Document R5Ld9v1OVeVpd1DkwzDq9m8E

kjlCuI 7Hu7 1 THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 250 PARK AVENUE NEW YORK. NEW YORK 10017 212 687-2675 MINUTES Statler Hilton Washington, D. C. Attendees: VCM AND PVC PRODUCERS GROUP June 5, 1974 8:30 a.m. Anton Vittone, Chairman. B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd., Cleve land, Ohio 44131 Ray J. Abramowits, Hooker Chemical Corp., River Road, Burlington, N. J. 08016 Dr. A. Ross Adams, Air Products & Chemicals, 3 Executive Mall Bldg., 656 Swedes- ford Road, Wayne, Pa. 19087 R. Craig Andrews, Diamond Shamrock Chemical Co., 1100 Superior Avenue, Cleveland, Ohio 44107 F. T. Barr, Air Products & Chemicals, 656 Swedesford Road, Wayne, Pa. 19087 Henry Bialecki, Olin Corporation, 120 Long Ridge Road, Stamford, Ct. 06904 Jerry Blizin, Hill & Knowlton, 1425 K Street, N.W., Washington, D. C. D. Bloomfield, Hooker Chemical Corp., River Road, Burlington, N. J, 08016 B. Gawain Bonner, Tenneco Inc., P. 0. Box 2511, Houston, Texas 77001 R. S. Brookman, Firestone Plastics Co., P. 0. Box 699, Pottstown, Pa. 19606 Fielding Cochran, Robintech Inc., 1407 Texas Street, Ft. Worth, Texas. H. E. Connors, Diamond Shamrock Chemical Co., 1100 Superior Ave., Cleveland, Ohio Walter B. Connolly, Jr., Firestone Plastics Co., 1200 Firestone Pky., Akron, Ohio Dr. William L. Cox, The Goodyear Tire & Rubber Co., 144 Goodyear Blvd., Akron, Ohio 44316 John M. DeVoe, Allied Chemical Corp., P. 0. Box 1057R, Morristown, N. J. 07960 D. S. Dixler, Keller & Heckman, 1150 17th St., N.W., Washington, D. C. 20036 D. J. Dowrick, ICI America Inc., 444 Madison Ave., New York, N. Y. Ray Durazo, PPI, 250 Park Avenue, New York, New York 10017 E. Whitehead Elmore, Ethyl Corporation, Ethyl Tower, 451 Florida, Baton Rouge, La. 70801 John E. ErteL, Robintech Inc., P. 0. Box 2342, Ft. Worth, Texas 76101 H. E. Everson, Diamond Shamrock Chemical Co., 1100 Superior Ave., Cleveland, Ohio Joe Fath, Tenneco Inc., P. 0. Box 2, Piscataway, N. J. 08833 Vince P. Ficcaglia, Arthur D. Little Inc., Acorn Park, Cambridge, Mass. 02140 Geo. S. Flint, Tenneco Chemicals, Park 80 Plaza W-l, Saddle Brook, N. J. John C. Floros, Great American Chemical Corp., 650 Water Street, Fitchburg, Mass. D. H. Francis, Goodyear Tire & Rubber Co., 1144 Market Street, Akron, Ohio A. W. Fuhrman, Great American Chemical Corp., 650 Water Street, Fitchburg, Mass. Robert Gerwig, Conoco, 34 Lake Drive, Park Eighty Plaza East, Saddle Brook, N.J. Jos. E. Hadley, Keller 6. Heckman, 1150 17th St., N.W., Washington, D. C. 20036 A. J. Haefner, Ethyl Corp,, P. 0. Box 341, Baton Rouge, La. 70821 George B. Hegeman, Arthur D. Little Inc., 35 Acorn Park, Cambridge, Mass. 02140 G. J. Henrich, Olin Corp., Long Ridge Road, Stamford, Ct. 06904 Mary-Elizabeth Jacques, The Pantasote Co., 51 Weaver Street, Greenwich, Ct. 06830 Jack Jaglom, Pantasote Co., 26 Jefferson Street, Passaic, N. J. 07055 sp|. 12326 2 Charles H. Jenest, Arthur D. Little Inc., Acorn Park, Cambridge, Mass. W. V. Kane, Esq., Diamond Shamrock Chemical Co., (Reavis, Pogue, Neal & Rose), 1100 Connecticut Ave., Washington, D. C. Flynt Kennedy, Continental Oil Co., P. 0. Box 1267, Ponca City, Oklahoma 74601 M. J. Kleinfeld, Uniroyal Chemical, Emic Building, Naugatuck, Ct. 06770 Milton Kline, Borden Inc., 511 Lancaster Street, Leominster, Mass. 01453 L. R. Kuhn, Stauffer Chemical Co., Westport, Ct. 06880 Cleveland Lane, B. F. Goodrich Chemical Co., 500 So. Main St., Akron, Ohio 44131 Benton R. Leach, Uniroyal Chemical, P. 0. Box 460, Painesville, Ohio 44077 R. W. Laundrie, General Tire & Rubber Co., One General St., Akron, Ohio 44329 D. H. Markusson, General Tire & Rubber Co., One General St., Akron, Ohio 44329 E. J. Masek, Diamond Shamrock Chemical Co., 1100 Superior Avenue, Cleveland, Ohio R. W. McBumey, Diamond Shamrock Chemical Co., 1100 Superior Ave., Cleveland, Ohio Roy W. McCune, The Pantasote Co., of N.Y. Inc., 26 Jefferson St., Passaic, N.J. Mark Minkus, Tenneco Inc., Park 80 Plaza West-1, Saddle Brook, N. J. J. R. Mudd, General Tire & Rubber Co., P. 0. Box 68, Ashtabula, Ohio 44004 C. M. Neher, Ethyl Corp., 861 Delgado, Baton Rouge, La. 70808 John L. Nelson, B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd., Cleveland, Ohio Nick Nuechterlein, Dow Chemical Co., 4604 Briston Ct., Midland, Michigan H. A. Peed, Borden Chemical Co., 511 Lancaster St., Leominster, Mass. 01453 R. J. Reynolds, Shell Chemical Co., One Shell Plaza, Houston, Texas Tom Riley, Goodyear Tire & Rubber Co., 812 National Press Bldg., Washington, D.C. F. X. Ritter, Tenneco Chemical, P. 0. Box 2, Plscataway, N. J. P. E. Roggi, Stauffer Chemical Co., Westport, Connecticut J. T. Ronan, Stauffer Chemical Co., Westport, Connecticut 06880 Melvin Rosensaft, Great American Chemical, 650 Water St., Fitchburg, Mass. William A. Runyan, Goodyear Tire & Rubber Co., 144 E. Market Street, Akron, Ohio L. F. Sargert, PPG Industries Inc., 1 Gateway Center, Pittsburgh, Pa. 15220 J. Scbastianelli, Air Products & Chemicals, 656 Swedesford Road, Wayne, Pa. 19087 K. L. Schurter, Continental Oil Co., (Conoco), Park 80 Plaza East, Saddle Brook, New Jersey Arthur Smith, Robintech Inc., P. 0. Box 2342, Fort Worth, Texas 76101 John T. Smith, II, Covington & Burling, (for Tenneco & Stauffer) 888 16th St., Washington, D. C. 20006 John Spano, Monsanto Co., 800 N. Lindbergh Blvd., St. Louis, Missouri 63166 Roy Stack, PPG Industries, 1 Gateway Center, Pittsburgh, Pa. 15222 Arthur B. Steele, Union Carbide Corp., 270 Park Avenue, New York, N. Y. 10017 William A. Sutton, Olin Corp., 120 Long Ridge Road, Stamford, Ct. 06902 Matthew M, Swetonic. Hill & Knowlton, 633 Third Avenue, New York, N.Y. 10017 Allan Topol, Covington & Burling, 888 16th St., N.W., Washington, D. C. 20006 Jerry Twomey, Uniroyal Chemical, Elm Street, Naugatuck, Ct. 06488 Todd Walker, Firestone Plastics Co., Pottstown, Pa. 19464 Phil Weaver, B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd., Cleveland, Ohio David A. Weinstein, Borden, Inc., 50 West Broad Street, Columbus, Ohio 43220 Richard A. Weller, Arthur, Dry & Kalish, Attorneys for Uniroyal, Inc., Emic Bldg., Naugatuck, Ct. 06525 William Wetzel, Hooker Chemical Corp., River Road, Burlington, N.J. R. N. Wheeler, Jr., Union Carbide Corp., 270 Park Avenue, New York, N. Y. 10017 John Whittberry, Union Carbide Corp., 270 Park Ave., New York, N. Y. 10017 G. J. Williams, Dow Chemical Co., Abbott Road Bldg., Midland, Michigan 48640 Paul Wright, Monsanto Co., 800 N. Lindbergh Blvd., St. Louis, Michigan 63166 Thomas J. McGrath, General Manager. SPI, 250 Park Avenue, New York, N.Y. 10017 spi- i27 _ 3- Committee Chairman Tony Vittone called the meeting to order and asked for self-introductions. Following the approval of the April 16 minutes he called upon the representatives from A. D. Little to give a preliminary report about their findings regarding the economic impact of a shutdown of the VCM and PVC industry. The impact of an instantaneous shutdown is as follows: SUMMARY ECONOMIC IMPACT OF IMMEDIATE SHUTDOWN OF PVC RESIN OPERATIONS 1972 (Preliminary) Industry Loss in Production and Sales (a) (Billion $) Loss in Employment (MN) Vinyl Chloride Monomer PVC Resin Construction-Related Apparel-Related Motor Vehicle-Related Specialty Products* Miscellaneous Products^ 0.2 0.6 14.0-20.0 2.5--3.5 35.0-50.0 8.0-10.0 4.7-5.7 * ** 0.5-0.8 0.1 0.6-1.0 0.3-0.4 0.1-0.3 TOTAL 65.0-90.0 1.6-2.6 COUNSEL REPORT Mr. Heckman reviewed the situation relative to OSHA and EPA. He advised that he has been in communication with OSHA and they are of the opinion that it is, at this time, impossible to present data which will establish a safe level for VCM exposure. He expressed the opinion that the 50 ppm has not been shown to be unsafe. We should adopts a position which will bring the exposure level of VCM to the workers down to a level as low as is technologically feasible. He stated that while 50 has not been shown to be unsafe it would be prudent for the industry to strive for the lowest level that technology will allow. In closing, he advised that the legislation which formed OSHA placed the burden on OSHA to demonstrate that their standards are technologically and economically feasible. The intent of the OSHA legislation is to insure that workers have a safe environment to work in, and not to close industry. EPA Committee The Committee is reviewing methods which will possibly remove VCM from the atmos phere. The Committee recognizes that there are no known technologically feasible methods to remove VCM from diluted streams and they will try to devise a method. SPI- 12328 -4 - OSHA COMMITTEE Chairman Harry Connors reported that the OSHA Committee has conducted an epidemiological study which indicated that in the past there were high levels of VCM in the polymer plants, but that since 1960 these levels have been con siderably reduced. The Committee has obtained data which indicates that the major portion of a fabricators plant is presently below one part per million of VCM. VCM has been measured at levels higher than one part per million in the processors mixing rooms and in their storage areas, however, it appears that with increased ven tilation, the VCM levels should be considerably reduced. Mr. Connors reported that the OSHA Committee members unanimously stated that it was not feasible for workers to continuously wear the prescribed OSHA respirators. He stated that at their last meeting several votes were taken regarding the proposed industry position. A majority believed that a maximum of 40 ppm with a TWA of 25 ppm was feasible but did not agree that we could gradually reduce this level. They also believed that processors do not have a VCM problem, and that processors should be eliminated from the standard. Jerry Heckman advised that we should be able to file post hearing comments. Usually the record will be kept open for two to three weeks. Industry Position Mr. Vittone noted that the British position as published in the European Chemical News Issue of May 24, 1974.was distributed to the attendees. A copy is attached to the minutes. He reported that the Steering Committee met last night until early in the morning. The major points of the industry position are: 1. We must make it clear to OSHA that there is considerable differences between monomer and polymer plants and that OSHA is not dealing with a monolltlc industry. 2. We must try to convince OSHA that fabricators or processors should not be subject to the standard because there is little if any worker exposure to VCM. Also, by means of improved ventilation, those few areas of the processors plant which show detectable levels can be reduced to no-detectable. 3. Industry health records survey can show that workers years ago were subject to large readings of VCM, but since the 1950's improved conditions have greatly reduced the VCM level. Monsanto Company has volunteered its facilities in Springfield to participate in an analysis and decision making program relative to the effects of VCM exposure. Those companies who supplied information for the Derhnel questionnaire should make every effort to attend the June 17-18 and 19 meetings. SPI-12329 5 The analysis and decision method used may show that the rat data is not applicable to humans, and it's possible that it will support Derhnel's conclusions. 4. It is the industry's position that it will do all it can to achieve the lowest feasible levels of VCM with its plants. The Steering Committee's recommended position for polymer plants is that by October 5, 1974,a 25 ppm ceiling using a sequential monitoring system which will sound an alarm when the level exceeds 25 ppm be established. When the alarm sounds, workers will be required to wear a canister type mask. After two years, or by October 5, 1976, the maximum ceiling will be 25 ppm with a TWA of 10 ppm. The Steering Committee's recommended position for monomer plants is that by October 5, 1974, a 10 ppm ceiling using a sequential monitoring system which will sound an alarm when the level exceeds 10 ppm be established. When the level exceeds 10 ppm, workers will be required to wear a canister mask. After two years, or by October 5, 1976, the maximum ceiling will be 10 ppm with a TWA of 5 ppm. It is recognized that not all plants will be able to meet these levels, and it is hoped that OSHA will permit those plants to avail themselves of the variance procedure allowed by law. Following the Steering Committee's statement there was considerable discussion. Joe Fath of Tenneco moved that as an industry position, the permanent standard be set at a maximum exposure level for workers without respirator equipment at 25 ppm accompanied by a continuous monitoring device for polymer plants. That after a two year period, or by October 1976, an additional standard of 25 ppm ceiling with a 10 ppm TWA be superimposed with the caveat, unless the industry shows that the standard is not economically and technologically feasible, and provided that medical and scientific research has not shown an acceptable risk threshold above that level by that date. The motion was seconded and defeated 10 to 8. A motion was made that Mr. Fath's motion be modified to a level of a 40 ppm ceiling with a TWA of 25 ppm, and with a 1976 level of a 25 ppm ceiling with a TWA of 10 ppm for polymer plants. The motion was seconded and carried 12 to 6. A motion was made that we accept the Monsanto offer to meet at their facilities on June 17-18 and 19 to participate in their analysis and decision making project. The motion was seconded and carried 20 to 0. A discussion was held about the approved industry position. Mr. Vittone stated that B. F. Goodrich is committed to moving faster to obtain lower levels. In view of this he was of the opinion that he should resign as Chairman, and let someone else state the industry position. spl-12330 6 The discussion that followed Mr. Vittone's comments revealed that there was no fundamental difference among the members. They agreed that the industry should achieve as low a level of worker exposure to VCM as possible. The concern of the attendees was the time frame in reaching the levels since it's based on the proposition that technology which does not now exist will hopefully be developed. A motion was made that we modify the industry position regarding the exposure levels as follows: By October 5, 1974 - A maximum of 40 ppm with a TWA By October 5, 1975 - A maximum of 25 ppm By October 5, 1976 - A maximum of 25 ppm with a TWA of 25 ppm of 10 ppm The motion was seconded and carried 15 to 4. For VCM plants, a motion was made that the levels be set at 10 ppm ceiling by October 5, 1974 and by October 5, 1976 a ceiling of 5 ppm TWA. The motion was seconded. It was agreed that after this meeting the VCM producers will determine if these levels are acceptable. If not, they will so advise SFI. If SF1 does not hear objection, it will be assumed that all VCM producers concur. Residual VCM Level A discussion was held about the acceptable VCM residual level. The attendees agreed that we should not strive to obtain the lowest possible VCM residual level in the resin. A motion was made that we recommend a residual level of 0.05% (500 ppm) by October 5, 1974. The motion was defeated 9 to 8. A number of attendees expressed the opinion that since 0SHA has permitted residuals of 0.17. in other OSHA standards concerned with carcinogens, we should recommend the same level because it will encompass a broad range of resin grades. A motion was made that we recommend a residual VCM level in PVC resins of 0.1% (1,000 ppm). The motion was seconded and carried 15 to 2. Witnesses In view of the lateness, Mr. Vittone stated we will not have time to review the witnesses needed to present the industry position. He requested that the attendees send the names of possible witnesses to Mr. Heckman. Mr. Vittone said that since we were unable to complete our business today we will hold another meeting on June 10, 1974 starting at 9:00 a.m. There being no further business to transact, the meeting was adjourned at 3:20 p.m. Respectfully submitted, Thomas J. McGrath General Manager TJMcG/pb Attachment SPI-12331 24 ^technical week European Chemical News. May 24 19/4 CIA argues case against zero Therefore the committee's work is being focused on the VCM poly merization process itself. It estimates VCM exposure limits that average atmospheric concentra tions in the UK were 1 000 ppm in the at a press briefing held last week in London on vinyl chloride (VCM) toxi city the UK Chemical Industries Asso ciation (CIA)'s vinyl chloride committee stressed that the PVC industry would stop dead if society demanded zero exposures to VCM in the production, fabrication and use of PVC to elimin ate the risk of industrial injuries. penetration of PVC in to a wide range of market applications, as a major industrial material where alternatives are not available in the quantities nor in most cases with the properties required, the CIA stated. The four UK producers of PVC arc so far spending over 4m. this year to reduce the maximum possible atmo 1945-1955 period, 400-500 ppm in l9Ss 1960, 300-400 ppm in 1960-1970, Im ppm in mid-1973, and is now 50 ppm. Major improvements in the past six months have come mainly from the elimination or procedures which per mitted vinyl chloride to escape into l he plant atmosphere (within the prescribed limit of 200 ppm). The vinyl chloride committee, which spheric concentration of VCM exposure was set up about three months ago, to plant operatives to 25 ppm bv has as its terms of reference, "to volume, from the existing legal limit enquire into the nature and extent of of VCM exposure of 220 ppm. the hazard to health of vinyl chloride, Currently, 12 cases of angiosarcoma whether in the free state or as a con of the liver (a rare liver cancer) have stituent of polymerized material. been discovered in the USA, one in the Secondly, to establish in collaboration UK, and around five in continental with expert bodies both in the UK Europe. These diagnoses (two cases are Tabla 1: UK use of PVC In till still surviving) have occurred over a ten- Application Tonnapo used Main um Market year period. penetration Ultimate levels Further improvement will conic from detailed plant modifications to eliminate or reduce adventitious leaks, according to the CIA committee, with the ultimate for most existing plants at 10 ppm. However, entirely new plants using the latest available technology might achieve 5 ppm, as the lowest possible level attainable, the CIA states In contrast, OSHA, the US Govern ment body concerned with the VCM % Of the 18 cases, problem has just proposed a standard Pipes A fittings 100 000 (30 000 ml let of pipework) Electric cables 46 000 Water mains. rainwater pipe, toll pipe, electrical conduit House wiring, motor vehicles. 30 seven have occurred 90 on one plant in the 75 25 100 USA (B. F. Good rich), a further three 100 in another US plant Herd flooring Packaging '30000 domestic appliances, power cables Tiles A continuous vinyl flooring 70-30 40-60 00 (Goodyear), with the incidence elsewhere being very low. Average exposure (a) Pott A film (b) Bottles (c) Bottle clotures 24 000 13 000 (400m. bottlea) 6 000 Foil: margarine tubs, biscuits, chocolate. Film: fresh meat A vagatablea Fruit squash, cooking oil, aweat jars, food and drink products 20-26 60 50 30 lime of the known cases approaches 20 years. However, the levels of vinyl chloride monomer to which these workers were exposed, Records (phonographic) 21 000 Cars (140m. records) 20 000 Footwear Colliery conveyor belting 20 000 70m. pairs 0 000 (about 1 000 mllss) all rscords art PVC Upholsttry, roof intsrlors wiring Shoes (36%) and shoe uppsrs Underground safety belting 100 95 100 100 thought to be at least I 000 ppm,, is ex tremely high compared with present permitted levels. Average exposure levels in the UK are now 5 ppm for plant and overseas as well as with govern atmospheres in VCM production, 50 ment departments, the actions neces ppm in plant atmospheres for produc sary to safeguard the health of workers tion of PVC from VCM, and generally and users and to make recommenda 0-5 ppm in plant atmospheres for fabri tions for their speedy implementation." cation of PVC articles. Vinyl chloride A major reason for the committee's absorbed in a human diet is about 0 00) determination to arrive at a satisfactory ppm of the diet. of less than 1 ppm for atmospheric VCM levels. The proposal is however open to public comment before being adopted as law and the US Society of the Plastics Industry has already re sponded by calling Ihc now standard "excessively and unrealistically restric tive." Up till now a temporary limit of 50 ppm has been established in the USA. Nevertheless a limit of less than I ppm is tantamount to a zero exposure, and therefore zero risk. The CIA stresses that it is impossible to prove a zero risk. In the case of VCM there has always been some risk, as VCM presents a fire and explosion risk very similar to that of butane and other liquefied gases used for heating and lighting. There have been more deaths from fire and explosions of such materials than from industrial disease and in the case of VCM, on a world wide basis, more people have died from these causes in the past ten years than from cancer, the CIA committee stated. As far as fabrication of PVC is con cerncd, the CIA is recommending that fabricators achieve atmospheric concen trations of less than 5 ppm. However, the fact remains that the concentration solution to the VCM carcinogenity Thus the CIA considers that the of VCM in freshly-produced PVC ex problem is the importance of PVC to problem, if one still exists, is confined plant is in the range of 200-400 ppm the UK national economy. to the industrial process of converting by weight, although the level drops on Four companies, BP Chemicals, ICI, VCM into PVC. Levels in food are storage. British Industrial Plastics and Vinatex infinitesimally small, and atmospheric Typical levels on delivery to a eusto (jointly owned by the National Coal exposure levels in the fabrication in mer arc around 250 ppm. but aft r Board and Conoco), produce 400 000 dustry, where they may at present processing this drops further to smu' ton oF PVC annually in the UK, in exceed 5 ppm, can easily be reduced where between "0.5 and 20 ppm In volving 2 000 workers. by improved ventilation, the CIA main weight, depending on tile fabrication Table I shows the extent of the tains. involved. S P I-12332 The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 MINUTES (212)573 9400 VINYL CHLORIDE/FDA MEETING Shorham Americana Washington, D. C. September 10, 1975 10:00 A.M, Attendees:, R. J. Abramowitz, Hooker Chemicals & Plastics, River Rd., Burlington, NJ 08016 W, B. Ackart, Union Carbide, One River Rd., Bound Brook, N.J. 08817 R. P. Becker, Diamond Shamrock, P.0. Box 191, Painesville, Ohio 44077 J. J. Birdsall, American Meat Institute, P.0. Box 3556, Washington, DC 20007 C. E. Blades, Air Products & Chemicals, One Possumtown Rd., Piscataway, NJ 08854 J. Blizin, Hill & Knowlton, One McPherson Square, Washington, D.C. 20005 D. Bloomfield, Hooker Chemical, River Road, Burlington, N.J. 08016 R, R. Boliffard, Pantasote Co. of NY, 26 Jefferson St., Passaic, N.J. 07055 Norm Burnstein, Cryovac, P.O. Box 464, Duncan, South Carolina 29334 R. C. Brooke, Borg-Warner Chemicals, Washington, West Virginia 26181 T. E. Brydon, XCel Corp., 290 Ferry St., Newark, N.J. 07105 H. B. Carr, Tenneco Chemicals, Turner Place, Piscataway, N.J. 08854 R. L. Chaffe, Reynolds Metals Co., 6601 W. Broad St., Richmond, Va. 23261 A. S. Cummin, Borden Inc., 277 Park Avenue, New York, N.Y. 10017 A. S. D'Amato, Borden Inc., One Clark Street, N. Andover, Mass. 01845 Bob DeValeria, Borg-Waraer Chemicals, Parkersburg, W. Va. 26101 D. S. Dixler, Keller and Heckman, 1150 17th St., N.W., Washington, DC 20036 R. J. Dowling, Uniroyal Chemical, Spencer St., Naugatuck, Ct. 06770 P. L. Fehrenbach, Goodyear Aerospace Corp., 1210 Massillon Rd., Akron, Ohio R. P. Finegart, American Can Co., 1660 L St., N.W., Washington, D. C. 20036 R. P. Fischer, Kerr Glass Mafg., P.O. Box 4000, Lancaster, Pa. 17604 P. A. Florio, American Hoechst, Rte 202-206, Bridgewater, N.J. 08876 J. C. Floros, Great American Chemical, 650 Water St., Fitchburg, Mass. 01420 A. W. Furhman, Great American Chemical, 650 Water St., Fitchburg, Mass. 01420 D. A. Giannotti, Hooker Chemical, 345 Third St., Niagara Falls, N.Y. 14302 W. J. Gort, American Hoechst, P.O. Box 340, Delaware City, Delaware J. E. Hadley, Keller and Heckman, 1150 17th St., N.W., Washington, DC 20036 A. J. Haefner, Ethyl Corp., P.O. Box 341, Baton Rouge, La. 70821 F. M. Harris, Aim Pkg, Div. of USI, Box 278, Port Clinton, Ohio 43452 J. H. Heckman, Keller and Heckman, 1150 17th St., N.W., Washington, DC 20036 R. W. Hill, Diamond Shamrock, 1100 Superior Ave., Cleveland, Ohio 44114 K. Hochschwender, American Hoechst Corp., Rt. 202-206 N., Sommerville, NJ 08876 L. K. Hunt, Goodyear, 142 Goodyear Blve., Akron, Ohio 44329 D. G. James, Borden Chemical Co., One Clark St., N. Andover, Mass. 01845 P. J. Josenhans, Borden Inc., 180 E. Broad St., Columbus, Ohio 43215 Arthur Karszes, Debell & Richardson, Water St., Enfield, Conn. 06082 J. G. Keller, American Can Co., American Lane, Greenwich, Ct. 06870 Flynt Kennedy, Continental Oil Co., P.O. Box 1267, Ponca City, OK 74601 SPl-12333 T Page Two FDA/VCM Mtg. 9/10/75 cont'd... R. L. Harding, SPI, 355 Lexington Ave., New York, N.Y. 10017 Richard Kingham, Covington & Burling, 888 16th St., NW, Washington, DC 20006 Michio Kohno, Kaneka America, 1251 Ave. of Americas, New York, NY 10020 A. A. Ropetz, American Can Co., American Lane, Greenwich, Conn. 06830 E. Kruger, American Hoechst Corp., Delaware City, Delaware Robert Laundrie, General Tire, One General St., Akron, Ohio 44329 J. H. Ludwig, Synthetic Products Co., 1636 Wayside Rd., Cleveland, Ohio 44112 J. F. Mizia, General Electric, One Plastics Ave., Pittsfield, Mass. 01201 John Malloy, SPI, 355 Lexington Avenue, Nw York, N.Y. 10017 J. R. Lawrence, SPI, 355 Lexington Ave., New York, N.Y. 10017 G. J. Mantell. Air Products & Chemicals, P.O. Box 538, Allentown, Pa. 18105 James R. Marshall, Johnson 6 Johnson, North Brunswick, N.J. Barbara L. McBride, Nat'l Assoc, of Food Chains, 1725 Eye St., NW, Wash. DC 20006 Stanley Mruk, PPI, New York, N.Y. Nina I. McClelland, NSF, P.O. Box 1468, Ann Arbor, Michigan 48106 W. D. Nesbeitt, Petrochemicals, Grove St., Fort Worth, Texas 76101 R. C. Parsons, Reynolds Metals, 6601 W. Broad St., Richmond, Va. 23201 Leo Pechinski, Allied Chemical, Columbia Road, Morristown, N. J. 07940 S. F. Peirce, Continental Can Co., One Lancaster Sq., Stamford, Conn. Charles W. Petty, Jr., Mayer Brown & Platt, 888 17th St.,NW, Washington DC 20006 Doug Proctor, Ethyl Corp., 8000 G. S. R, I, Ave, Baton Rouge, La. 70814 Harry Radloff, Oscar Mayer & Co., P.O. Box 1409, Madison, Wisconsin 53701 J. P. Rakus, Dart Industries, Box 37, Paramus, New Jersey 07652 R. C. Rinker, Borden Inc., 180 Broad St., Columbus, Ohio 43215 W. E. Risch, Anchor Hockin, 189 Container Place, Cincinnati, Ohio 45246 Melvin Rosensaft, Great American Chemical, 650 Water St., Fitchburg, Mass. 01420 J. L. Russ, Firestone Plastics, P.O. Box 699, Pottstown, Pa. 19464 W. E. Rinehart, Ethyl Corp., 451 Florida, Batai Rouge, La. 70801 Michael Saggese, Tenneco Chemicals, Nixon Lane, Nixon, New Jersey 08818 R. D. Satava, B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd., Cleveland, Oh 44131 R. D. Savage, Goodrich Chemical, 6100 Oak Tree Blvd., Cleveland, Ohio 44131 Jerome R. Schindler, Borden Inc., 180 E. Broad St., Columbus, Ohio 43215 E. R. Schutz, Keysor Century Corp., Saugus, California Frederick J. Schindler, Rohm & Haas, P.O. Box 219, Bristol, Pa. 19007 A. W. Sheldon, M & T Chemicals, Rahway, New Jersey 07065 J. P. Sibilia, Allied Chemical, Columbia Road, Morristown, New Jersey Gene Skiest, Borden Chemical, 511 Idweaslin St., Leominster, Mass Peter T. Smith, Keller and Heckman, 1150 17 St., NW, Washington, D. C. 20036 Ricahard Sterne, Fantasote Co. of NY, 26 Jefferson St., Passaic, N.J. 07055 R. W. Tannehill, B. F. Goodrich, 6100 Oak Tree Blvd,, Cleveland, Ohio 44131 H. L. Tenney, XCEL, 74 Golf St., W. Long Branch, New Jersey 07764 Lad Thomka, Dow Chemical, 2040 Dow Center, Midland, Michigan 48640 Judith Tins, Celanese Corp., 1211 Ave. of Americas, New York, N.Y. 10036 B. F. Vincent, Amercan Can Co., N. Commercial, Neenad, Wisconsin 54956 John W. Walker, Certain-Teed, P. 0. Box 860, Valley Forge, Pa. 19482 Patricia Watson, Stauffer Chemical Co., Westport, Connecticut 06897 William Wetzel, Hooker Chemical, River Road, Burlington New Jersey George White, Jr., Reynold Metals, 10 & Bird St., Richmond, Va. 23219 SPI-12334 Page Three FDA/VCM Mtg. 9/10/75 Cont'd... 1 - Mr. Ralph Harding, serving as Chairman, opened the meeting by asking for self introductions of those present. He then indicated that the proposed FDA rule on PVC for food packaging is a broad industry problem, not just a problem for producers of PVC resins. 2 - Mr. Heckman reviewed the background that led up to the present FDA proposal citing the following highlights: FDA's concern over the prior sanction of PVC for food packaging goes back 2-3 years. At the June 19, 1975 meeting of SPl's Food, Drug and Cosmetic Packaging Committee, Mr. Ronk indicated that FDA was continuing in its plan to issue a regulation that would call for no detectable VC migration into food simulating solvents using test methods sensitive to 50 ppb. Health Research Group's petition of July 1, 1975 to ban the use of PVC for food packaging. As a result of the HRG petition conflicts developed within FDA. Mr, Heckman's meeting with FDA Commissioner Schmidt on July 18 to update him on the industry's activities. Mr. Heckman's July 22 "confrontation" with Dr. Wolfe of HRG on WOR radio FDA's publishing its three tier proposed regulation on PVC for food packaging on September 3. 3 - Mr. Heckman outlined a strategy that industry might follow to encourage FDA to allow the continued use of PVC for rigid food packaging on the same basis as FDA's logic in allowing the continued use of plasticized PVC in films, gaskets, can linings, etc. This would require industry to develop data to show no detectable migration from rigid packaging materials into food simulating solvents. In following this strategy, Mr. Heckman pointed out the desirability of meeting the 60 day deadline for comments (November 3) if at all possible. This would require data to be available by October 3 so that it could be reviewed and put into proper form for submission to FDA. If necessary, Mr. Heckman indicated that an extension on the November 3 deadline could be requested. Also he recommends that a hearing be requested if FDA does not respond in a satisfactory manner to the data the industry submits. Mr. Heckman pointed out the importance of using consistent procedures in gathering data for submission to FDA. Sp/-12335 Page Four FDA/VCM Mtg. 9/10/75 cont'd. . . 4 - Dr. Rinehart of Ethyl Corp. reported on the August 8 visit of the SPI Ad Hoc PVC Toxicology Committee with representatives of FDA to discuss protocol for VC feeding studies. FDA representatives made a number of observations about the proposed protocol that would re quire careful review before any such studies were initiated. FDA further indicated no degree of urgency in initiating such studies at this time. Dr. Rinehart indicated that the MCA committee working on toxicity of VC is willing for SPI committees to pick up its various programs if they so desire. 5 - Mr. Nesbitt reported on the activities of the Plastic Pipe Institute's technical committee working on FDA and EPA issues. These include the following: Test method has been established. Future plans and anticipations: a- Notify FDA by 9/12/75 that studies are under way. b- Lowest level of VC in pipe is expected to be 1 ppm. c- PPI will represent members and non-members in establishing FDA's criteria as called for in proposed regulation, d- Intend to establish that VC does not become a component in drinking water. e- Action Committee will prepare a report for PPI review by approximately October 13. f- FDA jurisdiction over drinking water will be considered after data are collected. 6 The meeting was divided into working groups to discuss procedure for gathering data in four product areas and to plan legal strategy as follows: Chairmen Plastic Bottles Frank Harris Sheet and Blister Pack Bill Gort Plastic Pipe Plasticized Products Bill Nesbitt A. W. Sheldon Legal Committee Jerry Heckman Each of these groups subsequently reported back to the entire group as follows: Plastic Bottles- Mr. Harris reported that the objective of this group would be to determine the level of VC that might be in the container wall that would not reasonably become a food component. The group will proceed to gather data and meet again on September 18 to review plans and start the preparation of a statement on its work. SPI-12336 Page Five FDA/VCM 9/10/75 Mtg. cont1d... Sheet and Blister Pack- Mr. Gort cited the same objective as the bottle group and indicated that the next meeting of the group would be on September 22. Plasticized Products- Mr. A. Sheldon reported that this group feels that no additional data will be submitted to FDA at this time but that they will proceed to reconfirm the logic of FDA's own findings. This group plans to meet again on September 23. Plastic Pipe- Mr. Nesbitt had nothing further to report than covered in his earlier report. Legal Committee- Mr. Heckman reported that the committee plans to meet on October 3 and expects to review the subcommittees' comments on October 13. It further plans to develop a draft of its comments to FDA for review by the Legal Committee, Chairmen of the four Product Groups plus two designated members, also Chairmen of VCM/PVC Producers Group, PPI, PB1, FDC, PMC. This draft is targeted for October 20 unless it is later deemed that an extension should be requested. I Mr. Heckman further stated that any individual company may file its own Food Additive Petition. If this is done, it would be advisable to be alert to the contents of the petition with respect to what other companies are producing of a similar composition and intended use. 7 - Mr. Harding indicated that it would probably be necessary to appoint a Steering Committee to expedite industry action. The meeting adjourned at approximately 3:00 p.m. Respectfully submitted JRL:je Oohn R. Lawrence Technical Director SPI-12337