Document wQEKO46Kjb85v5NBV3mvZq4o

TO: H. D. Garrison, R. A. Conrad, J. Friend nr FROM: DATE: Interoffice Communication STJBJ: J. C. Ledvina January 27, 1988 VINYL CHLORIDE MUTUAL ASSISTANCE PROGRAM VIST/ The attached correspondence confirms that there is no longer a VCM Mutual Assistance Program. Transportation incidents involving VCM will be handled in the same manner as other chemicals in the CHEMTREC system. Q- CL- \J. C . Ledvina ajo .201 Attachment x/-- vvv 000028645 A Division of The Society of The Plastics Industry, Inc. Dear Customer, Because of the condition of th original, this is the best cop that could be made. & To: The VI Health, Safety and Environment Committee The VI Legal Committee Re: Vinvl Chloride Mutual Assistance Program The attached correspondence between Joe Mayhew of CMA and Peter de la Cruz should serve to complete your files on the abovereferenced program. MNS/pmb enclosure Meredith N. Scheck Assistant Director ooooi^6 \/M>f Wayne Interchange Plaza II 155 Route 46 Wesf Wayne, NJ 07470 (201) 890-9299 '* LAW OFFICES JOSEPH C. KELL** JCPOME H. HECKMAN CHAHLCI M. HffHAN muiAH H. IOMHUANI, OP MALCOWM 9. MCAIttMUA WAVMI V. SLACK TCPPENCE ft. UONEft maptin w, tefteovtci JOHN I. CLDUO PPEDEPlC* A. AHOVOAMf CAROLtC. NAHRII MICHAEL F, MOARONC KAHK FOX EVENS JOHN ft. OUftEC* ACTEA i. CPU* CHAHTIHC A. MCAftHEft SHIPLEY 9. FUJlMOTO LAWPENCE P. HALFPIN PALPH A. SIMMONS pctcp a. sussca C. OOUSLAS JAJVPCTT SHEILA A M'LLAP MART MASTHA MeMAMAPA JOHN ft. PICHAftOS* MELVIN S. OAOtEN FPEOEAICK J. DAY. JH HAACI C. SAfCNSTCm* SUSAN r. CONTI ftgftAN J. PiftNCP FATPICK J. HUftO** S, CRAIO TAUTFCST DAVIO H,JETT MAUREEN A. O'CONNELL** KAPEN C. CDCLftEPC* N>NA M. ftlNSTClN** MASK A. StCUCPS"* MART CHAMBERS CAANOT* Q FPAHKUN KOONTZH CATHERINE N. POEMCP-* ROBERT JEFFREY CftEP*** PICHAAO A JAFFE* AOMITTEO IN PENNSYLVANIA ONLY AOMITTCO IN VIPOINIA ONLY AOMITTEO IN MARVLANO ONLY "AOMITTEO IN COLOPAOO ONLY Keller and Heckman 1150 17" STREET. N.W. SUITE IOOO WASHINGTON. D.C. 20033 (202) 856*5600 January 14, 1988 SCIENTIFIC STAFF DANIEL S. DIXLCP DUPWAPO F. OOOOCN CNAPLES V. ftPCDCP POBEPT A, MATHEWS TCLXCOM N U N (CATIONS ENGINEER CNAPLES F. TURNER TELEX TELECOPIER (201) IS6TSBB CABLE ADOpCSS "KELMANWPITCP'S DIRECT OlAL NgMfttP (202) 956-5641 Meredith M. Scheck The Vinyl Institute Wayne Interchange Plaza II 155 Route 46 West Wayne, New Jersey 07470 Re: Vinyl Chloride Mutual Assistance Program Dear Meredith: I received the enclosed response from Joe Mayhew confirming that CHEMTREC has discontinued the Vinyl Chloride Mutual Assistance Program. It would be appropriate to dis tribute this letter to the Legal Committee and Health, Safety, and Environment Committee so that the members' files will be complete. know. If you have any comments or questions, please let me Cordially yours. Enclosure cc: Robert D. Luss, Esq. W. C. Holbrook Charles E. O'Connell Robert W. Sherman Peter L. de la Cruz 0000286^7 vvv CHEMICAL MANUFACTURERS ASSOCIATION January 7, 1988 Mr. Peter L. de la Cruz Keller and Heckman 1150 17th. Street, NW Suite 1000 Washington, DC 20036 Dear Mr. de la Cruz: Thank you or your correspondence o December 30 regarding the Vinyl Chloride Mutual Aid Assistance program. We recognize this program was never formalized, and that it was more of a "gentlemen's" agreement among the producers involved. However, during the years it was active, the program was one of the better tools CHEMTREC was able to use to the industry's advantage. Quite often during a train derailment actual shipper identification is impossible to obtain at the time of initial call to CHEMTREC. It was quite valuable to have this resource for VCM response available during such instances. During the later part of 1986, an attempt was made by us to revive the program. Each listed member was approached and asked to indicate his preference to one of three options. They were: 1) continue and reorganize the VCM plan to reflect the SPI withdrawal from sponsorship of the plan; 2) incorporate the VCM plan into the CHEMNET program; and 3) disband the VCM mutual aid plan without additional action. The majority preferred to disband. Although our records were modified to indicate that the VCM plan no longer existed, some references remained in our operations manual and thus a recent attempt was made to activate the system. Please be assured all files and references to this voluntary program have been removed from our operational files. Sincerely, JJM/ejf Director, National Chemical Response and Information Center (NCRIC) Formerly Manufacturing Chemists Association--Serving the Chemical Industry Since 1872. 2501 M Street. NW Washington. DC 20037 Telephone 202/887-1100 Telex 89617 (CMA WSH) VVV 00002864a LAW OFFICES Keller and Heckman JQlCPH C. KtUlt* JtftdMI M. HCCMAM CHAUkCV MCCHAM WILLIAM OKMUANI. J" MALCOLM 0 MA&AATMUA WATMC V. 0LAC tcn^cncf JONCS MAATlN w 0CCOVICI JOMM 0. ClOMCO F4f0f* A. MH9VOAMV CAROL! C- MAMII MICMACW F. MOAROMC MAR rvcN* vOhn . ovrkck Mere* C. ! i CRVI CHRIITINC A MIA0MCA HAL<Y 0 rg^lMOTO LAWRINCC . HAL 0AW0M A 0JMMOM0 Ct(RA. 0V00C0 C, 0OUOLA0 jA!tT 0MC11A A MILLAR MART MARTHA mHAMARA JOHN 0, RICHARDS* MCLVtN 0. OROZCN f0C0C0lCA J. AT, J* ** MARCl C. QRCCMSTCIN* 0IJ0AM T. CONTI 0USAM i. 0I0MC0 PATA'CA J NURO 0. C*A*4 TAUT0C0T OAVIO H. ICTT MAURCth A. O CONNCLL** MjLACM K. COCL0C*O* NINA M. 01N0TCCN HARK A. 040VC00*** MART CHAMRCRI QRAROY** 0 FMAMMON KOONT<R CATMCAlMC N ROCMCR** RO0C0T jcrraiY irir*^ AICMANO A. -JAffC* AOMITTtO IN 0CMN0TkVANlA ORLY T*AOMlTTtO IN VIAO>NLA ONLT h^OmiTTIO N MARYLAND ONLT AONlTTtO <N COLORADO 0"L.T 1150 17,a STREET. N.W. SUITE lOOO Washington, d.c. eoooe (202) 056-5000 December 30, 1987 Wcuti Vto IClfNTlflC STAFF OANICl 0. OlILCR OU0WA*O F. OOOQtm CHA0LC0 V. 00COC* *0tNf A. MATMCW0 TCLCC9RRNUNICATION0 CN6INCE0 Charles f. turhcr reexx 40 00001 TCLCCO0IC* <2001 J00-700* CA0LC AOORC00 -NtLNA* wRiTtn direct dial, nunrcr (202) 956-5641 4 7987 Mr. Joe J. Mayhew, Director National Chemical Response 0R.fi t rn ` ` *G0^SMaa; and Information Center Chemical Manufacturers Association 2501 M Street, N.W. Washington, D.C. 20037 Re: Vinyl Chloride Dear Mr. Mayhew: I am writing on behalf of the Vinyl Institute, a division of The Society of the Plastics Industry, Inc. (SPI), concerning response procedures for incidents involving vinyl chloride. This letter is intended to confirm the propriety of the Chemical Transportation Emergency Center's (CHEMTREC) cur rent handling of vinyl chloride in the same manner as other chemicals. In 1976, an SPI division known as the "VCM/PVC Produc ers Group" met and attempted to create an emergency response plan for incidents involving vinyl chloride under which the producers would respond to accidents located closest to their facilities regardless of the actual manufacturer or shipper. This was sometimes referred to as the VCM Voluntary Emergency Response Program and also the Vinyl Chloride Mutual Assistance Program. Participants in this program included Borden Chemical Company, Conoco Chemicals, Diamond Shamrock Chemical Company, Dow Chemical Company, General Tire and Rubber Company, BFGood- rich Chemical Company, Goodyear Tire and Rubber Company, Great American Chemical Company, Hooker Chemical and Plastics Com pany, PPG Industries, Shell Chemical Company and.Stauffer Chem ical Company. These companies and others may have written to ooooze^9 ^>4 Mr. Joe J. Mayhew December 30, 1987 Page Two Keller and Heckman CHEMTREC in 1976 and 1977 authorizing CHEMTREC to release the company's name and telephone numbers and the location of response teams when, in CHEMTREC*s judgment, the company's response personnel were in a geographic position to render aid most effectively. Although well-intentioned, this mutual assistance program did not work as a practical matter. We understand that CHEMTREC voluntarily retired the files relating to this program some years ago. Since the initial attempts to organize the program, the industry has undergone substantial consolidation. This, accompanied by shifts in the geographic distribution of production facilities, have also minimized the underlying ra tional for the program. Moreover, since there is no universal ly-followed standard for equipment coupling, technical obsta cles to an effective mutual response program exist. We trust that this letter will adequately summarize the reasons for CHEMTREC's discontinuance from the program and serve as a file memorandum rescinding any company authoriza tions. If you have any comments or questions, please let me know. Sincerely Peter L. de la Cruz cc: Robert D. Luss, Esq. W. C. Holbrook Herb Waltemate Charles E. O'Connell Robert W. Sherman Roy T. Gottesraan, Ph.D. VVV 000028650