Document jyoOm34ZV5BMjoabY042BED8N

(L&/&& A Division of The Society of The Plastics Industry, Inc. November 27, 1990 Mr. Ladd Smith Occidental Chemical Co. 360 Rainbow Boulevard South Niagara Falls, NY 14302 Dear Ladd: As follow up to our conversation this morning on the upcoming hearings of the California Air Resources Board on the listing of vinyl chloride as an air contaminant, enclosed is the material forwarded on November 5 to members of the VI Health, Safety & Environment Committee. If you would also like the background , documents, let me know. If after reviewing this information you believe that the Vinyl Institute should plan on submitting comments, let me know. The time is growing short for preparing comments and I would need some assistance in their preparation. Since I spoke with you earlier, Frank Borrelli (Chairman of the VI Health, Safety & Environment Committee) and I have spoken and are in the process of making additional follow up calls on my November 5 memo. It was nice talking with you again. Sincerely, CC: J. Coburn F. Borrelli, Georgia Gulf Meredith N. Scheck Assistant Director SPI-05562 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 Fax # (201) 890-7029 \Wiyt Institute .A OMa&rat The Sooty ot The PiesocrIndustry Inc September 8, 1989 Mr. Robert" Barham?- Chief. Toxic. Air Contaminant: Identification:- Branch: Air Resources- Board Attn: Vinyl Chloride 1102 Q Street Sacramento, California- 95812 Re: Draft Report on vinvl chloride Dear Mr*. Barham. On August 29th, the Vinyl Institute* received the preliminary draft report on vinyl chloride dated July 1989 being prepared by the California Air Resources Board (CARB). There has been, therefore, a limited amount of time for our membership to thoroughly review the documents prior to the comment, deadline. Nevertheless, after reviewing the document, there are at least two areas of discussion that are inadequately treated in the California Air Resources Board (CARB) document. Therefore, most of the comments will be spent on those two areas. They are the phar macokinetic knowledge of vinyl chloride in the risk assessment approach and a total inadequate treatment of the large number of epidemiology studies in the published literature. These are very concisely dismissed by the Department of Health Services (DKS) as being unacceptable to be used in the risk assessment process forregulatory purposes. * The Vinyl Institute is an operating division of the society of the Plastics Industry, Inc. Its members include Air Products and Chemicals, Borden Chemicals & Plastics, Certain- Teed Corporation, Dow Chemical USA, BFGoodrich company, Georgia Gulf Corporation, Occidental Chemical Corporation, PPG Industries, Shintech Inc., and Vista Chemical Company. Together, these companies account for more than 80% of the. domestic production of both vinyl chloride and polyvinyl chloride. 000GG6 SPI-05563 Wayne Interchange Plaza II * 755 Route 46 West Wayne, NJ 07470 (201) 890-9299