Document 93Z2Y03V9y2qzn4ZQgJr33vLp

TO: Rick Johnson XF: ^ 10 i Interoffice Communication FROM: DATE: SUBJ: E. R. Taylor November 22, 1989 SARA 313 CUSTOMER NOTIFICATIONS V1S1A The EPA, under Section 313 of SARA Title III, requires manufacturers (SIC codes 20-39) to notify customers (SIC codes 20-39) on products containing SARA 313 chemicals with the first shipment of each calendar year. Vista is subject to this regulation. Attached is an updated list of Vista products that contains SARA 313 chemicals and a sample notification letter. After talking to the EPA today, I have the following responses to your que s tions. If we sell Vista products to distributors, then it is up to the distributors to send the SARA 313 information that we supply on to their customers. 3 Customers in Puerto Rico, Guam, etc. and all other U. S. territories and possessions must receive notifications. To stay within the intent of the law, we should plan to send all sites a notification. I believe that by sending the notices out before 1/1/90, we will meet the intent of the regulation. we need to develop a listing of all customers using the attached products as soon as possible and determine the best way of informing these customers by 1/1/90. n ,E. R. Taylor dlj cc: M. H. Horowitz D. L. Cohen VVV 000000624 ALFOL 4 ALCOHOL AQUEOUS ALUMINUM CHLORIDE BLANE FVC COMPOUNDS BUTADIENE CONCENTRATE CATAPAL G AND GST ALUMINA EDC/VCM HEAVY ENDS ETHYLENE ETHYLENE DICHLORIDE (EDC) HEAVY AROMATIC DISTILLATE (HAD) LIGHT AROMATIC CONCENTRATE (LAC) MURIATIC ACID PREMIERE PVC COMPOUNDS ROTOFLEX RIGID COMPOUNDS (LEAD STABILIZED) RIGID DRYBLENDS (LEAD STABILIZED) PROPYLENE SPENT SULFURIC ACID VINYL CHLORIDE VINYL CHLORIDE LIGHT ENDS VISTA PVC COMPOUNDS VISTA 610 PLASTICIZER OOoo