Document gDpBzkDKk3vNwb8OLzj7RDYdG

Beveridge. Fairbanks & Diamond Agenda PVC SAFETY GROUP MEETING September 25, 1980 Washington, D.C. EPA Revision of Vinyl Chloride Standard I. Background A. Original EPA Position B. EDF Position C. Carcinogen Policy Hearings 1. Data 2. Witnesses D. EPA Estimated Costs for Compliance E. TRW Contract 1. Reasons for contract 2. Goal of contract 3. EPA authority to use private contractor a. No delegation of authority to enter premise for data gathering purposes 4. EPA prohibited from delegating rulemaking 5. Question on sharing confidential informa tion with contractor F. EPA Decision Date II. Possible Strategies A. Seek to rescind existing proposed 'll amendment and existing Vinyl Chloride Standard B. Strategy A plus oppose totally the proposed data gathering effort and subsequent amendments by TRW and EPA . . ./2 SPl-09013 Agenda 2 II. Possible Strategies (continued) C. Oppose the proposed amendments because there is no health basis, but accept amendments favorable to the PVC Safety Group D. Work with EPA on revising standard to alleviate the PVC Group's complaints E. Do not oppose any EPA effort F. Work with Congress to amend 112 III. Tactics A. Economic analysis B. Health data summary C. Legal summary D. Development of P.R. summary 1. Use with media 2. Use with Congressional and EPA staff IV. Future Action A. TRW plant visit problem B. Law suits filed by Department of Justice 1. Options a. Press release B. Contact with EPA and Justice lawyers C. Preparation to implement strategy SPI-09014 Beveridge. Fairbanks & Diamond PVC SAFETY GROUP October 9, 1980 Possible Strategies: 1. Rescind existing proposed '77 amendment. 2. Rescind existing vinyl chloride standard. 3. Rescind existing 'll amendment and oppose totally the proposed data gathering effort and subsequent amendments by TRW and EPA. \ ,- Oppose the proposed amendmentsbecause there is no s. 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. SPI-09015 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.] SPI-09016 i -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.] SPI-09017 -3Anticipatory Action Underway: [Describe any actions being taken by the PVC Safety Group.] S PI-09018