Document 82B2JnNyoLavZBzzzrYqx7yay

JOSEPH E. KELLER JEROME H. HECKMAN CHARLES M. MEEHAN WILLIAM H. BOSOHESA.V1, JR. ROBERT R. TIERNAN WAYNE V. BLACK DAVID L. HILL MARTIN W BERCOVIC: JOHN S. ELDRED JOSEPH E. HADLEY. JR. CaROLE C. HARRIS MICHAEL T. MORRONE Larry s. solomon JOHN B. DL'BECE CHRISTINE A. MEAGHER SHIRLEY S. FUJIMOTO LAWRENCE P. HALPKIN DEBORAH SHtTR THINKER C. DOUGLAS JARRETT LAW OFFICES Keller and Heckman 1130 17ZS STREET, S. W. SUITE lOOO Washington, d. c. 2003 February 5, 1978 TELEPHONE 202 437-1100 CABLE ADDRESS "KELM AN" WRITER'S DIRECT DIAL NUMBER (202) 457-1116 To: SPI-PVC Safety Group SPI-PVC Health Committee SPI-PVC Communications Committee Re: OSHA Request for Information on Vinyl Chloride and Polyvinyl Chloride Ladies and Gentlemen: Following up on our January 4, 1980 letter concerning the above-referenced Request for Information published by the Occupational Safety and Health Administration (OSHA), the purposes of this communication are to advise you that: 1) the filing date for responding to that Request for Infor mation has been extended to May 9 , 1980? 2) that some infor mation which might be of interest to OSHA will be forthcoming from individual companies which would like to see the data submitted under the auspices of SPI; 3)that both SPI-Canada and^APME (the European plastics trade association) will be coordinating with SPI regarding any submissions that are made; and 4) that plans for industry participation in the March 20-21, 1980 Symposium are nearing completion. As was indicated in our January 4 letter, we asked OSHA informally about the possibility of extending the Febru ary 10, 1980 filing deadline for its Request for Information. As reported, the Agency had reacted favorably to a request for an extension of time when we first contacted the staff. Then, prior to the time when we could prepare and submit a formal request for an extension of time we were informed that it would not be necessary for us to file such a request because an internal decision had been made at OSHA to extend the time by 90 days and to publish the Notice of Extension in the Federal Register. In case you did not see it, we are enclosing a copy of that Notice as it appeared at 45 Fed. Reg. 668, January 29, 1980. . ca o 3 BFG52094 A/ 1 February 5, 1980 Page Two ( Keller axd Heckman The new deadline for submitting written comments is May 9, 1980. The matter of responding to the Request for Information within that timeframe will be discussed by the Health Committee at its meeting on February 7 and we anticipate that a recommendation will be made to the Steering Committee at its meeting on February 8, 1980. As to a specific response to the Request for Infor mation, we have been advised by several companies that they intend to file individual responses. Several of these com panies and others have requested that they be permitted to send information to SPI for an industry-wide filing. We have also been contacted by a Canadian producer which intends to file its comments through SPI-Canada and request that SPl-Canada coordinate its filing in some way with any com ments filed by the PVC Safety Group. Similarly, we are in formed that APME will consider filing a response to the Re quest in conjunction with any SPI filing. These subjects are also likely to be discussed by both the Health Committee and the Steering Committee later this week. Accordingly, some time early next week we hope to be able to inform you about any "game plan" which pertains to an SPI response. Also covered in our January 4, 1980 letter, was the fact that OSHA is planning a Symposium on PVC for March. More specifically, "A Re-evaluation of the Toxicity of Vinyl Chloride, Polyvinyl Chloride and Structural Analogues" will be held on March 20 and 21, 1980 in the Masur Auditorium, Bldg. 10, Clement Center located in the National Institutes of Health campus in Bethesda, Maryland. The topics to be covered are the same as those detailed in our January 4 let ter. Program announcements and specific titles of presen-, tations are not yet out. In following up with the Agency staff regarding whether SPI and/or the Chemical Manufacturers' Association (CMA) would wish to offer speakers for this conference, with great difficulty the Health Committee assembled a list of speakers in which we thought the Agency would be interested. Our difficulties involved a lack of adequate notice relative to being able to find people still available to present re ports, a short time in which to prepare reports for the Sym posium, and a 15 minute limit on the length of presentations. Nonetheless, the Health Committee was able to compile a list of authors who would be willing to present papers at the Symposium. This list was submitted to the Agency. Because some of the subjects were already being covered, because some of the information which could be addressed involved BFG52095 03 C3 M February 5, 1980 Page Three ( Keller axd Heckman the re-presentation of old papers in which the Agency was not interested, or because they had already been invited by the Agency, only two of the industry-offered speakers were accepted. The first of these is Dr. Anthony Seaton, Director of the Institute of Occupational Medicine at the University of Edinburgh. The Institute of Occupational Medicine re cently completed a study for Imperial Chemical Industries, Ltd. on workers exposed to PVC dust. The second is Dr. Clark Cooper, one of the original authors of the Tabershaw-Cooper study of the PVC fabricating industry. The Agency had speci fically asked that SPI find someone such as Dr. Cooper to present a paper on the final results of the Equitable Environ mental Health study completed for GMA in January 1978. Other SPI-offered speakers who will not be sent in vitations were Dr. John Stafford of ICI, Dr. Thomas Downs of the University of Texas School of Public Health and Dr. Tassignon of Solvay & Cie. In addition. Dr. Tamboro of the Unversity of Louisville and Dr. Chiazzi of Georgetown Univer sity were on bur "list" but were also invited by OSHA. Obviously, there is considerable information about the Symposium which has not yet been made available to us by. OSHA but, as always, as soon as we get more detail we will send it to you. Finally, with regard to the bibliography of materials in the Agency files, an extensive list of documents was pro vided to us by OSHA and the same was distributed to members of the Health Committee. The next step is for the Health Committee to approve of a procedure for determining which studies are currently unavailable to industry so that they can be obtained from the Agency. We anticipate that this matter will also be taken up at the forthcoming meeting of the Health Committee. As always, should you have any questions, comments, suggestions or need any further information, please do not hesitate to let us know. Enclosure cc: Mr. Ronald Evason Mr. Joseph T. Seawell BFG52096 l 66SS Federal Register / VoL 45, No. 20 / Tuesday, January 29, 1980 / Notices DEPARTMENT OF LABOR Occupational Safety and Health Administration Occupational Exposure to Vinyl Chloride and Polyvinyl Chloride agency: Occupational Safety and Health Administration. Department of . Labor. - " action: Extension of time for written comments. / summary: This notice extends the time period for submission of written comments in response to a request for. information on vinyl chloride and ,, polyvinyl chloride which was published. on December 18,1979 (44 FR 74928). The December 18 notice had requested the submission of written comments not later than February 10/1980. Subsequently, several interested parties requested extension of the deadline by which their comments should be submitted- These requests were based on the need for additional time to coordinate efforts within the industrial groups to -collect and collate the information requested in a manner that would be. most beneficial to all parties concerned. OSHA finds v&lidity.in these requests and has granted an extension of time to submit written comments. Written submissions should be received by the OSHA Docket Officer, no later than May 9.1980. oate The period for submitting written comments is extended to May 9.1980. ADDRESS: Hie information requested on December 18 1S79 (44 FR 74928) should be submitted to the Docket Officer, Docket No. H-034. Room S621Z U.S. Department of Labor, OSHA. 200 * Constitution Ave N.W_ Washington. D.C. 20210. (202) 523-7894.- * FOR FURTHER INFORMATION CONTACT; Dr. Peter Infante, Office of Carcinogen Identification and Classification. Directorate of Health Standards Programs. Room N3718, U.S. Department, of Labor, OSHA, 200 Constitution Ave*"' .N.W- Washington, D.C.20210, . V-".' : Telephone (202) 357-0325. '" 7- : - ` f : BFG52097 21S81004