Document da8wgOBYkR3pOmKa5r9vv9Dpb

ACTION SHEET October 9/1980 . ' Health Committee (Dr. Ted Tolkelson) Manufacturing Technology Committee (R.W. Laundrie) Health data to support the need - or lack of need - for a lower VC standard., - Develop information as a basis for petition ing EPA to change the present standard: 3- Contingency Planning Assignments B. F. Goodrich Company Clean Air Act (EPA) 1. Conoco Clean Hater Act (EPA) Tenneco Chemical, Incorporated TSCA (EPA) Stauffer Chemical Company RCRA (EPA) Diamond Shamrock Corporation OSHA J. H. Heckman Contact Ethyl regarding the above Contingency Assignments. NOTE: Assignment drafts should be submitted on or before November 17. John Lawrence Contact TBW regarding status of its Phase I contract with EPA. BOH 008933 minutes PVC SAFETY GROUP - ALTERNATIVES COMMITTEE Keller & Heckman Offices Washington, D.C.__________ Thursday, October 9, 1980 10;30 A.M. S UMMARY 1 - It was agreed that initial steps be taken to develop contingency plans in the area of EFA, OSHA, and FDA. Draft plans are to be submitted to SFI by November 17. The committee will meet on December 5 to review these plans. 2 - The Health Committee is to be asked for an opinion as to whether there are health data to support the need, or lack of need, for a lower EPA vinyl chloride standard. 3 - The Manufacturing Technology Committee will be asked to develop information to serve as a basis for petitioning EPA to change the present standard. 4 - An inquiry will be made as to the status of TRW's standard review study. ### THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 355 Lexington Avenue New York, N.Y. 10017 (212) 5*< J-9400 Bor 08934 ATTENDEES: Bart A. DiLiddo - CHAIRMAN - B. F. Goodrich, 6100 Oak Tree Blvd., Independence, OH 44131 Gary H. Baise - Beveridge, Fairbanks & Diamond, 1333 New Hampshire Avenue, N.W., Washington, D.C. 20036 Rodney P. Becker - Diamond Shamrock Corporation, 1100 Superior Avenue, Cleveland, OH 44114 John Eldred - Keller & Heckman, 1150 17th Street, N.W., Washington, D.C. 20036 H. R. Flammer - Conoco Chemicals, F.O. Box 2197, Houston, TX 77001 Roy T. Gottesman - Tenneco Chemicals, Park 80 Plaza - West One, Saddle Brook, NJ 07662 Jerry Heckman - 1150 17th Street, N.W., Washington, D.C. 20036 John R. Lawrence - SPI, 355 Lexington Avenue, New York, NY 10017 P. E. Roggi - Stauffer Chemical, Westport, CT 06880 0009 1 - Mr. Heckman reviewed the general concept of a contingency alert system (Attachment A) which has been used by one of SPI's other monomer safety groups. A general outline for developing such a contingency plan was distributed to illustrate the components of such a plan (Attachment B). After some discussion, it was agreed that there would be value in applying this technique to the various regulatory concerns of VCM and PVC. Assignments for developing initial drafts of such plans were made as follows: Contingency Planning Assignments EPA Clean Air B.F. Goodrich Clean Water Conoco TSCA Tenneco RCRA Stauffer OSHA Diamond FDA Ethyl* *To be contacted by J. H. Heckman. Drafts of these assignments are to be developed and submitted to John Lawrence at SPI by November 17 for distribution to the entire committee. These drafts will be further reviewed at a meeting of the Alternatives Committee scheduled for Friday, December 5, at Keller & Heckman offices, at 10 a.m. BOR 008935 -3- 2 - EPA Strategies Hr. Baise reviewed the possible strategies which might be pursued with respect to EPA's VCM standard as presented to the Steering Committee at the September 25 meeting (Attachment C). After some discussion it was agreed that the Health and Technology Committees would be asked to respond to the following questions to assist in developing overall strategies alternatives: (1) Can the Health Committee reach a conclusion that there are no health data to support the need (or lack of need) for a lower EPA-VCM standard? It will likewise be asked to recommend the best way to support such a conclusion. (2) Can the Manufacuring Technology Committee develop a report to serve as a basis for petitioning EPA to change the standard? This report should identify areas which might be relaxed or modified to provide better interpretation of the present stan dard. Note: It is believed that the Manufacturing Technology Committee may have developed some material on this subject at the time amendments to the EPA standard were being considered in 1977. It was also suggested that inquiries be made to TRW as to the status of Phase I of its contract with EPA. If possible, it should be determined if there are still plans to meet with industry representatives. If so, will copies of their report be available prior to such a meeting? What is the overall timing? 3 - The meeting adjourned at 2:00 p.m. Respectfully submitted Attachments (3) October 13, 1980 John R. Lawrence Technical Director BOR 008936 ` 'This assumptions will help you very much to monitor yom jjewCrmanC': and to provide for contingencies. Finally, perform the same task for the programs which will con* tribute the most to your financial results. Tills programs list will illustrate where your greatest challenges lie. The "extent of change" review looks at the degree and type of change. It asks what changes arc required of you, your key mana gers, and the workforce. Arc you expecting a change of emphasis or a completely different type of behavior? Arc you forcing the organization to undo the past and adopt new habits or perceptions? h this change restricted to one part of the organization, or docs it permeate the entire organization? Remember a simultaneous change in alt levels of strategy will require a great deal of time and your personal attention. Human factors follows the lost analysis and probes the type of people, the organization, and measurement systems. Do you have the required number and quality of personnel? Is the current or ganizational structure appropriate to the hew strategy? What about your compensation, incentives, and reward systems? Remember that each of these reviews will require time, objec tivity, and a different type of thinking. Don't be too ambitious. Select the reviews you think will pay the best results. I think it is better to use one or two of these completely than to be superfi cial in applying them all. ATTACHMENT A THe case eor CONTINGENCY rtLGKT SYSTEMS Over and over again 1 have stressed that stratcg/ls aimed at the fu ture and built on assumptions. Assumptions are the platform or foundation of strategy. As with a house, if the foundation blocks come loose or slip, the structure will ultimately fall to the ground. Everyone knows this, butmost of us tend to ignore it and begin to equate assumptions with facts. We therefore give little thought to* contingency plans--what we should do in ease of a damaging vari ance from our suppositions. The reasons for this arc easy to understand. We make our as sumptions early in the strategic thinking process (us in any planning approach) and then subject them to review, argument, and modi fication. Pecau.se of all tills and ail unconscious concern that if we are wrong all our planning may be in vain, our minds pul the uncertainty aside and raise the likelihood (hat the assumptions will occur to a high level. Thus it is important to take one more look at the assumptions and force ourselves to ask, rtW!iut if reality turns out different?" This is your starling point for building a contin gency alert system. To do an efficient job of thinking through plans for handling vari ances from assumptions, I would recommend the following steps: 1. Select your assumptions discriiuinatuly. Concentrate on those that have the most leverage. ' 2. Formulaic other piobahlc "what ifs," BOR 0 0 8 9 3 8 [vdop your tracking plans for keeping tabs on variances ' * from your key assumptions. 4. Carefully define the triggers, and assign responsibility for monitoring them. 5. Outline the options; don't formulate them in detail. 1 SELECT YOUR ASSUMPTIONS D1SCRIMINATELY You can't monitor all assumptions. No one has enough time or resources to do this. Further, it isn't really worth the effort since some assumptions are not that important and others can be dealt with readily on the spot if and when they are proved wrong. So as with your strategic options, you should be selective in your con tingency survey. There arc three criteria that you can apply to hclp uncover the assumptions you should lay contingency plans for. These criteria are the impact on your results if an assumption is wrong, the degree of confidence you have in the suppositions, and the degree of influ ence you have to make them come true. Impact If you used some of the review techniques described in the pre vious chapter, you have already determined which of the assump tions has the greatest importance for your objectives. Gap analysis points out the key factors that affect whether net income and sales forecasts will be met. If a market doesn't grow so fast as you antic ipate or you do not obtain the share you expect, your sales and in come will fall below your targets. Further, there arc specific as sumptions you have made about the users, competitors, dealers, and so forth on which you based your quantification of results. Each of the techniques of strategy review highlights a different aspect of the assumption platform and helps you, identify the risk iest dements. Your impact evaluation should reflect on positive as well as neg ative contingencies. For instance a variance in events may result in a bigger opportunity than anticipated. The market may grow faster than expected, giving you larger potential sales. This possibility de serves attention since a failure to prepare for it may make you miss , sales or give a prepared competitor a leg up at your expense. Posi tive impact anticipation can yield dividends as well as negative. . * Confidence When I raise the criterion of confidence with businessmen, they normally equate this attribute with probability. They arc par tially correct. It is important to ask how probable it is that the assumption will turn out to be reality. Obviously the greater the probability is, the less likely it is that you will need to change your strategy. But there is more to confidence than probability. ' You should also ask, "Why do I think so?" Every assumption is based on either data from the past or analysis of the present, your intuition of how events wilt move, or your judgment of yourself or others. I have found it useful to record the source of each as sumption, since the source may have a great bearing on how valid and reliable the prediction is. This line of investigation starts with the question: "Where did the information come from?" Then ask yourself, "Why did I draw this conclusion? Was the information in conflict with input from other sources, and why did I accept these findings rather than others? What has the source's track record been? Is the assump tion close to or far from my past experience?" When you have answered these questions, you specify the degree of confidence you have in the assumption. This can be recorded simply as high, medium, or low or expressed quantitatively as a percentage. Many ihanagcrs estimated some years ago that tiie economy would continue to grow at the rate of 5 percent per year and that inflation would be held within the 4 to 6 percent range. These assumptions were based on the past and were confirmed by-many forecasts dis tributed by professional economists and the federal government. Had you questioned any businessmen who held these views, they would have retorted that they were perfectly logical since they represented overall trends for many years, though there have been cyclical swings. I am not suggesting that we argue about the validity of particular assumptions but merely pointing out that they should be recognized for what they are, uncertain predictions, and that it is important to understand why they have been made at all. BOR 0 0 8 9 3 9 v Influence People and organizations outside your own enterprise are dim* cull if not impossible to influence and arc ordinarily never within ' your control. For example many strategics call for some type of lobbying at either Die state or the federal level of government. The* efforts often fail to produce the desired results, and yet they arc sometimes assumed to be automatically effective. This is not to say that lobbying should not be tried, but it does require careful plan ning and usually the cooperation of many other interested organi zations. To take another example, even the degree of control managers have today over their own workforce is less than that ex ercised by businessmen two or three decades a go. Employees are less likely to follow an order to the letter, and more and more often they seek an explanation of it before they will act. The point is that assumptions should be scrutinized to determine how much power you have to influence events in their favor. Those you have little control over may be worth including on your contin gency list. When you have applied the three criteria to your assumptions, you can decide how much each forecast needs a contingency plan, as Table 12-1 illustrates. Table 12-1. Rating your assumptions. Impact Aisurr.plbns Hating Defers will airy our new line. High Competitor X will exit from the mediumprice market segment. High Confidence Rating Influence Rating Medium (Source: sales force inquiry of dealers) Low (Source: market manager's judgment) High Low Need for Contingency Plan Low High As you can see in this illustration, one assu...,Uion isTated high for impact, medium for confidence, and liip.lt for influence, while the other evokes low confidence and is less within control. It is thus not critical to outline a contingency plan Tor the first, but the second requires one. The next task is to determine how accu rate the components of the critical assumptions arc. FORMULATE OTHER PROBABLE "WHAT IFS" After the critical assumptions have been identified and ranked, . the "what if' questions should be raised. There arc some who ar gue that the most optimistic and pessimistic assumptions should be probed, stressing the need to prepare for the extreme possibili ties as well as the most likely. This is an interesting exercise, but is . otherwise a waste of time. I prefer that we think only about the probable possibilities. Let's go back to Table 12-1 and the dealers' receptivity to your new line. Assume further that the sales force inquiry has turned up a 95 percent acceptance ranging from enthusiastic to lukewarm. This is the basis for the medium rating on confidence. Now, it might be useful to think about the effect of only a 75 percent ac ceptance. Many dealers carry multiple lines or merchandise, and if they aren't convinced that your new line is up to their standards, they can easily change their emphasis to competitors* products. In the long run this may mean that your position with them will decline, and it may even result in the loss of some of your top dealers. Tims you think through the consequences of the modified assumption so that you can decide whether you should be prepared to change your plan or construct an alternative approach if the icycl of optimism is inaccurate. DEVELOP YOUR TRACKING PLANS Deciding the how of your tracking procedures during the Imple mentation phase of the strategy is the focus of your tracking plan, also called the monitoring plan. This step requires that you first BOR 0 0 8 9 4 0 ,'t !-* v' iiin/inwui/ii niJi )>; viiiicic you io Know ' wjjoili^^ou are on target or not. In the case of the dealers in . Table 12-1, this may mean surveys of end users that probe the rcasons they arc purchasing the product and further questioning of dealers to find out why they arc enthusiastic or lukewarm. It may also require the services of outside agencies to collect data about the dealers' sales approaches and brand preferences. The second method involves the question of the reliability of the source of as well as the' information itself. Will the source seek information directly or merely draw inferences from less specific mediums such as the news* papers? If we don't assess the source correctly, we may obtain mis leading or inapplicable information. You must next decide how much you want to spend on your tracking system. There is a whole area of decision theory dedicated to the question of the value of information. How much is it worth to you in dollars, time, and manpower to keep abreast of your en vironment or the condition of your resources? Information may be so difficult to obtain or so unreliable that it doesn't justify the effort required to collect it. Finally, who is to be responsible for the monitoring? What will the person or group do to communicate the slate of affairs? This assignment is critical to successful response, and it tics In with the next step in contingency planning, defining the trigger that signals when the variance from an assumption has reached the action point. There h2ve been many eases where information was tracked well but communicated so ineffectively that the organization was still * caught unprepared. DEFINE THE TRIGGERS Having thought out the system for monitoring assumptions, your ( next step is to identify the triggers that will activate the contingency plans. The need for these is obvious, but their definition is not. A trigger may be not one event or condition but rather a series. A question in point: When should the president of the United Slates change his main strategy for dealing with inflation and use an entirely new game plan? Richard Nixon was elected president alter campaign mg us an ecunuimv .vnn, ............ stated that government controls were ineffective and lli^Tue free enterprise system should be given a chance to operate without gov- , eminent interference. Yet he did a complete flip and resorted to * controls. What were Die events that led him to change his mindor to put it in our terms, what were the triggers? In his ease there were several conditions that arose simultane ously. First, there was the extraordinary rise in the rate of infla tion, which moved out of the normal bounds of 3 to 4 percent up to 8 and 9 percent. Then there wasuhcxpcctcd government * deficit spending. In addition the public was becoming Increasingly unhappy with the loss of purchasing power and choosing Democrats in a growing number of elections for executive and legislative posts on all levels of government. So Nixon resorted to changing his strat egy and ordered the imposition of yrage and price controls. The results of his about-face arc now history-a continuing rise in the rate of inflation, distress in the business sector, job layoffs, public exasperation. I'm not trying to develop a case for or against Nixon's actions, but they do serve to illustrate how complex triggers can be and how extreme the response they may provoke. Nixon's reaction was to abort his prune economic strategy. Not all contingency plans entail such radical change, of course; nor arc triggers neces sarily multiple or complicated. For example the fact that your competitors do not follow your new pricing policies may mean ! simply that you revert to a level halfway to the old levels, chang ing only this element of your original strategy. Another aspect of trigger identification Is the designation of the person or people who will be responsible for initiating the change. ' In the ease of national economic policy, Nixon reserved this task to himself, even at the. expense of having his chief economic coun. sclor resign and losing support from his major conservative backers. In the marketing function of a business, the responsibility for price changes may be given to the marketing manager or one of his sub* ' ordinates. The point is that someone must be made accountable in advance so that the contingency plan can be implemented. The Pearl Harbor fiasco illustrates what can happen when trig. gers are either not set or ignored. There is considerable evidence BOR 0 0 8 9 4 1 . lliat in^ossibility of a Japanese attack was recognized and dial Contingency plans had been developed. One of the problems w;n that no one was really sure who was responsible for the execution of these countermeasures. In fact, there arc reports that indicate that the written plans were locked in a safe and the authorized of ficers wore not available when the Japanese activated the trigger by launching their attack. Of course, Pearl Harbor may also demonstrate that triggers can't be set which are so close to the event or condition that there isn't a chance to do anything to minimize the impact except perhaps to run. The point to keep in mind is this: To be useful, triggers, like any other early warning system, must provide sufficient lead time. With your triggers identified and monitoring responsibility as signed, your contingency alert system is fully operative. It will Cujble yojLiL.Qrg:tnization to change dircction if and v/hcn this be comes necessary, By providing thought-out responses to variances from key assumptions, the system gives you (he lead time und Hie means to minimize the impact on promised results. PROVIDE OPTIONS NOT PLANS 1 have mentioned the need to have a plan of response which will be executed at the optimum time. Actually, this may be somewhat misleading. What I mean is not that you should prepare a detailed plan but that you should give some thought to the op tions that arc available. It is important to remember that any plan should be aimed at the cause of the problem and not at the symp toms. Suppose that you have a complete, well-developed plan to franc-Tc a contingency and that the plan is based on one set of as sumptions about the causes of such a problem. If your assump tions arc wrong, any response you would make to resolve such a problem might do more harm than no response at all. Having a varied set of oplions available, however, would give you more flex ibility and allow you to quickly choose the response that seemed most appropriate to the actual problem. CONTlNUtwcr i'LAMvmi*w FOR NONPROFIT INSTITUTIONS Contingency options are equally important.for the nonprofit or* , * ganization, A hospital director may build his strategy on the as sumption that Blue Cross or Blue Shield will obtain permission from the stale commission to raise its rates. But suppose the com* mission grants only 50 percent of the requested amount or delays the approval for six to nine months. This may allow the "Blues" to reimburse the hospital only partially, which in turn may significantly reduce the hospital's cash flow. What are the options that the hospi tal could adopt if the assumption of total reimbursement was Incor rect? llow could the hospital trigger a change in its strategy before it was too late and it ran out of cash? Universities, too, make assumptions which may prove Incorrect- assumptions about the size of the student body, the professional* ' ism of the faculty, and the continuing financial support of founda- , tions, alumni, and government. What If the number of students dramatically increased in some disciplines and dropped oTf in others? This would mean the wrong mix of faculty amt facilities. On the other hand, what if the government wanted to provide more funds for special research? Or a large company moved into the area amt needed university training for their engineering or professional staff? The point l am making is that contingencies can be positive as well as negative and the lack of preparedness can mean a missed opTphoertu1n9i7ty5. fiscal crisis of New York City is an excellent example of the need for contingency options and for recognizing the com plexity of making decisions. The "what if" question that should have been anticipated was the inability to continue obtaining fi nancing. It was painfully apparent that options were not thought through. The crisis was compounded by the fact that the mayor's authority to change strategy was limited by the city council and even the New York state legislature. In institutions where author ity or ability to act is restricted by law or the constitution, triggers should be set far enough in advance to provide Hie lead time to get Hie approvals necessary to avert a calastrophy. BOR 0 0 8 9 4 2 APPLI ION TIME Throughout this hook 1 have stressed your need to think alternii* lives through and then select the one you.prcfcr. If you have been following this advice, you will have developed alternate investment, management, and operating strategics. Since you have already dedi cated time and effort to this development of alternatives, you may find it beneficial to review thorn to determine whether any could be used as contingency options. The reward of having alternatives is that you may have already completed your contingency option list. If, on the other hand, you need more help in developing those options, take a dose look at the following example of an education equipment manufacturer. As you read through the example, apply tile procedure to your own needs. This manufacturer has developed a marketing strategy based on the assumption that its state government will continue to provide aid to local schools to purchase remedial language installations. The state has allocated more than S3 million a year to this effort in Die past five years, and the company anticipates that the aliocation will continue at lists level for the next three years. As a re sult it plans to add new plant capacity in the state capita! area to. produce the language equipment. It has had SO percent of that mark.-: segment, and this accounts for 30 percent of its lota! sales and 25 percent of its nut income. Using this and other information, the company constructs a contingency alert system as follows. Assumption. The state government will provide S3 million per year for the next three years for remedial language equipment. Impact: If the assumption is incorrect, this will seriously hurt the company's sales and net income. Conclusion: high impact. . Confidence: This assumption is based on past experience. There are conflicting reports on the total education aid budget, especially with the change of administration in the state. The allocation could be half of the original. Conclusion: low to medium confidence. Influence: Tills is a small business anu tins nu ___ _ Other companies in the education business ate mueh l^!er, and they will be interested in preserving their segment sir.c. Conclu sion: low influence potential. Need for contingency plan: This is a must for contingency planning. What if? The state may cut the program budget in half and spend the balance on teachers rather than equipment. Impact: Sales down by 25 percent and net income much smaller , than projected. Confidence: This is a more pessimistic possibility of what the state government might do. It is based on scattered but mounting opposition to the program in.the legislature. Tracking. Full monitoring is needed because of the high Impact of both assumptions. Information: Government expenditures for education. Budget proposals submitted by state officials. Pressure groups that can influence the expenditure. Local school remedial language programs. Sources: Budget documents. National Education Association publications. Speeches by educators, especially the head of the state Depart ment of Education, Speeches by state officials, especially the governor and his major opponents. Reports on education to the legislature. Documents of special interest groups. Budget: $4,000 for the purchase of publications and visits to the slate capital. Responsibility: One marketing employee assigned full time. Communications: Marketing manager will submit a monthly re Triggers. Three major warning signs exist: l. The preliminary budget calls for less than $3 million in reme language aid. f iOR 008943 2.^pbrc is public indication that top state officials arc changii their commitment to this activity. 3. Reports by top educators charge that remedial language labs are not meeting learning objectives. If any of these trends develops into an active threat, one of the following options may be executed: 1. Tie in with other manufacturers to lobby for education funds. 2. Promote the value of remedial language Jabs among local school authorities across the state to stimulate them to apply pressure in the slate capital. 3. Promote the use of general language equipment for advance ment of skills and possibly for foreign language learning. 4. Do a feasibility study of strategics for entering other geo graphic markets or possibly the college market. Strategic implications. Continue to base the strategy on the assump-. tion of S3 million in funding but be prepared for change. The respon sibility for change lies with the marketing and manufacturing managers, subject to final approval by the president. TH 91MGGV SUNWRV a new of- wmm EY STMeG We have come to the end of a long and difficult journey, rcquirii large amounts of time and concentrated thinking. You have cor templated your mission, completed your analyses, carefully scru nized your opportunities and threats, defined your potential ob jectives, and finally made your decisions. All these phases liave involved your top managers and staff executives, and through tli cussion, reflection, and even compromise, you now have an ovc business strategy. This strategy provides you and your organization with a blue of the direction you want to take as well as the means to your i The blueprint shows you where you are and will enable you to terminc as time passes how fur you itavc veered off course-*/t! strategy is understood by those responsible for Its imptemcnlai .and those who must continue to allocate the resources nccessai for success. The problem is how to communicate the strategy these decision makers and insure that they understand it. 1 ha known many businessmen to underestimate this task and even it is an unnecessary luxury. This is a serious mistake. It may i that all the work alrendy completed will go unattended. Thcr two questions to think about*. Why should investors put their or managers their efforts into your business if they don't und> what you arc doing and what they will get out of it? And ho managers below you implement something they don't under* attachment b October 9, 1980 FOR CONSIDERATION BY THE SPI PVC SAFETY GROUP ALTERNATIVES COMMITTEE OUTLINE--CONTINGENCY PLANNING Purpose; To identify some responses to potential [name of agency] regulatory activity. Situation: 1. ____________________ promulgates and enforces [name of agency] regulations addressing chemical substances pursuant to acts: [number] a. [Name of Act] b. [Etc.] 2-4. [Continue with general discussion of the regulatory posture taken by _________ [name of agency] toward PVC/VCM and toward the potential hazards presented by PVC/VCM, paying careful attention to the approach ____________________ [name of agency] has taken toward other substances associated with the same potential hazards.] 5. [Name of Act] [Provide basic discussion of situation as it relates to referenced act and repeat this treatment for each act referenced in paragraph 1 above.] BOR 008944 2- What If: 1. ___________________________________________________: [Cite relevant act or statutory provision] [Insert description of regulatory action of concern. The concern is usually with the less favorable course of action. Using this format, list all potential activities of concern.] a. Impact: [Low, Medium or High] b. Our influence: [Low, Medium or High] Tracking: Information and Sources: 1. _______ ______________________________________ : [Cite relevant act or statutory provision] a. _________ [name of source] b. [Etc.; List all sources.] [Possible sources include: direct agency contacts, other trade associations, Keller & Heckman, trade press, other industry sources, agency announcements, the Federal Register, public news media, member information, etc.] Triggers: 1. : [Cite relevant act or statutory provision] [Insert description of event which would trigger activation of contingency plans.] 2. [Etc.] Contingency Plans: [Describe the plans to be implemented if any of these trends develop into an active threat.] Trigger 1: [Contingency Actions a. b. c. ] Trigger 2: [Etc.] BOR 008945 -3Anticipatory Action Underway; [Describe any actions being taken by the PVC Safety Group.] COR 008946 Beveridge. Fairbanks & Diamond ATTACHMENT C PVC SAFETY GROUP October 9, 1980 Possible Strategies: 1. Rescind existing proposed '77 amendment. 2. Rescind existing vinyl chloride standard. 3. Rescind existing '77 amendment and oppose totally the proposed data gathering effort and subsequent amendments by TRW and EPA. 4. Oppose the proposed amendments because there is no health basis, but accept amendments favorable to the PVC Safety Group. 5. Work with EPA on revising standard to alleviate the PVC Group's complaints. 6. Do not oppose any EPA effort. 7. Work with Congress to amend 112. BOR 008947