Document e74JyD7XEdQkMVegr0Qwwq1aE

Vi f -interoffice MEMORANDUM To_____ W. Wirkus______ Froi11 C. E. Blades Data April 18. 1977 Subject TSCA - Raw Materials Inventory Certification _____ (LcciVion, Oruli4tlon, t,t 0<P*rwn*i.i) (Location, or Department) This is a follow-up on our conversation of Tuesday, April 5th concerning certifications from -suppliers that the chemical products we purchase will be included on the Inventory List of Existing Chemical Substances. The Toxic Substances Control Act has empowered the EPA to establish a list of Existing Chemical Substances manufactured, processed, or imported for "commercial purposes". Chemical substances to enter the stream of commerce after December 12, 1977 must be on this inventory list. It is required that a manu facturer, processor or importer of any given chemical substance certify that said substance was manufactured, processed in, or imported into the U. S. during the period June 10, 1974 to present in order to qualify for listing. Only one manufacturer, etc. needs to certify, however, for any one substance. There is always a possibility that certain materials may get overlooked. APCI business centers are interested in a continuing source of supply of the raw materials purchased for their operations. It is proposed, therefore, that the suppliers be requested to affirm their intentions to place products which we purchase on the EPA Inventory List of Existing Chemical Substances. A copy of proposed rules for preparation^of the .Inventory..is attached to this letter for your files. I understand from our conversation that your office will proceed to request these certifications from suppliers. By carbon copy of this memorandum to profit center and research managers, it is requested that they identify for you expected needs for raw materials arising from products now'in market or research development but not yet commercial. This memorandum supplements those of A. E. Perkins dated 22 March 1977 CEB:sk Enel. cc: H. L. Jaffe T. A. Manuel R. Blomquist D. G. Holland A. R. Adams G. J. Mantel1 H. L. Harwell A. E. Perkins / D. R. Harrter H. P. Gallagher J. W. Pervier Vi. C. Cross L. DOelp L. Friedman J. Armstrong Blades AP00049126 [7^ c^/i/z,'P/iodac^S-\ G& nate April 14, 1977 ,_________ 'INTEROFFICE '"Subject* TSCfr Inventory List Supplier Letters MEMORANDUM C. M. Carhart ToW. Wirkus ___________________________ From C. E. Blades_______________________ Brookside IIJ ' Trexlertown _________________________ (Loc*1icf>, Orjioizjtion.or pesriment) Pis'Cataway_______ _________________ (Location, O's-miiailon, or Djartmem( We have discussed the need for assurance by suppliers that the raw materials supplied to us fOT our chemical manufacturing, fabricating, or processing opera tions will continue to be available in the market place following finalization of the Existing Chemical Substances Inventory List to be published by EPA on November 11, 1977 under the provisions of the Toxic Substances Control Act. The question has arisen on how far back one should go in soljcit.vng assurance of raw material availability. There are two contingencies which we request you seek such assurance. (1) All suppliers of raw materials (i.e., existing chemical substances) which qualify for inclusion on the inventor/ list should be asked to certify that they intend to place such materials on the EPA Inventory list. (2) All suppliers of trade marked materials, whose identity is unknown to us are of particular concern. A certification from suppliers that the component(s) of such trade marked materials wall be on the inventory list, is required. The above rules remove the need to obtain certifications from suppliers of mixtures, or alloys, or fabricated items unless trade marked. As a generality, it is requested that for Existing Chemical Substances which the company purchases for any purpose, assurance of continuing supply under the provisions of the act be sought. However, priority concern is not with commodities as supplied by large cheirric-il companies. The main issue resides with small manufacturers of low volume, specialty materials. Small manufacturers may not be aware of the need to get products on the inventor)' list The matter is further aggravated when identity of a product is not generally known. CEB:sk cc: W. M. Smith L. B. Tepper J, C. Novak ' A. J. Diglio R. H. S'chenck W. L. Ent C. McKinley G. G. Handley C. E. Blades n*)rn AP00049127 AA r.'~V_ r.1 r*1 r' rr ra rr y"\ n /-V'/ ^v,7'r<^ / '' /c")' '7^ ^ > / '^n/V/VT^ ghlL'.';_^ iJ *\L slV |ji/ij..,;./i. jK ,v.7 L\ . U \j\ vi A./cj <C^.WcpJ>jy business newsletter published from the Nation's Capital Publisher: LEONARD A. CISEHfcP Editor: LINDA S, STCHN Vol. 4 No. 9 June 8, 1977 Page 119. * OTS Testing Theories Meet Sharp Criticism From Science Advisor/ Board...................... Pijx;e 120 * Dump Surveys, Hazardous Programs to be Top Priorities for EPA FV '7 Assistance Page 120 * New Lead Document in Circulation1, Standards Group begins '^cr!: or Air Levels - Page 121 SLANTS & TRENDS SHOULD HAZARDOUS WASTES CROSS STATE LINES FREELY? That question is becoming a key pare of EPA1 s implementation of the P.esource Conservation and Recovery Act. Illinois Attorney General William Scott says no and is attempting to shut down a V/ilconvf lie, 111., landfill because it handles wastes uf other, less popu lous states (see page 122). But the National Solid Waste Management Associa tion, in a letter to Doug Costle, told the Administrator that closing the land fill, "one of the best in the nation," would "establish a national precedeiit of incalculable damaging proportions" and seriously impair RCRA implementation efforts. And EFA seems to agree. In draft hazardous waste guidelines issued by that agency (see story, page 120), EPA. said it. strongly opposses "noninportniion" provisions of state and local laws. ti a ?; INVENTORY`REPORTING REGS WERE WIDENED to include use and production data re quirements. EPA Administrator Doug Costle made that decision this week after scvcral briefings from Office of Toxic Substances members. New plans call for those regulations to bo reproposed on or near July 1. ^____________ .. 1 ./ OBVIOUSLY, STATUTORY DEADLIKESlflLL NOfU MET under that schedule. Reporting rules will be Into, as will the inventory of existing chemicals, mandated by Nov. 11, Costle will be requesting, an extension from Congress on those dead lines and will include in his letter a request for one other -- undisclosed -- lute date. * ft ft EPA'S STRATEGY FOR IMPLEMENTATION OF TSCA is undergoing complete revision, as is the group who was writing that strategy. Original three EPA groups -- the Toxics Strategy Coordination Group, TSCA Strategy Task Group and the Inte grated Toxics Strategy Work Group -- have been disbanded. Stratr.f.y is now boinn written bv a higher-level working group of branch chiefs and others at the Deputy Assistant Administrator level. That group is out writing papers on various TSCA-rclutod subjects; they hope to incorporate Lhosc papers into a cohesive strategy. But first strategy work group had hoped to finish theirs by this month; it docs not appear likely that the new group will meet that date ft ft ft MONTGOMERY COUNTY, HD., SHOULD CLOSE ALL PARKS because of high amounts of as bestos in crushed stone used in walkways there, EPA warned county officials yes terday. But park officials have decided to pent: warning signs only, until stone Is replaced. In an effort not Lo "panic" local. ci tlr.ons. I'ublitlicil weekly by Business Publishes, Inc. editorial ,md business offices: P.O. Box 10G7, Silver Spring, MD 20910, 101 .$fc7-M00. Subsci ipiinn pi tee: S12-1 per ycat, S<5 foe six months, U.S., Catv.uh ami Mexico; S136 per yc:ir in all other commies (includes Ait Mini dclhviy). Multiple copy tales on request to Ilcmy Kleiner, Jr., Business ManapcT. Printed in U.S.A. ip) 1977 Business I'ul'lkhcis, Inc. AP00049128 INTEROFFICE MEMORANDUM To_______ TSCA Compliance Committee Prom_____C. E. Blades______________ cc: W. M. Smith L. B. Tepper J. C. Novak A. J. Diglio E. Handwerk Subject Date May 31, 1977 TSCA Nfeeting Agenda June 13, 1977 (Location, Organization, ot Ocpartmcnt) (Location. Organization, or Oopartmant) C. McKinley W. Ent G. Handley D. Pierce P. Bilan W, J. Wirkus E. M. Carhart *EcC|.__ : 7 iyv- l'"r The next meeting for the TSCA Compliance Committee has been set for 9:00 A.M. NONDAY, JUNE 13, 1977 in Conference Room 113G - Trexlertown. The agenda will be as follows: (1) Proposed budget and cost collection system for TSCA Compliance Matters. - Dennis Pierce (or assignee) (2) TSCA Compliance Committee Charter Review The Committee (3) Inventory List Problems (a) CAS Registry Nos. (b) Alloys, Catalysts, etc. are mixtures (c) Accuracy (d) Mechanism--who signs? (4) Customer Complaint Problems (a) Is a distributor a customer? (b) Who in GEG will issue? (5) Follow-Actions (aj) Substantial Risk (b) Report from the Purchasing Dept, re Certifications (6) Record Keeping Requirement ^ Action Now? R, H. Schenck E. Handwerk E. Handwerk C. E. Blades R. H. Schenck C. McKinley C. E. Blades W. J. Wirkus E. M. Carhart C. E. Blades CEB:sk C. E. Blades (320) AP00049129 Date May 26, 1977 INTEROFFICE MEMORANDUM Subject Minutes TSCA Compliance Conmittee Meeting - May 23, 1977___________ To Distribution.______________ _______ ______ ____________________` (Location, Organization, or Dapartmant) From_____ C. E. Blades ___________________________________ _ (Location, Organization, or Oapartmant) Attending: C. H. Blades W. M. Smith G. Handley A. J. Diglio L. B. Tepper J. Urenovitch E. Handwerk C. McKinley P. Bilan Absent: R. H. Schenck j. `Novak ~ W. Ent 1. TSCA Committee Chart Draft had. been circulated by P. Bilan prior to meeting. There was significant discussion of contents. Based on discussion and resolution of points, P, Bilan will issue a new draft, circulate to corporate executive comnittee, and then to TSCA Compliance Committee for final approval. Items of concern were: (1) Page 2 - Responsibilities In initial decisions regarding negotiations with EPA, the Chemicals' Group Environmental Affairs Manager (A. J. Diglio) had been assigned negotiations responsibility with EPA. The TSCA Chairman was to coordinate such activity as appropriate. The charter should reflect this. (2) Page 5 - G> - Inspections Concern was expressed that line management may be by-passed in notifying TSCA Chairman, Law Dept., etc. when inspections occur. To resolve, the directions will be rewritten to require line management to notify. C3) Page 5, d. - Substantial Risk Notification. GEG people concerned that the proposed policy permits by-passing line management. Questions raised dealt with standards for judgements, awareness program to all employees, absence of rules, etc. . Recommended that a notice be prepared for posting on bulletin boards notifying employees of requirement to report--or publish in company news organ. continued........ n?m AP00049130 Minutes TSCA Conpliance Comm. Meeting * May 23, 1977 2- - May 26, 1977 NOTE; Refer to memo CEB to TSCA Conmittee, 14 April 1977, item 3, The proposal in that memo was for notification, to proceed through the line management until further notice. Also, the prime source for recognition of information or its generation rests with the technical personnel in various sectors of the company. These have been iden tified and instructed* (4) General The first nine pages constitute the broad umbrella of the compliance policy statement. The subsequent documents were intended to be exemplary of implementing rules* It contemplates the possibility that such rules will not necessarily be uniform across the corporation. ACTION: P. Bilan will revise draft to take into account the comments made. Revised copy will be reviewed by executive committee and returned to TSCA Compliance Committee for final approval. 2. Budget Proposal The elements of a system for collecting costs associated with TSCA conpliance have been discussed with H. W. Parke of Chemicals Group accounting. Prior to submittal to the Committee, Denny Pierce will formalize, interface with J. Kaminsky and then present to TSCA Conpliance Committee, This is scheduled for June 13 meeting. Members of the committee should come prepared to critique the proposal. One problem is the-resolution of the needs for establishing a cost center for TSCA vs. the desirability of an expense entry for TSCA on each business areaTs budget. Intention is to prepare a budget for FY 1978 ready for cost collection in Oct. 1978. 3. M5D/MPD Status Report MSD Technical Marketing staff attended a TSCA Seminar. The product line has been reviewed. NED has prepared an internal inventory list. MSD is a processor and therefore has the option to report. After review, a decision will be made, MPD -- Robin Scott and John Eiding have been briefed on the proposed rules for inventory of existing chemical substances. Exclusive of ethylene oxide, nitrous oxide and oxygen, Eiding and Scott could not identify any existing chemical substances which MPD processes. They propose no additions to the inventory list. We will expect that Speciality Gases and IGD will place the eo, 02 and NO on the list. continued.... AP00049131 Minutes TSCA Compliance Cott*Meeting - May 23, 1977 -3- ' May 26, 1977 4. Environmental Harm Reports G. Handley and A. J. Diglio report under control. 5. Customer Complaint File Only partial response to the requirement for these reports--both sectors of the corporation. CEB will handle. 6. Confidentiality Matters (1) CAS Registry Numbers EPA has received a number of comments on the confidentiality problem. It is clear that confidential structures will be required to be placed on the inventory. At a recent EPA/MCA meeting in Washington, Schweitzer requested industry to solicit CAS Registry Number assignments for all chemicals not on Candidate list. The message was understood that this included confidentials. Recoirmend that we wait for June 29 final rule-making before submitting confidentials to CAS. 7. GEG Compliance Status - Committee Makeup C, McKinley proposed a Sub Committee be organized within GEG to deal with TSCA. He would envision that a single representative from the Sub Comnittee would sit on the TSCA Compliance Comnittee for correlation. It is not clear that such would necessarily meet the requirements and adequately serve GEG. Noted is the observation that prime TSCA compliance demands now rest with Specialty Gases of IGD. L. B. Tepper expects that he could represent MSD interests and concerns. MPD may be exempted. Action: Pete Bilan was charged to draft a proposal for such an organization. C. McKinley will provide basis. The next meeting of the TSCA Compliance Corrroittee is scheduled for JUNE 15, 1977 at 9:00 A.M. in Conference Room 113G. Also scheduled are meetings on JULY 11 and AUGUST 8 CEB:sk Distribution: M. Smith Handley J. Diglio B. Tepper H. Schenck Novak W. Ent J. Urenovitch E. Handwerk C. McKinley P. Bilan C. E. Blades AP00049132 \ interoffice MEMORANDUM Subject ToTSCA Compliance Committee Members _______. From C. E. Blades______________ ______ _ natP May 13, 1977 Meeting Notice - TSCA Compliance Committee ______ ________ (Location, Qifinlzjtlon, or Qp*rtment) Pis catawav (Location, Organisation, or Oaoartmant) There will be a TSCA Compliance Committee meeting at 9:00 A.M. in Conference Room 113G, main office building, Trexlertown on 23, 1977. The agenda will be as follows: 1. TSCA Committee Charter -- Draft 2. Budget Proposal P. Bilan Dennis Pierce 3. I'SD/MPD Status Report C. E. Blades 4. Environmental Harm Report Format/"Signiicant Adverse Actions'r G. Handley/A. Diglio 5. Customer Complaint File C. E. Blades 6. Confidentiality Matters 7. The Registry Numbers -- Chemical Abstract Service C. E. Blades C. E. Blades 8. GEG Compliance Status - Committee Make-up C. McKinley/W. Ent 9. New Business Members of the Committe Following die TSCA Committee meeting, which is scheduled for 1 hour, there will be a meeting of the HARAC Team. Agenda items for the HARAC Team Msetino are: 1. Guidelines for Product Reliability R. H. Schenck 2. Jefferson Notification of TDl/Dabco - Concensus for recamuendation (see Minutes April 25th Meeting) C. E. Blades 3. The M3DS Approval Circuit - Status Report | HARAC Product Reliability Programs E. Handwerk C. E. Blades 4. Crown Central on HFZ-20 Catalyst (copy attached to HARAC Team Members). C. E. Blades continued........ (320) AP00049133 Meeting Notice -2- 5/13/77 5. The OSKA Benzene Workplace Standard (HARAC Directive in order?) 6. Environmental Matters Related to HARAC 7. Ames Testing Decision (memo attached) - w. M. Smith/J. C. Novak - A. J. Diglio CEB:sk Distribution: W. M. Smith(with end.) ^ L. B. Tepper^ A. J* Diglio J. C. Novak " C. McKinley W. Ent G. Handley E. Handwerk P. Bilan D. Pierce C. E. Blades AP00049134