Document mqrx1EE46K2bpRkLrpMg8vn0d

r . . ..,j. .1: r:.:;i*s cmauti'.v *t WILVTAM 1' 1U tjltKSAN! JR KOft;:i;T j, rtrKXAK .*\: v m\c% n' '* i. i;ru. :y 'i i,\ v [iCirt/fiVK-'l W*l.\ ,i b"`u:* ^ - j..r >* y;*skciv . v u.\oj K v ('Ai.or.i: t irAWRts* viluam v,* pron Kr.r_i-r;i; HoO iV* sHtl.l.f. * . V, WA^mNOTUS, r> uoo;io June 18, 1974 SPI Food, Drug end Cosmetic Packaging Materials Committee; General Polyvinyl Chloride Interest Mailing List; Ad Hoc Liquor Bottle Committee; Elastic Pipe Institute (Executive Board); Plastic Bottle Division (Vot' g Representatives); SPI Executive Committee; SFI Public Affairs Committee; \ ; and PVC Producers Committee Ladies and Gentlemen: The usual weekly mailing to keep you up-to-date on the status of activities relating to the vinyl . chlor; -polyvinyl chloride problem was emitted last week fc.cause our time was so completely preempted by preparations for the forthcoming Hearing to be held by the Occupational Safety and Health Administration (OSKA). As you will recall, the notice of the Hearing which is to be held at 9:30 A.M. at the Departmental Auditorium on Constitution Avenue between 12th and 14th Streets, N.W. was included in cur letter to you dated May 24, 1974. The same Hearing notice stated that al those who wished to testify at the Hearing were recui to submit a notice of their intention to appear by June 17, 1974*, Although we were unable to write to you be cause of the nerd'to cbf.in witnesses and help them work towards develop; _nt of their testimony on a "crash" basis, H (-* ASI-pr 0002886 2 a tin'cly Kotico of Intention to Appear w?s filed on behalf of The Society of the Plastics Industry late yesterday aftonic on. v:e are enclosing a copy of the KotiC2 that re filed rhich, v:e hope, v/ill serve to inf err; you roe; acting our line-up cf witnesses and the nature of the presentation to be made by the Society. Although wo cannot be completely definite at this tire, re anticipate, as a result; of special con tact made with OSHA, that the SPI presentation will be the lead-eff testimony as far as industry witnesses are concerned. The Hearing will begin with testimony fromthe Department of Labor, NIOSH, and at least or.e Union official. This will then be follov:ed by the SI'I testi mony which it is hoped will set the stage for presenta tions by a number of the major VC and PVC producers. These will then probably be followed by other interested parties, including a large number of fabricators who have asked for time. It is the present intention of OSHA to keep the Hearing record open for some time, possibly for as much as a month after the oral hearings end, to provide for the inclusion of the maximum amount of information in the record. Consequently, all those who wish to submit statements and have not done so before the Hearing begins will probably still have time to submit statements later. It is our understanding that OSHA will include all statements and letters that it receives as a part of the record in this matter. Of less ir.mediate urgency, but of continuing Significance to us is the role that the Environmental Protection Agency (E?A) is playing with respect to emissions from VC and PVC plants. As many of you knew by this time, Russell Train, EPA Administrator, held a meeting last Tuesday with executives of many of the country's leading VC ana PVC producers. It was hearten:.::: to note that the preliminary EPA findings showed that, "There is no scientific evidence to indicate that these emissions pose an imminent hazard to people living near these plants..." We are enclosing a copy of the full EPA release on this meeting, as well as a reprint of a news paper article based upon Hr. Train's statement. ASI-PR 0002887 V 3 With respect to the er.tJ cdnat.id. Food end Drug Administration's p reL. o n :;I titcrim. Fora Additive Regulation on polyvinyl chloride, our presort inform riticn is the.t the Hesjul&tion will be issued "in abc^f t'.vO weeks". If. this sperms vr^t;ly familiar, pl: ..so believe we are only reporting T.b v:o have learned -- we are net the source of th i state1'arts. However, more spe cifieity has been provide:", in that June 28, 1974 plus cr minus a few days has now been mentioned as a target date It is still cur understanding that the Interim. Regulation will require no detectable migration of vinyl chloride monomer into food simulating solvents using analytical methods sensitive to 50 ppb, combined with some limitation on the residual monomer content of the food contact plastic surface. The situation here remains fluid but we believe the current intention is to fix the residual monomer level in the proposed Regulation at 10 ppn. During the next two weeks, we expect to be ex tremely busy preparing testimony for the C3HA hca:tngs a: d attending the sarr.e. Nevertheless, we will make* every effort to keep in touch with you by means of these letters and thereby keep \ u as up-to-date as pcssible. Enclosures ASI-PR 0002888 t i: m .ir!;o*rt; ii u::rh:f>\' ccaUu.s vih.ja.m. ii nouiiHitswi .iii kouiuit \i tii;k,na\ v.aynh v m,\CK 1>.S' ; n ]. HIU- MAiriiS v.\ JICIs". C'VJCI H' S` ]J f*^Ui\-\CK rr 1'i u M NTMKOV JOSKI'il 1" U;l)IJTY CAI OI-h C JfAi<***lS v:ji liA.*: w i*i:cTi 1..V.- Oi . Ii'l'i Ki-:i.]-r.Ti an r> TTrci. m ax 117*0 ir* ki \n i t, y, v iirin. !oou washing to'*:, D C- uco^r. June 17, 10 7'! Ms. Joanne Gor-Hell Attn: Docket CSH-3G Occupational Safety and Health Adminis tration U. S. Department of Labor 1726 "K"*Street, N. W. Room 200 VJashington, D. C. 20210 1; i i b'O'J , ' - CAlitC ^ Re: Notice of Intention to Apnea and Present Evidence; Occupa tional Exoosure Standard. Dear Ms. Goodell: Responsive to the May 24, 1974 Hearing Notice published by the Occupational Safety and Health Adminis tration of the Department of Labor in Docket OSH-36 (3S H:: Reg. 102, p. 18303), this is to advise you of the inter.tir of The Society of the Plastics Industry, Inc. (SPI)l/ to appear through its officers, various members and counsel t present comprehensive testimony relative to OSHA's propose permanent standard concerning vinyl chloride. It is the intention of the Society to provide CSH7v with an integrals presentation involving a group of witnesses expert in all of the relevant areas to be considered with respect to the standard in question. It is believed that such an in tegrated presentation, which we fervently hope, and ir.do'ec urge that CSIIA consider hearing before other industry wit nesses apoear in these proceedings, will serve to expedite the Rearing and provide perspective relative to other tes timony to be presented independently by witnesses appearrn on their own or individual coruoan; es' behalf. XT The Society of" tue Plastics Industry, Inc. (STI) is a Corporation organized under the Hot-for-Profit Corporal: on Lav; of the State of Hew York. It is composed of apprc::j 1400 member companies and individuals who supply rav: r.av process or manufacture plastics or plastics products; ev or construct molds or similar accessory ecuipront for t: plastics industry; and engage in the manufacture of mac; ir. used to make plastics products or materials of all type; Joanne Goc-dcll June 17, 1974 Page Two <* Vi 4 4 \ In keeping with this ebienti.vc, the Society pin** to make available the folio*-ing list of witnc: cos to teat-'f'.on the rubjects indicated.;?/ 1. Mr. Ralph L. Ilarflintf, Jr., President of The Society of the Plastics Industry, Inc. Mr. Harding will begin by explaining the nature, interests and role of SPI in the instant pro ceedings. He v.'ill identify the SPI constituency in this matter and the Society's general position relative to as. uring employee and public safety where plastics raw materials and products are concerned. 2. Jerome H. Heckman, Esquire, General Counsel of The Society of the Plastics Industry, Imr. Mr. Heckman's presentation will begin the SPI case in chief. After an opening statement re garding a suit-.ary of the evidence tc be adduced by the Society, Mr. Heckman will address the legal issues implicit in the proposed standard under consideration and a number of specific change in the proposed permanent standard dcer.e: essential to make some version of it workable. 3. Mr. Anton Vittor.e, Chairman of the SPI Vinyl Chloride and Polyvinyl Chloride Resin Producers Committee, and President of the B. F. Goodrich. Chemical Company. Mr. vittor.e will set forth the essential positions of the industry relativ; to the proposed permanent standard and, in term.: of the current state of the art and all forecast improvements, will indicate the general capabil: of thr industry to meat a feasible standard wit: in a reasonable time framework. i1 l .4 ] 4 T7 (Corit.) SPI is the major national trade association cf the plastics industry; its membership is responsible for an estimated 756 of the tota*l dollar volume of sales of plastics in this country. 2/ It should be understood that this Notice has been prepared on, an expedited basis in light of the rather short time pro vided for preparation for the Hearing. For this reason we trust that the Administration will understand that change*7 in the contemplated schedule, or even the precise witnesses maybecome n.eessury. To the extent possible, OSHA will he noti fied of any changes as much in advance of the Hearing as possible. ASI-pft 02s90 Ms. Joanne Co June 17, 19 -? / 0 Page Three ii 4. Mr. Vinccr.c P. Ficc*. jlia, Industrial Econo mist, Arthur D. Little, inc., Cambridge, Massa chusetts. Mr. Ficoaglia, project director of Arthur D. Little's Economic Impact Analysis Study of the United Pistes PVC Resin Industry, will testify on what might be expected to occur if the presently proposed permanent standard were adopted, thereby making it virtually impossible in the opinion of industry experts to produce vinyl chloride monomer and polyvinyl chloride resins. The impact of the if. S. PVC industry on the overall United States economy will be the focal point of Mr. Ficcaglia's testimony. - 5. Joseph F. Tomashefski, M. D., Chief of_the Pulmonary Department, The Cleveland Clinic, Cleveland, Ohio; Robert D. Soule, M. D., Vice President-Industrial hygiene Service:, George D. Clayton ar.d Associates, Southfield, Michigan; and Hr. Roger Strassburg, Division of Environ mental Affairs, the B. F. Goodrich Chemical Com pany. The named witnesses will address the pro tective equipment requirements of the proposed standard, the effectiveness and limitations of the variou: types of equipment involved, and human experience information related to various kinds of protective equipment. 6. M. 1. K plinger, Ph.D., Manager-Toxicology, Industrial Bio-Test Laboratories, Inc. Horthbrook, Illinois, will provide a current reper on the a- 'mal toxicology data presently avail and its relevance to the vinyl chloride mcr.crr. industrial hygiene problem.7 7. Carl U. Dernehl, K. D., Associate Medical Director, Union Carbide Corporation; and Paul L. Wright, Ph.D., Manager of Toxicology, M.or.s Company, will discuss the medical evidence an human experience data The Society of the Pias Industry's Vinyl Chloride and Polyvinyl Chloride Resin Producers' Committee has been a.hle to gather and analyze thus far. They will also provide their conclusions as experts in the field of industrial hygiene as to the irr.plicacionr: of such evidence. 4* frj C) rt Si -)> ASI-PR 0002891 : ' . JOaUUO CSC \ : 11 June 17, 1171 Page Four 8. Carl U. Dcrnehl, M. D and N. Johns or., M. D. , Dimeter cC Lemmon. rat: 1 dealt.i, D. F. Goodrich Company. Those witnesses will disci'": the medical re-rumen jn to of the ore -osed scand- especially -these involving hu:,an surveillance, make recor .cations as ho necessary anc. cic-s.'.r changes in uit proposed regulations. i 9. Rudolph Stohl, Ph.D., Senior Analytical Specialist, The Dow Chemical Co., U.S.A.. Dr. Stchl will _ res. at testimony' and reccmrondea icm concerning available monitoring ins crunentancr., its cost and reliability, for determining vinyl monomer concentrations under varying plant condi tion:. . Recommendations will also be r ,de by Dr. Stehl as to changes .at should be incorporated in the final standard so as to make it more practical and effective. rt- o 10. Mr. P.ul Beebe, Jr., Development ManagerFilms and Flooring Division, Goodyear Tire & Rubber Company; M`, Arthur A. Smith, Vice-Prosider.tOperaticns, Robin-Tech, Inc.; Mr. P. J. vreaver. Director of Industry Affairs, B. F. Goodrich Chemical Company; Mr. Rodney P. Becker, Mar.agerPVC Applications and Technical Services, Plastics Division, Diam.ona-Sham.rock Chemical Company; Mr. 1. Mollinini, Vice-President-Chief Chemist, Goli Analytical Service Corporation, Earkiey Heigh New Jersey. The. e witnesses will discuss -the implications of the proposed standard with re spect to PVC processors and fabricators. More specifically, this testimony will address the question of whether there is any necessity fer coverage of processors or fabricators by the standard, the technological and economic feasibility of requiring such compliance, available vinyl chloride exposure data in processors' plants and other, related buchgrourd and iaform.ation about how processors are likely to be affected by any standard ir osed on the VCM and PVC renin manu facturers . It is estimated that the direct test! 'ui by The Society of the Plastics Industry, Inc. w 11 rcc ire an allocation of approximately four (4) hours. ASI-PR 0002892 P:; . Jo. Good:11 Juno 17, 1974 Pago Five As will Lc 't irdic: it the ]' ? ? :;ir.o , i t the cer.eral cositicn of lie Scci 1 11 o Pi a s tics I r, d u that t:ic oropoocc. pen .mcrt o-a l u c n r. r e u o ,r. a CcUO bar 5, 1 ? 7 4 without destroying the viability of the pel- v chloride industry and too many oth.or industries da?c;ot.i t upon polyvinvl chloride resin nrcluc! n. Wit'; full rocryn tion that there is a significant problem, the Society wi 1 attempt to present acccptrblo reccr.nvendatior.s for char.; r o the nropocod norunnort standard and the tire-tnulc for is effectuation so that public and erne Icy,'e health will i; c p ro- tected, and risks and benefits will be sensibly fcalancri, taring into account all aspects of the public interest. Respectfully s 'or.ittod, THE SOCIETY OF THE PLASTICS ASI-PR 0002893 Cf'< Ii I/. 1 .> ` J'.'f *' ; i *;: i * i ' m f 1 / r " $ *' ' a *t . ai. o.'h:-*. njMrv : < , . c. vi >< 7;"^ ^ 77 I: \ Arsht (2 02! O'Neill (202! 4 -J J *7 r r _ / -J ^ qS * FOP. RELEASE A?' nr, G P.M., E.D.T., TUESE'Y, JUNE 11, lr, " EF.N LEGES P?.C''_'T STEPS BY CEE''ICAL IIjUSTIV CHECK'EE AIP Russell E. Train, EPA Adm.i nis tra lor, met today v:i in a: executives cf the 29 companies which mar.ofacv.ra vinyl chic and polyvinyl chloride rosin to urge accelerated efforts ro miniiabmc the discharge of vinyl chloride gas into the c.vir mont. Train recommended pror.pt tightening and improve operating procedures in the ran of actor ingzj p_ lants and early consideration of longer-term graces 3 ITtC Cl 1II X C c Z, C`3 * Train requested that each company begin, or cor.t: -.a: monitoring emissions from its plants in order to prove o.. me extensive information cn the quantities cf vinyl chloride entering the environment. EPA will support additional : torincj in cooperation with State and local governments. Train indicated that a number of the companies r reported 'substantial efforts ever a pcied of time to vinyl chloride emission:1, as well as monitoring aefir desire to provid- fuJ 1 effective solutions to the problem. Train called today's meeting after reviewing a r1 of EPA's preliminary non i boring results at seven ch... ! plexor:, including two vinyl chloride and ter. polyvinyl c'.b plants. (more) Flctifn sJn'.'t if yCw </u fif-T CPA ! Cf.M tUO-t (f ` V, t/; 1 to frctivo Ifni ("}. r r if of nt'drC'.'. 11 net J (J (u,^i ASI-PR 0002894 -3- the Mo::t of progjcrty the air rev; ling v;as liner, of Ik:: plants . don:: wit!:i :i one-!:a! In one ca re a level ,r '" c. / PM'I,'i, t. we r-. rcc'vbed at a 0 ' t/'noo of < ' a\ vaujo of several r.::.d i r.gr at tills vile s fro:: tin site war appro:. - , 1. ' 0 . f5 ppv. -. TPA nl.ro nv 'U lore d water effluents, and love1 r; verb considerably da; ,,vbiry on the in-plant l;:;ic ' : uy o' wv .' : trcatm.ut o 1 was Lov.v; tor. The highest level for vr: Lev:;' leaving the pP'r.L site i.'is 10 ppm. More typically, leva. 2 to 3 ppm vero found. Thera is ro .currently aval la;; 1 ' < to indie.1 - that vinyl chloride is present in detect:,;. V in drinking eater. Not unexpectedly, the levels of virrb chloride entrapp'd in sludge and other solid wantes from reactor kettles rancid from 100 to in one case 3,000 pc:: 1 ' "At the present time," Train said, "there is no bee considering that the levels of vir.yl chloride detected i; discharges or in sludro if handled orcocrl' ca 5J human health or to aquatic lira." As a precaution, EPA has initiated progra: s to cent ti;cr inform tier, concerning vinyl cliloridc levels in of water, drir.hirg waf-r, and sliv'yce; the persistence c: chloric:: in ester; and the effects, if any, of vinyl Vinyl chloride has been strongly implicated as a cv of a rare but fatal form of cancer, ar.yi scare cma of the 1 To date, 19 cases of angiosarccra have bear, confirm: d v;: in workers at polyvinyl chloride facilities. In 'all of eases, the workers had been repeatedly exposed to high 1; of the gas over a subs tantial number of years. It her a 1 been suggested that vinyl chloride may be implicated is. , non-worker deaths from this liver cancer. V.'hother vinyl chloride is the cause of these deaths is still being inv. gated. (more) ASI-PR 0002896 Results from /1 n proyrer: n , . have ra'^c-'. aa *' ppm cause thin sar: 1 ' noaid (rod-a,' th-.h of then- slu:ier on fa at .lover dr-r-u'. and ,v :j:',r:v' ; jr . of v.'h ai' all'' in P'V I'.:.-., '-a'.!'1 to ~cO'.-l,; c: ! 2 ; :c 'J r. a 1 V' or; -anc.^ '- its suy; ' L.nh-h 1 r. : : a ' or.:; of vinyl chic.!' con f : a a .re ef-.orts in turn rcy.vru. EP7. is p]inniuc ho raa; o>- h crgi dr: i cl cc/ic'-1 rtu.'' :. in rf neighborhoods near vir.Jl chlcri-OL. ar.o polyvinyl c!:lc: n. pb... to further " :o tin: ir. plications of vinyl chloride . i . . .' for the y.serai public. r The Occupations!! Safety and Par ] th A el r? i nfstrat i on (C:'d.V of the Department of Labor, responsible for uorkcr safety, in determined that lev' Is exceeding 5C1 pp~i in the nor!: pi:c^ p; sent a hazard and has sot an orrryoncy temporary star.'' :rd nf that level. To ini tit. to the process for setting or pcrmnr.nn a standard, on P. y 10, Of LA proponed levering the standard to ' level of detG.oti.cn. Public; hoar ires to go.ti'.or infer:::: tier, f' a permanent standard and to assist Of PA in racing a final ju ment as to the adverse effects of vinyl chloride and the opr priato levels of exposure to v:or':ers, have been scheduled by ODRA for Ju:ic 2"- -20. Detailed reports on LI'A sar.plin activities at L_e:'.:r.n Louisville, Piaguerin.: and Lory Done.: arc available tcf..y. Detailed re--arts concerning the ether three complexes are in final stages of compilation and vcill bo available vcirhin sev weeks. ### ASI-PR 0002897 vii:/l c:.v.' comill: L .> PY dpi; l.u ii i ; ' u. . .v Louisvilla, Ny. PVC V 1 #. V* The L. P. C01 L. F. Goo:1 Leominster Karo . rvc Plant Border , Ir.c. Borden Ch Playuonlno, La. Long Beach, Calif. PVC Plant VC Plant PVC Plant The Goodyear Chemical !> Dor Ch cubical The B. F. Co B. F. Goo . ) ch Che: i PVC P1 n 'L VC Plant Paineoville , Ohio PVC Plant PVC v,lar.t Delaware, City Dolav.'are ?VC leant PVC Plant American Cine Ar.''jricun Ciic Uniroyal, In Uniroyal C Robintcch, I Stauffer Che" icr 1 Cc: y Plastics Division Diamond Shm reck Co.:;.: Diamond Sax'..r c c *: C.. ,. Fler.iivgton, L.J PVC Plant Tenncco, Ir.c. Tcnncco Chemicals, I: NOTES: Water effluent san.p1l .na '..'ere a isc collected at the PVC clout of bide Corporation, Chemical and Plastics Divisionin^S. Char'.. Sanyo ling v:as attomnt ed b ut as ^ n r. h QS , ivcr.t dif ficult ics at the PVC a.\ - c g: pany / Pi reston 2 Plus tics Cc.,y.n. c / .in : .res tor.' Very lira Lted a ir sat y 1 in g v.n. s C O.'l ''.cl of the o "l Cv!"l i. Cl lxstc d tVJ '^ *1 0'.' He v. c V Cj.' , xr. viev: Oi tire mao. .y. . y acti w ty / W,*s, S. U.iS 1 X r. cj c f for L i t h. is area is being continv.ad . Deer Pax- k, Ten . , PVC ric nt Beer Pa r k, To;: ., VC V1 tin uU Lon.a ten, Tents , vc P -iL . % , j^. ] 1 -> C' 1 e:; i a, Ter. an, VC riant - Di r..\ o ... -i Shireeilil CChhee:mica 1 fM enn JC 3 , T - Ft i va 1L Co Co., industrial Ch ; ASI-PR 0002898 VINYL CHLORIDE I,'. R 0 ' CONN L O:-TI R.Y L] '/i AIR IP ON * 7^'l q , ' * 0 Ci. AMERI. , , *f , ! ; r ' Ar-' TC, I C ' - ( r." BOREN: C I , C 7 CI I , IN w , CONI'IN ] C * 1 0" l co: , X DIANON IE- SM. c N CM . C c; T co: ^ ' - *, T ' ETHYL cc FIREST C" . ' J 1 i. LAN iCS l-L - * ., X GENU'' " Lj "ir E A ,, l ;pn E- A- _j r 2 1 ' ~n > . 'Ir B. F. GO OD? :cci: CNEN 1CN L cc ' ' C 7 "Y GOODYE ` * I i TI i 'll, h ND R cT T' ' ' ' \r GREAT 7u ;* ^ T C.YC CNEN T CA cc 'p;_ 4- -L HOOKER c LTTJ7 ' T (7 * KEYson v CCNP-c J__ . , d. . '\ . --, - i. n-w<V^ \* NONSAN TO CC 1 NATION ,, ,L C - p CL"- ' * r\ .-,S *" ' "n , i Xj ccr.ron OL.IN C CM T-, ^ -- - ^ - <**' '' THE PA ABC T"1 C o o F N EN. V CNN , INC. rob i:;v CC inc STATNNF r^1i". " T* "V "D ' ' 1 TE'NNEC CNE NIC ' ** q -- -- r -- r 1 -V- , UN" I CM C" :a " 0 . /~'- UNIROY 7 , , T / IN C C . A 7' ^ Y /J J, ^ , . UNIROY AL 111 CO ' _ ' r' FD ALLIED C ME". ICT L CON.: roc _ , J. 10 A DOM CM 1_. . c 1 ' n;*- r ' *r Jj w - . - v*.. X KONOCE , I *. s 'w * PPG IN DU Cal ^ ^ q T * * i'"'1 *.1 V SHELL CM CAL CONN * GEONGI *"V p;.c r' * ccn -- *-v jCEKTAI ' ' .. TEE L P \ 3DUC TS 'w *, ` (PVC plant under construction) T IT 7 AS I-pfj 0002899 ASI--PR 0002900