Document 8RKkyQ6zJoMVVerOxvzx1qkQm
34.1
CHEMICAL MANUFACTURERS ASSOCIATION
OCCUPATIONAL SAFETY AND HEALTH COMMITTEE Minutes of Meeting
Sheraton Fredericksburg Inn and Conference Center
Fredericksburg, VA
At t.endees
Harry Eschenbach (chairman)
Gary Sunshine (vice chairman)
John Dougherty, MD Thomas Evans Luckey Heath Claude Irwin Richard Lippin, MD Paul Nees John G. Page, Jr. Charles Ryan, MD
Guests
Claire Baughman William Fishbeck, MD John Fossett Gary LeClercq, MD Ronald Van Mynen
(5/22 and 5/23 only)
Absent
James K. Filan, MD Brad Garber James Norwood Charles Richards Allan Sherr
Business Meeting, May 21, 1984 1:00 p.m. - 5:00 p.m.
Planning Meeting, May 21, 1984 8:00 p.m. - 10:00 p.m.
May 22, 1984 8:30 a.m. - 12:30 p.m.
May 23, 1984 8:30 a.m. - 11:05 a.m.
Company
W.R. Grace & Company
ICI Americas Inc.
Celanese Corporation Monsanto Company Stauffer Chemical Company Phillips Chemical Company ARCO Chemical Company Occidental Chemical Company E.I. du Pont de Nemours & Company Sun Company Inc.
Ciba-Geigy Corporation Dow Chemical Company Velsicol Chemical Company Exxon Chemical Americas Union Carbide Corporation
The Procter & Gamble Company Olin Corporation Air Products & Chemicals Inc. Gulf Oil Products Company American Cyanamid Company
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OSHC Minutes of Meeting May 21,22,23, 1964 Page Two
34.2
CMA Staff
Milton Freifeld Claire Boccella Robin Hertz Chris Nolde (5/21 Randal Schumacher
and 5/22 only] (5/21 - evening
only,
' 5/22,
5/23)
**
Action
84/7
Consider how to use information from the ASPER critique. Fishbeck/LeClercq
84/11
The Safety Standards Task Group will draft comments on preliminary
OSHA proposals on ladders and scaffolds and on the final standard
on advisory standards.
Garber
84/13
The Safety Standards Task Group will try to block a proposal in
NFPA 30 on flammable liquids storage which would make requirements
of all the options for automatic shut-off or diversion of the
stream to prevent tank overflow.
Garber
84/15
P. Nees, working with the Health Standards Task Group, will develop
a CMA position paper on NTP activities dealing with translation
of animal data to man.
84/16
The Future Issues Task Group will rewrite the draft CMA position on cytogenetic screening.
***
The meeting was convened at 1:00 p.m., May 21, 1984.
1.Minutes of Last Meeting, March 15, 1964
These were approved as distributed.
2. OSHA/EPA Overlap
T. Evans discussed activities of EPA and OSHA regarding workplace health risks.
The committee unanimously approved the "Policy Guidelines for CMA Committee and Program Panels on the Roles of EPA and OSHA in the Assessment and Management of Health Risks in the Workplace", dated April 18, 1984.
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OSHC Minutes of Meeting May 21,22,23, 1964 Page Three
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3. Task Group Reports
3.1 Coirnnunication and Education
This group is prepared to present their modified symposium program in Philadelphia, June 14.
The Committee directed this group to start a work group on real vs. perceived hazards.
3.2 Future Issues
The Committee asked this task group to rewrite the draft CMA position on cytogenetic screening. It should be a freestanding document rather than rely on quotes from another association.
The task group has started planning for a symposium on real vs. perceived haza'rds, but will turn the project over to the Communication and Education Task Group and may continue to have input.
C. Irwin distributed a summary of statements projecting trends in society, generally, and the chemical industry, in particular, over the next few years. It will be discussed at the next task group meeting. Suggestions for additions or modifications were solicited.
3 - 3 Health Standards
J. Dougherty reported that the Westat and Hull reports had been reviewed by the task group and final versions of them were being written by the contractors. Dr. Selikoff's portion, due last March, has not been started yet but was promised repeatedly.
The Argus Research Laboratory's report on single- and multi generation reproductive studies is under review by the task group.
The Reproductive Hazards Work Group is also exploring a possible CMA role in how registries should be set up to monitor reproductive outcomes. The work group is also reviewing Section 624: Reproductive and Fetal Hazards of the
Equal Employment Opportunity Commission Compliance Manual,
to determine whether to recommend changes.
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OSHC Minutes of Meeting May 21,22,23, 1964 Page Four
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3.3 Health Standards (contd.)
Since Title II, dealing with a central science board, has been dropped from the Ritter/Martin Bill (HR 4192), the work group charged with developing a position on it has been sunset.
The task group is also preparing a CMA response to generic issues in the OSHA proposal on asbestos (49 FR 14116).
The Committee directed the Health Standards Task Group to start a work group, headed by R. Lippin, on neurobehavioral effects.
The task group will identify issues the Committee will be expected to comment on in the near future and promote studies to develop data supporting positions it may recommend. In consultation with others, J. Dougherty will prepare the task group's work plan for the year ahead.
3.4 Process Safety Analysis
This group continues to revise its draft report, said J. Page.
3.5 Right to Know
C. Boccella reported that positions of the states and unions involved are now known in the litigation in the Third Circuit Court of Appeals on the OSHA Hazard Communication Rule. The CMA brief as intervenor siding with OSHA, is due July 30.
C, Nolde discussed House Joint Resolution 514, supporting worker's "right to know" about exposure to substances which are hazardous to their health, introduced by Representative Bruce Vento (D-Minn.). Hearings on this non-binding sense of the Congress resolution are expected soon in the Health and Safety Subcommittee of the Education and Labor Committee.
The State Activities Work Group prepared tables comparing the requirements of state right to know laws with the OSHA Hazard Communication standard. The Committee recommended changes in the cover letter to better explain the symbols
used in the tables. Assuming these changes would be made,
the Committee unanimously approved sending the letter and tables to CMA OSH contacts.
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OSHC Minutes of Meeting May 21,22,23, 1984 Page Five
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3.5 Right to Know (contd.)
The Community Activities Work Group will develop specific plans for helping local groups implement the "Tentative Local Guides" previously approved by the Committee.
3,6 Safety Standards
This task group is preparing comments on the performance language and confined spaces issues in the OSHA proposed standard for grain handling facilities (49 FR 996) and the OSHA proposed standard for General Environmental Controls: Accident Prevention Tags (49 FR 17541).
CMA comments on OSHA's second draft, of a proposed standard on confined space entry (29 CFR 1910.146) were submitted to the agency on May 9.
L. Heath reported that -the Bureau of Labor Statistics (BLS) draft revision of their booklet 412 on recording workplace injuries and illnesses presented many problems from industry's view and if implemented would seriously over state occupational injuries and illnesses. J. Page said that discussions with P. Tyson and others at OSHA indicated some of industry's concerns had been addressed in a modification of the BLS draft.
R. Hertz reported that, in a telephone poll, the Committee approved the Occupational Injury and Illness Guidelines drafted by the Safety Statistics Work Group. This completes action item 84/10.
The task group's effort to convince ASTM Committee D-26 on Halogenated Solvents to withdraw their work practice on confined spaces have been unsuccessful. While such efforts will continue action item 84/12 will be considered completed.
3.7 Planning Group
The Committee approved starting a planning group to meet between meetings of the OSH Committee. Members will include OSHC chairman and vice chairman, the advocates or their designees (e.g., task group leaders) of the Health Standards, Communication and Education, Safety Standards, and Right to Know Task Groups.
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OSHC Minutes of Meeting May 21,22,23, 1984 Page Six
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4. Liaison
R. Lippin reported that the American Occupational Medical Association (AOMA) is now tracking relevant legislative and regulatory initiatives and commenting where appropriate.
E-34 Committee on Occupational Safety and Health of the American Society for Testing and Materials [ASTM) has set up a subgroup to review its methods of operations. M. Freifeld will recommend that they avoid duplication of OSHA standards. E-34 will also start formally interacting with the International Standards Organization (ISO).
The International Affairs Group [IAG), C. Boccella said, has prepared a paper, which will be discussed at a meeting with CEFIC in June, that discusses the differences between u.S. and EEC labeling requirements, what impacts those differences have on trade, and possibilities for harmonization.
The CMA representative to -the National Fire Protection Association (NFPA) annual meeting, held in the same week as the OSHC meeting, will vote to retain NFPA Code 30 on flammable liquid storage without change. This will avoid adding burden some requirements relating to the prevention of overflow of storage tanks.
P. Nees, working with the Health Standards Task Group, will develop a CMA position paper on the National Toxicology Program's (NTP) activities. He will stress the translation of animal data to man and recommend ways of bolstering the position developed.
The Board of Directors has sunset the Special Programs Advisory Committee (SPAC), said G. Sunshine. The Board will appoint a group to help resolve administrative problems that arise in connection with the special programs. Staff members will be responsible for liaison between special committees and OSHC. M. Freifeld will coordinate, with L. Spurlock and C. stack, OSHC review of generic issues that arise in dealing with specific chemicaIs.
Committee members and staff drafted a letter to member companies urging critical review of voluntary standards that overlap regulations. It is now under review by senior CMA staff. This completes action item 83/3.
J. Clary of Celanese Corporation, the CMA representative to the June 1984 meeting of the International Agency for Research on Cancer, will give an oral report to interested CMA represen tatives early in July. This completes action item 84/14.
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OSMC Minutes of Meeting May 21,22,23, 1984 Page Seven
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5Worker's Compensation Reform
R. Schumacher reviewed the development of a CMA policy on this subject,
J. Browning of Union Carbide Corporation has agreed to present the CMA position at an International Conference on Disability Compensation for Occupational Diseases, June 6-9, 1984, in New York City. This completes action item 84/9.
6_.Budget. Projects
The Committee voted, without dissent, to grant $20,000 to Johns Hopkins University in support of a symposium the school is planning on "Issues at the Interface of Epidemiology and Health Risk Assessment".
7.Committee Assignments
Group Communication and Education Control Technology
Future Issues Health Standards Process Safety Analysis
Right to Know Safety Standards
Advocate Van Mynen/Baughman
Norwood Irwin LeClercq/Fishbeck Fosset t Evans Garber
Chair Heath
Schroy Irwin Dougherty Knowlton Wilkinson Page
Group AOMA APHA ANSI ASTM IAG NFPA NIOSH NTP OS HA
Liaison Lippin Hertz ' Garber Freifeld Boccella Fossett Fi lan/Evans Nees Evans
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OSHC Minutes oC Meeting May 21,22,23, 1984 Page Eight
8.Meetings Scheduled for Next Year
1984:
July 10 September 13 (since changed to Sept. 11) November 8
1985:
January 10 March 21 Week of May 20
The meeting was adjourned at. 11:05 a.m.. May 23 1984.
34.6
Minutes Subgect. to Approval MF: mw 062684
cc: H. Eschenbach G. Sunshine C. Boccella R. Hertz C. Nolde Ft. Schumacher P. Sokoloff
Milton Freifefa Associate Director Health, Safety and
Chemical Regulations
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35.1
CHEMICAL MANUFACTURERS ASSOCIATION
OCCUPATIONAL SAFETY AND HEALTH COMMITTEE
Minutes of Meeting
CMA Terrace Conference Rooms A & B 2501 M Street, NW Washington, DC 20037
Tuesday July 10, 1984 9:00 AM - 2:00 PM
Present
Harry Eschenbach (Chairman) Gary Sunshine (Vice Chairman) Claire Baughman Thomas Evans James K. Filan, MD William Fishbeck, MD John Fossett Luckey Heath Claude Irwin Gary LeClercq, MD Richard Lippin, MD Paul Nees John Thirion
(for J. Norwood) Ronald Van Mynen
Guest
R, Lemen
CMA Staff
Milton Freifeld Claire Boccella Robin Hertz Chris Nolde
Company W. R. Grace & Company ICI Americas Inc. CIBA-GEIGY Corporation Monsanto Company The Procter & Gamble Company Dow Chemical USA Velsicol Chemical Corporation Stauffer Chemical Company Phillips Chemical Company Exxon Chemical Americas ARCO Chemical Company Occidental Chemical Corporation Air Products & Chemicals Inc. Union Carbide Corporation
NI0SH
***
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OSHC Minutes of Meeting
July 10, 1984 Page Two
35.2
Action 84/7 84/11
84/15
84/16
Consider how to use information from the ASPER critique. Fishbeck/LeClercq
The Safety Standards Task Group will draft comments on
preliminary OSHA proposals on ladders and scaffolds and on the
final standard on advisory standards.
Fossett
P. Nees, working with the Health Standards Task Group, will
develop a CMA position on NTP activities dealing with trans
lation of animal data to man.
Nees
The Health Standards Task Group will rewrite the draft CMA position on cytogenetic screening. (This task was previously assigned to the Future Issues Task Group). Fishbeck/LeClercq
The meeting was convened at 9:00 a.m.
1. Minutes of Last Meeting, May 21-23, 1984
These were approved as distributed.
2. IARC Report
J. Clary reported on the proceedings of the International Agency for Research on Cancer meeting, June 19-26, 1984, in France. M. Freifeld will distribute his written report appropriately,
3. Task Group Reports
3.1 Communication and Education
R. Van Mynen said the symposium program, modified to place greater stress on hazard communication, was well received in Philadelphia on June 14.
The task group started planning a project on real vs. perceived hazards and outlined other projects, in order of priority, that it will undertake.
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OSHC Minutes of Meeting July 10, 1984 Page Three
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3.2 Future Issues
This group, said C. Irwin, is developing a scenario of the projected status of the chemical industry ten to fifteen years hence. It will distill likely issues of the future from that scenario.
In view of this group's new focus, the Committee assigned the rewriting of the draft CMA position on cytogenetic screening to the Health Standards Task Group.
3.3 Health Standards
G. LeClercq reported that final adjustments were being made in the Westat and Hull reports which should be ready soon. The group continues to try to get reviews started for the ASPER sections dealing with asbestos and toluene diisocyanate.
The Reproductive Hazards Work Group is working with the contractor to satisfactorily complete the Argus Research Laboratory report on single- and multi- generation reproduc tive studies.
The Work Group on Noise will address the issue of what crite ria should be used for recording a hearing loss in the OSHA 200 log as an occupational injury or illness.
The Work Group on Respirators will consider surveying CMA members to obtain data supporting cur position on the appro priate use of respirators.
P. Nees is developing a request for proposal for contractors to write a paper on National Toxicology Program activities dealing with translation of animal data to man.
CMA submitted comments to OSHA, May 24, 1984, on the notice of proposed rulemaking on Occupational Exposure to Asbestos.
3.4 Process Safety Analysis
J. Fossett said the group is revising its draft report.
3.5 Right to Know
The Federal Activities Work Group, said T, Evans, is develop ing interpretations of certain parts of the Hazard Communica tion Rule for discussion with OSHA.
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OSHC Minutes of Meeting July 10, 1984 Page Four
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3.5 Right to Know (contd)
The Community Activities Work Group is expanding its local action guidelines to facilitate their implementation by local groups and chemical plant managers.
3.6 Safety Standards
J. Fossett reported that the task group prepared comments to OSHA commending them on drafting performance standards for scaffolds and ladders. These comments will be modified slightly and submitted soon for Committee approval.
CMA submitted comments to OSHA on generic aspects of the proposed standard for Grain Handling Facilities, June 5, and on the proposed standard for General Environmental Controls: Accident Prevention Tags, June 8, 1984.
1984,
R. Hertz said that the draft revision of BLS booklet 412 on recording workplace injuries and illnesses will be made available for comment soon. The Safety Statistics Work Group will prepare comments when the notice on BLS 412 appears in the Federal Register.
The National Fire Protection Association retained its Code 30 on Flammable Liquids Storage without change at its recent annual meeting. This will avoid adding burdensome require ments relating to the prevention of overflow of storage tanks. This completes action item 84/13.
3.7 Planning Group
This group reviewed major Committee activities. H. Eschenbach reminded task group advocates of the importance of starting soon on specific projects that will require funding.
4. Guest Speaker - R. Lemen, NIOSH
R. Lemen reviewed the activities of the Division of Standards Development and Transfer Technology. He also said that CMA will be invited to participate in a conference planned for December on the top ten goals of NIOSH.
5. Liaison
R. Lippin noted a letter in a recent issue of the Journal of Occupational Medicine attacking some of the top ten goals of NIOSH.
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OSHC Minutes of Meeting July 10, 1984 Page Five
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In particular, the article criticizes presumed occupational causation of cardiovascular disease.
C. Boccella reported that the International Affairs Group (IAG) met with CEFIC in June. CEFIC is interested in working with IAG to harmonize the criteria for labeling chronic hazards; CEFIC sees no chance of harmonizing physical and acute hazard criteria.
6, International Conference on Disability Compensation for Occupational Diseases
J. Browning gave the CMA position on workers' compensation in the paper he presented at this conference held June 6-9, 1984, in New York City.
J. Dougherty discussed comments he made at the conference on the concept of proportionality in causes of disease. He explained a method for computing varying proportions of the contribution of smoking and occupational exposure to disease.
7, Legislative Oversight
C. Nolde reported that the Gaydos Subcommittee on Health and Safety has completed hearings on the Vento Resolution on right to know, and that no further action is planned by the Subcommittee. Rep. George Miller's Subcommittee, which obtained joint referral of the Vento Resolution, has yet to be heard from.
C. Nolde also discussed hearings on occupational illness of the Manpower and Housing Subcommittee in the U.S, House of Representa tives. B. Frank, the chairman, identified a need for improved data on occupational illness as a first step toward reducing it. R. Hertz reported that Chairman Frank charged the witnesses at the hearing with suggesting improved methods for collecting appropriate data.
8, New Committee Assignments
B. Garber, advocate for the Safety Standards Task Group, will be off the Committee since he has resigned from Olin. The Committee assigned J. Fossett to be advocate for the Safety Standards Task Group. J, Norwood will take over the assignment of advocate for the Process Safety Analysis Task Group from J. Fossett.
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