Document qke0mJk34mjM9xL7LeyyR4mBq

REPORT OF THE CHEMICAL REGULATIONS 27 ADVISORY COMMITTEE QUARTERLY INFORMATION MEETING CHEMICAL MANUFACTURERS ASSOCIATION Mayflower Hotel 1127 Connecticut Ave., N.W. Washington, DC 20036 Thursday January 17, 1980 9 AM - 4 PM AGENDA Welcome and Introduction Dr. Etcyl Blair 9:00 - 9:15 AM Health Effects Testing TSGA Mr. C. W. Umland 9:15 - 9:30 Health Effects Testing IRLG Mr. C. W. Umland 9:30 - 9:45 Break 9:45 - 10:00 Testing Cost Sharing and Reimbursement Dr. C. W. Smith 10:00 - 11:00 Premanufacture Notifi cation Issues Dr. C- W. Smith 11:00 - 11:45 Lunch 11:45 - 12:45 PM CMA's Public Relations Program Labeling Regulations Break TSCA Reporting and Recordkeeping EPA Section 8(d) Proposed Rule EPA Section 8(a) Proposed Rule Closing Comments Mr. John Slavick 12:45 - 1:15 PM Dr. Bittenbender 1:15 - 1:45 1:45 - 2:00 Mr. J.B. Charm 2:00 - 2:30 2:30 - 3:00 Mr. David T. Modi Mr. Philip Holladay 3:00 - 3:30 Dr. Etcyl Blair 2.1 3:30 CMA 083051 January 17, 1988 CRAC INFORMATIONAL MEETING Meeting Attendance 7 i CRAC Panel Dr. Etcyl Blair Mr. C.W. Umland Dr. C.W. Smith Mr. F. E. Bentley Mr. Dean Leib Mr. J. B. Charm Mr. David T. Modi Mr. Eugene Berman Mr. Philip Holladay Dr. Bittenbender Mr. John Slavick Mr. Gordon D. Strickland Companyr Dow Chemical Company Exxon Chemical Company, U.S.A. Shell Chemical Company Jefferson Chemical Company Rohm and "Haas Company Allied chemical Corporation DuPont de Nemours Company, Inc DuPont de Nemours Company, Inc Shell Oil Company Borden Chemical Chemical Manufacturers Association Chemical Manufacturers Association I ; ) ATTENDEES: Mr. Don A. Rolt Mary Killorin Sherry Boltz Ira MacDonald Steven Cragg Ann Rosser Wieseneck Lew Burnette Ann Baker Jenkins victor A. Dueslow British Embassy 3M Company NPCA Ashland Chemical Company API Kaiser Aluminum & Chemical Co. GAF Corp. Allied Chemical Corp. Amoco Chemicals 2.2 CMA 083052 ATTENDEES (Cont'd) Robert Gilden Herb Twaddle Lori Gribbin Chris Waisanen Philip C. Holladay Tatiana Roodkowsky James Hulme H. Adams, Jr. Robyn Reed H.K. Nason Donna Mauney-Tyler W. William Ament Joan M. Cloonan Edward P. Bouchard Jay H. Ashley J. H. Rook John M. Pashko Robert Gough Earl DeWitt Jim McClellan Robert M. Miller Judith A. DeFranco Judith A. Tins Paula Dunnigan Standard Oil Company Amoco Chemicals Corp. Rohm & Haas Company ICI Americas Shell Oil Company U.S. Chamber of Commerce American Cyanamid MMEPA Union Carbide IRI Research Corp. America Chemical Society O.R.C., Inc. G.E. Engineered Materials Group Pfizer Inc. Dow Chemical Co. American Cyanamid Merck & Co. Cincinnati Milacron Ethyl Corp. BASF Wyandotte Corp. Hercules Inc. Hercules Inc. Celanese Corp. B.F. Goodrich ATTENDEES (Cont'd) Ellen Spitz George Brokaw John B. Dubeck Jerome H. Heckman David M. Benforado Jean Auman R. S. Chamberlin Amy Shepard J.R. Cohn Mallincrodt Inc. Tennessee Eastman Co. Keller and Heckman Keller and Heckman 3M Company Chemical Manufacturers Assoc Dow Chemical Co., U.S.A. American Petroleum Institute Allied Chemical Co. The meeting was opened at 9:03 AM by Dr. Etcyl Blair. Each Panel member was introduced and guests were thanked for their company's support in CRAC activities. Mr. Carl Umland provided a thirty-minute presentation on the recent activities of the Section 4 task group. He discussed the CMA comments on the Section 4 Testing Rule, GLPs and IRLG draft guidelines. He concluded his presenta tion with a description of what is expected in the future from EPA and notified attendees that the name of his task group had been changed to the Testing Task Group. Following a brief question and answer session, the meeting recessed for a coffee break and to provide attendees a short reunion with friends. 2.4 CMA 083054 The meeting was called back to order at 10:00 AM for a presentation on Testing Cost Sharing and Reimbursement under Section 5 of TSCA. Dr. Smith, working from a chalk board described current CMA recommendations for resolving cost sharing and reimbursement issues among consortium members. He discussed the points of controversy which have existed during the development of the comments, and explained how and why those issues were resolved. Following a question and answer period. Dr. Smith continued with a discussion on major issues which had been raised on EPA's proposed rule covering premanufacture noti fication. He described the problems which had been over come and the issues which still remain to be resolved. He read aloud a recent letter from Congressman Broyhill to EPA which criticizes some of EPA's current positions on PMNs. {See letter attached). Mr. Berman, Chairman of the Oversight Task Group, was asked to describe CMA programs for developing legisla tive issues and to comment on possible issues that might be raised during future TSCA oversight hearings. He out lined issues currently being developed by the task group and pointed to PMN Testing and confidentiality issues as those which have imminent importance, and explained that although CMA did not prefer major oversight hearings this year, that could be unavoidable. 2.5 ' --T....... CMA 083055 Dr. Blair reported on a letter being sent to com panies by Hr. Blake Biles of EPA. The letter is an ad vertisement of EPA positions now available. He told those in attendance they should contact Mr. Biles if there is interest in filling such positions to improve EPA's aware ness of industrial processes. The floor was opened to questions on any subjects discussed. The meeting was recessed at 11:50 AM. Following lunch, Mr. John Slavick of CMA described the goals of CMA's broad base communications program and the methods by which those goals will be met. He discussed current activities: media hot box training, and publi cations on Transportation, Product and Worker Safety, and the speaker's kit. He concluded with a request for member company support and stressed the importance of the program to industry's image. Dr. Bittenbender provided a concise update on acti vities of the Intercommittee Task Group on Hazards communi cation and on Labeling initiatives. He endorsed support given by other Trade Associations, and pointed to Unions as the major factor behind demands for labeling. Industry'- I CMA 083056 desire to provide important health and safety information was stressed, as was its dissatisfaction with the $14 billion-dollar impact of OSHA's previous proposal. In detail, he explained the flows in OSHA's proposals, and concluded his presentation by stating that publication of the rule is imminent. Following a short question/answer period and a 15minute break. Dr. Blair called the meeting to order at 2:00 PM. Before turning the floor over to Mr. Charm, he briefly discussed CMA's economic impact study and told attendees that more participants for the study was essential if it is to proceed. Mr. Joel Charm described CMA's interest in the October 12, EPA proposed rule on PBB and TRIS as similar to that on the October 17, Asbestos ANPRM -- that interest being that they have precedent value as Section 6 and Section 8 rules in a restricted specific case. He pointed out that while we agree with EPA's basic interpretation of their authorization in this case, we also take the stand that 8(a)(2) is not merely illustrative of the type infor mation EPA can require, but it is all inclusive. Mr. Charm also discusssd definitions of terms which CMA will address in its comments. Terms believed to require better defi nitions include: "Reasonably ascertainable," "small manu facturer." Regarding the asbestos proposal, he stated that 2.7 CMA 083057 CMA basically opposes any system of production or import quotas, since such a system is unprecedented government interference with the operation of competitive business forces. He added that maintenance of confidentiality is a concern with the asbestos rule, because EPA has indi cated its intention to share its data with other agencies. He concluded that asbestos may be one of the first targets for a labeling rule. Mr. Charm stated that 8(c) rulemaking is now on EPA's back burners and no rule is expected for 2-3 months. However, one issue sure to be raised by the rule is the automatic reporting trigger. What EPA has done to publicize 8(e) submissions to date is mild compared to the following proposal, he said. EPA has proposed to issue a book of its own evaluations of submissions which are very critical of a number of com panies. Mr. Charm said he believes we have dissuaded EPA from this approach in favor of a far less controversial "log. Mr. Charm closed his introductory presentation on Reporting Task Group activities with a discussion on EPA's Chemical inventory. Mr. David Modi highlighted issues raised by the Section 8(d) rule proposed December 31 by EPA. He pointed out definitions of terms which are troublesome, such as, 2.8 CMA 083058 "for commercial purposes", "processors," and "study." He explained why EPA's estimate of cost of implementing the rule was grossly inaccurate. He said that although EPA estimated total cost to the industry at about $400,000; DuPont estimates their cost will approach $500,000. The error is attributable to EPA basing its calculations on their pre vious 8(d) rule which held a far narrower definition of study, he said. The current rule defines a study to include medical record information and industrial hygiene monitoring. EPA has also failed to consider the increased cost a company bears when data must be gleaned from multiple sites, fre quently distant from one another. - Mr. Philip Holladay concluded presentations from the Reporting Task group by giving an in-depth briefing on the soon to be published Section 8 (a) rule. He recounted the evolution of the 8(a) proposal beginning in August 1978. He said red border review of the draft rule was completed on January 16 and publication should be expected in February. View graphs were used as an aid to explaining what information must be reported and how the report form should be completed. Mr. Holladay said that while CMA still sees some faults in the draft it is the least objectionable rule to be published to date ---- a result of reasonable dialogue between EPA and industry. 2.9 CMA 083059 Mr. Leib briefly discussed the Toxic Substance Management Memo which will be circulated to keep member companies informed of CRAC activities, and announced that the next CRAC informa tional meeting would be held in mid-April in Chicago. Dr. Blair added that CRAC will consider the practicality of lending a symposium atmosphere to future meetings and of publishing Symposia for reference by attendees. | Dr. Blair concluded comments by thanking the attendees for their attendance and for their candid questions. The meeting was adjourned at 3:35 PM. dfmbn *D. StftckLued ^Gordon D. Strickland Staff Executive Chemical Regulations Advisory Committee 2.10 CMA 083060