Document JJZ8roD4dxOzBJ2gmXx6KN1Dr

TO: Rick Johnson paCwrf it?* rf XF: ^ icn Interoffice Communication FROM: DATE: SUBJ: E. R. Taylor November 22, 1989 SARA 313 CUSTOMER NOTIFICATIONS VIS1A * 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 questions. 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. 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. cc: M. H. Horowitz D. L. Cohen 0000070-rz ALFOL 4 ALCOHOL AQUEOUS ALUMINUM CHLORIDE BLANE PVG COMPOUNDS BUTADIENE CONCENTRATE CATAPAL G AND GST ALUMINA EDC/VCM HEAVY ENDS ETHYLENE ETHYLENE BICHLORIDE (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 vvy 000007073