Document wgKddqRr98KyvadpBm8apeZqd

INTEROFFICE MEMORANDUM Date: Frost: Dept: Tel No: 06-Jan-1994 09:32am CST Verne L. Rhodes RHODES, VERNE L. MCCENV 314-694-2575 FAX694 6262 TO: Leudtke, Al ( PAPER MAIL ) Subject: CRI Technical Program Al: The following is xny working document on the result! of the Executive Committee meeting of January 4, 1994: Problem: My conclusions after meeting with Tom IverBen: 1. We have new leadership on the executive committee level that wishes to cut costs and maintain "mill control". 2. MLB iB actually recommending that we back away from the next EPA workshop and the Executive Committee is willing to accept this recommendation. This is an unacceptable position. 3. We have a consensus problem between the tox (technical) committee and the Science Advisory Board on what research we need to do. Discussion: There is great frustration among the members of the executive committee (EC). They feel that they have spent over SI million on the issue and that there is no end in sight. The EC strongly wishes to move carpet out of the spotlight and into its real role a s 4a minor component of the indoor air quality issue. This should be the objective of our strategy. Early in the EC meeting, the proposal for an industry wide complaint handling system was brought before the group. Legal advised that this system would make the work of the plaintiffs easier in the class action suits. Several members felt strongly that handling complaints WAS NOT an appropriate roll of the CRI. They did not want to surrender the decision making power to clean or remove carpot. The decision was made that CRI should only collect data that the mills would input. The proposed EPA workshop was discussed and legal apparently pointed out the hazards associated with this meeting. Without any PR or government affairs input, the decision was made to back away from the 000108 w iuitl. J'oth current only weejcens iy eea to not be *enitiwe latuet. Alio, thelr * o 'he politicel and public relatione (<a'#u.joutte n out o f t h., t .`V"nihcani lwcornk rtoZ dTatla.T , (TAnTdersBoinl'*s` 9teesthti*myony the Amara case would have been FAR more significant without Dudek'i ticipation.) len CRI was called to defend the industry in front of the longressional committee on June 11, 1993, the major reasons that we lame away feeling that we were NOT going to be subjected to a lot of [ad publicity and unnecessary regulation were: We had been working hand in hand with EPA for several years in an pen, pro-active, responsible manner. (Carpet Policy Dialogue Croup, reen Label Program, etc.) . We had existing creditable, on-going research programs targeted at Lnding a problem if one existed. We made certain commitments to continue on this course of action, icluded in these commitments was the promise (to Synar) to spend up > 510 million to "put to rest" this issue 1 >A and the congressional committee are under the impression that we e committed to doing specific things. These things include: Investigation of complaints, ON SITE. Providing additional data on the nature and number of complaints i receive. Looking for problems among carpet industry workers or installers. Additional research on health effecte of chemicals that are itted from carpet. A continuing program of VOC reduction. Participation in meetings with complaintants and their physicians oking for the reason that these people say they are sick. Provide information as to the chemical composition of carpet, ere is of course, some room for negotiations in these commitments t we do not have the option of declaring victory and telling EPA to look for problems elsewhere. r" 1 ( VLR Comment and opinion: The lawyers axe advising as to how to win the law suits; both current and anticipated. They feel that any additional action only weakens their position in the class action suits. They seem to not be sensitive to the political and public relations issues. Also, their memory is very short on how much mileage they have gotten out of the technical work to date. (Anderson's testimony in the Amara case would have been FAR more significant without Dudek's participation.) When CRI was called to defend the industry in front of the congressional committee on June 11, 1993, the major reasons that we came away feeling that we were NOT going to be subjected to a lot of bad publicity and unnecessary regulation were: a. We had been working hand in hand with EPA for several years in an open, pro-active, responsible manner. (Carpet Policy Dialogue Croup, Green Label Program, etc.) b. We had existing creditable, on-going research programs targeted at finding a problem if one existed. c. We made certain commitments to continue on this course of action. Included in these commitments was the promise (to Synar) to spend up to S10 million to "put to rest" this issue] EPA and the congressional committee are under the impression that we are committed to doing specific things. These things include: a. Investigation of complaints, ON SITE. b. Providing additional data on the nature and number of complaints we receive. c. Looking for problems among carpet industry workers or installers. 9. d. Additional research on health effects of chemicals that are emitted from carpet. e. A continuing program of VOC reduction. f. Participation in meetings with complaintants and their physicians looking for the reason that these people say they are sick. g. Provide information as to the chemical composition of carpet. There is of course, some room for negotiations in these commitments but we do not have the option of declaring victory and telling EPA to go look for problems elsewhere. +f t with respect to the appaxent distyrtcMnt btw##n tbs TchQic&l Committee and the SAB, there wee e document from Kike Phillips which strongly urged human health work in place of the sensory irritation work. The fact that#we have some disagreement should not be surprising. The technical committee is made up of industry specialists with & strong toxicological / analytical chemistry background. This committee tends to look toward this type of science for safety assessment data. The SAB was selected from a broader scientific base. The study and testing methods Phillips is recommending may be worthy of additional consideration but we must be very careful not to test our products by unproven methods. Iversen's current position: Tom feels that he needs the following for the next Executive Committee meeting (currently scheduled for February 15, 1994): 1. List of Promises we have made to EPA a. What do they think is our obligation? b. What do we recommend? 2. What is going to happen if we don't follow through? 3. Get our house in order technically; what research do we want to do? How can we get EPA on board? 4. Have we gotten the most mileage out of work already done? Should we have a PR program? Should we communicate with Congress? Tom emphasized that the message from the Executive Committee is "How do we, in the most cost effective manner, get carpet out of the spotlight and back to being a part (small part) of the indoor air pollution issue?". I am to give Tom an update on these issues on January 24, 1$94. I currently have strong commitments on January 13 and 14 and a weaker one on 25th and 26th. Otherwise, I am available to help where I can. As we discussed, the current EC position is unacceptable and we must find a way to move them back to a pro-active position. We really need to get our act together prior to the EPA meeting on January 19th. I look forward to hearing from you or Werner. Best regards, Verne 000110 y?ifi 000112