Document Xzpoo2jjG6qwbRadgkJKvQ6k4

f< Date 30 October 1981 INTEROFFICE MEMORANDUM Subject Committee Meeting - Wednesday* 4 November 1981. 10:00 AM 119D ToTSCA Committee ________________________________ _____________ __________ (Location, Organization, or oapirtmant) From C. E. Blades__________________________ Toxicology Department (Location, Organization, or Department) TSCA Committee: A. 0. Diglio W. L. Ent G. G. Handley C. McKinley !L__y* Schenck L. B. Tepper Please refer to the agenda included in the notice of meeting dated October 1, 1981. For Item 1> we will refer to memo circulated to the Committee dated 1 October 1981 and providing a summary of a CMA/CRAC Informational Meeting of July 16, 1981. It is suggested you head the summary prior to the meeting and bring any questions or comments on that summary. For Item 4, "Reports on Audits for Compliance,1' please refer to Standard Practice 1007B, IVA.l. The implementation and control of compliance with TSCA is to proceed in the various sectors of the company through: A. J. Diglio for Chemicals Group W. L. Ent for IGD, including Spec. Gas and Technical Affairs G. G. Handley for PSG Including Arcair C. McKinley for R&D For this meeting I am asking that each of you be prepared to report on the status of company compliance with EPA regulations under TSCA for PCB's* CFC's, TCDD, and Asbestos. A recent inquiry from the EPA re CFC regulatory compliance emphasizes the importance of coordination and audit on this matter. CEB/sjw. 1320) AP00049198 'PAXX&C& j INTEROFFICE MEMORANDUM Date 1 October 1981 Subject TSCA Meeting Agenda To From TSCA Team, _______________________________________________ (Location, Ofgjniution, or pjr'tmantj C. E. Blades____________________________ Toxicology Department (Location, Organization, or Oaoartrnvrt) TSCA Team A. J. Dig 1 io W. 1. Ent G. G. Handley C. McKinley R. H. Schenck L. B. Tepper cc: J. T. Barr G. Crossland A. E. Greene E. I.-Handwerk S. Iannotta J. A. Seidman A meeting of the TSCA Team is called for Wednesday, November 4 at 10:00 AM in Conference Room 119D. The agenda will include the following: 1. Review and Update on Regulatory Development re TSCA (C. E. Blades) 2. Phenylenediamine Testing Rule (C. E. Blades) 3. Premanufacturing Notification in process (E. I. Handwerk) 4. Reports on Audits for Compliance A. J. Diglio W. L. Ent G. G. Handley C. McKinley R. H. Schenck PCB CFC TCDD on the CFC inquiry (D. C. Keehn) 5. The export rule - requirements for compliance (S. Iannotta) 6. Other CEB/sjw C. E. Blades (3201 AF00049I99 (A{ INTEROFFICE MEMORANDUM Date 1 October 1981 Subject TSCA Meeting Agenda To TSCA Team _________________________________ From C. E. Blades.____________________________ TSCA Team (Location, Organization, or O*0*rtmnt) Toxicology Department (Location, Organization, or Daoartmant) A. J. Diglio W. L. Ent G. G. Handley C. McKinley B. H. Schenqk L. B. Tepper cc: J. T. Barr G. Crossland A. E. Greene E. I. Handwerk S. lannotta J. A. Seidman received OCT 2 1981 LAW DEPT. rh - A meeting of the TSCA Team is called for Wednesday, November 4 at 10:00 AM in Conference Room 119D. The agenda will include the following: 1. Review and Update on Regulatory Development re TSCA (C. E. Blades) 2. Phenylenedlamlne Testing Rule (C. E. Blades) 3, Premanufacturing Notification in process (E. I. Handwerk) 4. Reports on Audits for Compliance A. J. Diglio W. L. Ent G. G. Handley C. McKinley R. H. Schenck PCB CFC TCDD on the CFC inquiry (D. C. Keehn) 5. The export rule - requirements for compliance (S. lannotta) 6. Other CEB/sjw C. E. Blades (320) AP00049200 (A< INTEROFFICE MEMORANDUM Date 16 February 1981 Subject TSCA Meeting Minutes - February 13, 1981 To TSCA Committee _ From E. I. Handwerk__________________________ TSCA Committee: (Location, Organization, or Department] Toxicology Department (Location, Organization, or Department) A. J. Diglio/J. Spata W. L. Ent P. Fong G. G. Handley &_tL..$ChQCl< W. M. Smith L. B. Tepper cc: J. T. Barr C. E. Blades J. W. Gentile A. E. Greene S. Iannotta j. C. Thirion M. F. Troutman 1. Import/Export Rules EPA has proposed a rule which would require Importers to certify in writing that each chemical substance being imported is in compliance with TSCA rules. Failure or inability to certify would disallow the material from entering the U.S.A. S. Iannotta, Mgr., Chem. Cust, Svcs., suggested that a Corporate Procedure be established to identify an administrative method for compliance. Authority to certify should rest with the Purchasing Department. C. E. Blades will coordinate the development of a Corporate Procedure. A final rule has been issued on an export policy requiring an exporter of chemical substances subject to TSCA regulatory action to notify the EPA of the country to which the material is beina shipped. EPA will notify the embassy of the receiving country. Chemicals subject to TSCA Sections 4, 5, 6 and 7 fall Into this category, e.g. PCB's, TCDD, CFC's and asbestos. Currently, the only materials of concern to APCI are the freon chlorofluorocarbons processed by Specialty Gases. W. Ent reported that Spec. Gases is in compliance with the Export Policy. 2, Premanufacture Notification (PMN) C. E. Blades informed the group that the EPA has proposed acceptance of the Organization for Economic Cooperation and Development's (OECD) base set of tests as a guideline for test results to be submitted with premanufacture notifications. Omission of elements of this base set will require explanation. Included in the base set are: (320) AP00049201 TO: T5CA Committee Page 2 16 February 1981 Physical/Chemical Data Acute Toxicity Data Repeated Dose Toxicity Data Mutagenicity Data Ecotoxicity Data Degradation/Accumulation Data A recently issued Significant New Use Rule (SNUR) is receiving heavy criticism for not following the intented purpose of SNUR's. In this case, the Agency is using the SNUR as an Information gathering instru ment as opposed to a method for assuring the risk arising from a sig nificant new use for a new chemical. 3. APCI Response to Issues APCI will not comment separately on Section 4 Environmental Testing Standards because of our lack of expertise in this area. APCI will endorse the CMA position. The Interagency Testing Committee (ITC) is examining a list of 107 chemicals from which selections will be made and transferred to the Priority List (top 50 list) for testing for adverse health and environ mental effects. The TSCA Chairman, in consultation with affected profit centers, finds no evidence for significant comment on APCI chemicals within the list of 107. 4. PCB's A district court has remanded certain sections of the PCB rules. PCB regulation is currently based on interpretation of the statute. The statute has no 50 ppm cut-off level, but does exempt PCB's in totally enclosed containers. R. H. Schenck informed the group that in the interim,APCI transformers should be treated as totally enclosed. R. H. Schenck will consult with G. G. Handley regarding the PCB law as it regulates transformer spills or leaks. 5. Asbestos Rule An 8(a) rule has been issued requiring manufacturers and processors to report commercial products containing asbestos. The Committee dis cussed the use of asbestos gaskets in heat exchangers. Since the company does not make the gaskets, the company is not required to respond to this rule. EIH/sjw ' E. I. Handwerk AP00049202 ^<^fcPA0duC(4r (3 INTEROFFICE MEMORANDUM To TSCA Committee From C. E. Blades TSCA Committee: A. J. Diglio W. L. Ent P. Fong G. G. Handley cc: J. T. Barr J. W. Gentile A. E. Greene J. C. Thirion Subject Date 29 January 1981 Notice of TSCA Meeting_________ R. H, Schenck,, W. M. Smith L. B. Tepper (Location, Organization, or Dpartrnnt| Toxicology Department (Location, Organization, or oapartmnt) There will be a TSCA Committee Meeting on February 13, 1981 at 1:30 PM In Conference Room 116F. This meeting is scheduled primarily as an update of TSCA activities. TSCA Committee agenda is as follows: 1. Review of issues and CMA activities from CRAC Informational Meeting, January 29, 1981 - C. . Blades. 2. The ITC List - 107 chemicals for Priority Testing - APCI interests. Comments due April 6, 1981 - J. T. Barr, 3. PCB Regulation - changes due to EOF case court ruling - report from A. J. Diglio, G G. Handley, W. L. Ent, and P. Fong. 4. APCI posture relative to export and import rules - J. T. Barr. 5. Presentations to research groups - substantial risk and premanufacturing notification. 6. Evaluation of Committee effectiveness. CEB/sjw C. E. Blades (320) AP00049203