Document ExVOGJ87BXjkX8mDVBZyXOkg0

1 1:30 p.m. 1:31-1:32 1:32-1:37 1:37-1:50 1:50-2:05 } *2:05-2:10 2:10-2:20 2:20 AGENDA CMA EXECUTIVE COMMITTEE MEETING 1:30 p.m., Monday, November 2, 1981 Olympic Room, Hyatt Regency on Capitol Hill Washington, D. C. 33379-385 niissing ------------------- -- -- ---------- ------------ ------------- i. Call to Order -- Chairman Simeral 2. Approval of Minutes of Meeting, September 28, 1931 3. Treasurer's Report -- G. C. Herrman 4. Association Activities: a. Report of Special Programs Advisory Committee -- Otto Sturzenegger b. Sunset of Public Risk Analysis Special Committee and Establishment of Regula tory Impact Special Committee -- Konrad M. Weis; Jackson B. Browning, Union Carbide Corporation c. Committee Appointments -- B. M. Barackman 5. New Business 6. Adjournment TAB 1 2 3 4 5 CMA 039385 -L MINUTES OF MEETING CMA EXECUTIVE COMMITTEE Olympic Room, Hyatt Regency on Capitol Hill Washington, D. C. Monday, November 2, 1981 1. The meeting was called to order at 1:30 p.m. by Chairman Simeral. There were present: William G. Simeral, Chairman Richard C- Ashley Harry W. Buchanan Louis Fernandez Alexander F. Giacco James B. Henderson Richard J. Hughes Richard H. Leet Paul F. Oreffice L. John Polite, Jr. Robert A. Roland George J. Sella, Jr. Konrad M. Weis Bruce M. Barackman, Secretary Edmund B. Frost, General Counsel Gary C. Herman, Treasurer By Invitation: Jackson B. Browning, Union Carbide Corporation D. Chris Cathcart, CMA Geraldine V. Cox, CMA John E. Dull, E. I. du Pont de Nemours & Company William C. Krumrei, The Procter & Gamble Company Victor H. Peterson, CMA - Ernest S. Robson, Jr., SOCMA, Monsanto Company James N. Sites, CMA William M. Stover, CMA Otto Sturzenegger, CIBA-GEIGY Corporation 2- Minutes of the Last Meeting meeting, as distributed, were approved. The minutes of the September 28, 1981 Treasurer's Report Mr. Herman's report is attached as Exhibit A. In addition he advised that the financial statements through September 30, 1981 indicate significant variances only in the revenue area with dues being less than budget. This, however, is offset by greater investment revenue than anticipated. 4- * Association Activities a- Report of Special Programs Advisory Committee Following the presentation of his report. Exhibit B, Dr. Sturzenegger recommended reauthorization of the Special Programs Advisory Committee for another year. This was approved. CMA 039386 ? 2- - b. Establishment of Regulatory Impact Special Committee Dr. Weis recommended the termination of the Public Risk Analysis Special Committee and, in its place, the establishment of the Regulatory Impact Special Committee (RISC) He also presented for consideration the RISC Charter, and the proposed membership of RISC, All of the foregoing, as set forth in Exhibit C, were approved. c. Committee Appointments The committee appointments listed in Exhibit D were approved. 5. New Business a. The resignation of Mr. William G. Kay, Jr., of the Sun Company, from the Board of Directors was received. Mr. Wilbert J. Magers, Group Vice President, Sun Company, Inc., and President of Sun Refining and Marketing Company, was recommended as his replacement for approval by the Board. b. Messrs. Oreffice and Simeral described their recent visit to Brussels where the dialogue on problems of common interest was continued with the policy group of CEFIC. c. Mr. Henderson reported on a meeting of the Communications Policy Review Special Committee (CPRSC) the previous evening at which time a mix of programs was discussed. It was recognized that the focus can't be solely on ChemCAP; the entire communications program must be reviewed. The Communications Committee and staff should be requested to recommend the best program alternatives for the balance of FY 81-82 and FY 82-83 with in the following constraints: no increase in staff; ChemCAP assessment to remain constant at 40% of dues; inclusion of the proposed $450,000 T.V. ad test within the preceding constraints; and presentation of below-the-line "regret" list. The foregoing would be reviewed by the CPRSC prior to the January 1982 Board meeting at which time the shape of the 1982-83 program will also be considered. During discussion by the Executive Committee the importance of moving fast on the T.V. ad test was suggested. At the same time concern was expressed that meaningful results could be obtained in a six months $450,000 test. It was recommended that a knowledgeable representative of the research company be available to make a presentation of the proposed T.V. ad test at the January meeting. d. Mr. Roland described discussions with the ABC Research Foundation concern ing creation of a fund of about $50,000 to reimburse scientists for outof-pocket expenses associated with appearances in Washington to contribute CMA 059387 "good science" when needed in the legislative and regulatory arena. This matter will be explored further and presented for consideration if it is felt to have real merit. Bruce M. Barackman Vice President-Secretary Certified correct: 'L ' .'1, ' ts- ' * William G. Simeral, Chairman CMA Executive Committee Ct/I* 039388 Exhibit A TREASURERS REPORT Five Months Ending October 31, 1981 This report will be prepared and distributed following the end of the month. For your reference, the following is provided: The approved budget and funding for the fiscal year beginning June 1, 1981 and ending May 31, 1982. t The approved budget for the separately funded 8iomedical and Environmental Special Program area. A sunmary recap of the approved budget and funding for all Communication and Public Relations expenditures through CMA. EC - 11/02/81 BD - 11/03/81 CMA 039389 CHEMICAL MANUFACTURERS ASSOCIATION APPROVED BUDGET AND FUNDING FOR THE Fiscal Year Beginning June 1, 1981 and ending May 31', 1982 REVENUE: Membership Dues Investment Revenue Meetings (Net of Expenses) GENERAL OPERATIONS REVENUE ChemCAP Assessment @ 40* of Dues Utilization of ChemCAP Assessment collected during prior year TOTAL REVENUE 1981-82 Annual Budget S 9,500,000 800,000 232,000 $10,532,000 3,800,000 160,000 $14,492,000 PROGRAM AND MANAGEMENT EXPENSES: General Counsel Government Relations International Trade & Economics State Activities Program Communications and Public Relations Technical Administration Health, Safety 4 Chemical Regulations Environmental Activities Distribution, Energy, Engineering Chemtrec Outside Legal Fees Outside Technical Consulting Executive Department Accounting, Purchasing & Building Services Printing, Distribution & Computer Services GENERAL OPERATIONS EXPENSES ChemCAP Expenses TOTAL EXPENSES $ 760,600 722.400 222.300 204.400 1,131,400 181,200 734.300 662.500 417,600 621.500 1,600,000 1,166,800 1,222,100 469,200 415,700 $10,532,000 3,960,000 $14,492,000 AUTHORIZED PERSONNEL 147 Note: The above budget and funding does not include the activities and staff of the separately funded Biomedical and Environmental Special Programs area. CMA 039390 CHEMICAL MANUFACTURERS ASSOCIATION APPROVED BUDGET AND FUNDING FOR BIOMEDICAL AND ENVIRONMENTAL SPECIAL PROGRAMS Fiscal Year Beginning June 1, 1981 and ending May 31, 1982 REVENUE: 1981-82 Annual Budget Overhead reimbursement @ S500 per day s 641,300 Investment Revenue @ 9% 324,000 Less: Direct Credit of Investment Revenue to the Fluorocarbon Program @ 9% (162,000) Publication Sales 1,000 TOTAL REVENUE s 804,300 EXPENSES: Salaries & Related Expenses s Employee Benefits Travel & Staff Training Dues, Subscriptions & Pubs. Meetings & Workshops Outside Printing, Artwork & Graphics Direct Postage, Freight & Delivery Direct Supplies & General Office Expense Taxes & Insurance Special Insurance Rent & Occupancy Common Cost Expenses Administrative Support: Technical Administration Office of General Counsel Accounting Printing & Distribution 349,200 65,600 8,400 1,200 800 500 11,000 25,800 27,300 56,000 44,300 66,700 48,700 74,100 13,700 11,000 TOTAL EXPENSES s 804,300 Budget Amendment* $ 39,200 -- 1981-82 Annual Budget As Amended $ 680,500 324,000 -- -- s 39,200 (162,000) 1,000 S 843,500 $ 29,400 5,500 800 200 100 -- 500 500 2,200 --- -- ---"" s 39,200 $ 378,600 71,100 9,200 1,400 900 500 11,500 26,300 29,500 56,000 44,300 66,700 48,700 74,100 13,700 11,000 s 843,500 AUTHORIZED PERSONNEL 12 14 * The addition of a program administrator and secretary to the Special Programs staff was approved at the September Executive Committee meeting. CMA 039391  CHEMICAL MANUFACTURERS ASSOCIATION SUMMARY RECAP OF COMMUNICATIONS AND PUBLIC RELATIONS EXPENDITURES Fiscal Year Beginning June 1, 1981 and ending May 3-1, 1982 j T'ne following detail summarizes total funding and expenditures through CMA in the Com- nwnications and Public Relations area as an integrated program. The portions funded by members dues and those funded by the special ChemCAP assessment are presented both separately and as a combined total. i PROGRAM FUNDING: Dues 4 Other General Revenue Required to support program ChemCAP Assessment (? 40% of Dues Utilization of ChemCAP assessment i collected during prior year 1981-82 Approved Communications 4 P.R. Budget 1981-82 Approved ChemCAP Budget S 1,131,400 N/A N/A $ N/A 3,800,000 160,000 TOTAL FUNDING ! -- % PROGRAM EXPENSES: Salaries 4 Related Expense employee Benefits Travel & Staff Training Dues, Subscriptions 4 Publications Meetings 4 Workshops Research 4 Opinion Polls Media 4 Public Relations Outside Printing, Artwork 4 Graphics (net of sales of $170,000) Audio Visual Material 4 Distribution (net of sales of $10,000) outside Publication Distribution News Materials/Workshops Community Committees Speakers Program Scientific/Academic Programing Direct Postage, Freight, Delivery Direct Supplies 4 General Office Taxes 4 Insurance Pent 4 Occupancy ':mmon Cost Expenses Administrative Allocation of Salaries, Benefits and Overhead Charges of Communications Personnel $ 1,131,400 $ 555,800 99,700 70,700 9,200 9,900 -0- 112,000 276,100 -0-0-0-0-c-0142,500 11,000 46,000 87,100 123,500 (412,100) $ 3,960,000 $* -0-0120,000 180,000 160,000 150,000 40,000 86,000 50,000 20,000 50,000 60,000 -0* it 412,100 PROGRAM EXPENSES EXCLUDING ALL ADVERTISING $ 1,131,400 Advertising development, space costs, etc. -0- 1QTAL PROGRAM EXPENSES $ 1,131,400 $ 1,328,100 2,631,900 $ 3,960,000 1981-82 Combined Communications Budget $ 1,131,400 3,800,000 160,000 $ 5,091,400 $ 555,800 99,700 70,700 9,200 9,900 120,000 292,000 436,100 150,000 40,000 86,000 50,000 20,000 50,000 202,500 11,000 46,000 87,100 123,500 $ 2,459,500 2,631,900 $ 5,091,400 i. =] CMA 039392 EXHIBIT B "f; 4 SPECIAL PROGRAMS ADVISORY COMMITTEE- Jf1 Objectives: SPAC will advise the Executive Committee on the acceptance of new programs, ensure that all special programs are conducted in a manner consistent with CMA policy and with the Special Program Guidelines, and review and make recommendations on all advocacy programs on individual chem ical (s) requested by a program panel or staff. Problems: None Recommendations: Extend authorization of SPAC for one year Impact: Money: There will be no dues impact. Company Personnel: One representative on the Committee from each of 15 companies. Staff Personnel: One staff executive co ordinating the work of the committee. No addi tional staff required. Action Required: Approval of recommendation CMA EC- 11-2-81 BD- 11-3-81 CMA 039393 TABLE OF CONTENTS SPECIAL PROGRAMS ADVISORY COMMITTEE REPORT TO THE CMA-- EXECUTIVE COMMITTEE I Proposed New Programs 1 Specific Recommendations to Panels 2 SPAC's Recommendations to the Executive Committee 4 ATTACHMENT I: BIOMEDICAL AND ENVIRONMENTAL SPECIAL PROGRAMS--AN OVERVIEW 1.0 Mission 2.0 Division Summary 3.0 Staff Organization and Responsibilities 4.0 Budget 5.0 Goals for 1981-82 6. C Long-range Plan 7.0 Major Accomplishments 8.0 Summaries of Programs 1 1 2 3 4 5 6 8 Table 1: Biomedical and Environmental Special Programs Budget Summary Figure 1: Biomedical and Environmental Special Programs Division--Organization Chart Appendix A: Special Programs Advisory Committee (SPAC) Appendix B: List of Special Programs Appendix C: Companies Participating in Special Programs CMA 039394 SPECIAL PROGRAMS ADVISORY COMMITTEE REPORT TO THE CMA EXECUTIVE COMMITTEE Since its first meeting in January, 1980, the Special Programs Advisory Committee (SPAC) developed guidelines for Che conduct of special programs, reviewed all of the ongoing special programs, and made recommendations on all proposed new programs. Significant recommendations resulting from SPAC's reviews are summarized below. PROPOSED NEW PROGRAMS Arsenic SPAC recommended approval of a new program on Arsenic. The primary objective of the program is the education of people within regulatory agencies through a jointly sponsored arsenic symposium with Che National Bureau of Standards. This symposium (November 4-6, 1981) will provide a means for industry and government agencies to come to an understanding of cost-effective regulation of arsenic as a hazardous material through knowledge of production and use patterns, toxicologic properties, and the presence of arsenic in the environment. Ethylene Oxide The Ethylene Oxide Industry Council was formed to (i) develop information regarding responsible industry programs to control exposure to ethylene oxide; (ii) to develop relevant scientific, technological, and economic data; and, (ill) to present such information and data to U. S. governmental bodies considering regulatory controls pertaining to ethylene oxide so as to assure that such standards, regulations or policies are reasonable, scientifically sound, and economically and socially effective. SPAC recommended approval of the formation of this Council. Polychlorinated Biphenyls Under the Chemical Regulations Advisory Committee (CRAC) companies affected by the Court's decision on Polychlorinated Biphenyls (PCBs) initiated two surveys to provide EPA with information for promulgating a final regulation. The estimated cost of these surveys and other consultant fees was 3165,000; CRAC budgeted the original phase and then asked that the program be moved to the Special Programs Division. SPAC approved the first phase of a PCB special program which will include conducting two surveys , analyzing the data from the surveys and participating in formal rulemaking. CRAC contributed $30,000 toward this effort. SPAC will review the program at the end of Phase I and will make a recommendation on whether Phase II should be continued under Special Programs, New Source Performance Standard on Non-Metallic Minerals Due to lack of funding, the Environmental Management Committee transferred a request for a new program on Non-Metallic Minerals to the Special Programs Division. Initially the burden of these regulations would have CMA 039395 been on the non-metallic mineral industry alone, but the precedent would be sec for the regulatory agency to take such actions on other sectors of the chemical industry. SPAC recommended approval of this program with the Special Programs division providing all administration and the Environmental Division providing all technical support. Subsequent to this recommendation, the EPA, under the new administration, decided not to pursue the proposed regulation, and therefore, the SPAC recommendation was not brought to the Executive Committee. SPECIFIC RECOMMENDATIONS TO PANELS Acrylonitrile In 1975 CMA signed a $576,300 contract to investigate the possible toxic effects and the pharmacodynamics of ingested and inhaled acrylonitrile in laboratory animals. In 1978 the contract was amended and the contract amount raised to $647,900. The contractor submitted the report on the last phase of this study on December 9, 1980. At the same time, the contractor submitted a final invoice containing a cost-overrun of $134,000. CMA has initiated balloting of panel members to determine if they approve payment of this cost overrun. Several ballots remain outstanding. Upon SPAC's recommendation the CMA legal department confirmed that CMA is not reponsible, under the terms of the contract, for the overrun. Although several companies have still not responded with their ballots, staff and CMA counsel are working closely with che contractor and the panel to resolve the cost overrun. Chlorobenzenes When EPA issued a TSCA Section 4(a) Draft Test Rules Package on chlorobenzenes two CMA groups became involved. The CRAC Testing Task Group identified broad policy and legal issues and spoke with EPA regarding the precedent-setting Implications. The program panel, which has always been research-oriented, established a Toxicology Regulatory Task Group to address specific toxicological issues concerning the six chlorobenzenes recommended for immediate testing. In addition, SOCMA formed the Chlorobenzenes Producers Association to assume an advocacy position. All of these groups worked together to form a unified industry position on the Test Rules Package. SPAC recommended that these groups continue with the work they have begun until the Federal Register notice comes out. SPAC further recommended that as most of Che companies participating in CMA (research) and SOCMA (advocacy) programs are the same, a consideration be given to bringing both the chlorobenzenes research and advocacy programs under one umbrella organization at an appropriate time. Ethylene Dibromide Audits of che NCI and NIOSH studies were completed and an independent auditor found that both of these studies were acceptable. SPAC, therefore, on August 25, 1981, supported che panel's decision to disband although they suggested a new panel be formed to continue for advocacy. Following this decision, OSHA received a petition from che Teamsters Union to lower the exposure limit on EDB from 20,000 ppb to 15 ppb. SPAC reviewed plans for a reconstituted panel on October 20, 1981. > fCMA 039396 Fluorocarbons SPAC approved a limited advocacy role for the Fluorocarbons Program Panel so that the panel could make statements on science. The first was in response to the November 1979 NAS Report, "Stratospheric Ozone Depletion by Halocarbons: Chemistry and Transport." SPAC recommended that the panel continue its limited advocacy charter and appointed two members to explore appropriate means of coordinating the Alliance, the CMA Fluorocarbons Panel and the CMA Section 4 Testing Task Force of the Chemical Regulations Advisory Committee. Ketones SPAC endorsed the panel's plans to establish an early dialogue with EPA regarding the anticipated TSCA Section 4(a) rule. However, SPAC recommended that the panel's charter be amended to include epidemiologic studies and possible evaluation of the environmental effects of ketone. Phthalate Esters In early 1980 the Phthalate Esters panel planned a material handling survey of the manufacturers, distributors and users of phthalates. However, since CMA is a trade association representing manufacturers, SPAC recommended that all action be tabled until the Society of the Plastics Industry could be contacted. In the meantime a study by the National Cancer Institute became available which for the first time raised health effects concerns for phthalate esters. In addition, based upon NCI's findings, EPA requested additional information on PMNs for phthalate esters. The panel was concerned that EPA had taken regulatory action on preliminary information and that EPA might come up with an unreasonable TSCA section 4(a) rule. SPAC recommended that the panel add advocacy to its charter and that they establish a dialogue with EPA on developing a voluntary test standard. This was a valuable recommendation as can be seen by the subsequent accomplishments of this panel (section 7.4 of the attachment). Titanium Dioxide SPAC recommended that in the absence of any significant findings in the long-term inhalation study in progress at dupont, the panel consider disbanding. Vinyl Chloride The Vinyl Chloride Panel hired an independent consultant to review the work performed by Industrial Bio-Test (IBT) under contract to CMA. This consultant recommended that CMA examine animal tissues still available from the study. The panel did not act upon this recommendation. However, they did ask IBT for a refund of the $130,000 they had already paid under the contract. The panel was waiting for financial resolution with IBT before submitting a final report to government agencies. SPAC recommended that the panel not wait for resolution before submitting a final and report that they act upon the consultants recommendation to do additional histopathology. The Panel followed this recommendation. 3 CMA 039397 Zinc Dialkyl Dithlophosphate SPAC heard a proposal for a new special program on ZDDP. Although this new panel was interested in studying the reproductive role of ZDDP in rats and rabbits SPAC recommended that they consider undertaking an epidemiological study. SPAC approved the panel's draft charter with a strong recommendation that it be expanded to Include advocacy. The panel followed this recommendation. SPAC'S RECOMMENDATIONS TO THE EXECUTIVE COMMITTEE SPAC's review of ongoing special programs, as well as proposals for new programs, concentrated on scientific and policy issues, the adequacy of professional and financial support from participating companies, the availability of CMA resources, and the inclusion of advocacy In the panels' charter. The first year of reviews under the new Special Programs Guidelines provided the members of SPAC with valuable insight into the workings of program panels. In the future, SPAC will concentrate on the significant activities of the panels since their last meeting with SPAC. SPAC will also make sure that recommendations made during previous reviews were acted upon. Staff will keep SPAC informed of new actions as they occur, rather than waiting for a scheduled meeting. Further background on the functioning of the Special Programs Division, its major accomplishments during the past year, and a summary of each program is attached to this report. SPAC has now completed Its first year, as authorized by the Executive Committee. SPAC is performing a valuable oversight function for CMA Special Programs and I therefore recommend re-authorization of this Committee for a second year. CMA EC-11/2/81 BD-11/3/8I 4 CMA 039398 ii ATTACHMENT 1 BIOMEDICAL AND ENVIRONMENTAL SPECIAL PROGRAMS AN OVERVIEW 1.0 MISSION The mission of Che CMA Biomedical and Environmental Special Programs Division (Special Programs) is Co provide manufacturers, processors, and/ or users of a chemical or chemicals vich Che opportunity to support collec tively research and/or advocacy on specific chemicals. When referring to Special Programs, advocacy involves external communication, not designed solely for information exchange, that relates to existing or developing regulations, legislation or litigation. CMA serves participating companies by providing proper and effective administration of programs. Scientific information developed through research programs should pro mote the health and safety of the general public and of workers involved in manufacturing, processing, and using these chemicals. All significant findings and reports of CMA-administered research programs are available to the public in a timely manner. 2. DIVISION SUMMARY CMA approved the first "special project" in 1972. The initial special projects were exclusively research oriented. The intent at that time was for CMA to collect and disburse the necessary funds, contract for the research to be done, and provide meeting facilities and surveillance over the conduct of the meetings. The time requirements on CMA staff were expected to be minimal since the participating companies would provide all technical expertise and management skills necessary to conduct the pro grams. The administration of these programs was assigned to CMA secretar ies of several standing committees. The number of special programs administered by CMA increased at a mod erate rate from 1972 to 1979. By the end of 1979, CMA was administering to seventeen special programs. Since 1980, requests for CMA to undertake new special programs have increased considerably. This increase is due mainly to increased activities related to the Toxic Substances Control Act, Clean Mr Act and Clean Water Act. The Special Programs Division presently coordinates research and/or advocacy for twenty-three special programs. CMA took its first steps toward advocacy in 1977 when the Benzene Pro gram Panel was formed in response to a worker-exposure standard proposed by OSHA. Industry believed that the scientific studies on which this standard was based were flawed. The Benzene Panel's Charter was to develop a sound technical base that could be used by industry to challenge the proposed regulations. The Benzene panel's Charter was expanded in November 1978 to 1^ CMA 039399 allow the Panel to represent the interests of the members of CMA before federal and state agencies in all matters relating to safety and healch is sues arising out of the production, reaction, release, packaging, repack ing, storage, transportation, handling or use of benzene. Since 1980, fif teen program panels have broadened their charters to include advocacy or begun programs which included advocacy. In September 1979, the CMA Executive Committee authorized the forma tion of a Special Programs Advisory Group (SPAG). SPAG was subsequently given the status of Special Committee which is now known as the Special Programs Advisory Committee (SPAC). Three major responsibilities of SPAC are: (1) to review requests for individual product advocacy by special pro gram panels and determine that appropriate conditions for these advocacy positions are met; (2) to review each ongoing special program at least once a year to provide guidance based on SPAC members' expertise; and, (3) to make certain that advocacy actions of each Special Program are in harmony with CMA Standing Committee positions. Appendix A lists current members of SPAC. During 1981,, SPAC completed review of all ongoing special programs. In addition, in 1980 and 1981, SPAC approved CMA undertaking new special programs on arsenic, ethylene oxide, glycol ethers, ketones, poly chlorinated biphenyls, and zinc dialkyl dithiophosphates. Appendix B lists all special programs undertaken by CMA to date. Appendix C lists companies that are currently participating in special programs. 3.0 STAFF ORGANIZATION AND RESPONSIBILITIES The Special Programs Division has a staff of thirteen, including a Director, five program administrators, a program coordinator, five secretaries, and one word processor. One program administrator and one secretary devote their time exclusively to the Fluorocarbon Program. The other four program administrators and four secretaries are responsible for the remaining twenty-two programs. Figure 1 outlines the organization of Special Programs with respect to both the staff and the specific programs. Program administrators prepare for and attend panel and task group meetings, prepare records of meetings, and write and administer all con tracts in their respective areas. In addition, program administrators: o maintain awareness of pertinent regulations relating to panel's activities; o communicate with government agencies on scientific and regulatory matters; o coordinate information flow to and from the agencies, the com panies, other trade associations and academic communities; o coordinate the development of advocacy and regulatory position 2 CMA 039400 tf papers with appropriate CMA staff, standing committees, and outside consultants; and, o provide monitoring and auditing services for ongoing research projects. The Special programs Division keeps the office of General Counsel informed of the status of ongoing panel activities. 4.0 BUDGET To date CMA program panels have spent $20,430,287 in research and advocacy programs on 24 families of chemicals (see Table 1). 4.1 Overhead Reimbursement Budget CMA charges participating companies the full costs, including overhead, for administration of special programs. The program account is charged $500 per day for professional staff. This charge includes both the direct and allocated costs of full time professional and clerical Special Programs staff and routine professional or support assistance from the Technical, Legal, Government Relations, Communica tions, and Administrative Services Departments. Other direct costs, such as out-of-town travel, meeting room and program equipment rentals when meeting outside CMA, conference calls, telex, unusually large printing and mailings, etc., are charged as miscellaneous administrative expenses to the program. Other CMA professional staff time, if required to work on specific or non-rou tine aspects of the program, is charged at the same rate as the pro gram administrator. In addition to an overhead reimbursement of $500 per day, the CMA Special programs Division is credited monthly with 0.75Z of received but not expended special program funds as interest. Interest received on non-disbursed Special Program funds is used to defray administrative costs not recovered by the daily rate. In the case of the fluorocarbon program, the unexpended funds balance is approximately $2 million. This has resulted in a special agreement with the Program Panel to credit its funds with interest at 9Z and charge a fixed fee of $16,500 per month from June 1981 to May 1982. This arrangement produces an effective billing rate of $825 per day instead of the normal $500 per day. The fixed fee of $16,500 will be reviewed in March 1982 for fiscal year 1982-1983. 42 Panel Research/Advocacy Budget CMA requires written commitment for the full amount of a study budget from all participating companies before executing study contract(s). A separate account is established to receive and disburse funds for each program. 3 CMA 039401 As a matter of CMA fiscal policy, participating companies are Invoiced for a minimum of 50% of the projected fiscal year commitments. Initial Invoicing occurs immediately after partici pating company management approval of the program activities. During the course of the program, additional collections are made as necessary to maintain a reserve from which disbursements are made. Reserves are maintained as low as possible under sound financial management. A new phase of a program begins whenever there is a change in composition of sponsoring companies. At the completion of any phase of a program, uncommitted funds are carried over to a sub sequent phase. If a company voluntarily drops out of a program at the completion of all contracted work, a refund is made if the pro-rated balance of uncommitted funds exceeds $2,500 for that company. A company which voluntarily drops out of a program during an ongoing study is expected to provide its full financial commitment to the current study phase Including any additions or extensions which were approved during the term of its participa tion. A financial statement detailing all expenses and commitments is prepared monthly for each program. A copy of the statement is provided to panel members at their meetings to keep them informed of the financial status of the panel. 5.0 GOALS FOR 1981 - 1982 o to continue working on establishing new contacts within regulatory agencies; o to establish better communication with both U.S. and non-U.S. trade associations involved in activities related to Special Programs; o to enhance the scientific credibility of CMA by promoting the publication of CMA-administered research in peer review j ournals; o to achieve better recognition of CMA's capabilitres by initi ating the Special Programs News Letter starting January 1982; and, o to establish semi-annual meetings with representatives of other trade associations involved in administration of toxicologic and epidemiologic research. 4 CMA 039402 6.0 LONG-RANGE PLAN Through much hard work on Che pare of CMA staff and panel members, CHA-admlnlsCered research Is developing a reputation for its objectivity and integrity. However, there is room for improvement. Special Programs needs to increase the chemical industry's awareness that Special Programs has the expertise to: o administer research and advocacy programs; and, o provide scientific services which, until recently, have not been available, expected, or requested. To accomplish this, Special Programs has identified steps which should be taken over the next few years. These include: o reducing the work load per program administrator to enable him/her to undertake the challenge of new tasks/programs; o encouraging staff, through educational benefits, to expand existing and develop new expertise in science and business management; o hiring new staff to complement existing staff in scientific disciplines not already adequately covered; o hiring additional support staff capable of assuming a portion of a program administrators non-scientific administrative duties in order to permit the program administrator to devote more time to scientific and liaison functions; o playing a larger role in penetrating the Washington scene and interacting with regulatory agencies and professional societies by establishing good professional relationships with peers in the regulatory agencies, the industry, and government-funded research laboratories; o utilizing the contacts and experience of individual`program administrators more effectively within the Special Programs Division and other Divisions of CMA; o completely reevaluating the method of compensating CMA for services provided; o developing the flexibility to provide services panels expect and for which they are willing to pay; and, o publicizing Special Programs accomplishments and capabilities in: - CMA News - ChemEcology - The newly-proposed Special Programs Newsletter - Peer review journals (publication of research results) - News releases on significant findings 5 CMA 039403 7.0 MAJOR ACCOMPLISHMENTS 7.1 Chlorobenzenes Panel toxicologists provided technical input to the Chloro benzenes Producers Association (CPA) for their submission to EPA in response to EPA's proposed TSCA Section 4(a) Test Rule on Chlorobenzenes. This group of panel toxicologists has continued to work closely with the CPA in the development of a voluntary industry testing program that would be acceptable by EPA in lieu of formal test rule. Following earlier dialogues between CMA/CPA and EPA a "decision-tree" approach to testing of commercial chlorobenzenes was adopted. The outline for this proposal is now being reviewed by EPA. The testing program as now envisioned would be much more conservative in scope than that originally outlined by EPA in their proposed Test Rule. 7.2 Ethylene Oxide The E0 council is organized in such a way chat it is able to respond immediately to emergency situations. A petition to OSHA to issue an emergency temporary standard of 1 ppm was submitted on August 13, 1981. Within two weeks the Council, working on advice from its regulatory and scientific committees and outside counsel, prepared a precise, detailed response which they sub mitted during a meeting with OSHA on September 2. This meeting was also attended by the American Hospital Association and the Veterans Administration--both of which were anxious to join with the Council to present a united industry position. On September 29 OSHA denied the petition. 7.3 Fluorocarbons o The Program has made substantial contributions to the scien tific understanding of what is happening in the stratosphere. The calculated ozone depletion at steady state (approximately 100 years from now) has fluctuated between 5Z and more Chan 20%. Current calculations indicate 62. o The Program has achieved a reputation for scientific objec tivity and integrity seldom attributed to industry-sponsored effort. o There has been cooperation with government agencies through out the world and with international agencies. Research con ducted by government agencies has been funded or co-funded and research with universities or private laboratories has been co-funded with government support. o CMA is the only member of the Coordinating Committee on the Ozone Layer of the United Nations Environment Program not ,6 CMA 039404 representing a national government or an -international agency. o Perhaps the greatest contribution has been the influence on the government funded stratospheric research, particularly in the U.S. The productivity of government agency research has been improved substantially over the past five years. At least in part this has been due to the methodology followed and advocated by the industry-spoasored program and the oversight and review provided by the Fluorocarbon Program Panel. m 7.4 Phthalate Esters o The Phthalate Esters Program Panel has developed a voluntary test Program to address potential health and environmental effects of a class of compounds. o The panel has worked with the Test Rules Development Branch >t i (TRDB) of the Environmental Protection Agency and has gained i I their acceptance of the test program. TRDB is currently proceeding with agency review of the program and we expect official acceptance by mid-November. o The Panel is optimistic that EPA will decide that the data do not warrant a 4(f) finding at this time. o The FDA Task Group has developed a voluntary test program for DEHA which is aimed at determining the cause of the bioassay results. This program will be presented to FDA with the hope chat the FDA will accept the program in lieu of an interim regulation or ban on DEHA. o The FDA Task Group has successfully altered the time table within the Bureau of Foods for regulatory action on DEHA. This delay has allowed FDA and CMA scientists to discuss the scientific issues to develop mutually acceptable regulatory actions to assure public safety and the continued use of an unreplaceable substance, DEHA, in food contact applications. 7.5 Polychlorinated Biphenyls There has been a spirit of mutual cooperation between CMA and EPA since the beginning of this program. EPA representatives worked with CMA in developing our surveys and presenting a sym posium on these surveys to induscry and other trade association representatives. o CMA obtained the cooperation of almost 50% of its membership in the 50 ppm incidental generation survey. 7 CMA 039405 o CMA has continued to maintain on open dialogue with other trade associations involved in collecting data for EPA-- especially the National Electrical Manufacturers Association and the Edison Electric Institute. o CMA submitted to EPA a narrative dissertation on the problems and costs associated with low level PCB analysis. This report was well accepted by the Agency and received good coverage in several trade publications. o In order to insure the objectivity of the data generated by its current round robin, CMA secured the participation of several EPA laboratories in addition to member company labs. It is hoped chat the data generated from this cooperative effort will demonstrate to EPA the variability of analytical results which must be considered in writing and enforcing a regulatory cut off level for PCBs. 8.0 SUMMARIES 8.1 Special Program Advisory Committee The Special Program Advisory Committee (SPAC) was formed to provide the Program Panels with multi-disciplinary expertise in areas of scientific research and governmental advocacy. SPAC reviews each special program on an annual basis and once a year reports to the CMA Executive Committee on the progress of each program. Controversies which exist either within a panel or between staff and panels which cannot be resolved at staff level, are brought to SPAC for review and recommendation. SPAC reviews all new and revised programs for consistency with Association policy. 8.2 Acrylonitrile (AN) The Arcrylonitrile Program is concerned with the epidemiology, toxicology, and environmental aspects of processes involving acrylonitrile, its copolymers and its end products. The program was begun in 1974 to develop additional data on the toxicology of AN. This was accomplished through animal exposure studies by inhalation and ingestion. An epidemiology study was not conducted because of lack of specific exposure data for most of the period to be studied as well as difficulties associated with designating a suitable control group. Several participating companies conducted their own internal epidemiology studies, three of which have been published in detail. 8 CMA 039406 I il M FDA has been interested in food-contact applications of AN polymers, especially beverage bottles. However, the Panel did not assume an advocacy position on this issue. The Society of Plastics Industry conducted advocacy related to OSHA regulations on AN, but CMA was not involved. As a result of proposed regulations by EPA in 1980, the monomer and polymer producers decided to charter a new organization under SOCMA to fulfill the necessary advocacy role. This new group will also perform any future research on Acrylonitrile. The CMA panel voted to disband upon completion of its current research. 8.3 Allyl Chloride Concern over the carcinogenic hazard attributed to vinyl chloride prompted the formation of the AC Program Panel in Jan uary, 1976. The panel has so far undertaken three research pro jects: a teratology study, a pharmacokinetic and metabolic study and a 90-day Inhalation probe study. The need for additional research will be determined after the results of these studies are evaluated. 8.4 Arsenic (AS) An Arsenic Program Panel was established in the first quar ter of 1981. The panel's objectives are to: 1) gather informa tion; 2) conduct necessary research to compliment existing infor mation; 3) educate regulators; and 4) undertake regulatory advo cacy. The panel's first priority was to sponsor an arsenic sym posium and an in-depth critical literature review on the health effects associated with arsenic. The symposium, scheduled for November 4-6 in Gaithersburg, Md. is being cosponsored with the National Bureau of Standards. Session topics include industrial sources and uses of arsenic, biomedical and environmental per spectives, and epidemiology. The literature review is underway and should be completed in November 1981. The panel may initiate research studies based on needs identified in this review and may undertake advocacy regarding present and proposed arsenic standards. 8.5 Benzene (B) The Benzene Program Panel was formed in November 1976- The Panel assessed the data used by NIOSH and OSHA in proposing work place standards for benzene, developed its own recommendations, and gathered additional data to substantiate establishment of a standard. 9 CMA 039407 The panel continues to be concerned with expansion of the toxicological and epidemiological data base, development of industry guidelines for workplace standards, and health and safety aspects of CPA's proposed National Emission Standards for Hazardous Air Pollutants (NESHAP). The panel completed a benzene reproduction study which showed no compound-related adverse effects in male and female rats exposed to levels up to 30x the present workplace standard, CMA and the American Petroleum Institute have initiated an extensive 90-day inhalation study of benzene toxicity in rats and mice which will be used to set dose levels for a subsequent two-year chronic benzene study. An epidemiology study of approximately 14,000 workers in nine plants should be completed in 1982. 8.6 Butylated Hydroxytoluene (BHT) The BHT Panel was formed in response to a proposed interim regulation issued by the FDA in May, 1977. The panel's goal is to collect toxicological information on BHT and to recommend research to fill any data gaps which might exist. An Agency Proposal Pending was published on December 31, 1979, but the final rule is still not out. The panel expects FDA to recommend that only a 90-day subchronic study be undertaken. The panel is waiting for U.S. government action before taking further action on BHT. The French government recently began phasing out BHT as a direct food additive and is at present reviewing the use of BHT as an indirect additive. The joint FAO/WHO Expert Committee on Food Additives recently extended the temporary Average Daily Intake (ADI) for BHT, pending receipt of additional testing data. 8.7 Chlorobenzenes (CB) The Chlorobenzenes Program Panel began its program in 1974 with the conduct of a worldwide literature search on available health data regarding monochlorobenzene (MCB), ortho-dichloro benzene (ODCB) and para-dichloro benzene (PDCB). Since that time, the panel has been concerned with expanding the toxico logical data base on these three compounds and has recently added a fourth (1,2,4-trichlorobenzene) to a proposed test program. In October 1980, the panel initiated a series of teratology studies on MCB, ODCB and PDCB in rats and rabbits. To clarify results obtained in the MCB study in rabbits, a follow-up study was conducted in this species. A draft final report on both MCB studies is expected by the end of the year. The ODCB research was completed and interim data are being assembled; animals go on test in the PDCB teratology study in November 1981- . 10 CMA 039408 j The panel has worked closely with the Chlorobenzenes Producers Association (CPA) In formulating comments on EPA's proposed rules for testing of chlorobenzenes under TSCA Section 4(a). The CPA has held a series of discussions with EPA in an effort to develop a voluntary industry-sponsored testing program in lieu of a formal test rule. A proposal outline was developed and submitted to the Agency. If approved, the CPA has asked the panel to provide funding and administration for the program. 8-8 Epoxy Resin (ER) The Special Program on Epoxy Resins was approved in July, 1977. The panel was formed to evaluate the available health effects literature on Epoxy Resins and to sponsor necessary research. Initially, the panel decided to concentrate on Bisphenol-A epichlorohydrin-derived epoxy resins. 10 The panel is initiating an advocacy role by requesting that OSHA remove Bisphenol A diglycldyl ether from OSHA's candidate carcinogen list. 8.9 Ethylene Dibromide (EDB) Concerned about possible government regulatory action, the panel was formed in 1979. On December 14, 1977, EPA issued a Notice of Rebuttable Presumption Against Registration (RPAR). The agency concluded that presumptions for oncogenicity, muta genicity and reproductive disorders had not been rebutted. A subchronic inhalation study conducted by Dow Chemical Toxicology Research Laboratory showed that repeated subchronic exposure of rats to 10 or 40 ppm of EDB induced pathologic changes in the respiratory epithelium of the nasal turbinate. Subsequent post-exposure phase revealed a lack of progression of the lesions, with almost complete reversion toward normal histologic appearance of the nasal turbinate. Two additional studies were conducted by the National Cancer Institute (NCI) and the National Institute for Occupational Safety and Health (N10SH). The panel conducted third-party auditing of both of these studies. The independent auditor found that both studies were of acceptable quality and their findings valid. Since EDB was shown to be carcinogenic in both studies, there is no need for either continued research or an advocacy program. The panel therefore decided to disband. However, the panel has been reactivated as a result of the National Brother hood of Teamsters' petition to OSHA to lower the current worker exposure standard from 20,000 ppb to 15 ppb. 11 CMA 039409 8.10 Ethylene Dichloride (EDC) The Ethylene Dichloride Program Panel was formed in Febru ary, 1975 to evaluate the adequacy of knowledge relating to EDC. The panel initiated a chronic inhalation, a metabolic, and a teratogenic study in experimental animals. The Panel decided to disband, pending the acceptance of all final reports on this research. This decision was reversed when it was learned that EPA was considering proposing a TSCA Section 8(a) rule. 8.11 Ethylene Oxide (EO) A study conducted at Bushy-Run labs showed Ethylene Oxide to be carcinogenic in rats. Industry was interested in gathering information on the safe handling of Ethylene Oxide which led to the formation of the Ethylene Oxide Industry Council on July 30, 1981. The Council operates through an Executive Committee and four operating committees: Scientific, Regulatory, Finance and Membership, and Communications. The Council is developing information regarding responsible industry programs to: 1) control exposure to ethylene oxide; 2) to develop relevant scientific, technological and economic data; and, 3) to cooperate with ocher national and international organ izations having similar objectives. The Council will present this information and data to any United States federal, state or municipal governmental body considering regulatory controls on ethylene oxide so as to assure that such standards, regulations or policies, are reasonable, scientifically sound, and economi cally and socially effective. The Council developed a response to the petition filed by the Public Citizen Health Research Group and the American Fed eration of State, County and Municipal Employees to lower the exposure standard for ethylene oxide. The petition asked that the eight hour TWA be lowered from 50 ppm to 1 ppm and chat a short-term exposure level of 5 ppm be established. Representa tives of the Council met with OS HA officials on September 2 to discuss industry's concern regarding the petition. On September 29 OSHA denied the petition. 8.12 Fluorocarbons (FC) The Fluorocarbon program was formally organized in the Spring of 1973 with essentially all of the Free World producers of chlorofluorocarbons (CFCs) supporting the effort. The panel's initial purpose was to determine the fate of CFCs in the atmos phere and the effects they may produce on plants or animals. There was no suspicion of their effect on Che stratosphere. With the publication of the Ozone Depletion Theory in June, 1974 the Program was expanded and accelerated. To date, over $10,000,000 has been spent on this research. There is no indica tion that the participants intend to curtail this effort in the immediate future. 12 CMA 039410 The panel limits its funding to scientific research and its advocacy to dissemination of research results and interpretation of the state of the science. Legislative and regulatory advocacy is handled by a coalition of CFC producers and users, the Alli ance for Responsible CFC Policy. The Alliance depends on the Fluorocarbon Program Panel for scientific data. 8.13 Glycol Ethers (GE) The Glycol Ethers Program was formed on June 26, 1980 and is concerned primarily with the alkyl and dialkyl ethers of ethylene glycol and diethylene glycol, selected ethers of propylene glycol, and their acetic acid esters. The panel conducted a review and evaluation of the published and available unpublished literature on health and environmental effects. As a result of the literature review the panel has developed a multi-phase testing program. This program includes testing of; Ethylene Glycol Monomethyl Ether (EM), Ethylene Glycol Monobutyl Ether (EB), and Ethylene Glycol Monoethyl Ether (EE) in 1981 (Phase I) for teratology and possible reproductive effects. Phase II will begin in 1982 and includes teratology studies on: Ethylene Glycol Monoethyl Ether Acetate (EE Acetate) and Propylene Glycol Monomethyl Ether (PM). Phase II also includes a subchronic study of EE and a research study still under development, which will allow a comparative assessment of glycol ethers with their acetates. A Phase II testing program on other glycol ethers may be developed in 1982. The Glycol Ethers Program Panel currently is considering developing exposure data and has begun a liaison program with NPCA and CSMA. The panel is also considering what role, if any, they wish to play in an advocacy program with EPA and/or OSHA. Current advocacy activities involve interactions with NIOSH, ACGIH, and ECETOC. 8.14 Ketones (K) In 1979 five ketones, methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK), mesityl oxide (MO), isophorone and cyclohexanone, were recommended for testing under Section 4(e) of TSCA by the Interagency Testing Committee. The Ketones Panel met for the first time on January 23, 1980. Their first activity was to assemble all toxicology literature on eight ketones, including the five on the ITC List. Both published and unpublished (from the files of participating companies) studies were reviewed and principal areas of deficiencies in toxicology information identi fied. Since the Industrial Health Foundation (IHF) already had a program on cyclohexanone, the present scope of the Ketones Panel is limited to the four remaining ketones on the ITC List. A revised EPA schedule resulted from a ruling in favor of the Natural Resources Defense Council which had sued EPA for 13 CMA 039411 non-compliance under Section 4 by not having initiated rule making within the one year deadline. The suit resulted in dead lines of 1982 for cyclohexanone and 1983 for the remaining four ketones. Further rescheduling resulted in deadlines in mld-1982 for'all five ketones. The panel is currently undertaking an advocacy program on four of the ketones on the ITC List: MEK, MIBK, MO and isophorone. The program involves developing use and exposure information, as well as a voluntary test program. A 90-day inhalation study on methyl isobutyl ketone (MIBK) is currently underway and reproduction and teratology studies are under consideration. The panel will follow closely complimentary testing on methyl ethyl ketone by CUT, and methyl isoamyl ketone by Eastman Kodak. The panel has met once with EFA on testing recommendations for ketones under Section 4(a) and is developing a document for submission to the Agency. The document will present summaries of toxicity data on the four ketones and use and exposure information. An overview of the research program will also be included. 8.15 Phosgene (P) The Phosgene Panel was formed in April, 1975. Its purpose is to maximize safety in the production and use of phosgene, to reduce the possibility of exposure incidents, and to develop effective diagnostic procedures and therapeutic countermeasures. The panel is studying means for monitoring concentrations of phosgene in air, means of evaluating actual exposures to phosgene as a guide to medical treatment, and means of preventing incidents of phosgene release. Toward this objective, the panel has funded: o two animal studies and published two papers in the Archives of Environmental Health (These studies suggested possible mechanisms of Phosgene poisoning and candidate therapeutic agents.); o a worldwide literature search; and, o a third animal study directed coward exposure of candidate therapeutic agents expected to be effective based on the literature search or on results from the first two animal research projects. In order to improve engineering and safety practices during the manufacturing or use of phosgene, the panel is structuring and conducting four surveys to identify and update this informa tion. Dupont and Dow have each conducted in-house retrospective epidemiology studies on vrorkers exposed to phosgene. The panel does not currently find it feasible to sponsor a prospective study due to the absence of a controlled, phosgene-only exposure. 14 CMA 039412 To improve worker safety, the panel is working with instru ment designers and manufacturers to develop instrumentation with maximum sensitivity for both industrial (process) and personal monitoring, develop protective clothing, and self contained breathing devices. The panel is also exploring improved in-plant safety practices and developing optimal post-exposure diagnostic procedures and therapeutic countermeasures. 8.16 Fhthalate Esters (PE) The CMA Phthalate Esters program Panel, which was formed in 1972, originally concentrated its efforts on studying the environmental effects of phthalates. Extensive literature surveys at that time indicated little or no concern over the health effects of phthalates. The Interagency Testing Committee recommended only environmental testing on the phthalate ester class of compounds. Under the provisions of Section 4 of the Toxic Substances Control Act (TSCA), EPA could develop test rules for environmental testing; however, the phthalate esters panel began development of a comprehensive voluntary environmental effects test program. As a result of a 1980 draft report from the NCI to the National Toxicology Program which shows that di-2-ethylhexyl phthalate (DEHP; also widely known as DOP) causes hepatocellular carcinoma at high dose levels in laboratory rodents, phthalate esters received increased attention from regulatory agencies. With the disclosure of the new NTP findings, the Program Panel expanded its efforts to include a comprehensive testing program to address the human health concerns. The goal was to develop a ccxnprehensive voluntary test program that would develop test data required under Section 4 of TSCA, but without the imposition of mandatory test rules. The first phase of the comprehensive environmental effects and human health effects testing program is ready to be imple mented. The human health effects portion has been designed to examine a limited number of compounds on a risk assessment basis. The studies which comprise this phase of the program will gener ate sound scientific data that can be applicable to phthalate esters as a class, rather than to specific chemicals. Allocation of costs, was developed to include all the affected industries, phthalate producers, raw materials suppliers and phthalate users. The environmental effects testing portion, includes the 14 phthalate esters produced in large volume. The program includes acute testing for all 14 phthalates in three species. Additional acute and chronic test data will be developed for those esters for which test data is not already available. The Phthalate Esters Panel has held several discussions with Mr. Newburg-Rinn of EPA's Test Rules Development Branch. As a result of these discussions, EPA held a public meeting on September 15, 1981 to propose acceptance of the Panel's Voluntary Test Program. Final .15 CMA 039413 acceptance awaits receipt of written comments from the public and some further review within the Agency. In a response to a Citizen's Petition filed under Section 21 of TSCA, the EPA Office of Pesticides and Toxic Substances con ducted a priority review assessment of DEHP which could result in a 4(f) Action being taken by the Agency. The CMA Phthalate Esters Panel is currently working with EPA on this issue. Phthalate and adipate esters are also of interest to three Bureaus within the FDA, the Bureau of Foods, the Bureau of Biologies and the Bureau of Medical Devices. The Bureau of Biologies and the Bureau of Medical Devices are primarily interested in DEHP use in flexible plastics that come in contact with blood, blood elements or intravenous solutions. The Bureau of Foods regulates DEHA for use in plastics that come in contact with foods, and DEHP for use in plastics that contact non-fatty foods. In addition, other adipates, di-(C7, Cg-alkyl) adipate and di-n-alkyl adipate (made from Cg, Cg, C^q alcohols) are sanctioned for use in foods, but foods, but the sanctions on these latter compounds were based upon safety of DEHA. In June 1981, a new Task Group (FDATG) was formed within the Phthalate Ester Panel, to interact with FDA on issues relating to adipates and phthalates. At that time the Bureau of Foods was preparing a strategy document for submission to the FDA commis sioner which could have resulted in a restriction or ban of DEHA in food contact applications. The Phthalate Esters FDATG met with representatives of the FDA and successfully delayed the strategy document. The FDATG is currently preparing a detailed review of DEHA toxicity data and developing a voluntary testing program which FDA could accept in lieu of an interim regulation or ban on DEHA. Since the Phthalate Esters Panel was originally organized and funded to address EFA's concerns, the FDATG activi ties will be funded separately. The panel faces the challenge of presenting an industry con census on a class of compounds. Individual participating com panies have diverse interests, but all have a common goal --to minimize the regulatory action on these substances by responsi ble, voluntary programs supported broadly. 8.17 Polychlorinated Biphenyls (PCBs) The recenc decision in EDF v. EPA, NO. 79-1580, set aside two parts of EPA's regulation pertaining to PCBs. The Court found that EPA did not present substantial evidence to support its determination to: 1) exclude from regulation materials containing less than 50 ppm PCBs and, b) define the statutorily exempted "totally enclosed uses" as intact and non-leaking. As a 16 CMA 039414 result of requests by EPA and EDF the Court decided to stay Its mandate for up to eighteen months. Within this time period EPA is to collect information and promulgate a supportable regulation on PCBs. CMA staff, with advice from the Chemical Regulations Advisory Committee (CRAC) and interested company representatives, negotiated with EPA and EDF to gather information on the 50-ppm incidental generation issue. Since CRAC's budget could not support the data-gathering efforts, the Special Programs Division was asked to assume responsibility for this project. The first panel meeting was held in February, 1981. The PCB Panel is conducting two surveys of its member com panies: 1) 50 ppm incidental generation survey - to characterize the nature and scope of the low concentrations of PCBs; 2) total ly enclosed survey - to identify the numbers of pieces of elec trical equipment which contain PCBs, the volume of such PCBs, and their concentration levels or ranges. The information obtained from these surveys will be presented to EPA. In August 1981, the panel submitted to EPA an analytical narrative dissertation dis cussing the problems and costs associated with low level PCB analysis. The panel is currently conducting an analytical roundrobin testing program which involves both industry and EPA laboratories. 8.18 Rubber Additives (RA) The Rubber Additives Program Panel was formed in March 1980 to sponsor research that would expand the toxicological data base on rubber chemicals of interest to participating companies. As an initial effort, the panel sponsored a series of in vitro tests on purified and commercial samples of 2-(morpholinothio) benzothiazolesulfenamide (MBS). Further testing of MBS is presently under consideration, as is the need for testing of other rubber additives. The panel works in close cooperation with both the WTR (International Working Group on Rubber Chemical Toxicology) and the Rubber Manufacturers Association. All three groups have been concerned with nitrosamines in the workplace and the panel is considering undertaking a testing program on nitrosamine. 8.19 Styrene (S) The Styrene Program Panel is expanding the styrene toxicol ogy data base. The panel also represents the interests of its members before federal agencies in matters relating to safety and health issues. A two-year chronic and three-generation reproduction study of styrene in drinking water was completed and released to fed- ,17 OMA 039415 eral agencies. The panel also reviewed a draft final report on a styrene pharmacokinetic study in mice. The latter study indi cated species differences with respect to acute styrene toxicity in rats and mice. The panel presently is assessing how these differences relate to man before proceeding further with a research program. The panel incorporated a Regulatory Task Group to address EPA's proposed regulations (NESHAP) for benzene emissions from ethyl benzene/styrene plants comments were submitted to EFA on June 1, 1981. 8.20 Titanium Dioxide (TD) In 1977, Du Pont initiated a review of the literature on titanium dioxide toxicity and concluded that further Information was needed to answer possible questions which might be directed at titanium dioxide. The impact of the Toxic Substances Control Act also raised concern as to the adequacy of existing information. The panel has tentatively concluded that a historical mortality study is not justified at this time. The panel plans to terminate program activities if no new evidence of human health effects is reported as a result of the two year inhalation studies being conducted by Du Pont. 8.21 Trichloroethylene (TCE) The Trichloroethylene Program Panel was formed on May 12, 1975 in response to an NCI Memorandum of Alert. The panel's primary concern was a long-term inhalation study. A contract was signed in 1975 with Industrial BIO-TEST Laboratories (IBT) to conduct such a study. The testing performed by IBT resulted in a number of grave inadequacies and a final report was not issued. Therefore, the CMA TCE Audit Task Group prepared an audit report. EPA's Cancer Assessment Group has asked the panel to provide validation of chamber concentrations for the first 12 to 15 months of the IBT study. The panel is monitoring the progress of the NCI bloassay on TCE which involves several strains of mice and rats. Although the panel contemplated an epidemiological study, SOCMA determined that a study population for an epidemiologic investigation would be too small to yield statistically signif icant results. Therefore, such a study was not conducted. 8.22 Vinyl Chloride (VC) Since 1972, the Program Panel has supported activities related to che accumulation and assessment of health and safety data of vinyl chloride monomer, .18 CMA 039416 | After funding several animal studies, the emphasis on research shifted from toxicological investigations to the early diagnosis and clinical management of vinyl chloride-related injuries. The panel is also funding an update of a vinyl chloride epidemiology study of 10,000 workers. The panel has maintained a close liaison with SPI and several European-based companies. The present interest in polyvinyl chloride (PVC) dust control limits in the UK is being closely followed. Several months ago OSHA requested information on PVC dust; however, no notice has been published or other action taken. 8-23 Vinylidene Chloride (VDC) The Vinylidene Chloride Program Panel was formed in May 15, 1974 to investigate the potential toxicologic effects and pharma cokinetics of Inhaled and Ingested VDC in laboratory animals. Dow Chemical, which was planning research on VDC toxicology, agreed to convert its program into an industry-wide effort. The IWo-Year Inhalation Toxicity and Oncogenicity Study of Vinylidene Chloride in Rats is stil in progress. The Work Practices Task Group of the panel prepared a Health and Safety Work Practices Guideline for Vinylidene Chloride to minimize exposure to Vrn.. The Guidelines were sent co the Director of NIOSH and the Project Manager for Criteria Documents at SRI. They received no other distribution. The panel is preparing to respond to a Health Risk Assess ment Criteria document on VDC under preparation by the EPA Cri teria and Health Assessment Group. OSHA does not have a standard for VDC and EPA is unlikely to require any further toxicity testing on VDC under TSCA Section 4. The pharmacokinetics and metabolism research show a species sensitivity of Mouse>Rat>Man. The total data bank indicates oncogenicity is not observed without recurrent tissue damage and without a cytotoxic dose; a tumorigenic response in man would be an improbable event. 8.24 Zinc Dialkyl Dithiophosphates (ZDDP) The ZDDP Program Panel was chartered in November 1980 to conduct research on this class of oil additives. As a first step, gonadal toxicity studies of three ZDDP compounds were initiated in immature and mature rats and rabbits. Obvious species differences were observed between rabbits and rats with respect to ZDDP toxicity. Consequently, the panel proposes to conduct a comparative in vivo pharmacokinetic study 19 CMA 039417 in the rat, rabbit, and man. A dose-response study is also proposed to determine a no-effect level In rats and rabbits. In vitro testing of ZDDPs by individual companies has shown that some members of the class have genotoxic potential. The Program Panel is considering conducting mutagenicity/carcino genicity assays to further assess this potential. CMA EC-11/2/81 BD-11/3/81 20 CMA 039418 TABLE 1 BIOMEDICAL AND ENVIRONMENTAL SPECIAL PROGRAMS BUDGET SUMMARY* PROGRAM RESEARCH AND ADVOCACY COMMITMENT ADMINISTRATIVE EXPENSES TOTAL Acrylonitrile S 728,484 $ 79,172 3807,656 Allyl Chloride 309,500 17,186 326,686 Arsenic 10,000 8,600 18,600 Benzene Butylated Hydroxytoluene Chlorobenzenes Epichlorohydrin Epoxy Resins Ethylene Dibromide Ethylene Dichloride Ethylene Oxide Glycol Ethers Ketones Phosgene Phthalate Esters Polychlorinated Biphenyl s t rubber Additives Styrene Titanium Dioxide Trichloroethylene ''inyl Chloride i-nylidene Chloride 2inc Dialkyl Dithiophosphates Subtotal fluorocarbons 3,048,684 21,944 370,722 315,032 -010,039 288,100 -0313,000 208,880 217,512 186,585 100,434 30,725 708,218 30,725 490,506 1,326,562 729,482 79,857 9,524,991 9,216,650 112,262 3 ,160,946 29,467 37,952 27,432 15,059 43,032 64,449 15,518 15,232 28,977 85,728 132,628 18,869 17,730 66,545 23,969 89,738 119,701 57,440 51,411 408,674 342,464 15,059 53,071 352,549 15,518 328,232 237,857 303,240 319,213 119,303 48,455 774,763 54,694 580,244 1, 446,263 786,922 12,207 1,118,893 569,753 92,064 10, 643,884 9, 786,403 T )TAL $18,741,641 31,688,646 $20, 430,287 a Fluorocarbons program from start thru May 30, 1981. ;A11 other programs start t co September 25, 1981. CMA039419 sliartj Figure ) - Blompilleal an.I Knvl romaental Special ProKroms Division CMA 039420 Hie Ccmnittee will: advise the Executive Ccmnittee on the acceptance of new programs, ensure that all special prograns are conducted in a manner consistent with CMA policy and with the Special Program Guidelines; and, review and make reccmnendations on all advocacy programs on individual chemical(s) requested by a program panel car staff. TERM ENDING MAY 31, 1982 H. Donald Feeney................................................ Borg-Wamer Chemical Corporation, International Center, Parkersbury, W 26101 George J. Levinskas.......................................... Monsanto Caipany, 800 North Lindbergh Boulevard, St. Louis, MO 63166 Curtis W. smith............................................... Shell Chemical COtpany, P. O. Box 2463, Houston, TX 77001 Otto Sturzenegger...................................... Chairman* CIBA-GEIGY Corporation, Ardsley, NY 10502 Carl Unland........................................................... Exxon Chemical Americas, P. O. Box 3272, Houston, TX 77001 TERM ENDING MAY 31, 1982 William C. Decker.............................................. The BFGoodrich Ccnpany, 6100 Oak Tree Boulevard, Cleveland, OH 44131 Calvin Benning..................................................... Essex Chemical Corporation, 1401 Broad Street, Clifton, NJ 07015 Conrad Kent........ .................................. .............. Stauffer Chemical Cfcnpany, Westport, CP 06800 Myrl E. Miller..................................................... IMC Chemical Group, 421 East Hawley Street, Mundelein, IL 60060 Gary Ter Haar..................................... ................. Ethyl Corporation, 451 Florida Avenue, Baton Rouge, LA 70801 T>3 *o it a3. X > TERM ENDING MAY 31, 1984 Noble Robinson..............Mallinckrodt, Inc., P O Box 5840, St. Louis, MO 63134 jerry M. Smith............. Rohm and Haas Company, Spring House, PA 19477 Gary Sunshine................ICI Americas, Wilmington, DE 19897 Joan E. Young................ Petrolite-Tretolite Division, 369 Marshall Avenue, St. Louis, MO 63119 John J. Zimmerman...ARCO Chemical Company, 3801 West Chester Pike, Newtown Square, PA 19073 Through May 31, 1982 Staff Executive: Hasmukh C. Shah CMA 039422 N> Appendix B CMA 039423 HUMBER 1. 2. 3. 4. 5. PROGRAM HAME Acrylonitrile Allyl Chloride Arsenic Benzene Bu ty1^ted ^Hy droxytoluene 6. Chlorobenzenes 7. Eplchlorohydrin 8. Epoxy Resins 9. Ethylene Dibromide 10. Ethylene Dichloride 11. Ethylene 0x1de 12. Fluorocarbons 13. Glycol Ethers 14. Ketones 15. Phosgene 16. Phthalate Esters 17. Polychlorinated Biphenols 18. Rubber Addltlves 19. Styrene 20. Titanium Dioxide 21. Trichloroethylene 22. Vinyl Chloride 23. Vinylidene Chloride 24. Zinc Dialkyl Dlthlopnosphates LIST OF SPECIAL PROGRAMS PROGRAM TYPE START DATE Research 06/20/74 Research 08/19/75 Research and Advocacy 01/29/81 Research and Advocacy 02/08/77 Research and Advocacy Research Research Research and Advocacy Research . Research Research and Advocacy Research and Advocacy Research and Advocacy Research and Advocacy Research Research and Advocacy Advocacy Research and Advocacy Research and Advocacy Research Research Research and Advocacy Research 09/19/77 12/16/74 08/19/75 01/18/77 03/22/79 12/17/74 04/16/81 04/09/73 06/26/80 01/23/80 05/18/72 02/24/72 02/11/81 09/10/79 10/24/74 06/13/77 05/12/75 11/16/71 05/15/74 Research and Advocacy 10/02/80 COMPLETION DATE 08/31/80 Appendix C COMPANIES PARTICIPATING IN SPECIAL PROGRAMS ABBOTT LABS Ethylene Oxide AIR PRODUCTS Vinyl Chloride AKZO CHEMIE BV Fluorocarbons ALLIED CORPORATION Fluorocarbons, Ketones, Phthalate Esters, Phosgene AMAX LEAD & ZINC, INC. Arsenic AMERICAN CYANAMID Acrylonitrile, Phthalate Esters, Rubber Additives AMERICAN HOECHST Styrene ~ AMOCO Benzene, Styrene, Zinc Dialkyl Dithiophosphates ANACONDA COPPER COMPANY Arsenic ARCO CHEMICAL Benzene, Phthalate Esters, Polychlorinated Biphenyls ARCO/POLYMERS Styrene A5AHI-DOW LIMITED vinylidene Chloride ASAHI GLASS CO., LTD. Fluorocarbons, Vinylidene Chloride ASARCO INC. Arsenic ASHLAND CHEMICAL Benzene ASSOCIATED OCTEL COMPANY Ethylene Dibromide CMA 039424 AUSTRALIAN FLUORINE CHEMICALS PARTY, LTD. Fluorocarbons BASF WYANADOTTE Ethyl"ene Dichloride, Ethylene Oxide, Phosgene, Phthalate Esters. BECTON DICKINSON Ethylene Oxide BETHLEHEM STEEL Benzene BORDEN CHEMICAL --Ethylene Dichloride, Phthalate Esters, Vinyl Chloride BORG-WARNER CHEMICALS Acrylonitrile, Styrene BRISTOL LABS Ethylene Oxide C-I-L, INC. Trichloroethylene CELANESE PLASTICS SPECIALTIES CO. Epoxy Resins, Ethylene Oxide CERTAIN-TEED Vinyl Chloride CHESEBROUGH PONDS Ethylene Oxide- CHEVRON Phthalate Esters, Zinc Dialkyl Dithiophosphates CIBA-GEIGY Epoxy Resins CONOCO CHEMICALS Ethylene Dichloride, Ethylene Oxide, Phthalate Esters, Vinyl Chloride COSDEN OIL Benzene, Styrene CRESCENT MANUFACTURING CO Ethylene Oxide DAIKIN KOGYO CO. LTD. Fluorocarbons CMA 039425 C-3 DART INDUSTRIES Butylated Hydroxytoluene DIAMOND SHAMROCK Arsenic, Ethylene Dichloride, Polychlorinated Biphenyls, Phthalate Esters, Trichloroethylene, Vinyl Chloride DOW CHEMICAL Acrylonitrile, Allyl Chloride, Benzene, Chlorobenzenes, Epoxy Resins, Ethylene Dibromide, Ethylene Dichloride, Ethylene Oxide, Glycol Ethers, Ketones, Styrene, Trichloroethylene, Vinyl Chloride, Vinylidene Chloride E. I. DU PONT DE NEMOURS & CO. Acrylonitrile, Benzene, Ethylene Dichloride, Fluorocarbons, Phosgene, Phthalate Esters, Polychlorinated Biphenyls, Titanium Dioxide, Vinylidene Chloride DU PONT CANADA INC. Fluorocarbons ELCO CORPORATION Zinc Dialkyl Dithiophosphates EL PASO PRODUCTS COMPANY Styrene EASTMAN KODAK Polychlorinated Biphenyls ESSEX CHEMICAL (RACON) Fluorocarbons ETHYL CORPORATION Allyl Chloride, Ethylene Dibromide, Ethylene Dichloride, Esters, Trichloroethylene, Vinyl Chloride, Zinc Dialkyl Dithiophosphates Phthalate EXXON Benzene, Ketones, Polychlorinated Biphenyls, Phthalate Esters, Vinyl Chloride, Zinc Dialkyl Dithiophosphates FOXMATIC CORP Ethylene Oxide GENERAL ELECTRIC Phosgene, Phthalate Esters, Polychlorinated Biphenyls GENERAL TIRE & RUBBER Phthalate Esters, Vinyl Chloride CMA 039426 C-4 bfgoodrich Allyl Chloride, Ethylene Dichloride, Rubber Additives, Vinyl Chloride, Vinylidene Chloride GOODYEAR TIRE & RUBBER Rubber Additives, Vinyl Chloride W. R. GRACE Vinyl Chloride, Vinylidene Chloride GREAT AMERICAN CHEMICAL Vinyl Chloride GREAT LAKES Ethylene Dibromide GULF CHEMICAL CO. Acrylonitrile^ Benzene, Ethylene Dichloride, Styrene, Vinyl Chloride GULF & WESTERN Titanium Dioxide HALCON Ethylene Oxide HOECHST AG/AMERICAN HOECHST Fluorocarbons HOOKER CHEMICAL Polychlorinated Biphenyls, Trichloroethylene, Vinyl Chloride ICI AMERICAS Ethylene Dichloride, Glycol Ethers, Vinyl Chloride IMPERIAL CHEMICAL INDUSTRIES PLC Fluorocarbons, Trichloroethylene INMONT CORPORATION Phthalate Esters ISC CHEMICALS LTD Fluorocarbons JAPAN FLON GAS ASSOC. Fluorocarbons JOHNSON & JOHNSON Ethylene Oxide C-5 KAISER ALUMINUM AND CHEMICAL CORP Fluorcarbons, Polychlorinated Biphenyls KALI CHEMIE AG Fluorocarbons KENDALL CO Ethylene Oxide KEYSOR-CENTURY vinyl Chloride KOPPERS COMPANY Arsenic, Benzene, Butylated Hydroxytoluene, Phthalate Esters KUREHA CHEMICAL INDUSTRY Vinylidene Chloride LOBRIZOL Zinc Dialkyl Dithiophosphates MALLINCKRODT INC Ethylene Oxide MICRO BIOTROL Ethylene Oxide MITSUI FLUOROCHEMICALS LTD Fluorocarbons MOBAY CHEMICAL Phosgene, Rubber Additives MOBIL OIL CORPORATION Benzene, Phthalate Esters MONSANTO COMPANY Acrylonitrile, Benzene, Chlorobenzenes, Ketones, Polychlorinated Biphenyls, Phthalate Esters, Rubber Additives, Styrene, Vinyl Chloride, Vinylidene Chloride MONTEDISON SPA Fluorocarbons, Phosgene MONTROSE CHEMICAL CORP OF CA Chlorobenzenes MORTON CHEMICAL Vinylidene Chloride CMA 039428 MALCO CHEMICAL COMPANY Ethylene Oxide C-6 NL INDUSTRIES Titanium Dioxide OLIN CORPORATION Glycol Ethers, Polychlorinated Biphenyls, Phosgene, Vinylidene Chloride OSMOSE WOOD PRESERVING COMPANY Arsenic PANTASOTE Phthalate Esters PENNWALT Arsenic, Fluorocarbons, Rubber Additives PHILLIPS PETROLEUM COMPANY Benzene PPG INDUSTRIES Chlorobenzenes, Ethylene Dibromide, Ethylene Dichloride, Ethylene Oxide, Glycol Ethers, Polychlorinated Biphenyls, Phosgene, Trichloroethylene, Vinyl Chloride, Vinylidene Chloride POLYSAR LIMITED Benzene PRODUITS CHIMIQUES UGINE KUHLMANN Fluorocarbons REICHHOLD CHEMICALS Epoxy Resins ROHM & HAAS Vinylidene Dichloride RUBICON Phosgene SALSBURY LABS Arsenic SCM CORPORATION Titanium Dioxide SHELL CHEMICAL COMPANY Allyl Chloride, Benzene, Butylated Hydroxytoluene, Epoxy Resins, Ethylene Dichloride, Ethylene Oxide, Glycol Ethers, Ketones, Phthalate Esters, Vinyl Chloride, Styrene, Zinc Dialkyl Dithiophosphates, SHERWIN WILLIAMS Butylated Hydroxytoluene CMA 039429 u- / SHERWOOD MEDICAL Ethylene Oxide SHOWA DENKO KK Fluorocarbons STANDARD CHLORINE CHEMICAL CO Chlorobenzenes STANDARD OIL (OHIO) Acrylonitrile, Benzene STANGE COMPANY Ethylene Oxide STAUFFER CHEMICAL Ethylene Dichloride, Phosgene, Phthalate Esters, Polychlorinated Biphenyls, vinyl Chloride STEPEN CHEMICAL Phthalate Esters SUN PETROLEUM PRODUCTS Styrene SUNSHINE MINING CO Arsenic TECKNOR-APEX Phthalate Esters TENNESSEE EASTMAN Acrylonitrile, Glycol Ethers, Ketones, Phthalate Esters, Vinylidene Chloride TENNECO CHEMICALS Vinyl Chloride TEXACO INC Benzene, Ethylene Oxide, Glycol Ethers, Zinc Dialkyl Dithiophosphates, TIOXIDE CANADA, LTD Titanium Dioxide TOMS RIVER Phosgene TRAVENOL LABS Ethylene Oxide UNION CARBIDE Benzene, Ethylene Dichloride, Ethylene Oxide, Glycol Ethers, Ketones, Polychlorinated Biphenyls, Phosgene, Phthalate Esters, Stvrene, Vinyl Chloride CMA 039430 C-8 UNION OIL OF CA Vinylidene Chloride UNIROYAL, INC. Acrylonitrile, Butylated Hydroxytoluene, Rubber Additives, Vinyl Chloride USS CHEMICALS Benzene, Phthalate Esters, Styrene UPJOHN COMPANY Phosgene VULCAN MATERIALS Ethylene Dichloride, Polychlorinated Biphenyls WITCO CHEMICALS Phthalate Esters WARREN CHEMICAL CO Ethylene Oxide 9/25/81 CMA 039431 Exhibit C REGULATORY IMPACT SPECIAL COMMITTEE Subject Objective Recommendations Action Required The Public Risk Analysis Special Committee (PRASC) has fulfilled the requirements of its Charter and should sunset. A new Reg ulatory Impact Special Committee should be formed to develop appropriate methodologies for use in regulatory impact analysis by CMA. To form a Special Committee which can help CMA support the Administration's regulatory policy more fully, and function within the guidelines of CMA's Policy for Regulatory Impact Analysis of Health, Safety and Environ mental Regulations. That the CMA Executive Committee sunset the Public Risk Analysis Special Committee and approve the attached charter for a new spe cial committee, the Regulatory Impact Special Committee (RISC). The list of proposed com mittee members will be sent to the Executive Committee under separate cover. Sunset PRASC and approve the charter for RISC. CMA EC - 11/2/81 BD - 11/3/81 CMA 039432 REGULATORY IMPACT SPECIAL COMMITTEE CHARTER Under the Regulatory Impact Analysis Policy for Health, Safety and Environmental Regulations approved by the Board of Directors and within the limits of authority specified by the Executive Committee, the Special Committee wi 11 define and develop appropriate methodologies for use In regulatory impact analysis by CMA. The Special Committee will maintain liaison with organizations active In regulatory impact analysis, and will promote an exchange of Information with regulatory ' agencies, other associations, and chemical and allied industries. Among Its members the Special Committee shall have repre sentatives from other appropriate CMA committees. This method of committee structure would insure consistent analysis across the spectrum of CMA Interests. CMA EC - 11/2/81 BD - 11/3/81 a CMA 039433 REGULATORY IMPACT SPECIAL COMMITTEE Nominees Mr. Jackson B. Browning (CHAIRMAN) Union Carbide Corporation 270 Park Avenue New York, NY 10017 Mr. Anthony DiBattista CIBA-GEIGY Corporation Saw Mill River Road Ardsley, NY 10502 Mr- H. Granville Haight, Jr.E. I. du Pont de Nemours & Company 1007 Market Street - Room 1354 Wilmington, DE 19898 Dr. Peter W. Ifland The Procter & Gamble Company Miami Valley Laboratories P. 0. Box 39175 Cincinnati, OH 45247 Dr. Ann Baker Jenkins Environmental Affairs Allied Corporation P. O. Box 2332-R Morristown,' NJ 07960 Mr. John McCarthy Hoppers Company, Inc. 1201 Koppers Building Pittsburgh, PA 15219 Mr. William K. Newbury Conoco Inc. High Ridge Park Stamford, CT 06904 Mr. Thomas H. Rhodes Exxon Chemical Americas P. 0. Box 3272 Houston, TX 77001 Dr. William R. Richard Monsanto Company 800 N. Lindbergh Boulevard St. Louis, MO 63166 Mr. Charles L. Sercu The Dow Chemical Company 1800 M Street, N.W. Washington, DC 20036 Dr. Peter M. Wolkonsky Standard Oil Company (Indiana) Mail Code 3805 P. 0. Box 5910-A Chicago, IL 60680 Mr. Rene D. Zentner Shell Oil Company P. 0. Box 2463 Houston, TX 77001 CMA EC-11/2/81 BD-11/3/81 Staff Executive: D. Chris Cathcart CMA 039434 COMMITTEE APPOINTMENTS Exhibit D 1. Communications Committee Gerald J. Hickman - Gulf Oil Chemicals Company (Term ending May 31, 1982) (Replacing James A. Pulver - Gulf) 2. Engineering Advisory Committee Vladimir Harris - Amoco Chemicals Corporation (Term ending May 31, 1984) (Replacing Porter G. Stevens - Amoco) R. N. Finch - El Paso Products Company (Term ending May 31, 1983) (Replacing J. C. Arnold - El Paso Products) 3. Environmental Management Committee Robert Wolfe - Ashland Chemical Company (Term ending May 31, 1983) (Replacing James H. Davis - Ashland) Edward J. Dineen - ARCO Chemical Company (Term ending May 31, 1982) (Replacing F. B. Friedman - Atlantic Richfield Company) 4. Hazards Communications Special Committee C. Duane Carley - Hooker Chemical Company Adna Casey - Stauffer Chemical Company CMA EC-11/2/81 CMA 039435