Document 82MG7yO1mbV1a3zjXKa8gvnNy
* RECEfVEO
STATE OF CONNECTICUT
DEPARTMENT OF HEALTH SERVICES
iNOV 2 0 1981
November 17, 1981
Brandon Hickey, Esq. Murtha, Cullina, Richter and Pinney 101 Pearl Street Hartford, Connecticut 06103
RE: Declaratory Ruling on Asbestos-Cement Pipe
Dear Mr. Hickey:
This office is in receipt of your letter of August 27, 1981 notifying the Commissioner of the "withdrawal" of the application of Certain-Teed, Inc. and Johns-Mansville Sales Corporation for a declaratory ruling in the above-captioned matter.
An application for a declaratory ruling, once granted, may not be with drawn at the whim of the applicant. This is particularly true when-the proceedings have progressed-beyond the point of issuance of a hearing panel's proposed memorandum of decision. Further, to allow the with drawal of the application at this time would be akin to granting the request to defer ruling received from the applicants on July 30, 1981 and denied by this office on August 19, 1981. In addition, fairness dictates that the applicant not be allowed to render meaningless the considerable effort made in this case to gather data and engage in careful deliberation simply because the anticipated outcome may be objectionable.
Conn. Gen. Stat. Section 4-176 authorizes a state agency to issue declaratory rulings concerning any statutory or regulatory provision within the purview of such agency. This authority exists even if the agency is not in receipt of a petition or application for declaratory ruling. In addition the specific language of Section 2 of Public Act 80-398 clearly imposes upon the Commis sioner the responsibility to make a determination concerning the effect of asbestos-cement pipe used in water supply systems on the public health. The withdrawal of the application for declaratory ruling in no way lessens that responsibility.
In light of the above Tuesday, December 8, 1981 at 10 a.m. has been scheduled to provide you an opportunity to submit oral argument on the hearing panel's proposed memorandum of decision. Written exceptions and briefs must be filed with this office no later than two business days prior to this date.
Sincerely yours,
cc: Daniel Millstone Stephen Havas, M.D. Dennis F. Kerrigan
Stan PeckTe/ephoae
Douglas S. Lloyd, M.D., M.P.H. Commissioner
79 Elm Street Hartford, Connecticut 06115 An Equal Opportunity Employer
CAP CO JEN 0013017
CC:
copies to:
HEGA/4 Chrono
A. Kahn, Esq. newsclips only N. Rahn, Esq. newsclips only Special Counsel N. Battle Asbestos International Association Asbestos Information Association/NA
Public Affairs Committee
H. Olson w/o enclosures I. Adams W. Perrell J. Woods J. Baker T. Dougherty D. Stinson W. McCallie w/o enclosures B. Collier B. Cook
International Affairs Committee
R. Dorner E. van der Rest B. Giboin C. Walters R. Hobbs A. Saoulis R. Jalan V. Pattabhi H. Hudson C. Barton S. Al-Tarkait
CAP CO JEN 0013016
Ret. 4th Tuesday of December, 1981
CERTAIN-TEED, INC.
)
)
AND
)
)
JOHNS-MANVILLE SALES CORPORATION)
)
vs. )
)
DOUGLAS S. LLOYD,
)
COMMISSIONER OF THE
)
DEPARTMENT OF HEALTH SERVICES )
SUPERIOR COURT
JUDICIAL DISTRICT OF HARTFORD/NEW BRITAIN
AT HARTFORD DECEMBER , 1981
SUMMONS AND ORDER OF SERVICE
TO THE' SHERIFF OF THE COUNTY,OF HARTFORD, OR HIS DEPUTY, GREETINGS:
By authority of the State of Connecticut, you are hereby commanded to summon Douglas S. Lloyd, the Commissioner of Health Services, State of Connecticut, to appear before the Superior Court, Judicial District of Hartford-New Britain, to be held at Hartford on the 4th day of December, 1981, which appearance is to be made by the Commissioner, or by his Attorney, by filing a written statement of appearance with the Clerk of that Court on or before the second day following the return date, then and there answer to the within Petition, by serving upon Douglas S. Lloyd, the Commis sioner of the Department of Health Services and upon Carl R.
CAP CO JEN 0013018
Ajello, Attorney General of the State of Connecticut, a
true and attested copy of the Petition and this Summons
and Order of Service at their offices at Hartford, Connecticut,
in the manner and time provided for the service of civil-
process and due return make.
You are further commanded to serve a true and attested
copy of the foregoing with Citizens for Clean Water in the
manner and time provided by law.
Hereof fail not, but due service and return make..
Dated at..Hartford, Connecticut, this
'- -day
of .
, 1981.
Brandon J. Hickey Commissioner of Superior Court
To the Clerk of the Superior Court: Please enter the appearance of Murtha., Cullina, Richter and Pinney for the Petitioners.
Brandon J. Hickey of
Murtha, Cullina, Richter and Pinney 101 Pearl Street - P.0. Box 3197 Hartford, Connecticut 06103 Telephone: S^-^OO
Their Attorneys
-2CAPCO JEN 0013019
PETITION FOR JUDICIAL REVIEW
J ' To the Superior Court, to be held at Hartford, within
j and for the Judicial District of Hartford-New Britain, to
t
be held on the 4th Tuesday of December, 1981, come CERTAIN-
TEED, INC., a corporation organized under the laws of the
State of Maryland, and JOHNS-MANVILLE SALES CORPORATION,
a corporation organized under the laws of the State of Delaware,
seeking an immediate review by this Court of action taken,
or a ruling made, by DOUGLAS S. LLOYD, Commissioner of the
Department of Health Services, and complain and say:
1. As used in this Petition:
"Petitioners" refers to Certain-Teed, Inc., and Johns-
Manville Sales Corporation;
"Commissioner" refers to Douglas S. Lloyd, the Commissioner
I of the Department of Health Services;
! ' "DHS" refers to the Department of Health Services;
1 "Section" refers to a section of the Connecticut General
Statutes,' Rev. 1958, as amended; and
i* "Application" refers to the Application for Declaratory
!; Ruling filed by the Petitioners with the DHS, as amended.
2. This Petition for Judicial Review is brought pursuant J*1l 1 to the provisions of Section 4-lB3(a), which states, in
j relevant part: 1
"A preliminary, procedural or intermediate
j agency action or ruling -is immediately reviewable if review
.of the final agency decision would not provide an adequate
^remedy."
ii CAP CO JEN 0013020
3. The Commissioner is, and at all times material hereto, was an officer of an agency of the St.ate of Connecticut, as defined by Section 4-166(1).
4. On May 1, 1980, the Connecticut General Assembly enacted Public Act 80-398, later incorporated into Section 19-560, which states: "On or after October 1, 1980, no person, firm, corporation or municipality may stall any asbestos-cement pipe in any water supply system until the Commissioner of.- Health'_jse_r vices_.dete.rminas-that--the-use -- d'f_suc'h pipe in water supply systems does not create a public health hazard."
5. Petitioners sold asbestos-cement pipe for installation within the State of Connecticut prior to October 1, 1980.
6. On August 5, 1980, pursuant to Section 4-176 and Section 19-560, Petitioners filed the Application with the DHS, a copy of which will be filed as Exhibit * A.
7. On October 29 and 30 1980, the DHS held a hearing on the Application before a hearing panel of three administrative j officers.
8. Citzens for Clean Water was accorded Intervenor j One status at that hearing. 4 9. At the hearing the Petitioners introduced extensive 41 Ijscientific and medical evidence, including certain results !| jjof federal animal feeding experiments and studies, demonstrating i; ;;that the use of asbestos-cement water'pipe is not hazardous I) :! to the public health.
CAPCO JEN 0013021
I
10. On January 19, 1981, the Petitioners filed with the DHS a brief in support of the Application.
11. On July 10, 1981, the DHS forwarded to the Petitioners the hearing panel's Memorandum of Decision, a copy of which
1
will be filed as Exhibit B. 12. On July 30, 1981, the Petitioners requested the
Commissioner to defer ruling on the Application until such time as the final results of the federal animal feeding experiments and studies could be reviewed and evaluated, a copy of which request will be filed as Exhibit C.
13* The Commissioner defied Petitioners' request for deferral on August 19, 1981, a copy of which denial will be filed as Exhibit D.
I1!. On August 27 , 1981 , the Petitioners withdrew the Application, a copy of which will be filed as Exhibit E.
15. By letter dated November 17, 1981, the Commissioner rejected Petitioners' withdrawal of the Application and, pursuant 'to Section H-179, notified Petitioners of their opportunity to submit briefs and to make exceptions by December -1|, I | 1981, and to submit oral argument on the hearing panel's j! proposed memorandum of decision on December 8, 1981, a copy ! I of which letter will be filed as Exhibit F.
16. The ruling of the Commissioner in rejecting Petitioners' withdrawal of the Application and the action taken in scheduling | further proceedings on the Application is illegal and void 1 in that:
-3-
CAPCO JEN 0013022
<i) there is no case, controversy or matter before
the Commissioner or DHS upon which he or it may
rule;
(ii)
the Commissioner does not have the lawful authority 1
to make a ruling on the Application because it
is no longer before him;
(iii) the Commissioner.lacked the authority to reject
the withdrawal of the Application;
3-'4;(iv) the Commissioner'has not complied with thd-'.`require
ments of Section JJ-168, and other provisions of
the law, and hence his claim to have continuing
authority in the matter is without merit;
(V) the Commissioner's action is unreasonable and
constitutes an abuse of discretion in view of
the fact that the installation of the subject
pipe remains prohibited by Public Act 80-398 and
hence the public health could not be affected
by the withdrawal of the Application; and
i (vi) since the Application has been withdrawn, Petitioners ltt 111 have no request for a ruling pending, and therefore
there is no issue upon which to hold further proceed
ings.
17. The Petitioners' substantial rights have been
prejudiced because the Commissioner's action in rejecting
withdrawal of the Application is:
-i)- CAP CO JEN 0013023
(i) contrary to the law and inconsistent with the regulations of the DHS; and
(ii) arbitrary or capricious and characterized by an abuse of discretion or a clearly unwarranted exercise of discretion.
18. The Petitioners are aggrieved by the Commissioner's action because:
(i) the Commissioner unlawfully attempts to expose and subject the Petitioners to the harm and damage of a decision based on less than all of the probative evidence; and
(ii) the Commissioner unlawfully seeks to interfere with the exercise of the Petitioners' right to withdraw from proceedings before an administrative agent or agency.
19. Review of the final agency decision would not provide the Petitioners with an adequate remedy because:
(i) the decision would be predicated on less than all of the facts available to the DHS and the Commissioner on the central issue of "public health hazard";
CAPCO JEN 0013024-
(ii) the Petitioners would be put to the cost, expense and risk of the continuing administrative proceedings;
(iii) a final decision, if unfavorable, would result in the necessity of an appeal by the Petitioners, with its attendant cost and expenses, in contravention of the interest in cessation of litigation;
(iv) an unfavorable decision, albeit based upon an incomplete record, would or might have a'harmful
' effect oh the Petitioners'" business,' which could' not be remedied by later judicial review and reversal; and
(v) the Petitioners would be exposed to the risk of an unfavorable decision by the Commissioner, in contravention of its legal rights.
WHEREFORE, the Petitioners appeal from the Commissioner's
decision and request that this Court: (i) issue an order staying any further proceedings on the Application by the Commissioner;
(ii) schedule an immediate and expedited hearing upon this petition and appeal;
(iii) issue a final order vacating and setting aside the Commissioner's action in rejecting withdrawal of the Application; and
(iv) grant such other relief in law or equity as may be required or appropriate.
CAPCO JEN 0013025
Susan M. Babcock of Suffield, Connecticut is recognized in the sufficient sum of $250 to prosecute, etc.
Dated at Hartford, Connecticut, this _____ day of December, 1981.
CERTAIN-TEED, INC. and JOHNS-MANVILLE SALES CORPORATION
By Brandon J. Hickey Commissioner of Superior Court
Please enter our appearance for the petitioners-appellants in the above-entitled action.
MURTHA, CULLINA, RICHTER AND PINNEY 101 Pearl Street - P.0. Box 3197 Hartford, Connecticut 06103 I Telephone: (203) 549-4500 !Juris No. 40248
l
I I1I -7-
CAPCO JEN 0013026
Ret. 4th Tuesday of December, 1981.
CERTAIN-TEED, INC.
)
)
AND
)
)
JOHNS-MANVILLE SALES CORPORATION)
)
vs. )
)
DOUGLAS S. LLOYD,
)
COMMISSIONER OF THE
)
DEPARTMENT OF HEALTH SERVICES )
SUPERIOR*COURT
JUDICIAL DISTRICT OF HARTFORD/NEW BRITAIN
AT HARTFORD DECEMBER , 1981
APPL I CATION TO STAY '
*~
Pursuant to Section* 4-l83(c), the Petitioners apply
to this Court for an Order staying the decision of the Commis
sioner, dated November 17, 1981, as annexed hereto, for the following reasons:
1. The Commissioner ruled and decided on November 17, 11981, that the Petitioners' withdrawal of its'Application
t jwas ineffectual.
j 2.' The Commissioner has ruled that the time within I jjwhich the Petitioners must file a brief with the Commissioner,
[land taken exceptions, as contemplated by Section 4-179,
(
is December 4, 1981, and the time within which the Petitioners
'must submit oral argument to the Commissioner, also as contemjplated by Section 4-179, is December 8, 1981.
II
CAP CO JEN 0013027
I
3. For the reasons set forth in the accompanying Petition for Judicial Review, the Commissioner's decision is illegal and void.
The Commissioner has the power to, and it may be assumed he will, issue a decision upon the Application on or after December 8, 1981.
5. If this Court does not stay the Commissioner from taking such action and making such a decision, then the Petitioners will be effectively deprived of their statutory right under Section 4-183 to have an immediate judicial review, of the Commissioner's.action since the issue will have become moot and the damage which the Petitioners seek to avoid may or will have been inflicted.
Respectfully, THE PETITIONERS
By______________________________________ , Brandon J. Hickey of
Murtha, Cullina, Richter and Pinney
j 101 Pearl Street - P.0. Box 3197 Hartford, Connecticut 06103 Telephone: 549-4500 Their Attorneys
^Certain of the capitalized terms used herein have been defined in the Petition for Judicial Review.
-2-
CAPCO JEN 0013028
Ret. 4th Tuesday of December, 1981
CERTAIN-TEED, INC.
)
)
AND '
)
)
JOHNS-MANVILLE SALES CORPORATION)
)
vs. )
)
DOUGLAS S. LLOYD,
)
COMMISSIONER OF THE
)
DEPARTMENT OF HEALTH SERVICES )
SUPERIOR*COURT
JUDICIAL DISTRICT OF HARTFORD/NEW BRITAIN
AT HARTFORD
DECEMBER
, 1981
TEMPORARY ORDER OF STAY AND ORDER ;TO SHOW.- CAUSED.-.'-'-
TO: DOUGLAS S. LLOYD, COMMISSIONER OF THE DEPARTMENT OF HEALTH SERVICES OF THE STATE OF CONNECTICUT
Whereas, an Application to Stay has been presented
to me, a Judge of the Superior Court, which Court is not
now in session, pursuant to Section 183(c); and
'Whereas, it appears to the undersigned that a Stay
should issue and hereby is issued, in accordance with the
attached'copy of an Order to Stay, pending a hearing on |jthe Application to Stay;
j These are, therefore, to require you to appear before
ijthe undersigned at the Superior Court, Judicial District of Hartford-New Britain, 95 Washington Street, Hartford,
Connecticut, on the
I
day of December, 1981,
i
CAP CO JEN 0013029
at o'clock in the forenoon, then and there to
show cause why a Stay should not be continued pending dispositio
of the Petition for Judicial Review.
Dated at Hartford, Connecticut, this
day of December,
1981.
A Judge of the Superior Court
I
t
i
i
i; \
J I I
CAP CO JEN 0013030
Ret. ^th Tuesday of December, 1981
CERTAIN-TEED, INC.
)
)
AND '
)
)
JOHNS-MANVILLE SALES CORPORATION)
)
vs. )
)
DOUGLAS S. LLOYD,
)
COMMISSIONER OF THE
)
DEPARTMENT OF HEALTH SERVICES )
SUPERIOR COURT
JUDICIAL DISTRICT OF HARTFORD/NEW BRITAIN
AT HARTFORD
DECEMBER
, 1981
ORDER OF STAY..... . <s- '
-
An Application to Stay, having been presented to me,
and it appearing that such Stay should be ordered, it is
hereby ordered that the Commissioner of Health Services
not proceed to process the Petitioners' Application by receiving
briefs and exceptions, hearing oral argument or making a
decision thereon until further order of this fourt'.
By the Court
Judge
I CAP CO JEN 0013031
Ret. 4th Tuesday of December, 1981.
CERTAIN-TEED, INC.
) SUPERIOR * COURT
)
AND `
)
)
JOHNS-MANVILLE SALES CORPORATION)
JUDICIAL DISTRICT OF
) HARTFORD/NEW BRITAIN
vs. DOUGLAS S. LLOYD,
)
)
) AT HARTFORD .
COMMISSIONER OF THE
)
DEPARTMENT OF HEALTH SERVICES ..) DECEMBER , 1981
CERTIFICATION INTO COURT
The accompanying Application to Stay, together with
related papers, made to me in the above-entitled action
and proceedings thereon had before me are hereby certified
to the Court.
Dated at Hartford, Connecticut, this 1981.
day of December,
A Judge of the Superior Court
CAP CO JEN 0013032
I Ret. 4th Tuesday of December, 1981.
CERTAIN-TEED, INC.
) SUPERIOR COURT
AND
)
).
)
JOHNS-MANVILLE SALES CORPORATION) JUDICIAL DISTRICT OF
) ' HARTFORD/NEW BRITAIN
vs. )
DOUGLAS S. LLOYD,
)
) AT HARTFORD
COMMISSIONER OF THE
.
)
.
DEPARTMENT OF HEALTH SERVICES ) DECEMBER' ,-198i'
SUMMONS AND ORDER OF SERVICE
j! TO THE'SHERIFF OF THE COUNTY OF HARTFORD OR HIS DEPUTY," j GREETING:
j BY AUTHORITY OF THE STATE OF CONNECTICUT, you are hereby i
commanded to give notice of the foregoing Order to Show
| Cause to the Commissioner of the Department of Health Services |by serving the Petition, with accompanying Summons and Order
of Service, the Application- to Stay, the Temporary Order
|I!| to Stay and Order to Show Cause, the Order of Stay, the ;! Certification and this Summons and Order of Service upon j Jj the Commissioner of the Department of Health Services, State !i jjof Connecticut and Carl R. Ajello, Attorney General of the
jjState of Connecticut, at their offices in Hartford in the
fjinanner and time prescribed by law for such service.
I CAPCO JEN 0013033
You are further commanded to leave a true and attested
copy thereof with Citizens for Clean Water, in the manner
prescribed by law for such service.
Hereof fail not but due service and return make.
Dated at Hartford, Connecticut, this
day of December,
1981.
Judge
i
-2CAPCO JEN 0013034
Denver, CO--December 4, 1981--Johns-Manvilie Sales Corporation yesterday charged that the Connecticut Department of Health Services is>, excluding important evidence from federal government animal feeding studies on ingested asbestos.
Johns-Manvilie and Certain-teed, Inc. commenced a proceeding in Hartford Superior Court yesterday against the Commissioner of the Department of Health Services. The proceeding seeks to prevent any ruling on asbestos-cement pipe that excludes the results of the government's feeding studies.
The two studies, the largest ever run and costing $4 million, have found no adverse health effects from ingested asbestos. In pro ceedings on Whether asbestos-cement pipe creates any health hazard, the Department of Health Services refused to consider the studies because they were not then "peer-reviewed," a process of having out side experts confirm the results.
"We asked Commissioner of Health Services Douglas Lloyd to defer ruling until peer review was completed. When he refused, we with drew our application for a ruling, but the commissioner is now seeking to issue the ruling anyway, in effect excluding the feeding study evidence," said Wyatt McCallie, senior counsel for JohnsManville.
In April 1980, Commissioner Lloyd advised the legislature that the feeding studies "should provide us with important information" . on ingested asbestos. "Peer review of one study has now been completed and confirms the absence of health effects. We can't understand how the commissioner can ignore this evidence," McCallie commented.
~X.
CAPCO JEN 0013035
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