Document ZJZ8kaV87d600KxmQx2X7QgRp

TO: R. D. Gamblin Fee? Jfc: .MIWGh' f!F XF: . "fecft W m FROM: DATE: Interoffice Communication SUBJ: T. G. Grumbles August 26, 1985 TSCA SECTION 4 TEST RULE FOR Cg AROMATIC HYDROCARBONS VEIA The subject rule requires specific toxicological testing of the CQ aromatic hydrocarbon fraction that contains ethyltoluenes ana trimethylbenzenes as primary components. The rule subjects anyone who manufacturers or processes the Cg fraction, other than as an impurity to the testing requirement. We have reviewed our manufacturing in relation to this test rule. We do have several hydrocarbon streams at the LCCP that contain Cg aromatic hydrocarbons in measurable amounts, however, it is our opinion these Cg's are present as an impurity. They are not intentionally manufactured, isolated, or processed in any manner. Also, to our knowledge the Cg's inadvertently produced have no specific commercial value as a component of the streams. Therefore, '/ista is not affected by this rule. Please let me know if you need further information on the above. <NUffh*Thomas G. Grumbles ajo/7 Attachment cc J. R. Ball W. L.`McClain 0ooV TO: Mary Arm Fisher Sifc: r;i: XF; , L ^ v FROM: DATE: interoffice Communication SUBJ: T. G. Grumbles August 26, 1985 DISTRIBUTOR SALES AGREEMENT VISTA Section 6(f) of our standard distributor agreement deals with the distributor duty to practice reasonable efforts to comply with environmental safety, and health standards. Based on the specific requirements for distributors in OSHA Hazard Communication Standard (29 CFR 1910.1200), as described below, would it be prudent to put specific language regarding those regulatory requirements in the agreement language? Under the standard distributors are obligated to distribute Material Safety Data Sheets to certain customers, and label containers of hazardous materials. We will be notifying them of these requirements in the near future and offering our help in supplying information. However, to afford Vista further protection I would appreciate discussion of adding specific language to our agreements regarding the new OSHA requirements. Please let me know when we can discuss. xl _________ Thomas G. Grumbles ajo/7 WV 000016683