Document jNzm4XRgy5Nvb77gd9MdZ50xN
January 12, 1977
Mr. William J. Driver President Manufacturing Chenista Association, Inc. 1825 Connecticut Avenue, H. W. Washington, D.C. 20009 Dear Bill: Recently 1 saw a clipping from the Washington Star where you consented on PVC vith the following statement: "PVC is contained In so many things. And It was on the market for years bbefore the harmful effects were found." Now, I fully recognise that that may not even be an approximation of what you actually told the reporter. On the other hand, that statement did prompt me to suggest that In the future you refer to vinyl chloride as the bad actor. PVC Itself Is In no way harmful to anyone. I know what you meant, and I even agree with what you meant. The problem, of courae, la the continuing general lack of understanding about the kind of toxicity problems faced by the PVC produeere because of vinyl chloride. To this end, I believe you would find interesting the enclosed brochure prepared by the VCM/PVC Producers to help reporters understand. I hops our paths cross soon.
Cordially,
RLE: sms ENCL. cc: A1 Clark
Nick Nuechterleln John Lawrence
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The Society of the Plastics Industry, Inc.
355 Lexmgtcn Ave'-r New Vqtk. New Ycr-\ ' COi 7 (212)573 9400
Ralph L. Harding, Jr. President
TO: PUBLIC AFFAIRS COMMITTEE SPI RESPONSE TO OSHA
December 1, 1977
We need to bring you up to speed now on the proposed OSHA anti-cancer regulations because there is much to be done directly on behalf of SPI's members.
As background for next Tuesday's discussion, enclosed is a representative cross-section of information received to date plus some SPI correspondence. Bud Lundgaard, John Lawrence and I will try to give you a fuller report verbally. Earlier John sent you a copy of the Snell questionnaire. Not enclosed but available is the full text of the OSHA proposal:
"Identification, Classification, and Regulation of Toxic Substances Posing A Potential Carcinogenic Risk" - Federal Register Volume 42 No. 192, Tuesday, October 4, Pages 54146 - 54195.
In capsule form here are some key points:
1. Timetable - OSHA has now responded in part to Industry requests by moving back the timetable as follows:
January 30 - all industry statements and proposed testimony
March 15 - OSHA's testimony available to us
April 4
- Hearings commence (expected to last for several weeks)
2. American Industrial Health Council - Formed by the Chemical Industry as an ad-hoc group to develop uad coordinate the industry's response. Chaired by Paul Oreffice, President - Dow U.S.A. Their original request for $25,000 each sent to 40 companies has already raised $800,000. Nine sub-committees: Alternatives, Scientific, Legal, Economics, International Liaison, Association Liaison, Labor, Public Affairs, Public Relations.
3. Role of AIHC - Mr. Oreffice has stated that the AIHC will function as the "arsenal" (my word), providing information and assistance, as well as the coordinating body. He wants a "cast of thousands" (his words) to be ready to testify - every company and every association'that1s willing.
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This is a key point: AIHC will not do the Job for the industry; it vill help each of us do our own thing.
4. Comnunications - In their necessary first pre-occupation with preparing responses to OSHA (original deadline December 8), AIHC has not had time to spend on developing any kind of conmunications plan - either internal or external. I had hoped by now to be able to send you their first background bulletin, reporting on their activities to date - there is none. Incidentally, at this point, the chemical industry's leading FR and PA specialists have not been brought together and asked for their collective recomaendations.
5. Strategy - As of now, there is no basic strategy being developed for all of the FR and FA activities needed in support of the direct response to OSHA. Apparently, there is not enough perception yet that all of these "indirect" activities may be at least as Important as the direct preparations for the OSHA hearing-circus in April. Unless (and that's a key word) these considerations receive proper attention, SPI may have to go our own way in order to bail our processors out as much as possible.
6. SPI Role in Support of AIHC - SPI members are well represented (Indirectly) on the AIHC Steering Committee. Keith McKennon of Dow, member of the PAC PR Committee, is the key staff man for Mr. Orefflee in this endeavor. We have very high regard for Ron Lang of the Synthetic Organic Chemical Manufacturers Association. In addition, we have volunteered to provide staff support for the International Liaison and the Public Affairs sub-connittees.
7. SPI's Role On its Own - Whether as part of AIHC or separately, we need to develop our own case and marshall our own witnesses. We also need to develop our own communications strategy and our plans to work with our support system. The question is: do we lock into AIHC or do we pull back and salvage what we can for our own membership? My answer goes back to #5 - "Unless...."
8. PAC's Role - Chairman Reed Est ibrook has asked the following to be part of an initial OSHA task force: Messrs. Lundgaard, Toohy, Malone, Schoen, Hidding, DeMatteo. I've named John Lawrence as the Staff Issue Manager, to be assisted by Messrs. Nuspllger, Sherman, Titus, Hadley (Keller and Heckman), Hearle (Hill and Knowlton) and Harding. This group will meet on Tuesday after the PAC meeting adjourns. Anybody else who wants to stay on is welcome.
9. Decisions - The background will be provided during the regular PAC meeting. The second meeting will be needed for agreement on SPI's strategy - with AIHC and for ourselves. Among the questions:
a. How should we be organized: Task Force - Sub-Committees - Staff?
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