Document gaqj4wOokOp6D9bbEba0rvaYV

------------------- rfl-------- ------- *f}P . .---------------------------------------- ----------- _ ZJ **s 1-----------------------------w ________________ _____________ '*.* 41*. PVC SAFETY GROUP * naytlower Hotel Washington, D.C. 4^ May 28, 1981 10:00 A.M. Attendees: Air Products & Chemicals Beveridge & Diamond Borden, Inc. A. R. Adams, Chairman R. C. Sander Gary Baise Scott W. Bowan W. B. Barton N. M. Blackman Milton W. Kline E. Skiest -- Conoco Chemicals H. J. Hall Joe Ledvina Dow Chemical U.S.A. Dr. Ted Torkelson General Tire & Rubber Co. R. W. Laundrie B. F. Goodrich Chemical Group Dr. W. C. Becker Dr. Robert A. Krueger V ';br- H.'-O'Mara ` / . ^' Goodyear Tire A Rubber Co'. D. H. Francis Great American Chemical Corp. John Floros Hooker Chemical Co. Pantasote, Inc. Raymond W. Arnold . Fran Ff**Hoy ^ *.***. J. E. Ertel PPG Industries Fred C. Dehn Shell Chemical Co. Lawrence A. Wheeler Tenneco Chemicals Wm. Dish Dr. Roy T. Gottesman Union Carbide Corporation' R. N. Wheeler, Jr.. TW SOCIETV rv. ! . .t y r, -= ,k' ' ~ ^ 'N'CUSTPY, INC. ucA cA 008463 SPI Legal Counsel Keller & Heckman 2- - SPI Staff Society of the Plastics Industry, Inc. John S. Eldred Peter de la Cruz Dr. Dan Dixler Jerome H. Heckman John R. Lawrence I. Chairman Adams opened the meeting with self-introductions. He indicated that he would generally follow the circulated agenda with certain changes in the order of discussion. II.Dr. Adams referred to the report from the treasurer circulated to the members present. He called attention to the fact that it is expected that we will be in a deficit position as of May 31. He proposed that an assessment be made for the collection of $250,000 on a pro-rated schedule based on June 1, 1981 capacities. This recommendation was approved unanimously. (Attached) He further indicated that he will request the treasurer to prepare a budget for the group's activities for the first six months of the new fiscal year. Dr. Adams pointed out that since the legal expenses of the group constitute the predominent expenditures, he was appointing Mr. Becker to review the legal activities from a cost effectiveness standpoint. III. Dr. Krueger repprted that the Alternatives Committee.'s plans included with his letter of; May 5.constitute the alternative plans which are;recommended for adoption. This recommendation was fully approved by those present. IV.Mr. Lawrence reported on the results of the meeting of the group's Fire Safety Committee held on May 14. As indicated in the minutes of this meeting, the group recommends that this committee be re-instated and charged with the responsibility of reviewing the alleged hazards with respect to PVC in fires and provide appropriate scientific data to support the industry's contention that such allegations are false. After some discussion, the group unanimously approved re-instating the PVC Fire Safety Committee. V. Dr. Torkelson itemized the activities of the Health Committee as follows: o The Crosbie paper on "Respiratory Complications of Burns" has been reviewed by the Health Committee and a recommendation has been made that Dr. Crosbie attempt having this material published in a scientific publication. It is anticipated that Dr. Crosbie will have a manuscript for such a publication by Summer. o It was indicated that the CMA Vinyl Chloride Committee is considering the update of the original Tabershaw-Cooper Epidemology study. ucc 008464 -3- o The Boyd computer file of abstracts of health studies on vinyl chloride and polyvinyl chloride now contains approximately 400 documents. A. user manual has been prepared. It was recommended that information on this material be circulated to all members of the PVC Safety Group to determine its value. o The EPA Conference on Vinyl Chloride scheduled for October 19-20 was dis cussed. A recommendation was made that further inquiries be made to determine the timeliness of such a Conference. VI. The brief report prepared by the Manufacturing Technology Committee was reviewed. (See attachment) Refernce was made to the comments on the TRW Study submitted to EPA with the cover letter of May 7, VII. Reference was made to the report from the Communications Committee (attached). No actions were taken on any items in this report. VIII. Mr. Scott Bowan reviewed the outline agenda of EPA activities (see attachment) Under Item 1, E3 he indicated the copy of the Radian report has been requested and will be distributed when received. The EPA cost of compliance estimates are being reviewed by Battelle Institute and will be reviewed by 0MB in their consideration of revisions in the vinyl chloride standard. In discussions with the Engineering Division of EPA indications are that they will proceed with minor changes in the present vinyl chloride standard without the assistance of TRW. These changes many be available for review by the end of the Summer. Mr. tiowan concluded'his report by refering to the acti'op alternatives in his outline agenda. He indicated a need for guidance from the PVC Safety Group with respect which of the possible alternatives are most desirable to pursue. IX.Peter De la Cruz reported that OSHA has no plans for the revision of the VCM standard at the present time. X. Mr. Heckman reported on the following activities with respect to FDA: 6 Reference was made to the May 25 issue of Food Chemical News in which it was reported that FDA is expected to propose that the dioctyl adipate and dioctyl phthalate be banned (copy attached). o The outlook for the continued approval of PVC for packaging based on prior sanction appears good. o It is not expected that BATF will take action on approving liquor bottles for issuance of FDA's constituents policy. This is expected in the period from June through October. o EPA's action on these plasticizers may be slower. It is suggested that FDA is moving directly because of the Delaney Clause and information indicated that substitutes are available. ucc 008465 -4- XI. The action being taken by the California Commission of Housing and Community Development with respect to plastic pipe was reviewed with a recommendation that two alternatives be considered as follows: 1. Industry could decide at this time not to participate in an EIR process designed to answer the environmental issues being raised by the Union (i.e. no action). 2. Industry could prepare a "reasonable" EIR, including all of the pertinent data currently on hand. After considerable discussion of this situation, a motion was made to the effect that the PVC Safety Group favor supporting the second alternative with immediate steps being taken to prepare the EIR. It was further recommended that financial support be given to this activity with strong effort being made to obtain contributions from other interest groups on a fair share basis, but that such support should not delay immediate action on the EIR. This motion was unanimously supported by the group. XII.The report of the Nominating Committee was accepted. It was unanimously approved that this slate of officers and members of the Steering Committee be put to a mail ballot to be issued from SPI. (See attached ballot). XIII. The meeting adjourned at 12:45 P.M. Respectfully submitted, Jdhiv R. Lawrence Technical Director JRL:iw end. ucc 008466 RECE/VE0 JUN i mi INDUSTRIES ATTACHMENT #1 PPG INDUSTRIES, INC./ONE GATEWAY CENTER/PITTSBURGH, PENNSYLVANIA 15222 Industrial Chemical Division May 27, 1981 Mr. J. R. Lawrence, Technical Director The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York,New York 10017 Dear Mr. Lawrence: I have reviewed the General Ledger computer printout and supporting invoices for the ten months ended' March 31,. 1981, for. the..SP.I-rPVC:Safety Group and EQCCommittee of the Safety Group and prepared a Summary of Source and Use of Funds for these committees. These statements have been prepared on a cash basis; however, when assessing the Committee's financial position, vou need to take into account services incurred, but not billed. As of the end of March, tne PVC Safety Group had a deficit of $6,147.33 plus $32,775.85 in unpaid bills for Public Relations, Legal Services, and Consultants for February and March 1981. In addition to a Summary of Source and Use of Funds for the first ten months, I have also estimated that we will need to assess members an additional $96,000 to cover all expenditures incurred for the year ended May 31, 1981. Details of this calculation are attached. Very truly yours. 'i EBP:paw E. B. Palmer Industrial Chemical Division CC: G. J. Lazarchik Treasurer, PVC Safety Group Attachments UCC 008467 SCHEDULE I SPI - PVC SAFETY GROUP SOURCE AND USE OF FUNDS - CASH BASIS FOR TEN MONTHS ENDED MARCH 31, 1981 SOURCE Funds Available June 1, 1980 Balance PVC Safety Group Balance EDC Committee $ 51,310.81 (1,823.21) Net Carry-Over From Prior Years Assessment Income 1980/1981 Sale of Literature Total Funds Available USE Legal Services $215,831.54 Public Relations 37,245.33 PVC Computerized Bibliography Temporary Employees 41,318.00 186.90 Postage, Printing, Mailing 437.05 Travel Expenses 1,917.69 Telephone and Telegraph Total Expenses Deficit at March 31, 1981 (See Mote) 588.97 $ 49,487.60 241,737.50 152.50 $ 291,377.60 297,525.48 $ (6,147.88) The following bills for services rendered in February and March were not paid as of March 31, 1981 and, therefore, were excluded from the above schedule: February March Hill and Knowlton - Public Relations Hill and Knowlton - Public Relations $ 2,966.26 5,818.92 Keller and Heckman - Legal Services 18,113.67 Daniel P. Boyd - Consultants Total 5,877.00 $ 32,775.85 UCC 008468 SCHEDULE II SPI - PVC SAFETY GROUP EDC COMMITTEE SOURCE AND USE OF FUNDS - CASH BASIS FOR TEN MONTHS ENDED MARCH 3V, 1981 SOURCE Funds Available June 1, 1980 Deficit Carry-Over From Prior Years Assessments 1930/1981 Total Funds Available ($1,823.21) _______ -Q- USE Legal Services $1,907.38 Telephone and Telegraph 8.56 Total Expenses Deficit Balance March 31, 1981 ($1,823.21) 1,915.94 ($3,739.15) NOTE: The EDC Committee continues to show a deficit balance. The PVC Safety group funds have been used to pay EDC Committee bills. ucc 008469 SCHEDULE i 11 SPI - PVC SAFETY GROUP ASSESSMENTS - 1980/1981 AIR PRODUCTS AND CHEMICALS B. F. GOODRICH CHEMICAL DIVISION BORDEN CHEMICAL CORPORATION CONTINENTAL OIL COMPANY DIAMONO SHAMROCK CHEMICAL COMPANY DOW CHEMICAL U.S.A. ETHYL CORPORATION -FIRESTONE PLASTICS COMPANY GENERAL TIRE AND RUBBER COMPANY GOODYEAR TIRE AND RUBBER COMPANY GREAT AMERICAN CHEMICAL COMPANY HOOKER CHEMICAL CORPORATION ICI .AMERICAS, INC:. . . PANTASOTE PPG INDUSTRIES, INC. SHELL CHEMICAL COMPANY INTECH, INC. STAUFFER CHEMICAL COMPANY TENNECO CHEMICALS UNION CARBIDE CORPORATION 'JNIROYAL CHEMICAL COMPANY Total Assessed ' (1) Less Shintech, Inc. (resigned membership in SPI) Total Received Through 3/31/81 (2) Now part of Hooker Chemical First Assessment Second Assessment $ 3,100.00 20.375.00 8.187.50 10.775.00 14.212.50 17.750.00 4.225.00 5.337.50 950.00 900.00 600.00 1.512.50 2.587.50 1.162.50 3.450.00 13.262.50 2.837.50 (1) 4.612.50 6.462.50 1.512.50 1.187.50 $ 125,000.00 2.837.50 $ 122,162.50 $ 3,100.00 20.375.00 8.187.50 10.775.00 14.212.50 17.750.00 4.225.00 N/A (2) 950.00 900.00 600.00 6.850.00 N/A (3) 1,162.50 3.450.00 13.262.50 4.612.50 6.462.50 1.512.50 1.187.50 $ 119,575.00 $ 119,575.00 (3) Discontinued production in U.S. - No longer part of Group IJCC 008470 SCHEDULE IV SPI - PVC SAFETY GROUP ESTIMATE OF EXPENDITURES FOR THE YEAR JUNE 1, 1980 TO MAY 31, 1981 Expenses for First Ten Months Ended March 31, 1981 on a Cash Basis Legal Services Public Relations PVC Bib!iography Travel, Postage, Telephone, etc. Total on a Cash Basis Plus February and March Bills for Public Relations, Legal Services and Consultants not paid as of March 31, 1981 Estimated First Ten Months Expenses on an Accrual Basis (M $) $ 216 37 41 ____3 297 33 $ 330 Estimate for April and May 1981 Legal Public Relations PVC Bibliography Travel, Postage, Telephone, etc. First 10 Months $ 234 46 47 3 $ 330 Estimate for April & May 1981 $ 47 9 0 (Project Completed _____ 1_ $ 57 Estimated Additional Assessment Needed to Meet Current Year Expenditures . (M $) Deficit as of March 31, 1981 - See Schedule I $6 Plus Expenses for February and March Incurred, But Not Paid Plus Estimate for April and May Expenses 33 57 Estimated Additional Assessment Needed to Cover 1980/1981 Expend.$ 96 1JCC 008471 ATTACHMENT it 2 May 28, 1981 REPORT OF ACTIVITIES ,,n - MANUFACTURING technology committee Aprii 9, 1981 (0830) April 9, 1981 (1300) May 5, 1981 (1000) A meeting of this Committee was held at the Ramada Inn, Durham, N.C. to consider the various responses and strategies for the meeting in the afternoon with EPA and TRW represen tatives to discuss the TRW report. A page-by-page review was made of the TRW report. The committee met with TRW and EPA personnel. It was evident from the introductory remarks by Jack Farmer and Don Gonuwin that the decision had already been made to proceed with Phase II of the review of the VC standard, we promised to get the Committee's remarks to the EPA by May 12, 1980. The Committee met in Columbus, Ohio to prepare our written comments to tire TRW report. Stress was placed on the fact that - 1. Based on Executive Order i2291, EPA does have a mandate to review the VC standard, 2. Any substantive changes must be based on health effects, 3. Errors in the report, and finally, 4. Some procedural changes may be desired in the present standard. A copy of our submission to EPA on May 12, 1981 has been distributed to all member companies. I wish to thank the following companies for their written comments to the Committee on the the TRW report: Air Products and Chemical Company Borden, Inc. Diamond Shamrock Corporation General Tire & Rubber Company R. F. Goodrich Company Hooker Chemicals fi. Plastics Corporation Stauffer Chemical Company Tenneco Chemical, Inc. Union Carbide Corporation, and assure them that their comments were considered in our deliberation. Thank 'T'-dUsA- Robert WTiaundrie, Chairman Manufacturing Technology Committee xd UCC 008472 Attachment //3 May 26, 1931 MEMORANDUM TO: PVC Safety Group FROM: Robert B. Downey Chairman, Communications Committee SUBJECT: Communications Committee Report The following is a summary of recent and ongoing projects of the Communications Committee. The Committee recently completed the first draft of a layman's summary of the w.A. Crosbie literature survey on the physiological effects of fire exposure, past and present, for use in various public relations situations, The Committee does not consider it necessary to have a PR representative attend the June 9-11 National Toxicology Program open symposium on phthalate esters; however. Hill and Knowlton's Washington office will be on alert to lend a hand, should the symposium generate any media interest- The Committee will be preparing, in time for the June 9-11 symposium, a one-page statement summarizing SPI's position on the phthalate ester situation. Emphasis will be on correcting the impression created by the Smith, Barney bulletin of April 15 that a large percentage of the PVC market is in jeopardy because of anticipated government action on DEHA and DEHP.' The Committee is following closely the activities of the PVC Fire Safety Committee in anticipation that the Fire Safety Committee's efforts to develop answers to basic questions regarding PVC and fire will provide much needed ammunition for the Communications Committee in its efforts to correct negative publicity on this issue. The Communications Committee is coordinating its activities on fire with the SPI-PVC Public Relations Committee. Among projects being jointly discussed is a test editorial back ground briefing tour aimed at educating the media on the behavior of plastics in fires. ucc 008473 The Committee has been following closely developments in California regarding the use of plastic, including PVC, pipe in housing. Accusations of DEHP water con tamination from polybutylene pipe may create, through misunderstanding, similar accusations against PVC that may require public relations action. Both the California and Smith,Barney situations are scheduled to be the subject of articles in Business Week and Chemical Week. The Committee, through SPI staff, has been working to correct in advance any possible misstatements in these articles. The Committee has studied the various scenarios of the Alternatives Committee and is prepared to assist, as appropriate, in implementing those scenarios, when and if necessary. ucc 008474 Beveridge & Diamond Attachment #5 PVC Safety Group May 28, 1981 Washington, D. C. Draft Agenda; EPA's National Emission Standard for Vinyl Chloride I. Background A. 1977 Proposed Amendments B. 1.979 Proposed Airborne Carcinogen Policy C. Relief Valve Discharge Litigation D. SPI Request for Rescission of Standard E. Revisions to Standard 1. TRW Study a. Work plan b. Plant visits .2 SPI response to TRW draft report a. Manufacturing Technology Committee - April 9 b. EPA (OAQPS) & TRW - April 9 c. Alternatives Committee - April 20 d. Comments on TRW report Recent activities a. Radian report b. EPA cost estimates c. 1977 proposed amendments d. ANPR e. CAG plans uce 008475 Beveridge & Diamond 2- - H. Other 1. Noncompliance penalty ($ 120) Litigation 2. NESHAP general provisions II. Action Alternatives A. Possible Goals 1. Withdrawal of 1977 Amendments 2. Revision of existing Standard a. Manufacturing Technology Committee . Emergency releases . Malfunctions . Bubble concept . Reporting/Recordkeeping exceptions . averaging periods (ROL, stripping) . Leak detection ' . Other . ..'"v b. EPA ANPR/TRW study 3 . Rescission of existing Standard 4. Clean Air Act amendments 5. . Other B. Possible Positions 1. Technological 2. Health 3. Financial UCC 008476 Beveridge & Diamond -3- 4. Legal 5. Other C. Possible Approaches 1. EPA a. OAQPS b. OGC c. Enforcement d. Administrator/Assistant Administrator 2. OMB 3. Vice Presidential Task Force 4. Congress 5. Other D. Possible Strategies 1. Do nothing 2. Pursue compromise on amendments 3* Pursue desired amendments, but oppose, tightening of standard 4. Pursue rescission of Standard 5. Legislative action E. Recommendations UCC 008477