Document MGD5krDzaNLkGX3BZ2yEd2mLx
.MANUFACTURING PRACTICES COMMITTEE:
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The Clarion 7401 North Scottsdale Road Scottsdale, Arizona .
Wednesday October 10, 1984 9 am
Preparation of additional technical information for EPA regarding modification to the VCM standard:
a. EDC Tanks: Members should come prepared with a list of tanks and cost for control of VCM emissions to 10 ppm should EPA change the definition of Part 61.61 (0) as proposed thereby requiring control of emissions from crude and finished EDC storage tanks and by-product storage tanks.
b. Leak Detection: Members should come prepared to discuss the specific differences betweerT their existing leak detection and elimination plans versus Subpart V. Mr. Holbrook expects this discussion to take quite a bit of time as we will be preparing what he envisions to be minimum requirements to present to EPA.
c. Incinerator Bypassing: Members should come prepared to discuss their prior two years' history of incinerator bypassing including causes therefore, number of times bypassed, duration of each bypass, VCM emissions associated with each bypass, etc.
2. Feedback from Dr. Gottesman regarding Committee's planned activities as presented at the Annual VI Executive Board meeting.
3. Other business as necessary.
THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue * New York, N.Y. 10017 (212) 503-0600
agreemente.ia^b^on^ng to a trade association like SPI which takes itsobligations in this regard
very seriously.
All SPI Staffltiembersare well versed in antitrust matters and the assodatiori relies heavily on their
judgmenttcr;see that.topics which may give an appearance ofanagreement that would violate the
: ,,,,4htitrdeya^!ftarenotdiscussed at SPI meetings: Th&fapf^hpjpn SFljJ^member ^present at a
meeting--however, should not invite probing to determine how far a discussion can proceed before it
becomes apparent that it is improper and is cut off. It is the responsibility of each member in the first
instance to avoid raising improper subjects for discussion. This reminder has been prepared to
assure that participants in SPI meetings are aware of this obligation/-'
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The Dos and Don'ts presented below highlight only the most basic antitrust "principles. Each
participant in an SPI meeting should be thoroughly familiar with the SPI Bulletin, "The Antitrust Laws
and You--A Guide and Introduction to an Understanding of the Federal Antitrust Laws," and should
consult counsel in all cases involving specific situations, interpretations, or advice.
DON'T
1. Do not, in fact or appearance, discuss or exchange information regarding:'
(a) Individual company prices, price changes, price differentials, mark-UpS, discounts, allow ances, credit terms, etc., or data that bear on price, e.g., costs, production, capacity, inventories, sales, etc.(b) Industry pricing policies, price levels, price changes, differentials, etc.
(c) Changes in industry production, capacity or inventories.
(dt Bids on contracts for particular products; procedures for responding to bid invitations.
'e) Plans of individual companies concerning me design, production, distribution or marketing of particular products, including proposed territories or customers. (f) Matters relating to actual or potential individual suppliers that might have the effect of excluding them from any market or of influencing the business conduct of firms toward such suppliers or customers. 2. Do not discuss or exchange information regarding the above matters during social gatherings incidental to SPi-sponsored meetings, even in jest.
3. Do not ftteet without SPI staff or counsel present.
DO
1. Adhere to prepared agendas for all SPI meetings and object any time meeting minutes do not accurately reflect the matters which transpired.
2. Understand the purposes and authority of each SPI group in which you participate.
3. Consult with the SPI General Counsel and your company counsel on all antitrust questions relating to SPI meetings.
4 Protest against any discussions or meeting activities which appear to violate the antitrust laws; disassociate yourself from any such discussions or activities and leave any meeting in which they
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