Document q3eO3jQ0Y54L0v5RpDLL6rzRn

To From INTEROFFICE MEMORANDUM RECEIVED JAN 24 1977 Subject LAW DEPT. TSCA Corrpliance Committee C. E. Blades______________ 1 Data JanUaiy 19 1978 Background for Items on Agenda TSCA. Meeting - January 50. 1978 (Location. Organization, or Dapartrianij Piscataway [Location, Organization, or Department) 1. Substantial Risk Notification See Appendix A for final draft of Notice to Employees. Each member of committee please be prepared to identify receipients of the notice. 2. Budget $ Cost Gathering Report Presentation by H. W. Parke. See Appendix B for outline of presentation. 3. Product File Progress report on Raw Materials Inventory Update on Product File -- Appendix C. T. C. Collins 4. Review on Chemical Substances Inventory--Dec 25. 1977 Timetable -- Appendix D TSCA Bulletin 45 E. I. Handwerk 5* Key Events for TSCA 197S Timetable, Appendix E 6. Member Assignments C. E, Blades Appendix F 7. Significant Adverse Reactions Directive Appendix G C. E. Blades C. E. Blades Attachments w. M. Smith R. H. Schenck*L. B. Tepper J. C. Novak A. J. Diglio W. Ent G. Handley R. Collins E. I. Handwerk M. G. Zeliner J. H. Body A. I. Dalton H. W. Parke T. C. Collins J. Egan J. Urenovitch (320) AP00049067 DIRECTIVE ON ' SUBSTANTIAL RISK NOTIFICATION January 19, 1978 App&p/x A The Toxic Substances Control Act, signed in October 1976, became effect ive January 1, 1977. One of the features of the Act which became effective on January 1, 1977 is contained in Section 8(e) known as "Substantial Risk Notification". As passed by the Congress, any person engaged in the manu facture, processing, or distribution of chemical substances, who obtains information which supports the conclusion that substantial risk to human health or the environment exists, is required to notify the Environmental Protection Agency imnediately of such risk. Referring to APCI's Standard Practice No. 702A, p. 5, and to directions given at the training sessions on TSCA compliance, the company procedure for dealing with matters of potential "substantial risk" is given. It is reproduced here. "The Conpany is required to inform the EPA immediately if it obtains any information which reasonably supports the conclusion that one of its chemical products presents a substantial risk of injury to health or the environment. Anyone in the Company obtaining such information shall immediately forward it through the appropriate line management . . 4 to. the Group/Division Manager with environmental responsibility and to the TSCA Chairman who, along with the committee and appropriate management, shall evaluate the degree of risk presented." The purpose of this present notice is to advise APCI employees of a revision in the Conpany procedure for compliance with TSCA.-Section 8(e), Substantial Risk Notification. The following directions are to be followed in all sectors of the company: AP00049068 Directive On Substantial Risk Notification 2- - January 19, 1978 (1) All employees capable of appreciating pertinent information relative to substantial risk are required to notify their line supervisor immediately* in writing, with a copy to the TSCA Com pliance Chairman (C. E. Blades). Such Witten notification ` shall be followed by documentation with attached reports describ ing the information which leads to a potential conclusion of substantial risk to health or the environment. (2) Beginning January 1, 1978, all orders for toxicological testing are to be placed through the TSCA Chairman's office. Reports o results, the management of toxicological testing contracts, and the responsibility for evaluation and pertinence of testing will reside with C. E. Blades and the TSCA Compliance Committee. For your guidance, we sunmarize below the types of information which could lead to a Substantial Risk Notification. (1) Demonstrated instances (or a series of events in a pattern which lead to a conclusion of a relationship) in which a product produces cancer, gene mutations, birth defects, death, or serious prolonged incapacitation in humans. (2) Epidemiological studies, bioassays (in vitro or in vivo) which would reasonably support the conclusion of substantial risk of " ` injury to human health or the environment when levels of exposure and degree of toxic hazard are taken into consideration. (3) Information which illustrates: (a). Organic chemicals with extreme persistance or non-biodegradabilitv (excludes inorganic materials). (b) Pronounced bioaccumulation (e.g., 50,000 X in 30 days for fish * Immediately means within 1-2 days after the information is received. AP00049069 `Directive on Substant ' Risk Notification -3- January 19, 1978 or >10,000 partition coeff. with n-octanol/water). (c) Interference with biogeochemical cycles (e.g., kills or inhibits nitrifying bacteria). (d) Stimulates primary producers (e.g., algae, macrophytes) in aquatic ecosystems, (e.g., excessive discharge of phosphates into natural waterways can stimulate algae growth which, in turn, depletes oxygen levels in the water and adversely affects other life.) (e) My observed acute or chronic toxicity effects relating to cancer, mutations of genes, or birth defects, or serious harm to health in non-human organisms. () Facile metabolism or degradation to a chemical product with any of the above. (4) Emergency incidents, such as spills or releases, which because of the extent of the contamination, critically imperils a human popu- . . lation and critically threatens other life forms with significant population destruction. R. Fleming AP00049070 H. W. Parke C. E.Blades APfEtfO /X 3 December 12, 1977 Labor Distribution of C.E. Blades Staff on TSCA Matters - tf.O. tfFL-OOOS TTexlertown Piscataway Pertinent to the distribution of TSCA costs from Dept. 641-4040, I propose the following revision: IGD M5D CSD MPD Specialty Gases Industrial Giem. R$D Polymers R$D Ammonia Prod. R?jD Chemical Add. R$D Acetylenics ROD Process Catalysts PVC R$D 1% 1% 3% 1* 144 254 34 54 20% 15% 10% 2% CEB:sk cc: B. Horton C. E. Blades AP00049071 L AP00049072 TSCQ C*si. Syyf^rn n7S B**ZA) `Tsc*> C -v /W e c *. OclHVC. T>ma p tw M iO d^e/opnnt) (7 bo) EXHIBIT II ($000) To Profit Centers Processes & Catalysts Chemical Additives Acetylenics Polymers Industrial Chemicals Ammonia Plastics Fabricated Plastics Specialty Gas TOTAL TSCA Costs By Profit Center Budget FV 1978 From Coordinator!! Office sn 23 17 2 29 6 2 1 23 $114 From Outside Testinq $67 - 33 - - - $100 From Profit Center Marketinq $- - - - 9 - 1 7 $17 From Profit Center R&D $26 - 25 - - - - - $51 Total $ 11 116 17 60 38 6 3 1 30 $282 AP00049073 HWP/tfls 11/10/77 \ CHEMICAL SUBSTANCE DATA SHEET /-/ms* ts/x a. PRODUCT NAME PRODUCTION LOCATION PRODUCT USES METHOD OF DISPOSAL EMPLOYEES EXPOSED PUBLIC EXPOSED CHEMICAL IDENTITY . NAME IMPURITIES BY-PRODUCTS INTERMEDIATES RAH MATERIALS VOLUME STRUCTURE CAS I AP00049074