Document Znp70kMbwRxm5Garvpqr84K6J

This long-expected new U S . /ar;r--ln/hich was passed :es:ing of esisting and new materials last Ocfober-features remedies much and to regulate their manufacture and use accordingly. Cnder TSCX, much better than those proposed in previously recommended legislafion. Here's how compliance can occur thought was given as to how to CDordinate tl?e administration of these laws. Goal: to develop most effec- tive action and minimize confusing overlap. Curtis W. Smith, For 40 years, there was only one Most existing chemicals have been Shell Oil Co., Houston la\\- in this area, the Food, Drug and studied to determine whether short- Cosmetic .Act. As you can see from term esposure causes illness or death. THE SEW TOSIC Substances Con- Fig. 1, the number of major laus But the hazards from long-term extrol Act (TSC.4) will have a major has increased markedly. There are posure to commodity chemicals have impact on hydrocarbon processing op- laws to protect \\.orken, consumers, only been appreciated for a few years. erations. This Act-and \chat industry drinking water, air, food, transporta- These tests require lifetime studies is doing to meet its requirements- tion and storage, and to guarantee with hundreds of animals (2-3 years -should be undentood by plant man- c- agers, their d e p a r t m e n t heads and safety professionals. Here, I will deal with five areas: (1) Changes already taking place to provide greater safety from chemicals, (2) Major features of the Act, ( 3 ) Economic impact of the Act, (4) T h e Office of Tosic Substances set up to administer the .Act and ( 5 ) A new lianufacturing Chemists Association's Chemical Regulations Advisor). Com- mittee set up to serve as a focus for l f C A to deal with the Act. :&:; [. l o HAZARD%OUSMATERIALS TRANSPORTATION AC 9 FEDERAL ENVIRONMENTAL FEDERAL WATER POLLUTION CONTROL ACT s 8 CONSUMER PRODUCT SAFETY ACT 4 7- FWPCA CPSA CHANGES TO IMPROVE SAFETY If we choose to believe many newspaper articles, T V reports and books, we must conclude the sky of toxic substances is falling and nothing is being done about it. But things are being done to reduce chemical hazards, especially those related to the Tosic Substances Control Act. I a m not saying that the struggle is over. But a definite beginning has been made. ASwe work together, the problem can be solved. O n e area of progress is legislation. CLEAN AIR ACT ! ' FDCA ,FOOD, qRUG, AYD COSM,ETlC ACT I I P __ . _ _ _ _ _ _I 1915 1925 1935 1945 1955 1965 1975 *- - - - - . ~ _.-__. .-.-.--., ~---------_.LL--- I "9. l-Since 1915. a dozen toxicology and safety-related laws have been passed which impact upon HPI operations. HYDROCARBON PROCE.SSING January 1977 213 TOXIC SUESTANCES CONTFiOL IS HERE 3 IP The e s t i m a t e d cost for individual compounds varies from $400,000 to $1 million. ;\lost of these arc jointly supported by industry under CIIT, hfCX, Intcrnationnl Institute of Stn- thetic Rubber and one joint industry study not under any trade association. In addition to this, the Xational Paint and Coatings Association is inst i t u t i ng a QSi5,OOO epidemiologic study of workers in the paint indus:ry. S h y other epidemiologic studies are underway or being planned. Xany industries are esamining carefully records of illness and death against e s p o s u r e for all employes. IYnere any potential problems are cbsexed, these are brought to the at:en:ion of e m p l o y e s , governmefital agencies and the press. Rightly or Lvrongly, a number of chemicals have already been removed from the market, some by governmental action, some voluntarily. Sow, let me turn to major featores of the Act, as shown in Table 1. TAELE l--FAajor feGturer P = PUNNING STAGE C = READY TO CONTRACT U = UNDERWAY U-18 = UNDERWAY 18 MONTHS JIS = JOINT INTERNATIONALSTUDY SR = INTERCATIONALINSTITUTEOF SYNTHETIC RU3BER S = EXPECTED STARTI'NG DATE F = FINAL IP = IN PROGRESS 'STATUS REPORT = LITEWTURE SURVCl ** = CHRONIC INCLUDES ... CARCINOGENIC EVALUATION = HUMAN-CHRONICORAL Fig. 2-These activi!ies are underway by the Chemical Industry Institute of Toxicology (CIIT), Manufacturing Chemists Association (MCA) and others. with mice or rats) and are expensive. To carry them out requires greatly increased laboratory facilities and commi:ment of people. Let me discuss changes being made in this area. CllT formed. A new Chemical Industry Institute of Tosicology ( C I I T ) has been established by industry. I t will conduct tosicologic studies and research. Guarantees are built in to protect the scientific integrity of, the laboratory. It will e.upress the voice of science and not the commercial interests of industry. Already some 22 companies have joined the organiution. Others are invited. Contracts for long-term studies with ethylene and toluene have been established. Four more contracts should follow soon. More are in various stages of dcveloprnent. Plans arc well underway to\vard the constructio-n of a $12-mil- lion laboratory. 't Major e s p a n s i o n s of tosicology laboratories, up to doubling capacity, h3ve been completed at DOW,duPont, Carbide, Stauffer, Shell International in England and E a s t m a n Kodak. Monsanto has announced a new tosi- c o l o ~laboratory. Other companies considering construction of new lab- oratories are Celanese, Esson, Gulf -and Olin. The contract l a b o r a t o r i e s have mostly doubled in size and are operat- ing at capacity. Joint smudies. A b o u t $7 million of jointly supported industrial contracts for long-term studies on commodities have been let over the past 12-18 months. This list is in addition to other continuing studies. (See Fig. 2.) 214 Edsting Substancu 0 Inventory oi existing chemicd substances or c3:cgories thereof 0 Reportll from manufacturers or processors lor c h e m i d substances and mixtures 0 Chemical Substances List 0 Pnority List Testing 0 May be required b y EPA by rule o Standards set by EPA by rule 0 Companies may share umr hlAJOR FEATURES OF ACT T h e Act is designed to guarantee testing and regulation of esisting and new materials which present unreasonable risk to health or the environment. Chemical substances (individual elements or compounds) are treated differently from m i s t u r e s . 5Iistures are combinations of substances such as in paints, adhesives, rubber, plastics, etc. In general, it is assumed that the safety of a misture can be d e t e r m i n e d from what is known about component substances. IVhen I say materials, I mean both substances and mistures. In the fol- lowing discussion, major features of the Act are presented in about the order in \vhich industry ivill meet them. Reporting. To e s t a b l i s h w h i c h materials exist and which are new, an inuentory of chemicals and categories will-be prepared and submitted to industry for additions. I t will be important Tor domestic and foreign 002250 Circle 247 on Reader Service Card- 0 ' TOXIC SUBSTANCES CONTROL IS HERE T-A.o:nore requirerncnis: llanufac- turers are reqiiircd to retain records industry to get their compounds on the inventory. Any substance not there will be treated as new and must go through premarket notification. Pesticides, tobacco, materials under the Atomic Energy .Act, food, drugs and cosmetics are esempt from this Act. Chemicals p r o d u c e d in small quantities or used solely in research and development and mistures may not need to be listed, reported or given premarket notification. T h e .Adminis- uator may request infomation and regulate them \<here it is needed. The ;\dministra t o r may require manufacturers and processors to report on the chemicals substances and mixtures they produce. This may include: chemical identity, ca:egories of use, volumes and b y p r o d u c t s . Small businesses are not required to submit these repor:s routinely. T h e .Administrator \\.ill request tosicolo,aic information available \\+ere the need is indicated. of significant adverse effects to heal;h or the en\.ironment. They must inform EP.4 on obtaining information regarding a substantial risk caused by a chemical. Chemical S u b s t a n c e s List. The .Administrator \\.ill compile a lis; of suhs:ances Lvhich he has found present or may present an unreasonable risk of injury to health or t5e enviio5nient. Prior to manufacture of a substance on that list one mus: presen: da:a believed to show that such sub- stance \\.ill not present an uxcason- a5ie risk of injury. DISCOVER WHAT'S NEW IN BETTER W PERFORiV;IMG FURNACE T U B E S Pull boring and new generation alloys increase furnace efficiency for greater production and reduced cost. 0 With pull boring you can convert from as-cast wall sections to thinner, fully sound wall tubes. Thinner walls mean lower tube skin temperatures and lower thermal stresses. 1mproved.thermal efficiency means increased production at the same firing temperature. 0 Additional production benefits are also available from higher hot- strength alloys: HP. 25-35W and 30-5OW. Other special alloys are available for manifolds, transfer lines and piping applications. WCI provides you with the knowhow in metallurgy, fabrication, quality control, centrifugal casting, plus investment cast U bends and fittings. rd The complete kncivplace lor your lurnace tube requirements. Waukesha, Wisconsin 53186 (414) 544-7700 Circle 248 on Reader Service Card 0 Priority List. There is io be a piicrity conimittee \\.ith one icpresentative from each of eight go\.ern::iental and scientific agencies. It !\.ill develop a priority list for texing of no nioie than j0 chemical su5s:ances or mistures. This list is to be pblisked. T h e =\dministrator is not compelled to follow the list esactlg. But, if he departs from it, he must publish his re3ions. Testing. The Act establishes procedures by which existing and new ma~erialsare to be tested for hazards to man and the environment. The .Administrator may prescribe tectir.,o for: Cumulative or synergistic effec:s, cancer, gene mutation, birth defects and behavioral disorders. .I\ major problem is how to test the hazards to man. I n most areas, we cannot experiment with man, only \\.ith animals. \Ye know that different animals sometimes respond differendy to a chemical. S o t infrequently cancers arise in mice, but not in other spxies. In ninny situations, not all of the people esposed develop cancer. Cntil we understand these differences more completely, \\.e have to be cautious. Scientists in government, universities and i n d u s t 7 are workins to increase our ability to assess the hazards of chemicals to man. Each company i n v o l v e d with 3 chemical is responsible for the tests. IYhere more than one c o r n p n y is in\.olved they may designate a sing!e par:y to perform the tests and share the costs. .As I mentioned earlier, this cooperation is already going on. Because of the limitatlor~sof testing facilities and qualified people, especially toxicologists, $\.e cannot tolerate unt\.arranted duplication in testing. There are about 500-700 identified ' TOXIC SUBSTANCES CONTROL IS HERE I n dcvcloping rcgu!ation, t3e .Idministrator shall cocsider the risks, t0sicoIogist.s in the U.S. Competition vironment, he s h a l l b y rule a p p l y benefits, economic consequences and for their senices by new and espand- among othcrs the l e a : b u r d e r ~ o r n eof the impact on small business. ing laboratories is very strong. T h e the follow-ing correc:ions: S e w substances. A manufacturer univenities are turnkg out only about 1. Label with adequate \\.arnings who intends to produce a new chemi- 150 p.er y.ear. 2. Limit the concentration of mate- cal substance not on the inventory Replation. If the Administrator finds that there is a reasonable basis to conclude that the manufacture, processing, distrib3:ion in commerce, US or disposal o r a c h e m i d substance or misture may present unresonable risk to 3ealth o r the en- rial for a particular use 3. Limit the amount which may be manufactured, procesed or distributed for a p,uticular use 4. Prohibit manufacture, piocessing or distribution for a ?articular use 5. Prohibit manufac:ure, processing or distribution. P -71 -. -. + __- - - &-. _ -_d I . . ~-_ _I_ ------. must submit a notice to the .Administrator at least 90 days before manufacture. Even if the substance is on the inventory, such notice must be given by a manufacturer or processor if the intended use of the substance is significantly different from past use. .A11 notices shall g v e the trade name and chemical identity of the product, the amounts manufactured and pro2osed :o be rnanufac:ured, the proposed ca:egories of product uses, descrigtion of byproducts, e x i s t i n g data pertinent to health and env'xon- mental effects related to the product, the estimated number of employes that d l be es2osed to the product (and the duration of that exposure) and the anticipated manner of dis- posal of the product. G(J---...:* management 5805 E. 15th St. 1 P.O. Box 15609 1Tulsa, Okla. 74112 918 1835-9471 EP.4 A u t h o r i t y to >fake Rules ERective Imniediately. If there is iniuflicicnt i n f o r m a t i o n to evaluate health or environmental effects, the EP.4 may propose a ban. If the manufacturer objects, EP.4 must go to court to halt manufacture. \$'here there is adequate infomation to indicate that the substance presents an unreasonable risk, EP.\ must go to court to halt manufacture or prohibit specific sole use. But it may make immediately effective rules to restrict use, require labeling o r impose other lesser restrictions while formal rulemaking is proceeding if it deternines that c o n t i n u e d manufacture would present serious or \videspread injury or damage to health. Effect on State Law. The .L\dmin- istrator may, on application, permit a state or local government to have a rule for testing or a replation if compliance does not cause violation of this Act and if the state's require- ment provides + significantly higher degree of protection and does not unduly burden interstate commerce. States and local governments may prohibit the use of a substance or mixture (other than in manufacture or processing). Imports. Chemical substances or mistures shall be refused e n t q into the United States if they fail to conform \\.ith any rule in effect under 213 TOXIC SUi3STANCES CONTROL Circle 253 on Reader Service Card (NOw...a retractable 7 uB - e:- -.-/ For low-cost, easily installed flow measurement in pipes to 6 ft. in dia. Can b e inserted or withdrawn under line pressures to 10,000PSI. I Turbine rate directly proportional to velocity of fluid. I Well-suited for u s e with conventional flow-rate indicators. controllers, totalizers which accept pulse inp Easily interfaces with systems providing temperature and/or pressure corrections to to standard ccnditions. con.ve rt data Shrouded rotor. -Non-rotating stem to provide precise and repeata.ble alignment in line. Call sales for details NOW! _I ;1:2( f f - LC fqs,4 ._* ,.:3. .'$<. : 3-20 Circle 254 on Reader Service Card this .\ct. This is designed to pro:ect both the consumer and the producer. What HTI must do. I will now dis- cuss five things your company may do to comply with the Act. 1. Follow F e d e r a l Register. The Federal Register is t h e o n e place tvhere all announcements of agency actions are publis:?ed. Man). companies provide one individual w i h a list of their produc:s and concerns. He has the respoxibility of reading the Register and keeping them 2dvised. \\.here size does not permit, a nest a1:erna:e is to look to a : r d e association such as the 1lC.l or others for alerting on regulatory de\.elc?nients. 2. I\'ork with Trade Association. Two or more compnies producing or using a p a r t i c u l a r compound will need to s\.ork toget>.er to develop information about the hazards, :he ccsu of various means of regulation and to present a consensus view to :he EP.4. This can bes: be done xvithin a trade association to a\.oid daidication, spread the cost and m i n i m i z e the concern for antitrus: \.iolations. IRcrease of trsde association activity of this sort is inevitajle. 3. Compounds on Inventory List. You \<ill need a list of all the products you use, produce and discard. See that your products are on the EP.\ list of esisting substances. If you have a chemical in:ermediate whic!! does not get out of the plant, you may wish to "?ply for an esemption. 4. Testing. You \%.ill want to be sure that any material on your list p r e s e n h g an unrezsonable risk has been adequately tested. You should be able to o b t a i n information on testing of raw materials frsm your suppliers. For t e s t i n g c o m m o d i t y products, work with other companies under a trade association. For proprietary products, for which you are the only manufacturer, you will probably want to develop your own priority list to decide which corn- pounds to :est first. Input from toxicologists, nianufacturing, business cen- ters, esperts in governmental rcgulations will be i m p o r t a n t in these decisions. 5. Reporting. .\ great many procedural details for reporting are yet to be develoixd by the OEice of Circle 255 on R e d e r Service C a e + Clrcls 256 on Reader Service Card 222 - ~ TOXIC SUESTANCES CONTROL IS H E R E Tosic Substances. Sonetheless, for an undetermined number of chemicals, you will be expected to report the volume of production, categories of uses, c h e m i c a l identity, impurities, byproducts, disposal materials and the number of people esposed. YOU may have to submit a list of a11 toxicologic information available on particular compounds and later on the reports themselves. YOU will be espec:ed to keep records of and report on significant adverse effects to health or the environment a n d i n f o r m a t i o n a c q u i r e d regirding a substantial risk caused by a chemical. For future epidemiologic studies you will need readily accessible records i.e. compu:erized records of exposure, illness and cause of death. ACT'S 'cCONOF.;IC IL;';:?ACT From a documented study of the economic impact of a Tosic Sub- stances Bill, SIC.\ estimates the cost of the bill to the Chemical and Allied Products Industry a t $260 million to $1.3 billion (Table 2 ) . This is not the total cost in the United States but only for the chemical and allied products industry. Unknowns. There are two major unknowns in assessing the economic impact of this legislation. T h e first of these is the jud,pent and poIicies of the Administrator. Of necessity, much is left to his discretion. H e has a highly comples subject and not enough information to mske critical decisions objectively. H e is faced with tremendous political pressures from environmentalists, acdvists and industrialists. EPA Administrator, Russell E. Train, has promised a "go-slow" approach. This is yet to be demonstrated. IVhat will his successor be like? A. second major unknown is industry's response to the regulations. T h e two columns in Table 2 reflect two ranges for these interactions. The column on the right is based on the suppositions that \\*ith an agressive Administrator there will be comprehensive premarket screening of all major new substances and applications, with selective screening of minor ones, and thst industry will i n c r w e espenditure on research by $600 million to maintain the development of new products a t a steady rate. T h e column on the left is based on TABLE 2--Economic impact Start-up Coat. 115 Annual Expensc I s~1IIIlon Administration. ............... Extra So. Rk new D co mtopmouanindtsa.i.n..sa.m..e.. .Tea:inc of existing r u b s m n c u . . .........P:cr.arkct screening.. D-days (time c completed R ost k sDa)f.t.a......... APprmc?dEouCnciatttolioarbinne/lglei.ng. g.d...qf.un.a.l..i.t.y....c..o..n..t.r..o.l.. 64 ... 29 50 24 P 4 &! KO 40 252 86 51 19 193 llJ0 --Exta and obradnni ninugy.c.o.s.t.l.i.m.i.t.in.g...... 165 195 Total continuing cost.. ......... 358 1325 the suppositions that the .ldrninistrator will be more selective in requifing testing and that indus:iy will reduce the level of RSrD by 15 percent to pay for the costs of compliance and that this will result in a 40 percent reduction in the number of new prodUC'J to be tested. Aiinual e x p e n s e . The figures of $29-.$40 million in Table 2 represmt testing for some 65-100 existing c o a poundsjyr. respectively. Industry \dl be testing compounds beyond the 50 es:ablished in the priority list. Prcrnarket Screening was projected to require testing of some 1,200-6,500 new or modified products and significant new applications of older prcducts and to cost some $50-$250 million. Sfr. Schweitzer now projects tes:ing for only 200 new products and uses. .idding this to testing on esisting products gives a total of $80-$290 million per ye3r as added direct costs for t o s i col ogi c and environmental testing. Fees not to esceed $2,500 for large companies and $100 for small ones are charged for submitting test dzta under the legislation. Litigation is assumed to occur in 10 percent of the cases. I n spite of efforts to minimize costs to small businesses, there will be pressures on small volume products bea u s e of the difficulty in spreading the costs of testing and compliance. Because of this, there will be pressure for removal of lower volume products from the market, and reluctance or refusal to consider new ventures u n l w truly large-scale and continuing production appear highly probable. Of the pesticides coming up for regis- tration, 30 percent are being dropped. Continur d 002234 Clrcla 257 on RcaGer Servlce b r d j , # TOXIC SUSSTANCES CONTROL IS HERE por:ant. I: m e m s that variatiom in these factors can be carried out \vi:>- OFFICE OF TOXIC SUSSTANCES T h e Office of Tosic Substances (OTS) \\.as set u p within the EP.\ in 1973 when passage of a bill \\.'as espected (Table 3 ) . There is currently great confusion in the O T S d u e to a major reorganization. TABLE 3 - O f i c eof t o x i c substances out having to go through premar2et notification. Questions remain as :o her\* to handle and protect confilenti31 information. T h e Office now has a total staff of 45 people \vith 14 professionals and has been operating with a budget of $6 million/yr. Sow that the Tosic Key p e r s o n n e l . Glen Schweitzer is giving personal at:ention to a group of people with new assignments for implementation of the Act. Ken Olsen has been brought in from the Office of Pesricides :o handle any communication with the public concerning tosic substances. The OTS is preparing a P E R T the nest hazard before it breaks as a crisis. Much w o r k ahead. There is a tremendous amount of work to be doce. F o m s for reporting the amount of diiferent chemicals prcjduced, their compositions, uses: impurities and byproducts i x i l l need to be prepared. Substances Control Act has passed, the staff \vi11 be espanded to 150 people and a budget over the nest three years of $10 million, $13 million and $16 million/yr. Lfuch of the z spomibility of the OTS will be CCXtracted to outside offices and laboxtories. I.? CA A 3VIS0RY COh?i.41iiE E chart of future actk-ities 3nd has is- Caregories of chemicals and of uses In i n d u s t r y , the \lanufactur::.g sued a summary of the ACT. T h e for the \\.:?ole of the chemical indss- Che:nists Xssoci3 t i o n (>IC.\) k . 2 ~ publication in the Federal Register is try \\.ill have to be defined: something created a n e w c o m m i t t e e - T h e due no later than July 1 on proposed like higher aliphatic alco5ols to cover Chemical Regulations Advisory Corn- rules for inventor). reporting. Publica- C,, and higher alcohols ra:her than nii:tce to s e n e as a focal point for tion of the final in\.entory report and listing each indi\.idual alcohol. I t is deabng I\ ith matters developing from Priorit). Committee is due no later the espressed intent of the OTS that t o s i c substances legislation ( T a b l e than Sovember 1977. the category of polypropylene will 4). They will be ivorking closely \\ irh Dr. Ithllen, Deputy Director, will cover materials of different molecular the EP.4 and Office of Tosic Su5- be managing continuing line activities weights, blends with other pol>mers, stances. such as E o d y ll'arning to anticipate dyes, inhibitors, etc. This is very im- -4first activity joint \vith the OTS .~- For original thinking.. Y4DALET DIVISION caoi WEST 1 5 0 T H STREET. CLEVELAND. OHIO 441 35 m1-A SCOTT L FETZER COh!?ANY Circle 258 on Reader Service Card -3-34 Uni!ed structural grating with unique Anti-Skid is the safest surface for surest footing even wet, oily or covered with ic? and snow Inside on a floor or mezzanine or outside on an EJA inspection deck, United friction-lock grating installs faster and gives the best coefficient of friction available. TWO widths -TWO heights -- choice of gage and length. Slotted- Grip a safe surface available without Anti-Skid shoe-grippers. Write for FREE catalog 8 samples. P 0.a o x S20. Co!urnbus. Ohio 13216.6141 Circle 259 on Reader Service Card 235 - Circle 260 on Rester Service Care-. ** TOXIC SUBSTANCES CONTROL TABLE 4-hIanufacturing ch cm ist s a s5 oc i ati on,ch emica I r e g u l a t i o n s advisory c o m m i t t e e Chaiman C. Doainaea C. Inz!e (MCA Rcpraentati~e) P.eak.iou F. Hoeriyr T o x k o l o ~ J. M c Donough T e c h i d &sin C. Smith Lemal s ? a h T. H I C ~ M LLbn C.Ha& V. Chairman M. Tktze will be a series of meetings in S e w York, St. L o u i s , S a n Frar.cisco, Chicago and Houston to inform indus:ry as to rvhat will be needed to comply ivith the . k t . TSCA SOCIS. I n review, the major impacts of the TSC.4 are: 1. Insure adequate testing of esisting and new rna:erials Xchich present an unreasonable risk to health and the environment. This means testing about 65 existing and 1,000 new materials per year at a cost of about $80 million/yr. This will require a significant increase in laboratory facilities and in training of toxicologists. Many small volume products will be withdrawn from the market. T h e cost of testing and c o m p l i a n c e will esert critical pressure on small scale mmufacturers of proprietary products, and other information. 2. Besides the testing, industry will be required to record and report exposure data: toxicologic informa:ion, volumes of production, uses, bpproducts. CY<" %)f-T-L-7About the author CURTIS W. SMITHis a chemist a special assignment in R & D 8 , PRODCCTS, with . -I . >\ 1 S h e l l Oil Co., Hous- \.: ->. /J. - ton. In research work wsi.ni ct eh 13t:h2,e hceo mhopldasn ay Ph.D. d e g r e e in or- gcnic chemistry f r o m the L'niuersity of Illinois. O r . Smith is au:hor of a book on acrolein, holds nmre tlmn 75 patents and has served as manager of R & D f o r the former Industrial Chemical Di- t<sion of Shell Chentical. He i s deeply incolced in the company's phans for re- action t o safety and health legislative acts and standards, and also works with major industry organizations and so- cieties which are active in coping w i t h health/saf e t y/enrironmmtal problems. 3. EP.\ ivill r c ~ p l a t etesting, U X , Iziheling, manufacture, d is t r i b u t i o n and disposal. 4. T h e MCA will provide a foc.Js for responding to the EPX. Looking a h e a d . I n conclusion, :.h current Act represents significant pr03ress over many of the areas of previoxs bills which t r o u b l e d industry :he most. It has: greater procedural safeguards than in earlier versions, a :equirement that EP.4 must get a c o x t order before it can ban the manuficture of a new chemical, i m p r o v e d definitions and procedures for regu!z:ing mistures and new chemicals \\,hi:h \\-ill reduce the scope and burden of the . k t , graduated regu!atory s:e;s. Lye absence of quotas a c d reduccd re2orting burdens on small companies. 1I.e now face the task of making ::?e industry's expertise availshle to ?.e government so that the new law c i n be implemented in a reasonable azd prudent manner. ACKSOIVLEDGJIESr T!x author is.gratcfu1 to Dr. R. F. Glasser !or F i p . 1 and 2 and for m 3 n y helpful dircursionr. Pre-engineered, packaged, a n d s k i d - m o u n t e d for fast f i e l d hook-up, t h e s e p r o v e n a m i n e g a s -t r e a t i n g p l a n t s are s t o c k e d in c o m m o n sizes. A v a i l a b l e from 5-to-140 GPM capacities, l a r g e r on request. D e h y d r a t i o n a n d sulfur-removal e q u i p m e n t also available. E x c e l l e n t w a y .to save t i m e a n d h e a d a c h e s . . u s u a l l y a t a c o s t b e l o w t h e norm. P h o n e i n q u i r i e s w e l c o m e , or w r i t e for f r e e literature. for boilers, heat exchangers, turbines, cornpressors - UAP L?e!allic 0-rinEs form reliable static seals in metal-to-matal a p p l k tions. Fabricated from stainless steel or Inconel. they offer optirnm strength and sgring-back to maintain a seal through fluctuations in ?xtreme tsmperatms and prssures. They can meet speci!ications f r r virtually every component in the power or chemical process plant ai: refinery including fire test requirements to 1800' F. Tubular or SO:.^ types range up to 25 feet or more diameter, or as snall as ,250inch 03. Write for Handbook or call (513) 223-3525. United Aircraft Products. CI.: Box 1335, Dayton, Ohio 55401. 226 Circle 261 on Reader Service Card