Document DMKVb9REVdbm0NEQ5XJeeQexB

AIHC AMERICAN INDUSTRIAL HEALTH COUNCIL 1075 CENTRAL PARK AVENUE SCARSDALE, NEW YORK 10583 (914) 725-1492 December 23, 1977 TO: AIHC PARTICIPATING ASSOCIATIONS AIHC ASSISTANCE IN DRAFTING TESTIMONY Gentlemen: Representatives of the American Industrial Health Council plan to be available in Washington from January 9th-12th to help associations and their member companies prepare testimony for April 4th hearings on OSHA's proposed generic standard on carcinogenicity. The deadline for submitting written comments, requesting time to appear at the April 4th hearings and submitting at least an outline of that April 4th testimony is January 30th. AIHC is putting together a team of experts in the areas of economic, science, alternatives and legcl who will be in Washington at the offices of AIHC Counsel, Cleary, Gottlieb, Steen & Hamilton, 1250 Connecticut Ave., NW, Washington, DC from January 9th-12th. They will be available to discuss individually and jointly questions involving an analysis of OSHA's regulations as well as to assist in drafting testimony. In addition, if there is a demand for it, assis tance can be provided that week by a team in Chicago, Atlanta or other appropriate cities. It is important, however, that we know what help your members may need and whether they are in a position to come to Washington for such assistance. Attached is a draft letter you may wish to modify and send to your members within the next few days notifying them of this service and putting them in touch with Ms. Terri Brown at(914) 725-1492. Sincerely, Ronald A. Lang ^ Executive Director ALCo*oo64 DRAFT AIHC ASSISTANCE IN DRAFTING TESTIMONY Gentlemen: Hundreds of manufacturers and users of chemicals are presently in the process of attempting to measure the economic impact of OSHA's proposed generic standard on carcinogenicity on their operations. Many will be presenting this economic impact analysis to the Agency either in the form of written comments next month or in oral testimony at the hearings which begin April 4th. However, the deadline for filing comments is January 30th (although only a detailed outline is required then for oral presentations of less than 15 minutes). The job is clearly a difficult one, particularly for snaller companies producing or using chemicals, and the American Industrial Health Council, with which we are cooperating, would like to provide assistance where necessary in the preparation of such testimony. Experts from AIHC plan to be in Washington from January 9th12th to help individual companies in measuring economic impact, in reviewing scientific issues and alternatives and in drafting testimony. They will be operating out of a suite at AIHC's legal Counsel, Cleary, Gottlieb, Steen and Hamilton, 1250 Connecticut Avenue, N. W., Washington, D. C. and will be available from 9:00 a.m. - 4:30 p.m. each day. Companies planning to take advantage of this opportunity should let AIHC know when they plan to be in Washington by contacting Ms. Terri Brown at (914) 725-1492. There is no charge for this individualized service since AIHC believes it is vital that every company which will be affected by the 0SHA standard makes its voice heard in connection with the regulatory process. Sincerely ALCOA0004465