Document e7DQe5y0XEaoBmn2xXgrz1QZg

,Vrr'1', L7> * >A -`r* Krfl s * ^4J A-" '*>r*"': f , AP}'T;:niA a PPG INDUSTRIES, INC./ONC GATEWAY CL NTIR/PIT ISUURGH, PENNSYL VANIA l'j???/ARA 412/4-J4 Pf July 31, 1974 7CFl r, tlLLL. Jr., Sc [) , t)iri-t Sr CnvironnirntAl rnnlrnt, InrluMn,-,! Chfi-irt.il (V, i\> ,n / Mr. John Step Assistant Secretary Department'" of Labor Room 3115 14th and Constitution Avenue, N.W. Washington, DC 20210 D^ar Mr. Stender: . The reason for this correspondence is to express my objection to the position taken by the American Chemical Society on the proposed permanent standard for vinyl chloride presented at the Public Hearing in Washington, DC. The past president of AI HA requested in a telephone conversation that I repre sent the Association at the American Chemical Society meeting scheduled for May 21, 1974, on vinyl chloride. I received a confirming letter dated April 26 thanking me for consenting to represent the AIHA (Enclosure No. I). On April 29, 1974, Mr. H. H. Fawcett sent me a letter and additional correspon dence (Enclosure No. II). The American Chemical Society ad-hoc Task Force met on May 21., 1974. The basic questions confronting the ACS were: 1) Should the Society take a position on the proposed standard? 2) Is VCM the chemical that has caused the problem? 3) In the opinion of the Society, is the proposed standard reasonable ana appropriate? The ad_hoc_ Task Force on Vinyl Chloride had only two members currently employed in industry--myself (representing AKIA) and Mr.. George Wilson of Firestone Tire and Rubber (representing the ASTM, E-34). OCC 1447 Mr. John Stendur July 31, 1974 Page 2 I The attendance at the ad hoc Task Force meeting on May 21 is shown in Enclosure No. III. The outgrowth of this meeting was a draft of a position to be taken by the Society (Enclosure IV - May 23, 1974, cover letter from H. H. Fawcett and copy of first draft). This draft addressed itself Ur the basic rationale used in setting the proposed standard and not directly to the specifics of the proposed standard. Further, this draft did not indicate r.oy endorsement of the proposed "non-detectable" level concept nor was technical feasibility discussed at the May 21, 1974, meeting. Upon review of the draft position by the Society, I had no major objections. ' In the subsequent correspondence package from the Society (Enclosure No. V - transmittal letter from Mr. Halley Merrell, dated June 12, 1974, and from Mr. S. T. Quigley, dated June 7, 1974), it can be seen that a dead line of 5:00 p.m., June 12 was set for comments on the third revision of the draft. However, this draft was received in my office on June 13, 1974. Concurrently, I wau on vacation during that entire week. In addition, the accompanying cover letter stated: "It would likely be helpful if the ad_ jiqc_ Task Force and CCS members were on record as recomv wding Board approval of the statement. If you approve the statement, may I request that you telephone me immediately." I did rot telephone approval. Through retrospective deduction, I must assume there was a second draft which I did not receive or review. Because of my extensive traveling, a recent bereavement, and a presumption that subsequent drafts would not deviate substantially from the original draft, I did not appreciate the substantive changes that were incorporated in the latest draft or the final testimony given by the American Chemical Society. I was given no further opportunity to review the final position taken by the American Chemical Society nor was any other meeting of the ad hoc Task Force members called before the final position was presented*at "the Public Hearing. OCC 1448 Mr. John Slender July 31, 1974 Page 3 I personally cannot support the final position taken by ACS nor do I believe ttiat it is proper to necessarily imply that the AI HA endorses the American Chemical Society's position. Very truly yours, Zeb G. Bell, Jr. ZGBrmal Attachments cc: Daniel Boyd - OSHA Howard H. Fawcett - National Academy of Sciences Paul Halley - Standard Oil Co. __Jerome H. Heckman - Keller and Heckman Edward Kline - Office of the Solicitor Donald Lassiter - OSHA William E. McCormick - AIHA John A. Pendergrass - AIHA Stephen T. Quigley - ACS Jerome T. Siedlocki - AIHA. W. Mayo Smith - Air Product's Henry Streinba - ASTM George L. Wilson - Firestone OCC 1449