffs. The staff answered numerous requests from member companies and media regarding the multilateral trade negotiations. A staff member represented MCA as a consultant to the u. S. Government's delegation to the annual meeting of the Economic Commission of Europe, Chemical industry Committee, in connection with the visit by leaders from the European Council of chemical Industry Federations, we prepared an economic analysis and fore cast paper for their advance review, in addition, the staff chaired the staff-level briefing conducted for the delegation during their visit October 10. The staff participated in numerous meetings with government officials on trade matters including r presentatives of GAO, the Office of the Special Representative for Trade Negotiations, the Department of commerce and congressional staff. Product Liability. The MCA staff helped prepare a letter to a Senate Finance Subcommittee setting forth the Association's views on legislation to provide tax deductions for amounts held in reserve for product liability losses. The letter was submitted in early September. Later that month we were also involved in preparing testimony in the same area which was presented to the House Ways and Means Subcommittee. CMA 039022 I I -9- PROJECTS AND SERVICES: chemical Forum. The Chemical Forum lunch eon series is planned and managed by the staff of the Government Relations Department. The September 12 luncheon featured an ad dress by Representative James G. Martin (R-NC), a member of the House Ways and Means Committee and a well-known spokesman for reasonableness on questions of science and government regulation. On October 10 the forum was addressed by Under Secretary of commerce Sidney Harman. Briefing Breakfasts. The Briefing Breakfast series is conduc-' t d by the MCA staff as a means of providing regular up-dates for Washington representatives of member companies. Status r ports and current action in both legislative and regulatory areas are presented. Special guests frequently make brief presentations and answer questions. On August 31 the special guest was Charles Bruce, a counsel on the staff of the Senate Finance Committee, who discussed pending tax legislation. On October 26, William F. Hildenbrand, secretary to the minority of the Senate and principal Senate floor aide to Senate Minor ity Leader Howard Baker, gave his forecast on the Senate races in .the November 7 elections. Monitoring and Publications. In addition to routine legislative monitoring, the staff published editions of the Federal Legisla, tive Bulletin on August 29 and October 19 that gave up-to-date reports on legislation of interest to the chemical industry. The October issue furnished a wrap-up of the 95th Congress. L gislative status charts were also prepared on several oc casions for use at Briefing Breakfasts and for distribution to the MCA Board of Directors and MCA Executive Committee. INTERNAL MISCELLANEOUS: During this quarter the Department added two new staff members. H. Christopher Nolde joined us as legis lative representative for safety and health. He will manage the legislative communications programs which relate to TSCA and OSHA and will serve as legislative editor. Miss Doris Baquine joins the staff as secretary to Mr. Nolde. CMA 039023 GENERAL COUNSEL The first few months of activities under the MCA reorganiza tion have brought a significant increase in the scope of MCA's legal advisory program. The successful litigation in the Western District of Louisiana against EPA's regulations under Section 311 of the Clean Water Act was the first major case brought by MCA. More recently MCA joined the American petro leum Institute and the American iron and Steel institute in successfully challenging OSHA's benzene regulations in the Fifth Circuit Court of Appeals. MCA also has asked for a review of EPA's Pretreatment Regulations adopted under Sec tion 307 of the Clean Water Act and a review of EPA's Pre vention of Significant Deterioration regulations under the Cl an Air Act. MCA's legal advocacy presently covers a broad range of ad ministrative and regulatory activity including OSHA's proposed g neric cancer regulation, OSHA's proposed medical records r tention regulations, consumer Product Safety Commission's cancer regulation, EPA's TSCA regulations, EPA's clean Water Act permit regulations, and EPA's Resource and Recovery Act r gulations. This broad scope of advocacy is not just legal argument. Rather, it integrates legal and technical advocacy, with MCA counsel working closely with MCA committees and tech nical staff. Not all of the advocacy is litigation. In the case of Section 311 regulations, successful litigation paved the way for a more permanent settlement negotiated with EPA and implemented by legislative amendment. The Section 311 negotiation has, in turn, provided the opportunity for what may be very meaningful, high-level negotiations concerning RCRA and liabilities related to solid waste disposal. PUBLIC RELATIONS AND EDUCATION ENVIRONMENTAL INFORMATION. In addition to continuing to pro vide news on environmental and occupational health matters. CMA 039024 I -11 ChemEcology addressed three major issues o importance to the industry during this quarter. Transportation safety was the theme in the August issue. In September, ChemEcology was careful to provide facts about the Love Canal incident which most of the media chose to ignore. This helped to put that issue much more in its proper perspec tive. Several articles in the October issue emphasized the growing realization that risk/benefit is more than a concept-- it is a fact of life. For example, the National Research coun cil says that the benefits of nitrogen fertilizers outweigh their possible risk to the ozone layer, and a federal court struck down a workplace standard for benzene on the basis that its cost exceeded potential benefits to employees. During this period 400 additional thought and opinion leaders voluntarily asked to be added to our mailing list, bringing total ChemEcology circulation to 24,000. Three Toxic Substances Management Memos were issued on Sec tions 5 and 8(d) of the Toxic Substances control Act, and on the Association's economic impact study of the Act. At the same time, the circulation of the memos has been expanded and opened to anyone in the industry with a "need to know." ' Environmental information was made available during these three months through MCA exhibits at meetings of the American Chemical Society, the American Public Health Association and the National Science Teachers Association. i Education Activities. An ititial printing of 50,000 copies of Minority Engineers--A Guide to Career Selection" has been exhausted. The booklet is MCA's contribution to the industry's effort to achieve a parity in the hiring of minority engineers within 10 years. A completely new edition of "Chemistry Proj ects and Science Fairs" was also published. Distribution of "Experiments in the Chemistry of Foods" was stopped because it included suspect chemicals. A public advisory has been issued. MCA exhibited for the first time at a meeting of the CMA 039025 i -12- American public Health Association, a group that includes environmentalists, public health directors, government ad ministrators and educators. October was also MCA's first time to exhibit at an American Chemical Society meeting. At the National Science Teachers Association convention in October, MCA strengthened its liaison and continued its role of leadership within NSTA by serving on the conven tion planning committee. Through MCA's efforts, the chief toxicologist of The Dow Chemical Company probably will address the NSTA national meeting next April. The manager of education participated in several ACS con ferences and in a conference on high school chemical edu cation. preparations for the next teacher awards have begun. Consumer Information. MCA has arranged for the first time to participate in the National Association of Farm Broad casters annual meeting in November. Before this meeting began, MCA had received more than 60 requests from indiv iduals for two to four interviews each with industry repres ntatives for a total of 100-250 tapes. Since this is a first-time effort, only audio tapes will be made. About 3,000 tapes of interviews made at the American Women in Ra dio and Television annual meeting in June have been requested fbr use by extension home economists around the country. Response has been positive, with most of the tapes being used at least three times--on the radio, with discussion groups and as source material for newspaper columns. MCA has arranged with the National Association of Extension Home Economists to sponsor a contest for the best multi-media packet which conveys positive aspects of chemistry in extension home economics pro grams. The winner of the CHEMM-PAK (Creative Home Economics Multi-Media packet) award will receive $500. Another contest, sponsored originally by the General Federation of Women's Clubs and MCA, will be continued alone by GFWC over the next two years. "It's your country. Make It Work" was designed by MCA to explain the U.S. economic system. In addition to exhibits at the National Extension Homemakers CMA 039026 I " 13- Council and tho National Association o Extension Home Econom* ists, the Consumor Information Section also participated in a National Safety Council program. Another participant used the occasion to ask tho consumer information manager to pre pare a program on food additives for the annual meeting of the American Association of Orthodontists. Two six--minute interviews of Edward Donley were conducted by the section for the radio show "Good Living." Arrangements also were made to interview Tom K. Smith Jr. and John Henske for the program. Magazines and trade papers continue to call for reprint rights to "Your Breakfast chemicals"--one of the most recent uses showing a color photo of a typical break fast and its natural chomical ingredients in chemistry maga zine of the American Chomical Society. - Relations. The section worked closely with parade magazine on its October cover story on Chemtrec. parade has a circulation of 55 million, plus multipliers. Arrangements have boon mado to reprint the story. The section also has cooporated with Chemtrec in writing an article on the emergency service for the monthly publica tion of the Intornational Association of Fire Chiefs and *on another article for Firehouse, a monthly magazine of 100,000 circulation that goes to the firefighter. Chem- ' tree and the section are also preparing a presentation alk * for the Chemtrec manager. The manager of press relations made the arrangements for an NBC television interview with the president of MCA on tlB Love Canal incident and the pos sible ramifications of RCRA. Staff also arranged the press luncheon on tho industry's energy conservation report that featured MCA s president and members of the Energy Conserva tion Committee. forUth?sDeciaieTtatiVa have been contacted to write articles the chemical industadition that highlights Coverage of the mn the daV of the Semiannual Meeting, arranged, press re by the trada and ^neral press has been statements and activi?^8' urse- were iasued on all major itios of the Association. . CMA 039027 -14- Special Publications. MCA News in October published a special insert on the good work of the Government Relations and Legal Departments in the last session of Congress. It also published Representative Jim Martin's Chemical Forum address as an insert. Dr. Martin's speech was made into a brochure, which will get the widest possible distribution, including 400 copies that were gratefully received by Dr. Martin himself. A special effort was made to call attention to the impressive work of the chemical industry in energy conservation by publishing the results of the latest enery report to DOB in a 12-page booklet, in addition to the figures, a statement by Mr. Roland and a narrative section on "how the industry did it" filled out the publication. The booklet will get wide dis tribution, but its primary audience will be the Hill and the bureaucrats in DOE, The section wrote and edited some of the materials that went into the work book for the Department of Commerce briefing by the industry on November 14. The s ction also prepared this report. Chemical industry councils and similar groups have expressed gr at interest in having Mr. Roland speak to them. The new MCA president spoke to the Louisiana and Texas chemical as sociations in this past quarter and he is scheduled to speak to the Los Angeles and Northern California groups in November smd to the Midwest CIC in the spring. CMA 039028 Attachment E SUGGESTED NAME CHANGE FOR MCA As previously discussed with the Executive Committee and Board, it is believed advisable and appropriate at this time to consider a change in the corporate name of the MCA. At the October Executive Committee Meeting, Staff was authorized to prepare several suggestions for consideration by the Executive Committee at the next meeting. While the designation "Manu facturing Chemists Association" has been in use for more than 100 years, th literal understanding of these words does not accurately reflect the mem bership of our industry association for today's man in the street. "Manu facturing Chemist" carries the connotation of an industrial term of art similar to "Purveyors to the Trade" and does not simply describe the role of our m mbers. The following suggestions have been discussed by Staff and are presented in the order of preference for Executive Committee consideration: 1. Chemical Manufacturers Association (CMA) 2. Association of Chemical Manufacturers (ACM) . 3. Chemical Industry Manufacturers Association (C1MA) 4. Association of the Chemical Industry (ACI) Associated with this issue is the related consideration of developing an appropri ate logo for the organization. It is believed that deciding the Association's n w name is necessary before any work can be done on a logo, since the Association's initials may be used in some fashion to develop the logo. ACTION REQUIRED Decision by the Executive Committee regarding MCA name change. MCA EC - 11/20/78 CMA 039029 Attachment F Benzene Panel Charter By action taken at its meeting on October 25, 1978, the MCA Benzene Panel has requested that its Charter be broad ened to cover the regulation of benzene by agencies other than OSHA. The new Charter requested would read as follows: Consistent with MCA practices and policies the Benzene Technical Panel will represent the interests of the members of the Manufacturing Chemists Association before Federal and State agencies in all matters relating to safety and health issues arising out of the production, re action, release, packaging, repackaging, storage, transportation, handling or use of benzene. The expanded Charter recognizes the fact that EPA, the Consumer Product Safety Commission, the Coast Guard, other Federal, and many State agencies are or will be engaged in the reg ulation of benzene. Previously, the Benzene Panel has presented its OSHA arguments to other agencies and this has been technically within the scope of the old Charter. Now, however, the extent of potential regulation of benzene has become so broad that formal expansion of the Charter is appropriate. It should be noted that the Benzene Panel as originally chartered has functioned as a Special Committee and will continue to function as a Special Committee under MCA's Bylaws. As such, it is fully subject to the "General Principles Applicable to the Struc ture and Operations of Committees. " Accordingly, expansion of the Charter will still leave the activities of the Panel subject to MCA's advocacy policy and appropriate coordination and control by MCA's president, staff, and Executive Committee. EC - 11/20/78 CMA 039030