Document GmxMo7KgLKj9MRyq0DLDm6nY4

SENT BYrHYOTT SO SOLES OFFICE : 10- 7-93 8:520f1 Interoffice Memo via tax 02274923-* Ait G*llnr B. F. GOODRICH MSXX - HAZARDS 06-26-93 Artt X mi contacting vith you certainTeed's representative for pvc retina. At mentioned in our telephone oonvereetion this morning, on June 34th 1993 XPA visited our flrinnell fsoility end did Community Right to Knew inspection. The inepector did not tek ieeue vith anything ve were doing aueapfc that he eurmieed thet ve had violated the IIA&A reporting requirement in our not reporting B p Goodrich Seen Vinyl Resins at haiardoue. Thia oonoluaion vaa bated on a review of the Aeon kids (attached) vhiah indio tee that there are haiiarde aaaooiatad with thia material, vhich ve Jcnov factually are not legitimate. CertainTeed had and oontinuea to uee OSSA 39 CPU 1910.1300 (d) which allows that if ve take a poo it ion eohtrary to the XSOS ve oan do our own haaard aeeeeeaent and base our reporting on that. We verb required by SPA to oontaet Xova'a osHA group and have them egree vith our aeooeemeat in order to vaeete the violation, vhich ::o*ha had indicttod, after toae long and datailad dialogue, that thay vould confirm and agroa vith our petition, tlnco Idiat time, the parties Involved have changed, and the person from that agency new involved has indioetod that ha foole vs are wens. Sa has taken that position based on a 1attar in the fedorel database from the Vinyl institute arguing 1 [lrevents of vinyl chloride .. js to defend our position end ve evpaet a meeting vith the agency shortly. The position of BPS doss not serve anyone including them. Nike colittl's position io that if SPC only offers haiardoue rtains, ve vill buy a eoapetiters' product vhich is not listed as being haiardoue. X agree vith and support Hike's position. inoe then. WTO has laaued a letter (alee attached) vhloh advisee that vhllu they oontinua to assess no heaards vith the use of their product, end thet they are not required te do t by regulation, they intend nonethe lees to re-institute the oarcinogen labeling of their produots on rail eare, ato. which they had dieeentlnued soma 104- years before. i Our company's position is that ve report oubotonooo vhich ar haiardoue via IAXA reporting obligation!, but vs do not var-r p rt in ritr to ml lead th public into believing that va are using oavaral ml111 n pound! f materialo vhich ar oonaidarad hazardous but vhich d n't represent any ha sards. CTL009992 0331Niai4G3 9E:i0 6. A0 IDO SENT BY:HYQTT SO SOLES OFFICE i10- 7-93 8:530M : 2102274928-) 21B227492S; Zf BfO Is ta);ino this position in sooo sannsr to farther protoot thsoaolvsii, thsy nasd to know that they ars going to pay a prioo to do so* ovsr-vsrning dots nothing hut oonfuos tho roguiatory oonunlty and it oorvoo to causa othoro in tho saao industry to vasts tins dsaonstrating thoir rational* vhieh happsns to bo diflorsnt txam pro's, riasso 1st so knov hot your disoussiens go with *79's roprossntstivs. CTL009993 e-d 0331NIWia3D Z`.i0 E6< 40 100