Document XOZ8EzBd2boD9kqEp10on2V3w

TO: Distribution Vi-slc FROM: DATE: T. G. Grumbles March 21, 1988 ANALYTICAL WORK FOR REGULATORY REQUIREMENTS VIS1A Based on a review of the list Jim Yates prepared, it is clear that benzene and the PNA's are the chemicals with the potential to appear most often in our products.. Therefore, initial efforts should be prioritized towards the analytical work for those two chemicals. From a Proposition 6,5 standpoint warnings are required now for tyenzene and will be required beginning in July for the PNA's. If analytical method development is required for the PNA analysis, this should be high priority. Second in priority, based on regulatory deadlines and product volume in commerce, would be EtO and dioxane. We already know a lot about these levels and additional work may only include data gathering, reviewing sampling frequency, and determining if current sampling frequency allows us to generate representative data. Third in priority would be the various chlorinated compounds on the Prop 65 list. These are BCME, CCL4, chloroform, epichlorohydrin, PCB's and vinyl chloride. These chemicals have the potential to be present in less volume for commercial purposes, but the warnings will be required in October of this year, except for BCME which is required now. The remaining analytical needs are for DEHP, nickel catalyst fines, lead acetate and arsenic. Arsenic warnings are required now. Attached is a suggested "project" organization based on the priorities described. Also, I've listed several general issues that should be considered. It should be noted that some PCB analysis and benzene in LAB work has been done in response to other regulations in the last two years. In several cases, collection of existing data will be our first step. Please review the enclosed then we'll schedule a conference call to discuss details of the project. \ G5~'J --------------------------' T. G. Grumbles aj o .310 Enclosure DISTRIBUTION: Jim Yates Ron Poe Charlie Starks VVV 000009915 GENERAL ISSUES How do we represent the data? Ranges, accuracy statements, not to exceed .., How do we collect samples and/or how many analysis do we do to assure representative data? How do we validate non-referenced methods? be an issue.) (This may or may not Pro/cons of doing the work or all of the work at an "outside" contract laboratory. Analytical method applicability to different products (i.e., is benzene in LAB method same as benzene in HCL?) Significant data currently exists for dioxane, EtO, and VCM residual levies. Some data exists for benzene and PCB's. VVV 000009916 PROPOSITION 65 CHEHTfTAT.S (EFFECTIVE DATE) AND PRODUCTS TO BE ANALYZED - PRIORITY GROUPINGS BENZENE (3/1/88) LAB Hydrotropes Specialty Alkylates AICI3 Liquor Muriatic Acid Sulfonic Acids Na Salt Slurries N-Paraffins Solvents (LPA, MR) HAD LAC Plasticizers PNA s (7/1/88) LAB Hydrotropes Specialty Alkylates AICI3 Liquor Sulfonic Acids Na Salt Slurries N-Paraffins Solvents (LPA, MR) HAD LAC ALFOLS (mp greater than 708F) Plasticizers ETHYLENE OXIDE (7/1/88) Ether Sulfates ALFONICS 1.4 DIOXANE (1/1/89) Ether Sulfates ALFONICS Epichlorohvdrin (10/1/87) BCME (3/1/88) CCL/. Chloroform (10/1/88) (10/1/88) PCB's VCM (1/1/89) (3/1/88) EDC VCM MECL VCM EDC MECL VCM EDC MECL VCM EDC EDC VCM PVC LAB's MECL EDC PVC LEAD ACETATE (1/1/89) Hydrotopes AICI3 Liquor HCL Sulfonic Acids Ether Sulfates Na Salt Slurries MECL Alumina PVC ARSENIC (3/1/88) Hydrotopes AICI3 HCL Sulfonic Acids Ether Sulfates Na Salt Slurries Ether Sulfates NICKEL CATALYST FINES (10/1/88) ALFOLS ALFONICS Solvents VVV 000009917 VVV 0 0 0 0 0 9 9 1 B 1 23 PNA's Eto/Dloxane BCME. CCL4, Chloroform, Epichlorohydrin, PCB's, VCM Develop Methods Determine Method -9 If Necessary St Availability Determine Resources Needed Collect Data Determine Suitability :es No In/Out Decision Analysis Prepare Written Responses Determine How To Represent Additional Analysis Prepare Written Responses Lead Acetate Arsenic DEHP Nickel Catalyst Fines Determine Analytical Needs Methods Development St Determine Resources Needed In/Out Decision 1 Collect data: Correspond with plants 2 In/out decision: decision on whether to use outside 3 The end product would be a form or standard response contract letter laboratory Analyze Prepare Written Responses