Document KGvD1e5qKY1a4dXJGpqgVz290

CHEMICAL MANUFACTURERS ASSOCIATION January 7, 1988 Mr. Peter L. de la Cruz Keller and Heckman 1150 17th Street, NW Suite 1000 Washington, DC 20036 Dear Mr. de la Cruz: Thank you for your correspondence of December 30 regarding the Vinyl Chloride Mutual Aid Assistance program. We recognize this program was never formalized, and that it was more of a "gentlemen's" agreement among the producers involved. However, during the years it was active, the program was one of the better tools CHEMTREC was able to use to the industry's advantage. Quite often during a train derailment actual shipper identification is impossible to obtain at the time of initial call to CHEMTREC. It was quite valuable to have this resource for VCM response available during such instances. During the later part of 1986, on attempt was made by us to revive the program. Each listed member was approached and asked to Indicate his preference to one of three options. They were: 1) continue and reorganize the VCM plan to reflect the SPI withdrawal from sponsorship of the plan; 2) incorporate the VCM plan into the CHEMNET program; and 3) disband the VCM mutual aid plan without additional action. The majority preferred to disband. Although our records were modified to indicate that the VCM plan no longer existed, some references remained in our operations manual and thus a recent attempt was made to activate the system. Please be assured all files and references to this voluntary program have been removed from our operational files. Sincerely, JJM/ejf Joe 4. Mayhew Director, National Chemical Response and Information Center (NCRIC) Formerly Manufacturing Chemists Associatioh--Serving the Chemical Industry Since 1872. 2501 M Street. NW Washington, DC 20037 Telephone 202/887-1100 Telex 89617 (CMA WSH) BOR 014686 LAW OFFICES Kelleh and Heckman C *CLLft tlCWOMt h hcc*mam chanlca m human WlLUAM M lONOMtlANI, JN, MALCOLM ft MAA*tHUH AVNE V BLACK t(KCHCC 0 JONH MARTIN W, BCHCOVlCl JOHN ft tlftAEO FREDERICK A ft0VOaWV CAROLE C MICHAEL t mORRONE MACK ro EVEN* JOHN ft. DUftECK aETCH L. LA CRUI CHAlftTIME A. mCaAnER hIRLCT ft fUJIMOTO LAWRENCE a HALAKIM AALKM A. IIUEONl acre* a. muftten C. DQUOLAft VAftRETT ftMOLA A MiLLAft (Alia MARTHA MrMAMAJEA jtmm ricmanor* MftLVIN ft. OftOlEM wredCRiCh y. bay. ya MARCI E. CftftCNftTftlH* SUftAH T CONTI w*am v aistoca mtwCr v HUM** ft, CHAIO TAUTFCST OAVI0 H JETT MALIREEN A O'CONNELL** KAREN ft. EOELftERO* MIMA M RlMftTEIM**HAMM A, ft'CVERR*** MART CHAMBERS ORANOV** O FRANKLIN koontiTM CATHERINE N NQSNEN** Kofttar Jeffrey til***** RICHARD A. JAFFE* `ADMITTED IN AWM*WVAMIA ONLY **ADMtTTE0 IN VIRGINIA ONLY ***ARMlVTED IM MARYLAND ORLY --aomitteO in COLOKAM Only UOO 17" STREET, N.W, SUITE lOOO WASHINGTON. D.C. 80038 (208) 950-0000 December 30, 1987 H,iveiVi;0 SCIENTIFIC tTAPf DANIEL ft OlXLfft DUNWAIIO P QOOOt* Charles v, ftftcocft ROBERT a. MATHCWft TELECOMMUNICATIONS CHARLES P. TURNER TKLCX TcLECoaita iiou !#?*> CABLE AQQatftft "KELMAN" writer's piafter dial number (202) 956-5641 JAN 41987 Mr. Joe J. Mayhew, Director National Chemical Response Ofl.fi r m ' ` ,G0nESLt4yy and Information Center Chemical Manufacturers Association 2501 M Street, N.W. Washington, D.C. 20037 Re: Vinyl Chloride Dear Mr. Mayhew: I am writing on behalf of the Vinyl Institute, a division of The Society of the Plastics Industry, Inc. (SPI), concerning response procedures for incidents involving vinyl chloride. This letter is intended to confirm the propriety of the Chemical Transportation Emergency Center's (CHEMTREC) cur rent handling of vinyl chloride in the same manner as other chemicals. In 1976, an SPI division known as the "VCM/PVC Produc ers Group" met and attempted to create an emergency response plan for incidents involving vinyl chloride under which the producers would respond to accidents located closest to their facilities regardless of the actual manufacturer or shipper. This was sometimes referred to as the VCM Voluntary Emergency Response Program and also the Vinyl Chloride Mutual Assistance Program. Participants in this program included Borden Chemical Company, Conoco Chemicals, Diamond Shamrock Chemical Company, Dow Chemical Company, General Tire and Rubber Company, BFGoodrich Chemical Company, Goodyear Tire and Rubber Company, Great American Chemical Company, Hooker Chemical and Plastics Com pany, PPG Industries, Shell Chemical Company and Stauffer Chem ical Company. These companies and others may have written to BOR 014687 Mr. Joe J. Mayhew December 30, 1987 Page Two . Keller and Heckman CHEMTREC in 1976 and 1977 authorizing CHEMTREC to release the company's name and telephone numbers and the location of response teams when, in CHEMTREC's judgment, the company's response personnel were in a geographic position to render aid most effectively. Although well-intentioned, this mutual assistance program did not work as a practical matter. We understand that CHEMTREC voluntarily retired the files relating to this program some years ago. Since the initial attempts to organize the program, the industry has undergone substantial consolidation. This, accompanied by shifts in the geographic distribution of production facilities, have also minimized the underlying ra tional for the program. Moreover, since there is no universal ly-followed standard for equipment coupling, technical obsta cles to an effective mutual response program exist. We trust that this letter will adequately summarize the reasons for CHEMTREC's discontinuance from the program and serve as a file memorandum rescinding any company authoriza tions. If you have any comments or questions, please let me know. Sincerely Peter L. de la Cruz cc: Robert D. Luss, Esq. W. C. Holbrook Herb Waltemate Charles E. O'Connell Robert W. Sherman Roy T. Gottesman, Ph.D. BOR 014688