Document x1v3p3Zb43M38bDgbGRjz4r8J

> COPIES TO: VU ISCS AIR PROD VAFG 032661C07* 161bEDT ZCZC WAYNE PA 3-19-74 PMS MR JOHN H STENDLR ASSISTANT SECRETARY OF LABOR A. 0. T. R. 0. /A. w. H. DEPARTMENT OF LABOR ROOM 311S 14TH AND CONSTITUTION AVENUE N W WASHINGTON, 0 C 23 210 BT WE HAVE CAREFULLY REVIEWED THi "RECOMMENDED OCCUPATIONAL HEALTH STANDARD FOP THE MANUFACTURE OF SYNTHETIC POLYMER FROM VINYL CHLORIDE* MARCH 11, 197 4". OUF CONCLUSION IS THAT WE WOULD BE UNABLE TO COMPLY WITH THE RECOMMENDED STANDARDS AMD.WOULD THEREFORE HAVE NO ALTERNATIVE PUT TO SHUT DOWN BOTH OF OUR PVC PLAINTS* ONE AT CALVERT CITY, KENTUCKY AND THE OTHER AT PACE, FLORIDA. IN SUCH AM EVENT THE IMMEDIATE AND DIRECT CONSEQUENCES WOULD BE* A. A'"REDUCTION IN FORCE" OF NEARLY 300 feMPLOYLES. 0. BETWEEN 230 AND 330 CUSTOMERS WOULD BE WITHOUT OUR SUPPLY OF PVC AND COMPOUND. C. NO FURTHER NEED FOR 220,300,000 POUNDS PER YEAR OF VINYL CHLORIDE MONOMER. WE BELIEVE A SIMILAR SITUATION WOULD EXIST WITH ALL U- S- ' POLYVINYL CHLORIDE PRODUCERS. OBVIOUSLY THE ECONOMIC IM PACT OF SUCH ACTIONS WOULD BE ENORMOUS. IN VIEW OF THE TREMENDOUS STRIDES BEING MADE IN THE RE DUCTION OF WORKER liXPOSURE, VE STPONGLY URGE YOUR. CARE FUL CONSIDERATION OF OUP PREVIOUS RECOMMENDATIONS AND SUG- *L RULE MAKING PROCEDURES BE FOLLOWED* R. Adams T* Barr L. Carey Fleming D. Kramer K. McMillan n. Smlxfi L. Watson MANUFACTURING AIR PRODUCTS AND CHEMICALS, INC. b EXECUTIVE MALL 650 E SVElfcSFORD ROAD * VAYN E, P M?' 1 9307 BND/XMA -5 a*' NNNN ACCEPTED 30000 1 -PC A. tv. l\ X AP00035271