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SURVEY OF CHEMICAL COMPANY ACTIVITIES TO REDUCE UNREASONABLE RISK CHEMICAL MANUFACTURERS ASSOCIATION 2501 M Street, N.W. Washington, D.C. 20037 PURPOSE; To survey the chemical industry's commitment to reducing unreasonable risk to health and the environment. BENEFIT; To demonstrate tz policy makers and the general public the degree to which the chemical industry is ensuring the safety of chemicals. Please return this survey form by November 30, 1982. Thank you for participating in this important effort. CMA EC-10/4/82 CMA 064630 SURVEY OF CHEMICAL COMPANY ACTIVITIES TO REDUCE UNREASONABLE RISK The U.S. chemical industry needs information to demonstrate its commitment to controlling and reducing unreasonable risk to health and the environment. This is a survey to identify that information. The results are intended to: . present the U.S. chemical industry's efforts to reduce unreasonable risk for the TSCA reauthorization hearings; . support the regulatory positions of the chemical industry; . provide performance and compliance documentation for the public; and . provide feedback to participating companies on the industry's effort to control and reduce chemical risks. Instructions for Completing the Questionnaire This is a survey of the U.S. chemical industry's activities to reduce unreasonable risk in calendar year 1981. For the purposes of this survey, the industry is defined as all domes tic sales plus domestic based exports of products in SIC code 28 {chemicals and allied products), excluding 283 (drugs). ^ This definition must be used in completing the questionnaire for your U.S. chemical business, unless specific requests are made for other information. The questionnaire contains five major sections, addressing: I. General Company Information; II. Chemical Hazard Assessment; III. Chemical Hazard Communication; IV. Chemical Hazard Control; and V. Environmental Control Costs. Each section contains three to eight subsections with specific instructions for completing each question. The questionnaire is printed so that the sections can be separated and distribu ted to appropriate personnel for completion. If you do sepa rate the questionnaire, please copy these instructions and send them with the portion(s) of the questionnaire being distributed The questionnaire is designed to minimize the effort required to respond. Therefore informed estimates are acceptable where exact data is not available, we are not requesting that major internal studies be undertaken to complete the questionnaire. If you have any problems in completing the questionnaire, please call Mr. Deems Buell of Peat, Marwick, Mitchell & Co. at (202) 223-9525. Confidentiality of Questionnaire Responses Completing the questionnaire requires the disclosure of business information that many companies will consider confidential. To assure that responses are maintained confidentially during and after the survey, CMA is using Peat, Marwick, Mitchell & Co., a major public accounting and management consulting firm, to conduct the survey and evaluate the survey results. The information released at the conclusion of the survey will be in aggregated form to protect the identity of individual respondents. To provide additional assurance to your company, a confidentiality agreement is enclosed for your company to enter into with Peat, Marwick, Mitchell & Co. Your response will be maintained as confidential even if your company does not enter into this agreement. Responding to the Survey All participating companies must return their completed questionnaire by November 30, 1982. To limit follow up, a postcard is enclosed for your company to complete and return as soon as a decision has been made about participating in the survey. A return envelope is enclosed for submitting your completed questionnaire. If you do not use this envelope, please mark your return envelope "CONFIDENTIAL" and mail it to: Peat, Marwick, Mitchell & Co. 1990 K Street, N.W. Washington, D.C. 20006 ATTN: Mr. Deems Buell CMA0&4632 TABLE OF CONTENTS / CURRENT ACTIVITIES TO REDUCE UNREASONABLE RISK I. GENERAL COMPANY INFORMATION A. Company Information B. Management Attention to Health and Environmental Matters C. Organization II. CHEMICAL HAZARD ASSESSMENT A. Chemical Hazard Assessment Review B Testing C. TSCA Premanufacture Notification (PMN) D. TSCA 8(e) Reports III. HAZARD COMMUNICATION A. MSDS B. Labels C. Information Systems D. Training IV. HAZARD CONTROL A. Listings of Chemicals B. industrial Hygiene Program C. Health Effects Monitoring D. Emergency Response E. Internal Health/Environmental Compliance Audits/Reviews F. Transportation G. Waste Disposal Procedures V. Environmental Control Costs A. Capital Investment B. Operation and Maintenance (O&M) Costs C. Staffing PAGE 1 1 3 4 5 5 6 8 9 11 11 13 13 14 15 15 16 16 . 17 18 19 20 21 21 22 22 CMA 064633 SECTION I. GENERAL COMPANY INFORMATION This section will identify general information about your company. The results from this section of the questionnaire will establish the baseline for analyzing all of your survey responses. I. A. Company information Specific company information is essential to the survey for standardizing responses. The questions below request information about your entire company's activities (world-wide) and your company's chemical business (world-wide and U.S.). For this survey, a chemical business is defined by products in SIC code 28, excluding 283, and a U.S. chemical business is defined as domestic sales plus domestic based exports of products in SIC code 28, excluding 283. Your responses to the remainder of the questionnaire must be based on your U.S. chemical business, unless a question specifically states otherwise. Supporting functions provided by other areas of your company should be considered to be a part of your U.S. chemical business on a proportional basis when possible. A.1 Provide the following information about your company's activities for the 1981 calendar year. 1.1 Total company sales (world-wide) in millions of dollars $ {19814s") 1.2 Total company employment (world wide) at calendar year end 1.3 Total world-wide chemical/product sales (all sales of products in SIC Code 28, exluding 283) in millions of dollars 4 (19814s) 1.4 Total number of employees at calendar year end associated with your world wide chemical/product sales (ref. question 1.3) 1 CMA 064634 1.5 Total U.S. chemical/product sales (domestic sales plus domestic based exports of products in SIC code 28, excluding 283) in millions of dollars $ 7l98l$iT 1.6 Total number of employees at calendar year end associated with your U.S. chemical/product sales (ref. question 1.5) ________ 1.7 Total number of chemical products (count all product distinctions except package size as individual products) associated with your U.S. chemical/product sales (ref. question 1.5) ________ 1.8 Identify the major products associated with your 1981 U.S. chemical/product sales (ref. question 1.5) by checking the appropriate SIC codes below. (Consider major chemical product categories to represent at least 10% of your total U.S. chemical/product sales.) SIC Code Title 281 Industrial Inorganic Chemicals 282 Plastics and Synthetics 284 Toilet Preparations 265 Paints and Allied Products 286 Industrial Organic Chemicals 287 Agricultural Chemicals 289 Miscellaneous Chemical Products A.2 What is your company's name? A.3 Who is your company's principal contact in completing the questionnaire, their job title, and telephone number? Name Job Title Telephone Number"" 2 CMA 064635 I. B. Management Attention to Health and Environmental Hatters The following questions will determine the attention that management devotes to health and environmental matters. ' For each question/ check (V) all appropriate answers or provide the requested information. B.l What is the highest level in your company that is routinely involved in health and environmental matters concerning your U.S. chemical business? (check appropriate response) BOARD OF DIRECTORS PRESIDENT CORPORATE VICE-PRESIDENT VICE-PRESIDENT DEPARTMENT HEAD OTHER (SPECIFY): ______ ______ ______ ______ ______ B.2 Does your company have formal policies that address the following health and environmental concerns and are these policies publicly available? (check appropriate responses) INTERNAL PUBLICLY POLICY AVAILABLE YES NO YES NO MEDICAL PRODUCT SAFETY WORKER SAFETY TRANSPORTATION HAZARDOUS WASTES ENVIRONMENT DISASTER PLANS OTHER (SPECIFY) ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ ____ __ __ __ __ __ __ B.3 Please provide any specific examples that demonstrate your management's approach for dealing with health and environmental matters. 3 CMA 064636 C. Organization The following questions will find how companies have organized their O.S. chemical business to carry out their environmental and health policies. For each question, check (V) all appropriate answers or provide the requested information. C.1 Do you have one or more groups whose sole function is dealing with health or environmental matters? TBS _______NO C.2 Use the matrix below to provide a count of all the health/ environmental specialists (internal personnel plus outside consultants) that your U.S. chemical business used in calendar year 1981. Present all specialists on an equi valent full-time basis according to their most appropriate health/environmental function. Do not double count. (In completing the matrix, product safety is defined as a function that includes coordination and development of hazard communication and regulatory compliance programs making use of other health information. Worker safety is defined as a function that includes occuptional safety anc employee health monitoring. Health is defined as a function that includes human, animal, and environmental research and assessment.) socialists FUNCTIONS Ftaduot Srtwy HWW VmtWUf Us* (EmJHaoithi LaMing Air Pollution Control Wear pollution Control H- s'zazwrgSoomuwi Wrt ot DtJwr's (SoMtyi 4 CMA 064637 SECTION II. CHEMICAL HAZARD ASSESSMENT in this section we would like to know what your company is doing to identify chemical hazards to health and the environ ment within your U.S. chemical business. Hazard assessment is sometimes called loss prevention or product safety review; it involves .the determination of a hazard's presence or absence through the review of available data such as toxicity, environ mental fate, and physical/chemical properties to evaluate the potential for harm or need for additional information. II. A. Chemical Hazard Assessment Review We need to know what your company is doing to assess chemical hazards. For each question, check W) all appropriate answers or provide the requested information. A.1 Do you have a program for chemical hazard assessment? YES ____ NO If the answer is NO, skip to question II.B.l. ` A.2 About what percent of the time do you perform chemical hazard assessments when you have; New Products ______ % New Processes ______ % Any FormulationChanges ________ % A.3 Which of the following events typically trigger a chemical hazard assessment for existing products or existing processes. (Check all appropriate answers) Routine ProcessChange New Data New Product Use Employee concern Consumer concern New regulatory requirements _________ ___ _________ _________ _________ _________ _________ Other (Specify) 5 CMA 064638 A.4 What technical specialties were involved in your chemical hazard assessment program during 1981? (check all appropriate answers.) Specialties Internal Outside Personnel Consultants TOXICOLOGY LEGAL REGULATORY ENGINEERING ENVIRONMENTAL SAFETY ANALYTICAL (CHEMIST) MEDICAL INDUSTRIAL HYGIENE R & D/TECHNICAL PRODUCTION SPECIFY OTHERS: ___________ ___________ ___________ ___________ __ ________ ___________ ___________ ___________ ___________ ___________ ___________ _____________ _____________ _ _____________ _____________ _____________ . _____________ ____________ _ _____________ _____________ _____________ A.5 Do you have a chemical hazard assessment committee(s}? _____ Yes _______ No 5.1 If yes, in approximately what year was your committee(s) started? ______ A.6 Does your company conduct formal environmental health and safety reviews for the design of new plants or equipment projects? YES NO B. Testing Toxicity testing can be helpful to determine whether a substance could pose a hazard. This testing is defined to include animal, environmental, epidemiological, clinical, toxicological, etc. For each question, check (%/) all appropriate answers or provide the requested information. B.l Does your company have toxicity tests performed to evaluate the health effects or environmental effects of chemicals? YES _______NO If the answer is NO, skip to question II.C.l. 6 CMA 064639 1.1 In approximately what year did your company begin performing toxicity tests? B.2 Toxicity testing programs often overlap between testing in support of a company's U.S. chemical business and testing in support of a company's other activities. To simplify estimating U.S. chemical business toxicity testing efforts, provide the following information on the entire toxicity testing program(s) within your company in 1981 that provides all support for your U.S. chemical business. Include both human health effects and environmental effects testing. 2.1 Equivalent full-time technical staff directly involved in the toxicity testing program. ____________ 2.2 Number of new substances/products tested (don't count individual tests) ____________ 2.3 Number of existing substances/products tested (don't count individual tests) ____________ 2.4 Annual operating expense of in-house toxicity testing $_______ (1981 is") 2.5 Annual expense of contracted toxicity testing $ (1981 $s) 2.6 Annual expense of toxicity testing performed in cooperative research programs ' $_______ (1981 is) B.3 Based on your answer to B.2, estimate the percentage of total testing expense that was attributable to your U.S. chemical business. ______ % B.4 Estimate the replacement value of your toxicity testing facilities that were in place during 1981 for the toxicity testing program described in question B.2. $ (1981 $s) 7 CMA 064640 B.5 Do you have examples which demonstrate changes in your testing program during the past ten years? (Consider planning, protocols, auditing, recordkeeping, types of studies, and reporting.) . C. TSCA Premanufacture Notification (PMN) The impact of PMN may be different depending on company size and the products involved. The questions below will indicate the factors that affect your U.s. chemical business. For each question, check U/) all appropriate answers or provide the requested information. C.l Do you have a procedure for determining that a PMN is required? YES ______ NO C.2 Have you declined to manufacture any new chemicals because of the time or cost of PMN compliance? YES ______ NO If yes, how many due to: Time Cost Please explain C.3 How many PMN's did your company submit in: 1979________ 1980________ 1981 If none, skip to question II.D.l. C.4 How many of your PMN substances, reported in C.3, have actually been or are likely to be commercialized? _____ 8 064641 II. D. TSCA 8(e) Reports An 8(e) report informs EPA that a chemical may present a substantial risk to health or the environment. For each question, check (</} all appropriate answers or provide the requested information. D.l Do you have a company procedure in place for considering 8(e) reports? YES ______ NO If the answer is NO, skip to question II.D.4. 1.1 What are the sources of information that initiate an 8(e) review? (Check all appropriate answers) TOXICOLOGY RESEARCH PRODUCTION (EMPLOYEES) CUSTOMER/CONSUMER REPORT DATA FROM SUPPLIERS OTHER (SPECIFY) ______ ______ ______ ______ ______ 1.2 Approximately how many people are normally involved , in your company's 8(e) review procedure? D.2 Has your company filed at least one 8(e) report? YES ______ NO 2.1 If yes, whom do you advise of your 8(e) reports? (Check all appropriate answers) CUSTOMERS CO-PRODUCERS . EMPLOYEES OTHERS (SPECIFY) ______ ______ ______ 9 CMA 064642 D.3 Has the information provided on 8(e) reports prepared by your company or any other company been used for your Material Safety Data Sheets (MSDS's)? (Check appropriate answers) Always Sometimes Never Your own 8(e) reports Other 8(e) reports ________ ____________ _ ________ ____________ ~~ ~ 3.1 Has this information been used in your industrial hygiene practices? (Check appropriate answers) Always Sometimes Never Your own 8(e) reports Other 8(e) reports CM*0646A3 10 SECTION III. HAZARD COMMUNICATI0N This section will identify what chemical companies are doing to inform employees and customers about chemical hazards. HI. A. MSDS The Material Safety Data Sheet (MSDS) is a source of information about a chemical. This question will deter mine how extensively they are used to transmit informa tion. For each question, check t>/J all appropriate answers or provide the requested information. A.1 What systems do you use to communicate information about chemical products. (Check all appropriate answers} MSDS LABELS PRODUCT BULLETIN LETTERS TRAINING POISON CONTROL CENTERS OTHER (SPECIFY) ______ ______ ______ _______ _______ (If you do not use MSDSs, skip to question III.B.l) A.2 Do you send MSDSs to your customers? (Check all appropriate answers) UPON THE FIRST SHIPMENT ONLY UPON EVERY SHIPMENT ON REQUEST WHEN UPDATED OTHER (SPECIFY) ______ ______ ______ ______ 11 064644 A.3 Approximately what percent of your purchased chemicals and chemical products were covered by MSDSs in 1981? Purchased Chemicals _____ % Chemical Products _____ % A.4 is the information provided on your MSDS more, the same, or less then that called for on OSHA Form 20? More The Same Less ______ ______ ___ A.5 How often do you review and update your MSDSs? ANNUALLY AS NEW INFORMATION BECOMES AVAILABLE OTHER (SPECIFY). ______ ______ A.6 Do you maintain files of MSDS's? YES NO If the answer is NO, skip to question III.B.l 6.1 Are these MSDS's available to company personnel? YES NO 6.2 Are these MSDS'S available to the public? YES NO < 12 CMA 064645 III. B Labels Labeling provides information to customers and employees. The following questions will indicate the type of information transmitted and the proportion of chemical products for which such information is provided. For this question, check { y') all appropriate answers. B.l Typically, which of the following pieces of information appeared on your chemical product labels in 1981, PRODUCT OR TRADE NAME COMMON NAME CODE NUMBER CHEMICAL NAME NAME OF MANUFACTURER CAS NUMBER HAZARD IDENTIFICATION PRECAUTIONS FOR USE EMERGENCY PROCEDURES CONTAINER DISPOSAL COMPANY ADDRESS TELEPHONE CONTACT OTHER (specify) _____ _____ _____ _____ _____ _____ _____ _____ _____ _____ _____ _____ III. C. Information Systems Information systems identify, communicate, and record information on chemicals. For each question, check (v') all appropriate answers. C.l Do you formally maintain the following information at either a corporate, divisional or local level? YES NO LISTS OF CHEMICALS USED LISTS OF CHEMICALS PRODUCED WORK HISTORY WORK SITE EXPOSURES MEDICAL RECORDS SIGNIFICANT ADVERSE EFFECTS CUSTOMER COMPLAINTS EMPLOYEE COMPLAINTS 13 CMA 064646 C.2 Do you have procedures established to respond to health and safety questions raised by; CUSTOMERS YES NO EMPLOYEES YES NO III. D. Training Training frequently involves communicating infor mation on chemical hazards and teaches people how to avoid those hazards. We would like to obtain information on the areas in which you train your employees. For this question# check (%/) all appropriate answers. D.l In which areas do your chemical plant employees (hourly and supervisory) receive training? (Check all appropriate answers) Chemical Plant Employees AREAS OF TRAINING HOURLY SUPERVISORY CHEMICAL HAZARDS WORKPLACE SAFETY HANDLING of MATERIALS EMERGENCY RESPONSE OFF THE JOB SAFETY REGULATORY COMPLIANCE OTHER (SPECIFY) 14 CMA 064647 SECTION IV. HAZARD CONTROL This section will identify what chemical companies are doing to control hazards that have been identified. IV. A Listing of Chemicals Lists of chemicals are ready sources of information that management can use to control hazards. The following questions will identify items that are listed and how the information is used. For each question, check V) all appropriate answers or provide the requested information. A.1 Does your company maintain complete lists of the follow ing materials? If yes, approximately when was this practice started? WHEN YES NO STARTED PRODUCTS RAW MATERIALS AND SEG REGATED INTERMEDIATES SOLID WASTES EFFLUENTS EMISSIONS OTHER (SPECIFY) If the answer is NO in each case skip to question IV.B.l A.2 Are internal chemical lists used to: MEET REGULATORY REQUIREMENTS? MAINTAIN INTERNAL CONTROL? RESEARCH HEALTH AND SAFETY? OTHER (SPECIFY) YES ____ ____ ____ NO ___ ___ ___ 15 chfA <eo IV. B. Industrial Hygiene Program Industrial hygiene or similar programs are designed to protect workers from chemical hazards. For each question/ check (/) all appropriate answers or provide the requested information. B.l Do you have an industrial hygiene program or a similar program performing the same functions? YES ______ NO If the answer is NO, skip to question IV.C.l B.2 How many total industrial hygienists and/or trained hygiene technicians were used in your U.S. chemical business in 1981 on. an equivalent full-time basis? B.3 What areas of operation does your industrial hygiene or similar program address? (Check appropriate items.) MANUFACTURING MAINTENANCE INCOMING RAW MATERIALS PROCESSING PACKAGING STORAGE TRANSPORTATION LABORATORY PRODUCT USE DISPOSAL OTHER (SPECIFY) ______ ______ ______ ______ ______ ______ IV. C. Health Effects Monitoring Health effects monitoring provides an early warning of work-related health problems. C.l Does your company perform periodic reviews of their employees* medical histories? (check appropriate answer) ALL EMPLOYEES SELECTED GROUP(S) OF EMPLOYEES (SPECIFY) DOES NOT PERFORM REVIEW 16 CMA 064649 IV. D. Emergency Response The following questions seek to find out the types of emergency response teams that companies maintain and the training that they receive. These teams could include fire brigades, first aid teams, or chemical .spills teams. For each question, check } all appropriate answers or provide the requested information. D.l Does your company have emergency response teams for: YES NO Fire Control First Aid Chemical Spills or Releases Other (Specify) ____ ____ ____ ____ ____ ____ If you do not have emergency response teams for chemical spills or releases, skip to question iv.E.l D.2 Indicate the number of trained emergency response person nel for chemical spills or releases inside and outside of your facilities (emergency site activities and all activities) that your company maintained in the O.S. in 1981. Emergency Site Activities _____ All Emergency Activities _____ D.3 Do your company's emergency response teams respond to outside emergencies not involving your products? YES NO 17 CMA 064650 IV. E. Internal Health/Environmental Compliance Audits/Reviews Internal health/environmental compliance audits/reviews are one means that companies use to ensure that they are following health and environmental policies and regulations. The following questions will determine 'how extensively U.S. chemical companies use this management tool. For each question, check (vO all appropriate answers or provide the requested information. E.l Does your company have an internal health, environmental, or other type of compliance audit program? YES ______ NO If the answer is NO, skip to question IV.F.l E.2 Indicate below which programs you have, the approximate year started, and approximate frequency that each type of audit is conducted on an annual basis. YES Health compliance audits/reviews ____ Environmental compli ance audits/reviews ____ Other (specify) If yes, approx. Frequency NO Year Started Audit is Conducted ____ ___________ _______________________ ____ __________ _______________________ E.3 What skills are represented in conducting and reviewing the audits identified in E.2? (check appropriate answers) Others Specified in E.2 Health Environmental Legal Technical Management Other (specify) 18 CMA 064651 IV. F. Transportation Transportation safety is an important element in reducing the public's risk from chemicals. The following questions seek to determine what your company is doing concerning transportation. For each question, check (yO all appropriate answers. F.l Does your company train its personnel to understand transportation safety regulations and standards? YES NO F.2 Does your company have a transportation procedures manual? ____ YES _____ NO F.3 if you have procedures, are the following items included in the transportation procedures manual? LOADING/UNLOADING HANDLING PACKAGING LABELING PLACARDING INSPECTION SPILL/EMERGENCY OTHER (SPECIFY) YES ______ ______ ______ ______ ______ ______ NO ________ ________ ________ ________ ________ ________ F.4 Does your company provide precautionary information beyond Department of Transportation (DOT) standards for identifying the hazardous nature of chemicals in transit? YES ______ NO F.5 Does your company use: YES NO LABELS PLACARDS WRITTEN INSTRUCTIONS VERBAL INSTRUCTIONS OTHER (SPECIFY) ____ ____ ____ ____ ____ ____ ____ ____ . 19 CMA 064652 SECTION V. ENVIRONMENTAL CONTROL COSTS This section will serve to update the estimated cost to the U.S. chemical industry of end-of-process pollution control. Please provide the following information for your U.S. chemical business, defined as domestic sales plus domestic based exports of products in SIC code 28 (excluding 283). In cases where your pollution control facilities serve company activities beyond your U.S. chemical business, answer the following questions using appropriate estimates of the proportion dedicated to your U.S. chemical business. One source of information for this section may be submittals to the Census Bureau on Form MA-200. For the purposes of the survey, pollution control facilities fall into three major categories; air, water, and solid waste. Use the following definitions of these pollutants to complete Section V. ' Air pollutants are airborne substances including particulates (dust, fly ash, smoke), sulfur oxides, nitrogen oxides, carbon monoxide, hydrocarbons, odors, fluorides, lead and other heavy metals, radioactive and toxic substances. Water pollutants are waterborne substances including phosphate, nitrates(trites), substances that generate chemical or biochemical oxygen demand, solids, acids, bases, heavy metals, radioactive and toxic substances, synthetic organic molecules, harmful microbes, oil, grease, dyes, and heat. Solid waste includes garbage, trash, sewage sludge, dredged spoil, incinerator residue, wrecked or discarded equipment, biological and chemical wastes, radioactive and other toxic ^ materials. Include solid waste produced as a result of air and water pollutant abatement. V. A. Capital Investment Estimate your capital investment in pollution control facilities (original installed cost) during calendar years 1981, 1980, 1979, 1978, and 1977 for end-of-process waste treatment/disposal. (Ranges may be used.) Air Pollution Control Water Pollution Control Solid Waste Disposal 1981 (installed cost) 1980 (installed cost) $ (1981 $'s) $ (1980 S1s) $ (1981 $'s) $ "(1980 $*s) $ "1981 S's) $__________ ___ Tl980 $'s) (Continued to next page) 21 CMA 064653 P.6 Are your company products listed with CHEMTREC? YES ______ NO F.7 Does your company maintain its own transportation emergency hotline? YES ______ NO IV. G, Waste Disposal Procedures We would like to determine how companies handle their chemical wastes. . For the following question, check (v'') the appropriate answers. G.l In recent years, has your company been using proportion ately more, the same, or less of the following waste disposal methods for your chemical wastes? Indicate in the right-hand column if the method has not been used recently. (Check appropriate answers) USE OF MORE RECENT DISPOSAL METHODS METHOD NOT SAME LESS USED RECENTLY RECYCLED STORED ON-SITE STORED OFF-SITE INCINERATED: ON-SITE OFF-SITE LANDFILLED: ON-SITE OFF-SITE OTHER (SPECIFY) j \ ; ; ) 20 CMA 064664 V A. Capital Investment (Con't.) 1979 (installed cost) 1978 (installed cost) 1977 (installed cost) J (1979 9 s) $ (1978 S a) S (1977 9 's) 9 (1979 $'S) $ (1978 S's) 9 (1977 S's) 9 (1979 3 s) $ (1978 3 's) $ (1977 S TS) i i i t V. B. Operation and Maintenance (O&M) Costs , Estimate your 1981, 1980, 1979, 1978, and 1977 annual O&M costs for end-of-process waste treatment/disposal. (Ranges may be used.) j j ` Air Pollution Water Pollution Control _____ Control_____ Solid Waste Disposal 1981 1980 1979 1978 1977 $ (1981 $'s) $ (1980 $'s) $ (1979 $' s) $ (1978 $'s) $ (1977 S's) S (1981 S's) $ (1980 S's) S (1979 S's) S (1978 thtt $ (1977 S's) $ (1981 S's) $ (1980 T's) $ (1979 S's) S (1978 S's) $ (1977 T's! V. C. Staffing ` Estimate the equivalent number of full-time personnel (operations, maintenance, engineering, administration, etc.) dedicated to operating and maintaining your pollution control facilities in 1981, 1979, and 1977 at calendar year end. ' < Air Pollution ____ Control Water Pollution Control Solid Waste Disposal 1981 1979 1977 r CMA EC-10/4/82 22 --T { JCMA 064655 COMMITTEE APPOINTMENTS EXHIBIT I 1. Communications Committee W. L. (Bill) Lafield, Shell Chemical Company - Term ending May 31, 1983 (replacing K. L. Spalding -- same company) 2. State Affairs Special Committee Talbot C. Smith, Pfizer Inc. (replacing Robert C. Ross -- same company K. L. (Ken) Spalding, Shell Chemical Company (replacing w. A. Wood -- same company CMA EC-10/4/82 CMA 064656 EXHIBIT J October , 1982 TO EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES Dear Executive Contact: Investment issues have come to be recognized by both industry and the U.S. Government as a growing problem. Furthermore, the U.S. Government now realizes that investment issues are closely related to trade issues. Accordingly, you are requested to complete the attached questionnaire which seeks your views on these issues. Information obtained from the questionnaire will provide the CMA Inter national Trade Committee with the necessary background to make future decisions on recommendations regarding the United States' foreign investment policies. It will also ,aid Dexter Baker, President of Air Products and Chemicals, Inc., in his role as CMA's representative to the Office of the U.S. Trade Representatives' Investment Policy Advisory Committee. All data received from this questionnaire will be held confidential and will be compiled by CMA staff. Release of any information obtained through this questionnaire will be in an aggregated form and will not disclose the operations of any individual company. Sincerely, Robert A. Roland President Attachment cc: CMA Designated Washington Representatives Designated Trade Contacts of CMA Member Companies INSTRUCTIONS Please complete Parts I, II and III of the attached questionnaire and return to CMA by November 4, 1982. PART I Complete for all foreign investment. Add additional countries as appropriate to your company's operations even if you do not plan to complete Part II for those countries. Each respondent should use its own criteria for assessing whether its investment is slight, moderate or significant. When determining whether investment would have been more in the past, consider both of the following conditions: A. no investment was made because of investment restrictions; B. investment was made, but it would have been greater had it not been for restrictions. PART II Use the appropriate letter code shown in Attachment A. When prioritizing restrictions to foreign investment, please list only one restriction in each column. Note that space has been provided on Attachment A for you to specify additional restrictions.* PART III These statements apply to all foreign investment. Complete this part without regard to any specific country. Any questions should be directed to Jim O'Connor at (202) 887-1130. RETURN PARTS I, II AND III {AND ATTACHMENT A IF APPROPRIATE) BY NOVEMBER 4 TO K. James O'Connor, Jr. Economic Analyst Chemical Manufacturers Association 2501 M Street, NW Washington, D.C. 20037 MExample: If your company feels that the greatest restriction to investment in Argentina is "Location restriction", place the letter "G" in Column 1 on the line for Argentina. If the next greatest restriction to investment is "Feedstock restriction", place the letter "D" in Column 2 on the line for Argentina. Repeat for each country listed. Up to five restrictions to foreign investment may be listed for each country.) -Xr2* -cTCO C C oo B J=3 oOLO -- o ur> 0zo0 ek--g UegJ =E < eOog' aLLUu; UNQJl LQui as: eg J TJ CO </*> L<cC0: 'I--ioc~ --tttooy E oo <eg Cl >> C $- U 4- O S O r- -.- 0 4- UosO-' a> ao j>D ,cO CMA 064659 BUSINESS CONFIDENTIAL PART III - Using the following list, does your company have any suggestions for U.S. law or policy to provide equitable treatment for U.S. companies abroad? (Check as many as appropriate) Allow the President to impose trade or investment restrictions as he deems appropriate against nations that apply onerous investment restrictions against U.S. companies. Call for the 1976 OECD Declaration on International Investment and Multi national Enterprise to be escalated to treaty level. Develop a foreign investment screening mechanism to protect U.S. producers. Extend the General Agreement oh Tariffs and Trade (GATT) to directly address investment related policies. Impose "mirror-image" investment restrictions against nations that dis criminate against U.S.-based investors. Instruct Eximbank to withhold financing for projects linked with investment restrictions. Legislate investment restrictions (local content, etc.) for foreign investors. Negotiate a new GATT treaty covering investment which would initially freeze existing trade distorting investment policies and then progressively roll these back. Negotiate bi-lateral investment treaties with other countries. Withdraw Generalized System of Preferences (GSP) benefits from developing ' countries which impose restrictions on U.S. investors. -Other - . Do nothing because increased U.S. restrictions may jeopardize the huge U.S. overseas investment. CMA 064660 BUSINESS CONFIDENTIAL ATTACHMENT A RESTRICTIONS TO FOREIGN INVESTMENT ----------------Ulse'for Part' II)---------------- A. Employment of local nationals requirements B. Excessive withholding taxes on dividend, royalty and loan interest payments C. Export requirements D. Feedstock restrictions E. Industrial sector restrictions F l art- r,-F 1-->,.-1 ^ p. Jtevt"TM,' G. Location restrictions H. Maximum foreign ownership restrictions J. Minimum capital invested or employment level requirements K. Minimum local content requirements L. Remittance of earnings/repatriation of capital restrictions M. Requirements concerning the introduction of new products and technology N. Restrictions on acquisitions of existing businesses P. Restrictions on management fee payments to U.S. parent Q. Restrictions on royalty payments to U.S. parent *X. *Y. *Z. _____ ^Return this sheet only if additional restrictions to foreign investment are listed. CMA 064661 AGENDA Special Executive Committee Meeting Chemical Manufacturers Association Headquarters November 2, 1982 1, Call To Order 2. Scope of Problem; Status Reports 3. Strategies For Addressing The Problem Discussion to identify the range of strategies which could be pursued without reaching final recommendations. Three basic strategies are all we need (i.e., {1} total opposition; (2) selective opposition; selective embrace; (3) preemption embrace). It's also acceptable to let the strategies range as follows: A. Product Liability 1. No new federal law (Kasten); reliance upon existing state tort law system. 2. Support federal product liability bill (Kasten) and oppose any fund proposals. B. Work Place Exposure 1. `No new federal law (oppose Miller and asbestos bills) and reliance upon existing state tort law system. 2. Support an asbestos only federal compensation fund to relieve immediate pressure of the large number of asbestos claims while protecting- against a broad workplace exposure compensation fund. 3. Support a broad occupational disease fund (Miller) but with appropriate limitations. C. Hazardous Waste Sites 1. No new federal fund but creation of a federal toxic tort. CMA 064662 2 2. Create a federal compensation fund but no federal toxic tort. 3. Accept Stafford's federal compensation fund proposal be fore a more unacceptable proposal is advanced and accept limited changes to tort law system. 4. Develop our own federal compensation fund proposal and/or tort law changes in order to take initiative. 5. No new federal law because such changes have not been shown to be necessary. D. General 1. Develop one federal fund compensation proposal for products, work place exposure, hazardous waste sites and all releases. 2. Oppose everything (except perhaps Kasten) because all the proposals on these issues have gotten too broad in their application and contain open-ended industry funding. 4. Action Time Table 5. Implementing Structure The Executives select their very top people in each of the folowing disciplines: a. Public Affairs (PR and GR) b. Scientific/Technical c. Legal The committee will work in three groups to expand and refine the questions to be answered. Those which can be answered immediately will be; those which cannot will be distributed to our committees. Informational needs will be assigned to appropriate CMA committees for response. (Legal questions to General Counsels Group; Technical and scientific to, as appropriate, CRAC, EMC, OSHC, RISC, etc.; Communications and Government Relations would address "delivery" and "tactics",) Those committee members, with assistance of CMA staff, try to provide answers to the questions or identify what efforts, CMk 064663 3 time frames and resources would be required to obtain the answers. The latter information can be as important as hard answers. For instance, if little data exists regarding the adverse health effects from toxic dumps but the data could be collected in two years, that fact would be relevant to whether, given the potential pressures, we have time to defend ourselves on the basis of a we-don1t-know-the-facts tactic. Once this information is collected, the staff presents it to the special committee or the three groups. At this point, the function of the special committee or the groups is to frame the data in a format they believe could be presented to the Executive Committee (i.e., hard options and strategies). The Executive Committee then has a data base on which to select its primary strategies and tactics. 6. Information Needs Currently Apparent 7. Miscellaneous 8. Adjournment CMA 064664 7