Document x1b97m1oj7Qx3aQLOmYOXkMjQ

oA <;-) V HU^LWI w uU *7 JAN 1 b 197b Date September 8. 1977 INTEROFFICE MEMORANDUM J - ^AR&bject____ Chemicals Group .Safety 6 Health Costs FY 7 To R. Fleming____ From J. C. Novak cc: T. L. Carey J. H. Body Trexlertown (Location, Or^jnuation, or Otoartmont) Trexlertown (Location, Organisation, or 0Mrtmnt) At your request, I have compiled the Chemicals Group's spending during FY 77. The numbers below represent the best available information. There were two major difficulties in obtaining the correct figures a) Some of the locations just recently began separating Safety and Health costs from their overall operating expenses. Therefore, the numbers they report are on the conservative side, b) On major construction projects, the cost of Safety and Health is again lumped in with the total cost of the project. At times it is difficult to judge whether individual costs are due to new technology which improves the operation, or for safety and health reasons. Nevertheless, the cost figure for capital expenditure is rather close to actual spending, again on the conservative side. Operating cost dollars for the month of August and September have been prorated based on prior experience. This portion of the total cost may have a * 101 error. The Legal Department's charges for Safety and Health could not be broken out from the total charged against the Chemicals Group. There was a substantial tiros and effort spent by the Legal Department on OSHA related items. JCN:djm J. C. Novak (3201 AP00025492 cdtA. 'fyoctuZZi anZ C6emicatINC. INTEROFFICE MEMORANDUM To From Date Subject---------------------- (Location, Organisation, or Department) (Location, Organisation, or Department) (320) AP00025493 '* -Iffthe WALL STREET lOl'RNAj, *Si_=IsWMiy, March 14, 1971 - Federal Regulation Of Business on Rise, Budget Study Shows ergy increased 11% to 51.12 billion fro* INI rnUUee a year earlier, and reflect wi gam since fiscal 1974. For instance, the bafc get for the Environmental Protection Agency is 622 million, up from $473 million in fiscal 1976 and (232 million in fiscal 1974. "Old-Line" Agencies ##* Mr. Weidenbaum maintained that "much Increase in U.S. Agency Costs media attention" Is focused on "old-line" agencies such as the Federal Communica Indicates More Red Tape tions Commission, the Federal Trade Com mission and the Interstate Commerce Com ' Despite Carter's Pledge ^ mission. Yet, this group's expenditures "have a much more stable pattern," he said. "The big money isn't here; the action By a Wall strut Journal 8taff Reporter Is in the newer agencies," he said. ST. LOUIS-Govemment regulation ol Regulatory costs budgeted lor these "old- business will continue its climb in fiscal line" agencies edged upward to (341 million 1979. despite pledges from the Carter admin in fiscal 1979 from (340 million the year ear istration to trim red tape, says a report by lier. The fiscal 1979 figure was up 39% from the Center for the Study of American Busi fiscal 1974, the economist said. ness at Washington University here. "Frankly," he observed, "I wasn't aware The federal government's 41 regulatory of the extent the Department of Agriculture agencies have a combined budget of 14.82 has expanded its role.'' The overall regula billion in fiscal 1979, up from (4.54 billion in tory costs declined to (830 million from (862 fiscal 1978 and (2.24 billion in fiscal 1974. million In fiscal 1978; however, both years This level of expenditure "represents a "are substantially ahead of fiscal 1974's growth rate that is unsurpassed by the fed costs of (314 million, he said. eral budget as a whole, the population of the "In all fairness," Mr. Weidenbaum said, country, the gross national product or any "a lid has been kept on expenditures of the other applicable basis for comparison." the Consumer Product Safety Commission" ja study notes. recent years. The fiscal 1979 budget allogM In. an interview, Murray L. Weidenbaum, the commission (40 million, from (42 ndBio the center's director, said the study "Is a the year, earlier and (40 million la fiaeal good, direct measure of the rising interven 1977. tion of government in the economy." He stressed that "the overriding concern isn't just S4.S bllUon, but the costs to business tor complying with the regulations" which are ultimately passed on to the consumer. Multiplier Effect An earlier 3tudy by the center Indicated a multiplier effect of about 20 times the fed eral regulatory expenditures. Mr. Weiden baum said. Thus, we reasoned that the cost to business in fiscal 1879 "could easily be close to (100 billkm." Mr. Weidenbaum. formerly Assistant Treasury Secretary for economic policy, said he and a graduate student, Robert De- Ftna, had pored through the budget since late January, 'when it became available, picking out regulatory costs. "It was quite a chore," he continued, not ing that "you have to know your way around budget concepts and tables." Nonetheless, he added with a chuckle, "It was something like a detective story. You had to find bits and pieces" related to costs of regulation. The report disclosed that the bulk of bud geted expenditures for fiscal 1979, which be gins Oct. 1, are earmarked for areas of so cial regulation that have received increasing attention in recent yean. For instance, the total tor consumer health and safety is (2.67 billion, up 3% from fiscal 1978, but a 105% Increase from fiscal 1974. Job safety receives (626 million, up 11% from fiscal 1979 and 102% from five yeereearltar. >7 Regulatory costs tor evrlNMbent and en AP00025495 TO: R. Fleming -2- Safety & Health Costs FY 77. The Chemicals Group' s Safety and Health costs on capital expenditures FY 77 is $1,688,682. The operating costs FY 77 have been broken down by locations. Escambia Plant Pasadena Plant St. Gabriel Plant Calvert City Plant Paulsboro Plant Outlying Plants Fab. Plastics Div. R D Labs Group Engineering Group Transportation (DOT - transportation safety) Industrial Chemicals Process Technology Group Industrial Chemicals Business Area Chemicals Group Safety $695,140. 405,000. 68,000. 550,000. 114,761. 315,400. 20,599. . 147,276. 78,000. 25,000. 39,700 10,000. 89,000. TOTAL $2,557,876. AP00025496 NEWS ANALYSIS agreement on the transfer of new pow ers to EEOC. The agency has been criticized by industry. Congress, and the Executive Branch for its backlog of charges, inefficient management, and revolving leadership. (It has had seven chairmen in its 14-year history.) But re cently. under the leadership of Eleanor Holmes Norton. EEOC has tajeen steps to streamline its procedures. However, warns William Knapp, labor attorney with the U. S. Chamber of Commerce's Labor Relations Sec tion. "There's a lot more that needs to be done [at EEOC] before going out and talcing on added responsibility." The chamber also believes that the expertise for administering the ae and equal-pay laws is in the Labor Dept, and should remain there. ' More ageactionr A major change for employers, unless Congress disapproves transfer of ADEA responsibilities to EEOC, will be mere vigorous enforce ment of the age la/v, believes Mr. Jager- son. / "The law has/traditionally been fee bly enforced." he observes. "The vast majority of action has come from pri vate suits. Watch the age issue when EEOC has it^It will become as big an issue as thosfe related to women and minorities." ' Mr. Jager^on also believes the Presi dent's reorganization reflects a trend which may. eventually lead to a com plete takeover of anti-discrimination ac tivity by EtOC.' `There won't be a con solidation of EEOC and OFCCP. EEOC will just eat it up and assume all its re sponsibilities. No matter what the people ih the Labor Dept, say, the real ity is that EEOC has a more vigorous and direct approach, albeit a confused approach because of all the problems it's had. But it is taking all the power." The proposals call for transfer of en forcement responsibilities over a twoyear period. The first scheduled change is termination of the coordinating coun cil and transferral of its duties to EEOC on July I of this year. The transfer of the Equal Pay Act and ADEA would take place July I. 1979. An environmental threat to exports? By John S. McClenahen U. S. export sales, already dragging because of the world's slow recovery from the 1974-75 recession, could be further depressed by the actions of some environmentalists inside and outside government. That, at least, is the fear of some busi ness analysts who are alarmed by the prospective impact of current Washinging maneuvers. The White House Council on En vironmental Quality (CEQ) is con templating regulations that- would re quire federal agencies, including the Commerce Dept, and the ExportImport Bank ofthe U.S.(Eximbank),to file environmental impact statements (EIS) before making any "major" inter national moves "significantly affecting the quality ofthe human environment." At the same time. Eximbank is the target of a 13-month-old lawsuit which also seeks to mandate EIS filings before export sales can be consummated. The suit, which has yet to advance beyond preliminary legal maneuvering in a Washington federal district courtroom, has been brought by the Natural Re sources Defense Council (NRDC) and the National Audubon Society. Both the CEQ draft regulations and the environmental groups' lawsuit are attempting to apply the EIS require ments of the 1969 National Environ mental Policy Act to international commerce on the assumption that the law does not confine "human environ ment" to the U, S. Early readings. Many companies are just learning ofthe CEQ proposal, still a month or more from public proposal, and are unable to discuss its probable impact in detail. A reading of the plan by Dow Chemi cal Co.. Midland. Mich., for example, suggests no direct effect on product exports--since most do not involve any U. S. government financing. But, the firm says, the rules could produce prob lems for Dow's overseas capital proj ects. which have drawn on Eximbank financing and risk guarantees from the Overseas Private Investment Corp., a federal investment insurance agency whose own future is now in doubt. Executives at General Electric Co.. Fairfield. Conn., term the ideaof requir ing Eximbank to file an EIS on export sales "just about as unrealistic as you can get." Foreign countries would re ject being told what was or was not en vironmentally acceptable, a GE official explains, and these nations could simply turn to suppliers from other countries. ' ' Foreign governments do not want to be told by American environmentalists that they cannot drain marshlands to Dew Chemical doesn't believe EIS filings would affect Its exports, such as pesticides which aid rice farmers in Asia, but they could hamper overseas capital projects. as INDUSTRY WEEK. Mlrch 9. U79 AP00025497 START HERE:NEWS ANALYSIS Commission (EEOC) the predominant anti-bias agency. The plan will have an "extraordi nary" impact on employers, says G. Todd Jagerson. president. EEO Ser vices Div.. Jagerson Associates Inc., a New York equal employment opportu nity consulting firm. "The power is go ing to what has become the most vig orous enforcement center. EEOC is the leading edge. . . . It's ominous for the employer." The Administration's proposals transfer to EEOC the enforcement of the Equal Pay Act and of the Age Dis crimination in Employment Act (ADEA). both formerly the responsibil ity of the Labor Dept. They also abolish the Equal Employment Opportunity Coordinating Council and transfer its duties to EEOC. The council was estab lished four years ago to eliminate dupli cation and inconsistency among the var ious federal anti-bias agencies, but has had only one major accomplishment: creation of uniform employee selection guidelines. Also transferred to EEOC under the reorganization is the responsibility for equal employment opportunity for fed eral employees, formerly the charge of the Civil Service Commission. Consolidation. These changes will re quire Congressional hearings. Another step outlined in the plan, however, will be accomplished by Executive Order. The President will amend Executive Order 11246. as of Oct. I, to terminate the authority of 11 government agencies currently responsible for nondiscrimi nation by federal contractors and con solidate this authority in the Labor Dept.'s Office of Federal Contract Compliance Programs (OFCCP). which now coordinates the activities of the 11 agencies. This consolidation is widely approved by business. EEO Services' Mr. Jager son points out that one of his clients, a large corporation, is required to have six affirmative action plans, each for a dif ferent government agency, atjust one of its plants. There is. however, considerably less POP-ON' FASTENERS VEITRACK' FASTENERS Molded Tapes Start by thinking of the many ways you could use a fastening system that can: Reduce weight Do things no old fash ioned metal system can do Prove safer in use Reduce maintenance cost Generate consumer preference Outlast other fasteners Versatility, strength and ease of applica tion are only three reasons why velcro systems are being used more every year by a wide range of manufacturers. Industrial-strength velcro fasteners are available as woven tapes or in the form of heavy- duty tapes and extrusions. There are also special adhesive pre-coat backings for specific applications. All velcro systems share the advantages of being lightweight, corrosion-resistant, flexible, durable, and sure to open and close in everyday use. Typical applications in the apparel indus try involve replacing snaps, hooks-ana-eyes and buttons, velcro tapes are also used on uniforms of all kinds: they function so easily that they add a safety factor where quick action and freedom from jamming are essential. The transportation industry has found velcro products ideal for securing carpets, head liners and access panels in cars, trucks, buses, RV's and aircraft. (Custom-engineered VELCRO fasteners woven of stainless steel have been developed for special applications in aerospace and areas where high heat condi- tions exist.) Makers vatnan vUtunlf of leather goods and luggage use velcro closures for their smooth fit and sleek line and for strength, adjust- jF <- ability and light weight. Makers of sporting goods o, have found that velcro fas* jfF ^ teners have toughness, flex ibility, suppleness and great tenacity. J? The functional applications for velcro fasteners are, literally, endless. For more information A about this extraordinary product and the ways it f sPe can make your pro- ^ duct even better, please write. o For Information, Circle No. 52 March 6, 1978. INDUSTRY WEEK 29 AP00025498 NEWS ANALYSIS plant rice to feed their people. or build a cement plant or a railroad or a fertilizer plant to develop their economies." con tends the National Legal Center for the Public Interest, a Washington group with pro-business leanings. On the practical level, indicates E. H. Dowd, the center's director of legal re search and planning, if NRDC and the Audubon Society win their suit, Eximbank might have to spend six to 18 months on EIS preparation for an ex port side--when speed in reaching a financing decision could well be the dif ference between a U. S. manufacturer winning or losing an overseas order. That point is picked up by Frank A. Weil, assistant secretary of Commerce for industry and trade. Impact state ments on all exports would be regarded by many foreign buyers "as just one more headache ... and if there was any alternative, they would tend to go to that." he says. CEQ view. While alarms are starting to go off among international business people. CEQ is proceeding with cool determination to put final touches on its draft regulations. That process involves accommodat ing the views of the State, Treasury, Defense, and Commerce departments, which generally have looked upon the proposal with the same fondness they would display toward a 30% budget cut. As CEQ finishes its writing task, no one seems sure how soon--or if--its proposed rules will be published in the Federal Register for business and other public comment. A lot depends upon the reaction of Stuart E. Eizenstat. one of President Carter's policy assistants. The council believes, nevertheless, that its regulations would not harm U. S. exports, which totaled $127.1 billion last year. For one thing, the EIS requirement would apply only to those goods that need a government export license. CEQ states. By the council's calculations, about 10% of all If. S. exports fall into that category, but it feels that far fewer would actually be affected since they would not constitute a "mAior" gov ernment action or produce "signifi cant" environmental effects. CEQ insists it is not trying to set up the council as the world's environmen tal policeman. Emphasizes one CEQ of ficial: "We're not imposing our stan dards on the world: we're just making the information available." She notes 21 INDUSTRY WEEK. Mirch t. 197E AP00025499 tfith Digital word processing,] you're not limited to processing words. Some word processing systems are limited, and therefore limit what you can do. Not Digital's. With our approach to word processing, your system can be used the way you want. Only a Digital word process ing system gives you the flexibility to start small with a full-capability stand-alone system; expand to multi-terminal shared logic sys tems for distributed processing; or even combine data processing and word processing, by adding termi nals, printers, and communica tions pnly when ajjjiwte' Better management decisions and sound implementation need complete information processingin sales analysis, contract prepara tion, engineering specifications, legal, personnel, and technical documentation. A Digital word processing system provides that information oy notlimiting you to just processing words. To find out more about Digital word processing, send the coupon to Digital Equipment Cv.ourippvoiraautiwonn,, Wr vouriud Pi IrWoc.Ce3sJsing, Computer Systems Group, Merrimack, New Hampshire c03054. In Canada, Digital Equipment of Canada, Ltd. Word Processing Computer Systems HID AP00025500 NEWS ANALYSIS that the impact statements (there would be two kinds, with their comprehen siveness determined by the areas of the world they applied to) would be similar to the warnings that appear on cigarette packages. An export EIS would simply provide information, not be a barrier to sale, she contends. A country which still wanted the product, despite the prospect of some adverse environmental impact, could have it. The CEQ also pooh-poohs the notion that EIS preparation would delay things long enough to lose sales. The regula tions are ``very flexible." the CEQ offi cial says. ``In general, we're not saying that you have one for every action. You have large, programmatic ones, and then you just cite them for a specific situation." To help bolster its side, CEQ likes to show off a December 1977 letter from John J. Gilligan. administrator of the Agency for International Development (AID), the State Dept, group that over sees U. S. foreign assistance. Loss of business--and a consequent loss ofjobs--has not been significant in AID'S experience with its 20-month-old program of environmental impact statements, Mr. Gilligan claims. "No project has fallen through because ofthe required environmental analyses, and. as far as we can discern, compliance with our environmental regulations may have had only minimal impact on U. S. jobs in the chemical industry as a result of the discontinuance of our financing selected pesticides." Businessmen reply that AID's ex perience can't be compared with what is likely to happen in the open mar ketplace. A government agency, they imply, does not face the competitive pressures a company must confront. Detroit senses victory in emissions battle By Chariot R. Day Jr. As if existing federal emissions and fuel economyyegulations weren't enough for the atRo industry effort to meet, another omin(s cloud now clut ters Detroit's horizonN. Concern is growing ths(he 1985 cor porate average fuel econohvy of 27.5 miles per gallon (mpg) will ndv be the ultimate federal standard, as it'Vnow advertised. "No. we don't think wave heard the last word about those 1985 100year Salute to the AMERICAN ELECTRIC UTILITY INDUSTRY Public electric utilities have played a prominent role in the growth of this nation. They have also been valued customers of Buffalo Forge, virtually since our founding in 1878. Today, our public utilities are faced with many complex prob lems as they continue to meet obligations to customers and shareholders alike. Given a fair chance, they can do the job. We, for one, wouldn't have it any other way. Buffalo Forge Company, Buffalo, N.Y. 14240. Buffalo Forge Company For Information, Circla No. 53 Mireh 9. 1978. INDUSTRY WEEK 29 AP00025501 "Wfe cut order processing time by 74% and saved $200,000 with distributed processing." U.S. Motors President Fred Gloeckner 30 INDUSTRY WEEK. Marcn 6. 197$ In other AP00025502 Excess Regulations--Count the Cost! The Impact of federal regulations on Dow Chemical U.S.A. operations during 1976 increased by more than 27 percent from the previous year and cost more than $186 mil lion, according to a study by the company. The follow-up study, launched to deter mine regulatory trends in more than 70 agencies and their impact on Dow, clas sified government regulations as either ap propriate, excessive or questionable. Of the $186 million total cost to the com pany, more than $69 million (37 percent) was considered excessive by Dow. Ques tionable regulations grew from $10 million to $14 million, up 40 percent. Costs consid ered appropriate increased 18 percent, from $87 million to $103 million. The study covered regulations mainly on the environment, health and safety and transportation. Complying with federal paperwork alone on top of the $186 million cost of meeting the regulations cost Dow $20 million in 1976. This included manpower to fill out reams of reports, Paul F. Oreffice, president of Dow U.S.A., said the excess costs eventually "translate down not only to the oonsumer, but also to American workers whose jobs are jeopardized by excessive and burden some federal regulations.'' Another company feeling the pinch has taken action. Hooker cnemicals and Plastics Corpora tion says it is laying off 100 employees in several western New York plants because growing costs for environmental protection, government regulations, taxes and energy cut Into available funds. i SUBJECT BY FORM 80/3 IREV 4/7S) OATE FILE SECTION SHE6T OF AP00025504 t Pollution War Spending By Governments Soars. By a WALLSTKECT JOCRSAL Stajf Reporter WASHINGTON- Federal, state and local spending for pollution-control 1* soaring. Tbs Cantos Bureau reported that all levels of government spent $10.2 billion on environmental quality control active tie* in their 197* fiscal years, up 14it% from 1915 and almost double tha 4Ubb% lion spent in fiscal 1971 Transfers.be tween levels of government are counted only once In the totals. Most of thru* cal years ended June 30. gnats. State spending rose 7(% trStfr tiUMsai latai goeenunentpeantien Pen.MS operations ^eot KthUMav#* AP00025505 .SJHS - \0tiiaS i 3 * j ! axva A3 xoarsns Noavoai 62 52 i? 92 52 < 22 22 !2 02 6' Si i' 9i 5. f i ji'I 01 6 8 Z 5 fi *' C/r ^ t 0 * K AP00025506 SUBSTANCE OF SUBMISSION TO EPA CANCER POLICY RULE MAKING RECORD The Environmental Protection Agency has repeatedly cited figures concerning the costs incurred by the vinyl chloride and polyvinyl chloride industries for in coming into compliance with its regulation of vinyl chloride emis sions under $112 of the Clean Air Act. To ensure that the Agency is using proper figures and in order that the actual figures could be evaluated by the industry, the following data were developed by SPI's Polyvinyl Chloride Safety Group. 1. Cost of Capital Equipment Investments Required to Conform With OSHA and EPA Vinyl Chloride Standards from 1974 to Present - in millions of dollars. OSHA EPA TOTAL VC PVC VC PVC VC PVC $19.8 158. 79.4 119. 99.2 277 2. Yearly Operating Expenses Required to Comply With OSHA and EPA Vinyl CHloride Standards from 1974 to Present - in millions of dollars. OSHA EPA TOTAL VC PVC VC PVC VC PVC 1974 $0.6 3.7 0.8 3.4 1.4 7 1975 .9 4.8 1.4 4.1 2.3 8.9 1976 1977 1.5 6.1 2.2 7.6 1.9 4.3 3.4 2.6 5.3 4.8 10.4 12.9 1978 1979 2.2 8.5 2.8 11.9 6.1 9.7 8.3 10.4 19.5 13.2 18.3 31.5 AP00025507 - 2- In the process of developing these statistics, spi also collected capacity-related information. In so doing. The Society was able to quantify the loss of capacity attri butable to the two regulations. Comparing nameplate capa city and practical operating capacity, it has been deter mined that the vinyl chloride producing industry can operate to only 93% of capacity and that the PVC industry can only operate to 89% of nameplate capacity. This reduction in capacity is due to process modifications required in order for the industry to obtain compliance with the OSHA and EPA regulations applicable to vinyl chloride. This survey was conducted by mailing a copy of a survey form to each company for the preparation of a re sponse. After the response was prepared a representative of The Society contacted each member company to gather the data. Based on the results obtained it can be stated that the foregoing data are based on responses from more than 80% of the entire vinyl chloride producing industry and over 601 of the entire polyvinyl chloride producing indus try. Should the Agency have any questions or comments regarding the foregoing, contact should be established with Mr. John R. Lawrence, Technical Director of SPI, at: Mr. John R. Lawrence The Society of the Plastics Industry, Inc. 355 Lexington Avenue New York, New York 10017 (212)573-9400 AP00025508