Document LgdpRnQpZpOqM3qx1bJKxDkqw

The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, NewYork 10017 (212)573 9400 March 10, 1978 < i RECEIVED MAR 13 1978 O t4. wheeler, JR TO: THE PVC SAFETY GROUP Gentlemen: Piease note as indicated in. the Minutes of the PVC Steering and Communications Committees, it is planned that the PVC Safety Group will take part in the EPA meeting scheduled for March 23 at the EPA offices. Waterside Mall, 410 M. Street, S.W. Washington, D.C. Room 3906 at 8:30 A.M. It would be advisable to have a representative from your company attend this meeting if at all possible. You can expect that a draft of the presentation material will be sent to your attention about March 20. Very truly yours. John R. Lawrence Technical Director JRL:gm ucc 008194 minut s PVC SAFETY GROUP STEERING COMMITTEE Tuesday, February 28, 1978 8:30 A. M. Sheraton Hopkins Hotel Cleveland, OHIO SUMMARY: 1 - PVC Safety Group has been designated by The American Industrial Health Council (AIHC) to represent them at the EPA meeting to review its carcinogen policy on March 23. PVC Safety Group members are urged to to be present. 2 - Nominating Committee recommends present officers of Steering Committee to serve for a second year. 3 - The next meeting of the full PVC Safety Group is March 31, 1978 in Arlington, Virginia. ATTENDEES: D. C. Nuechterlein - CHAIRMAN - Dow Chemical USA, 2020 Dow Center, Midland, Mi 48640 E. G. Ackerman - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 A. Ross Adams - Air Products & Chemicals, 400 Orchid Circle, Emmaus, Pa 18049 Gary H. Baise - Beveridge, Fairbanks & Diamond, One Farragut Square South, Wash. D.C. J. T. Barr - Air Products & Chemicals, Box 538, Allentown, Pa 18105 R, W. Fortenbach - Shell Chemical Co., One Shell Plaza, Houston, Texas 77001 Ralph L. Harding - SPI - 355 Lexington Avenue, New York, NY 10017 Francis Hor - Firestone Plastics Co., P. 0. Box 699, Pottstown, Pa 19464 Jack Jaglom - The Pantasote Co., of N.Y. 26 Jefferson Street, Passiac, NJ 07055 R. W. Laundrie - General Tire & Rubber Co., One General Street, Akron, Ohio 44329 John R. Lawrence - SPI - 355 Lexington Avenue, New York, NY 10017 William Rupp - Tenneco Chemicals, P. 0. Box 365, Piscataway, NJ 08854 Dick Savage - B. F. Goodrich Chemical Div., 6100 Oak Tree Blvd., Cleveland, Ohio 44131 Steve Schaefer - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 Don K. Spencer - Shell Chemical Co., One Shell Plaza, Houston, Texas 77001 Dale W. Sullivan - Ethyl Corp., 451 Florida Blvd., Baton Rouge, La 70801 Todd Walker - Firestone Plastics Co., Firestone Blvd., Pottstown, Pa 19464 Professor Richard Wilson - Harvard University. THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue * New York, N.Y. 10017 (212)573-9400 ucc 008195 Chairman Nuechterlein opened the meeting by calling on Messrs. Schaefer and Barr to review the results of the meeting held with the AIHC Steering Committee relative to the review of EFA's carcinogen policy. The conclusion of this meeting was that AIHC wishes the PVC Safety Group to act for AIHC at the EPA hearing scheduled for March 23. In doing this, AIHC would make available any of their background preparations that have been made for the chemical industry's response to the OSHA Generic Carcinogen proposals. Mr. Baise presented a Proposal Work Plan for an SPI presentation at the EPA March 23 meeting on its generic regulation of carcinogenic air pollutants. (Attachment A). With respect to broadening the SPI comments to cover materials other than just vinyl chloride or plastics related chemicals, he suggested it would be difficult to do this adequately by March 23. Reference was made to two reports that might be cited to EPA as a basis for any changes in the EPA's carcinogen policy: . Principles for Evaluating Chemicals in the Environment National Academy of Sciences, 1973 . Decision Making for Regulating Chemicals in the Environment - National Academy of Sciences, 1975. In discussing the policy consideration, the group reached the following decisions: i) Seeking a delay In the March 23 hearing would not be advisable. ii) The AIHC's Alternatives document can be used as a basis for critiquing the EDF proposal. However, legal counsel pointed out that there are some fine points of differences between the legislative authority of OSHA and EPA and these should be taken into account. iii) It will be important to coordinate the approach used in the AIHC proposal with prior industry positions at EPA. iv) It will onyl be necessary to make reference to industry's previous comments on EDF position on vinyl chloride and provide a summary of the industry's position on these points. ucc 008196 -3- 3 ~ Risk-Benefit Concepts Professor Richard Wilson of Harvard University was introduced by Dr. Adams He gave a brief statement on his risk-benefit concept as related to vinyl chloride and other carcinogen risks. He pointed out that because it breaks down in the atmosphere rapidly that the concern should be the primary contact (i.e., exposure in the workplace). On the basis of EPA's 1976 regulation, the risk projects to perhaps one case in 20 years. Several references were made to Professor Wilson's position papers on this subj ect: . Risk-Benefit Analysis for Vinyl Chloride (ACS Meeting, September 1, 1976) . Magnitude of the Chemical Cancer Problem: A Review of Some Opinions and Numbers. NOTE: Copies of these papers can be obtained from John Lawrence at the SPI office. 4 - Committee Reports (a) PVC Fire Safety Committee - Mr. Dan Kent reviewed the activities of the committee making specific reference to the minutes of the January 5 meeting. He also called attention to the toxicity studies proposed to be conducted at the University of Michigan on off"gases from burning materials. The.Steering Committee recommended.that PAC be urgently requested to support this study because it involves all types of plastics. (b) Financial Report - Mr. Walker distributed the report on expenses through December 1977. (Attachment B). It was also indicated that approximately 50% of the January assessment of $400,000 has been received. In response to a request by the Chairman, Mr. Walker indicated that a budget projection will be prepared for the full Committee to review at the March 31 meeting. (c) Communications Committee - On behalf of this committee Mr. Ackerman reported that activities have been at a low level pending EPA's action on the proposed VC amendments. It was agreed that the Communications Committee should be ready to provide appropriate backup to the Group's participation at the EPA meeting on March 23. A summary of Hill & Knowlton's activities for the month of January on behalf of the Group is enclosed. (Attachment C). ucc 008197 -4- 5_ 67- Nominating Committee - Dr. Adams reported that the Nominating committee recommends that Messrs. Nuechterlein, Schaefer and Walker be re-nominated to their present offices and that their respective companies be nominated to the Steering Committee for a three year term. It was agreed that these nominations should be directed to the attention of the full PVC Safety Group for action at the March 31 meeting. Health Committee - Mr. Nuechterlein reported on behalf of Dr. Torkelson that the Health committee was still searching out an organization main taining complete records on VC health studies and related information. It was urged that one of the several organizations under consideration be retained for a trial period of 6-12 months. EPA Hearing Plans Beveridge, Fairbanks & Diamond will prepare a draft of an industry presenta tion to cover legal, technical and health considerations. It was agreed that we should make it clear 'that comments were preliminary in reponse to the "meeting" context rather than a "public hearing". Further, that we should reserve the right to make further comments relative to any un resolved technical considerations. Plans were made for Messrs. Baise, Laundrie and Barr, to meet with the AIHC's Scientific Committee on March 7. Final plans for participation at the March 23 meeting are to be reviewed with the AIHC Steering Committee in Chicago on March 15. A draft of the presentation material will be sent to the full PVC Safety Group by March 20 of it is at all possible. It is urged that all PVC Safety Group member companies try to be represented at the March 23 meeting. The next meeting of the Steering Committee will take place at 8:00 a.m. just prior to the meeting of the full committee on Friday, March 31, 1978. The meeting adjourned at 2:40 p.m. ATTACHMENTS 3/8/78 John R. Lawrence Technical Director ucc 008198 Beveridge, Fairbanks & Diamond 2/24/78 ATTACHMENT A Proposed Work Plan for the SPI Presentation at the EPA March 23 Hearing on Generic Regulation of Carcinogenic Air Pollutants I. Overall Approach EPA has announced that it intends in its March 23 hearing to solicit recommendations' leading to possible development of a proposed generic cancer policy for airborne carcinogens. It may be desirable simply to put EPA on notice that SPI,intends to be heard force fully on EPA's cancer policy, address the eight questions EPA posed in its amendment, and then raise the literally dozens of questions posed by EDF's petition. We should indicate that the Agency needs far more time and addi tional meetings before it could possibly consider pro posing any new scheme. II. Committee Work Needed Before March 23. A. Policy Considerations 1. Whether to seek a delay of the March 23 hearing or to press for prompt EPA action because EPA's current policy is acceptable. 2. Development of an approach to EDF's proposal for a classifi cation scheme for airborne carcinogens; consider how to distinguish EPA concerns from OSHA. 3. Coordinate approach of the AIHC proposal with prior industry position at EPA. 4. How to challenge EDF's presen tation of the "Vinyl Chloride Story." How to treat EDF's statistics and such issues as substitutes, threshold, zero emissions, extrapolation of animal data to humans, repli cation, and offset. 2 B. Technical and Health By March 10, 1978, SPI should have papers pre pared analyzing the EDF proposal in detail (state ment by statement), raise all of the questions necessary to challenge that proposal, and consider an appropriate answer or alternative to the EDF proposal. Among the overriding issues are: 1. To what degree and in what manner should EDF cancer statistics be . challenged? 2. V.'hat information is available to rebut, correct, supplement the studies relied upon by EDF? 3. What position should be taken with re gard to EDF *s non-threshold and zero emission theories? 4. What implications are there to the off-set policy? 5. What assumptions/facts does EDF rely upon which are erroneous? 6. What is wrong with EDF's proposed regulatory scheme both theoretically, and, assuming implementation, from a practical standpoint? C. Legal The Legal Committee should complete by March 10 a review of the legal questions which are posed by the EDF petition. Among the issues are: 1. What is the interrelationship of EPA's authority under the Clean Air Act and the Toxic Substances Conhrd) Act, the Federal Insecticide, Fungicide and Rodcntici.de Act, the Federal Water Pollution Control Act and related laws and regula tions ? UCC 008200 3 2. Can EDF's scheme of relying on Section 111 to regulate new sources of Category II substances be effectuated? 3. What procedural safeguards are necessary under any regulatory scheme? Ill - Presentation at Hearing A. Background. Establish setting for the hearing; identify the key parties; establish SPI stature, experience and standing. B. Present policy statement, consistent with overall approach outlined above. C. Consider having technical, medical, scientific and legal experts available to testify. D. Consider submission of key policy, factual and lega] issues and questions raised by EDF petition and the prospect of EPA action. E. Call for further informal meetings before decision on whether to even propose regulations. F. Establish groundrules if regulations are proposed, such as right of cross-examination. IV. Other Issues A. Consider filing a Freedom of Information Act request to obtain (a) all EPA cancer policy docu ments which led to its May 1976, statement, and (2) any new information the Agency lias received on this subject relevant to the EDF proposal. B. Establish procedures for liaison with AIHC. C. Schedule of meetings. D. Establishment of committees and selection of chair persons . E. Coordination of expert witnesses with AIMC. 1. Oral presentation. 2. Written submission. UCC 008201 SPI-PVC & VCM PRODUCERS GROUP SOURCE & DISPOSITION OF FUNDS AS OF 12-31-77 ATTACHMENT B SOUBCE: \ 1. Carryover (Loss), From 1976/77 Operations-Per Ledger Print-Out Plus: Duplicate Entry of Allied Chem.Payment Less: Assessments Paid-Not Recorded on Ledger Great American Chemical Hooker Chemical N t (Loss) Carryover from 1976-1977 AMOUNT $(28784.58) ( 2460.00) 912.00 167.50 $(30165.08) 2* Assessments: Total Assmt. Net Assmt. Assnrt.Pajlfl, . ____ Pag, a. 1976/77 Assessment No.3 $100000.00 $1pp99^'92 b. 1977/78 Assessment No.1 250000.00 244512.50 c. 1977/78 Assessment No.2 394100.00 - Total Assessment Income Net Assessments Receivable Per Attached Detail Meeting Income: Total Funds Available - 12-31-77 $5487.50 39*100.00 3W12.50 $399587.50 399587.50 380.00 $714314.92 DISPOSITION: 1 * Curr nt Year Expenses: Legal Expense - Paid thru 12-31-77 - Accrued for December Public Relations Expense-Paid thru 12-31-77 -Accrued for December Me ting Expense (Incl. Travel) Res arch & Development Expense Office Supplies & Expense Telephone & Telegraph Expense Total Expense thru 12-31-77 Net Funds Available at 12-31-77 $204711.76 _12366.80 $ 95076.52 107-56.73 $217078.56 105833.25 6777.92 33gl 896.47 1502.45 ------ $365107.32 $349207.60 uec 008202 HIM. AND KN'OWLTON, Inc ATTACHMENT C Memo to: Robert B. Downey, Chairman Date: February 28, 1978 PVC Communications Committee The Society of the Plastics Industry, Inc. Subject: PVC "Action Program" Bill and Activities -- January 1978 Copies: (See below) Following is a breakdown of H&K staff time charges and out-ofpocket expenses billed at cost, and a summary of activities on behalf of the PVC "Action Program" for the month of January 1977: 1. Political Education ------ o No activities in this category during the month. 2. Radio-TV Training ------ o No activities in this category during the month. 3. Washington Activities $ 1,667.00 o Continued liaison with SPI's Legal Counsel in Washington. o .Continued to monitor Washington press and regulatory agencies for developments on VCM/P.VC-related issues. . - o Discussed with SPI's Legal Counsel actions by EPA res vinyl chloride (they may not repropose the standard). o Discussed with SPI's Legal Counsel impact of Supreme Court decision on asbestos and EPA on PVC or other air pollution actions. o Discussed with SPI's Washington Represen tative, SPI's Legal Counsel, members of Communications Committee and H&K-New York re: Sen. Moss hearings touching on ethylene dichloride. o Assembled information on International Trade Commission-U.S. Treasury action re: dumping of PVC sheet and sent to SPI's Legal Counsel. UCC 008203 Robert B. Downey February 28, 1978 2 4. Intra-Industry Communications $ 1,791.00 o Researched and prepared draft of copy for "Management Summary" Vol. Ill, No. 1. o Monitored national, international, trade, medical and environmental press for mention of VCM/PVC. Sent major stories to SPI. 5. Staff and Committee Liaison $ 2,060.00 o Prepared activities report for PVC Safety Group covering communications activities from April through November 1977. o Preparations for and participation in meeting of PVC Communications Committee on January 9. o Preparations for and participation in meeting of PVC Steering Committee on January 10. o Developed detailed budget and program outline for communications activities for PVC Safety Group thru end of May 1978. 6. Intelligence and Document Development and Updating $ 1,553.00 o Discussed a series of updated papers to be written on PVC and occupational:health. Began researching background materials on papers. . o Researched and began drafting new version of the paper "Vinyl Chloride and Birth. Defects, 7. Media Contact and Response, including Positive Publicity $ 1,893.00 o Story on system to reduce theft of books from libraries, composed of sensing element and special check-out gate made of rigid PVC was carried by Associated Press (All 1,500 newspapers, periodical and broadcast outlets). o Story on how the housewife can stretch her household budget by using certain kinds of items made out of PVC was placed with Lady* s Cirr i q ''Circulation - 750,000). ucc 008204 Robert B. Downey February 28, 1978 3 o Story on how the homeowner can save money and energy by heeding the advice of government energy engineers working to combat energy waste in the home featuring uses of PVC to effect these savings was placed with the Los Angeles Times Syndicate (100 newspapers - readership, 3,000,000) . o Continued contact with the following magazines/news services on stories which have been placed with them in the past few months: Associated Press Features 1001 Decorating Ideas Mechanix Illustrated Women's News Service Lady's Circle Enterprise Science News (NEA) c Awaiting approval on service piece for consumer magazine or syndicated column entitled "Six Ways to Prevent Fires in the Home" focusing on the use of smoke and heat detectors to signal an alarm before smoke overcomes the occupants of the house. o .Continued work on consumer story pitched for garden columns about the growing use of plastics in gardening, focusing on PVC for use in automatic water sprinkling system for the garden; also use of .PVC for lining ornamental pools in the garden. o Continued working on stories previously listed on activities reports for which additional data is being researched. 8. Out-of-Pocket Expenses $ 515.44 Telephone and telegraph Miscellaneous publications Multilithing and photostats Postage charges Travel and expenses $ 78.86 7.75 128.80 194.81 105.22 9. Editorial Briefings $ 261.00 o Prepared draft of "VCM-PVC Summary for the press, Vol- III, No. ' ucc Robert B. Downey February 28, 1978 4 10. New Jersey Carcinogens Bill ------ o No activities in this category during the month. 11. PVC Conduit/FDA ------ o No activities in this category during the month. 12. Fire Safety Program Development $ 1,213.00 o Preparations for and participation in meeting of PVC Fire Safety Subcommittee in Cleveland on January 5. o Prepared memo on PR problem for fire safety and submitted to you. 13. Out-of-Pocket Expenses (for 11 and 12) $ 196.85 Travel and expenses $196.85 TOTAL $11,150.29 If you have any questions on the breakdown or activities, please give me a call. Cordially MMS:jmv Matthew M. Swetonic cc: PVC Steering Committee PVC Communications Committee Messrs. Harding, Collins, Lawrence, McGrath, Nuspliger, Haley, Heckman, Burleson, Hadley, Durbin, Kiss, Hearle, McLoughlin, White Titus, Bochat, l SCO 008206 minut s Thursday, March 9, 1978 9:30 A.M. PVC SAFETY GROUP COMMUNICATIONS COMMITTEE The International Club WashingtonT D.C. ATTENDEES: Robert C. Downey - CHAIRMAN - B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd. Cleveland, Ohio 44131 Ed Ackerman - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 M. C. Carpenter - Dow Chemical, 2020 Dow Center, Midland, Michigan 48640 Joe Hadley - Keller & Heckman, 1150 17th Street, N.W. Washington, D.C. 20-36 Gary Baise - Beveridge. Fairbanks & Diamond, One Farragut Square South, Wash. D.C. Jerry Blizin - Hill & Knowlton, Inc., One McPherson Square, Vermont at K. St. N.W. Washington, D. C.20005 Matt Swetonic - Hill & Knowlton, Inc., 633 Third Avenue, New York, N.Y. 10017 John R. Lawrence - SPI - 355 Lexington Avenue, New York, NY 10017 Ed Collins - SPI - 355 Lexington Avenue, New York, N.Y. 10017 #### 1 - Chairman Downey opened the meeting by calling on Mr. Baise to review the background o the assignment AIHC has tentatively given to SPI/PVC Safety Group to represent them at the March 23 EFA meeting on its cancer policy and the EDF petition on a suggested new carcinogen policy. Mr. Baise reported on the actions leading to the preparation of a draft statement to represent the PVC Safety Group, SPI and/or AIHC. This statement was presented to the AIHC Scientific Committee on March 7 and will be presented to the AIHC Steering Committee on March 15. The final version will be available for review at various stages before the March 23 meeting. 2 - Public Relations Consideration After considering various alternatives, the committee agreed that the following elements should be developed for PR support to the industry's participation at the March 23 hearing. (a) Press Conference (b) Radio Actuality (c) Press Release (d) Coverage Washington Media . TV . Papers National Media . All normal channels THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 Lexington Avenue * New York, N.Y. 10017 (212) 573-9400 UCC 008207 2- - General strategy would be to set up a defensive position to avoid being pre-empted by environmental groups. Presenters Two tier AIHC Steering Committee member SPI - PVC Representative - ^Fleming, *Walker Press Conference - March 22 (11;00 A.M.) Brian McMann ) Experts Richard Wilson ) (No press conference if experts are not available) (Briefing of experts on March 20, 21 or before) *Clearance by John Lawrence as soon as possible 3 - Background Documents Mr. Swetonic will update various PVC/VC background papers for hand-out if necessary. 4 - Mr. Downey will prepare a recommendation for presentation of the PR Program to the AIHC Committee on March 15. Respectfully submitted, 3/10/78 --'John R. Lawrence Technical Director UCC 008208