Document 91rv3z1xxDgJq7qvn23yOQ6m5
The Brighton Hotel Atlantic City, New Jersey
September 18, 1980
The meeting was called to order by the chairman at 2:00 P. M: with the following members present:
Neil Ault, ChairmanSubrata Banerjee Patricia Bankenstein Irving Dulberg Robert B. Greer Leonard C. Hanson Curt Horton David A. Knovlton Lynn A. Morrison David M. Myers Jon D. Walton George L. Winchester
Norton Company General Refractories Co. Dolomite Brick Corp. of America J. H. France Refractories Co. Babcock & Wilcox Co. Martin Marietta Chemicals North American Refractories Co. BM1, Inc. The Whitacre-Greer Fireproofing Co. Allied Mineral Products Inc. Harbison-Walker Refractories Resco Products, Inc. (North State Tyro)
Also present were: H. W. Fulton, Jr., T.R.l. Counsel, and Charles G. Marvin, Vice President, T.R.l.
Mr. Paul Crouch, President of The Institute, introduced Charles Marvin to the committee.
A brief review of the minutes of the meeting held April 24, 1980 was given and these were approved without comment.
Item (71 on the agenda, TSCA,Confidential Business Information Security Manual. A report was prepared by L. Hanson and D. Myers. It was`explained that the * agency was trying to set up guidelines to make certain that confidential material supplied by industry would remain secure. The information would be stored and released only by permission. It was believed that The Refractories Insticute could not improve on or do anything about the TSCA method. All generally felt that the disciplinary action of TSCA left something to be desired mainly because a course of disciplinary action is not spelled out.
It was decided that no action be taken by The Institute and Charles Marvin will inquire if the Chemical Manufacturers Association will take any action. If they (ChA) requires assistance, we will try to help.
Item $2 on the agenda, A Proposed Statement of Policy on Exemption from TSCA Rules. A report by Patricia Bankenstein and Curt Horton was given and in general it was felt that a problem could arise over the responsibility for pay ments of tests performed to determine the toxic nature of materials. There are three (3) methods of testing:
1. Individual testing
or the testing b:is been ft rf orr.cd.) 3n the letter case, reimbursement for trating may ho authorized by the Agency.
It was believed that too many aspects of this statement of policy were objection able. In fact, the subcommittee did not know where ro start to list their objections. Since it was deemed very import tha* objections be listed. Chairman Ault referred the issue back to subcommittee for reappraisal. A letter is to be forwarded to The Institute by October 1st. The Refracrories Institute will send a final letter to TSCA by October 25th.
Item 03, Records and Reports of Allegations, (July 11, 19S0, Federal Register)
Proposed Rules was considered with a'letter from C. E. Shaw disfrihuied *To"cTie
committee. Comments on allegations are to be submitted by October 9th and hear
ings are currently in progress in several areas. It was believed that the CMA
comments were very complete, but further conmencs from committee were requested.
Exception was taken .to the numerical estimates and their derivation. Chairman Ault requested that conmencs from The Institute be included with theCMAoutline
possibly serving as a guide. The CMA outline will be used as a guide for a letter from The Institute to TSCA. The commitree would draft suggested comments
for submission by The Institute. It was also stressed that it is important for
the member companies to write directly to TSCA giving their individual comments.
Charles Marvin will write on behalf of The Refractories Institute.
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Item 04, TSCA Premanufacture Comments. These were reviewed and it was determined
chat no action is required by The Institute. It was requested that Mr. Marvin
write member companies and make them aware the tact that any change in process
may require a report to TSCA or EPA.
Item 05, Labeling Update. It was reported that a labeling conference will be held in Arlington, Virginia on October 30 and 31. A recent meeting of the labeling subcommittee reported on the types of labels required. A proposal will be forthcoming from EPA and OSHA in the very near future and labels will be required on hazardous and carcinogenic materials. Strong consideration is being given to requiring labeling where as little as 1/10 of one percent by weight of a carcinogenic material is involved. Exports may not require labeling.
Item 06, OSHA Carcinogjfn List. A candidate list was distributed with little or
no comment*
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Item 07, Toxic Integration Information Series. Chairman Ault, read a summary and announced that no action is to be taken.
Item 08, Hew Business. The status of chromium oxide was briefly considered and
any consideration was held in abeyance for future action when there are specific
regulatory proposals to be considered.
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No further business* The meeting adjourned at 5:15 P. M.
Respectfully submitted.
Irving Dulberg Toxic Substances Committee
10-2-80