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THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 250 PARK AVENUE * NEW YORK. NEW YORK 10017 212/573-9400
PART I REPORT ON PUBLIC/GOVERNMENT RELATIONS ACTIVITIES
FOR
VCM - PVC PRODUCERS COMMITTEE APRIL-JULY 1974
CONFIDENTIAL
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HILL and KNOWLTON, Inc.
Executive Summary Publlc/Government Relations Activities
for VCM-PVC Producers Committee
April-November 1974
Introduction Beginning unofficially in mid-April and officially in mid-June 1974, Hill and
Knowlton has engaged in a wide variety of public and government affairs activities on behalf of the VCM-PVC Producers Committee of The Society of Hie Plastics Industry. The following is a report chronologizing those activities. The report is broken down into a number of sub-sections, each containing memoranda* press releases, news paper and magazine clippings, etc. relating to H&K activities during various time periods. Following is a brief summary of the full report.
Preliminary Stage
At the request of SPI, representatives of Hill and Knowlton attended the formation meeting of the VCM-PVC Producers Committee April 16 in Washington. At that meeting the Committee decided that, for the time being, it would assume a low profile as far as public affairs activities were concerned.
Following the meeting, a series of recommendations relating to the scheduled Occupational Safety and Health Administration hearings were prepared for SPI.
Pre-Hearing Stage As the scheduled hearings approached, H&K prepared a proposal for an extensive
public relations effort aimed at obtaining, to the extent feasible, balanced press coverage of the industry's positions and presentations at the hearings. A government relations
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THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 250 PARK AVENUE NEW YORK. NEW YORK 10017 ?5?/667.2675
JULY 3, 1974
Contact: E.S. Nusplfger (212) 687-2675
FIRST WEEK OF OSHA HEARINGS ON VINYL CHLORIDE
HELD IN WASHINGTON
Last week the Occupational Safety and Health Administration (OSHA) of the U.S. Department of Labor began public hearings on a proposed new standard for exposure to vinyl chloride monomer (VCM), which has been linked recently to angiosarcoma of the liver in previously heavily exposed workers.
Nearly a thousand representatives of government, industry, organized labor and the medical profession gathered for the hearings, with 82 organizations scheduled to present or submit testimony.
The following is a day-by-day summary of the first week of hearings: June 25, 1974 {First Day of Hearings)
Daniel Boyd, director of the OSHA Office of Standards Development, reviewed the "no detectable level" standard proposed by OSHA in May; stressed that the govern ment believes it to be "proper and necessary" to weigh economic and technical feasibility in the development of a final standard; and stated that OSHA recognized that control problems within various segments of the industry differed widely.
The second witness, Dr. Herman Kraybill of the National Cancer Institute, reported on recent animal studies on vinyl chloride inhalation and concluded that VCM "fulfills the requirements for a proven carcinogen. M He alleged that the present
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temporary occupational health standard of 50 ppm has a "high probability of causing cancer in man. "
Dr. Marvin Schneiderman, also of the National Cancer Institute, presented testimony on the techniques -- and difficulties -- of extrapolating from animal to human data. Based on a mathematical evaluation of the animal research of Dr. Cesare Maltoni, Dr. Schneiderman concluded that the probability to man of contracting angiosarcoma at 50 ppm (parts per million) would be greater than one in 100.
Dr. Edwin Hyatt, a consultant to OSHA, reviewed the OSHA recommendations for respiratory protection equipment. He admitted under questioning that it would take two years for manufacturers to provide enough self contained breathing apparatus to supply the entire vinyl chloride industry, and that the wearing of such a device for extensive periods of time was "at best an instrument of torture. "
Dr. Marcus Key of the National Institute of Occupational Safety and Health (NIOSH) reported on research activities undertaken by his agency since the beginning of the year, including limited investigations of VCM levels in PVC fabricating plants.
Peter Bommarito, president of the United Rubber Workers, and Chairman of the Industrial Union Department of the AFL-CIO, stated that the United States got along without vinyl chloride for 200 years and that it could get along without it again if the proposed OSHA standard forces the closing of the industry.
Louis S. Beliczky, also of the United Rubber Workers, suggested numerous minor changes in the proposed standard, including the setting of a 0.01 per cent limit on residual VCM in PVC resin. Beliczky admitted that he had no epidemiological or technical feasibility data to support his position, but reaffirmed his belief that the . industry "would have no difficulty" in achieving the proposed standard.
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THE SOCIETY OF THE PLASTICS INDUSTRY, INC.
25 0 PARK AVENUE NEW YORK. NEW YORK 10017 ' 712/657-2675
FOR FURTHER INFORMATION Contact* E.S. Nuspliger
(212) 687-2675
SUMMARY FOR TRADE PUBLICATIONS OF SECOND WEEK OF OSHA HEARINGS ON VINYL CHLORIDE (July 8 - 11, 1974)
July 8 The B.F. Goodrich Chemical Company was the lead-off witness for the
second week of hearings. In its testimony, Goodrich stated that a no-detectable level is technologically infeasible, and that it is not safe to require employees to wear respiratory protection for full eight-hour work shifts.
According to John L. Nelson, Vice President-Manufacturing, 'peak exposure levels ten and twenty years ago were 100 times today's emergency standard, and probably averaged forty times today's average levels. " This year, average exposure levels in Goodrich plants have been reduced from about 35-40 ppm to about 12-14, with some excursions over 50.
Nelson also said that construction of a new PVC facility at the Louisville plant will begin about mid-1975. Preliminary engineering work on the new plant was started in 1972.
Dr. Condict Moore, Director of the Cancer Center, University of Louisville School of Medicine, reported on a new three-part research program being sponsored by Goodrich to investigate the health effects of vinyl chloride.
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In other testimony, Johns-ManviUe, the nation's largest manufacturer of PVC pipe, asked OSHA to exempt manufacturers of PVC pipe and pipe fittings from the proposed standards or, as an alternative, to develop a separate standard for the pipe industry. J-M submitted the draft of a proposed alternative standard with its comments.
The Armstrong Cork Company requested OSHA to exempt from coverage under the standards any manufacturer using PVC resin containing less than 0.2 percent uncombined monomer. July 9
The International Association of Machinists and Aerospace Workers supported the proposed standard, and warned that the VCM situation is creating a psychological problem among long-term workers, who are worried about what may be happening to them as a result of their past exposure.
Anthony Mazzocchi of the Oil, Chemical and Atomic Workers International Union questioned industry claims as to die technical infeasibility of the proposed standard and urged that fabricators be included in the coverage.
Goodyear recommended the establishment of separate standards for the producers of VC monomer, the producers of PVC resin, and for fabricators. In its testimony, Goodyear said that it "fails to see how OSHA can scientifically conclude that exposure to vinyl chloride at concentrations of 50 ppm can constitute a serious health hazard to humans. "
The American Chemical Society endorsed the proposed "no detectable" standard because of the lack of available data establishing a safe level of exposure to vinyl chloride, but recommended periodic review of the standard in light of new data.
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Public Affairs Committee
of The Society of The Plastics Industry, Inc.
250 Park Avenue, New York, New York 10017
212:687-2675
Public
s Bulletin
Please route:
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No. 6 - July 1974
WRAP-UP OF THE OSHA HEARINGS ON VCM
As promised, here is a suirmary of the second week of OSHA hearings on the subject'of Vinyl Chloride Monomer. As in the past, this issue will contain a direct copy of a news release on the subject (beginning on the next page).
OUR NEW LOOK
This is the first issue of the Public Affairs Bulletin to use our newly designed letterhead. It is our intent to set these public affairs communiques apart from the rest of your mail and make it easier for you to identify. We ho'pe you like it.
REMINDER TO PROCESSORS
Until OSHA issues their new permanent standard, you are obliged to comply vrith their emergency temporary standard which went into effect last April 5th.
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SUMMARY OF SECOND WEEK OF OSHA HEARINGS ON VINYL CHLORIDE
July 8
The B.F. Goodrich Chemical Company was the lead-off witness for the second week of hearings. In its testimony, Goodrich stated that a no-detectable level is technologically infeasible, and that it is not safe to require employees to wear respiratory protection for full eight-hour work shifts.
According to John L. Nelson, Vice President Manufacturing, "peak exposure levels ten and twenty years ago were 100 times today's emergency standard, and probably averaged forty times today's average levels." This year, average exposure levels in Goodrich plants have been reduced from about 35-40 ppm to about 12-14, with some excursions over 50.
Nelson also said that construction of a new PVC facility at the Louisville plant will begin about mid-1975. Preliminary engineering work on the new plant was started in 1972.
Dr. Condict Moore, Director of the Cancer Center, University of Louisville School of Medicine, reported on a new three-part research program being sponsored by Goodrich to investigate the health effects of vinyl chloride.
In other testimony, Johns-Manville, the nation's largest manufacturer of PVC pipe, asked OSHA to exempt manufacturers of PVC pipe and pipe fittings from the proposed standards, or, as an alternative, to develop a separate standard for the pipe industry. J-M submitted the draft of a proposed alternative standard with its comments.
The Armstrong Cork Company requested OSHA to exempt from coverage under the standards any manufacturer using PVC resin containing less than 0.2 percent uncombined monomer.
July 9
The International Association of Machinists and Aerospace Workers supported the proposed standard, and warned that the VCM situation is creating a psychological problem among long-term workers, who are worried about what may be happening to them as a result of their past exposure.
Anthony Mazzocchi of the Oil, Chemical and Atomic Workers International Union questioned industry claims as to the technical infeasibility of the proposed standard and urged that fabricators be included in the coverage.
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