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A Divisions The Society of The Plastics Industry, Inc. TO: Vinyl Institute Board Members IJC Mobilization Coordinators DATE: October 5, 1993 FROM: Meredith Scheck SUBJECT: Customer Mobilization COPIES: Issues Management Committee Ad Hoc Advocacy Task Force At the last issues management committee meeting, we agreed to provide an IJC "action kit" for members to use to enlist the help of their customers on this issue. Those materials are enclosed for your use. They include: 1) A backgrounder that describes the IJC, its recommendation on sunsetting chlorinebased feedstocks and the implications of that recommendation for the vinyl industry. 2) A model letter that you can use or adapt to contact and enlist the help of your customers. It briefly explains the IJC, the significance of the Windsor meeting, and asks them to become involved in the effort to fight the IJC's recommendation to sunset chlorine-based industrial feedstocks. 3) The model letter asks customers to write to their state legislators, their governors and the IJC commissioners. To help them do this, your kit also contains: a) Two additional model letters -- one each to a legislator or a governor, and one to the IJC commissioners. b) Talking points customers can use to write their own letters to these individuals. Writing an original letter takes more effort, but is more effective than a form letter. We encourage you to solicit as many original letters as possible. c) Names and addresses for each of the governors, and federal legislators in the Great Lakes states.* d) Names and addresses for each of the current IJC commissioners. 4) I have also enclosed an economic impact summary from the Charles River study. All materials are designed so that you can easily reproduce and mail them to your customers. Please enlist as many customers as you feel appropriate. Obviously, customers who have operations in the Great Lakes region (including Ontario and Quebec) are the most logical targets. After the Windsor meeting, we may want to expand this effort to other states. Please call me if you have any questions, or if we can assist you further. * If you need the names and addresses of state legislators, please call me. CTL006542 Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (201) 890-9299 Fax # (201) 890-7029 mB#/mg Vminyl W m Institute The International Joint Commission's Recommendation to "Sunset" Vinyl A Division of The Society of The Plastics Industry, Inc. Background The International Joint Commission is a bi-national organization established in 1909 by the U.S. and Canadian governments. Its primary charter is to set common water quality goals between the two countries for the Great Lakes region. In April 1992, the IJC issued its sixth biennial report on Great Lakes water quality, which focused on those lake contaminants known as persistent toxic substances. It also presented ways to reduce their presence in the lakes to zero. In that report, chlorine-based chemicals, and particularly chlorine-based industrial feedstocks, were identified as a major source of persistent toxic substances, and the recommendation was made to begin "sunsetting" their use in the Great Lakes region (Recommendation Seven). At its upcoming meeting (October 21-24, 1993) the IJC's Virtual Elimination Task Force will present a report that describes a procedure for implementing the process of sunsetting. The IJC is expected to issue a final recommendation on the sunsetting of chlorine-based chemicals after it receives a variety of information and comment at this meeting. Any recommendations that the IJC makes do not have the force of law, but could be used as a model to draft legislation or implement regulations at the state, federal or provincial level. Why the vinyl industry vigorously objects to the IJC's recommendations, especially Recommendation Seven: Vinyl (polyvinyl chloride, or PVC), is the largest chlorine-based product and therefore a primary target in the IJC's campaign to eliminate persistent toxic substances from the Great Lakes. However, vinyl is not a persistent toxic substance and its manufacture and use do not represent a threat to the environment of the Great Lakes region, nor to the wildlife and humans that live there. Here are some of the reasons why the vinyl industry objects to the IJC's plan to sunset chlorine-based industrial feedstocks as outlined in its 1992 report: The report treats all chemicals within a class the same, regardless of the safe performance history of individual products within the class. Vinyl is one of those products with a demonstrated record of safe production and use. The report acknowledges, but deliberately chooses to ignore, that harmful effects have not been established for many of the substances it examines. Vinyl is one of those substances for which the IJC does not establish, with any scientific validity, harmful effects. The report erroneously concludes that chlorine-based manufacturing is an uncontrollable process and that the environmental impact of that process is unknown and unpredictable. To the contrary, the manufacture of vinyl chloride and polyvinyl chloride is a sophisticated and well-understood process that is entirely predictable and controllable. All of the by-products are known and quantifiable. In fact, one independent consultant, ICF Incorporated, characterized Recommendation Seven as "overly broad and not supported by analysis of risk and costs, including net environmental costs." CTL006543 -more- Wayne Interchange Plaza II 155 Route 46 West Wayne, NJ 07470 (207) 890-9299 Fax # (201) 890-7029 Page 2 Why Is Vinyl Being Targeted For Virtual Elimination? In recent years, certain environmental groups have pushed for the elimination of various chlorine-containing products, claiming that their manufacture represents a threat to human health and the environment. But the evidence these groups present to support their campaign against chlorine relies either on bad science or emotional rhetoric. Because it represents a large percentage of chlorine usage, vinyl has been singled out in these attacks. In fact, Greenpeace has admitted in public meetings that vinyl is merely a piece in its "chess game" against the entire petrochemical industry. More facts about vinyl's environmental performance: The overall vinyl production process has a 99+ percent conversion rate. By-products are either contained, neutralized, recycled or incinerated, or disposed of in an environ mentally approved manner. Vinyl is a highly efficient user of energy and feedstocks. For instance, it takes about half the energy to make PVC sewer pipe as it does to make other plastic pipe, and about a third the amount it takes to make cast iron pipe. In its 1992 lifecycle comparison of various packaging materials, Chem Systems found vinyl to be the material with "the lowest production energy and carbon dioxide emissions, and the lowest fossil fuel and raw material requirements of the plastics studied." Vinyl chloride, the raw material used to make vinyl plastics, is one of the most studied and carefully regulated chemical substances in use today. There are strict controls in place to measure and limit all environmental emissions. Those controls, along with voluntary efforts undertaken by industry, have virtually eliminated any health hazards to workers and plant-site communities. Since the 1970s, the industry has reduced its VCM emissions in the U.S. more than 95%. What are the consequences of eliminating the production and use of vinyl? In April 1993, the consulting firm of Charles River Associates, Boston, looked at the cost to replace vinyl with alternative materials in fourteen major applications and markets. The study calculated the amount of material needed to maintain the same market share currently held by vinyl in each application. It also estimated, where appropriate, the capital cost to build new capacity or convert existing capacity to produce that material or fabricate end-products from it, and considered any incremental or additional costs to install the material compared to the current cost to install the vinyl product. The study found that the cost to replace vinyl in these markets would require an additional investment of $974 million in new equipment and cost consumers $6.7 billion more per year to purchase substitute materials. The vinyl industry contributes $4 billion to the U.S. economy each year and operates 1,008 plants in the Great Lakes states alone, where approximately 60% of its employment is concentrated. Eliminating vinyl would shut down this business, and have serious implications for customers in hundreds of markets, including health care, communications, aerospace, automotive, retailing, textiles, construction, durable goods and agriculture. -more- CTL006544 Page 3 Even more important are the societal benefits at risk by eliminating the use of vinyl. A few examples: Pipe made from it economically delivers pure water to places that have never had this basic necessity; PVC irrigation pipe helps increase crop yields, and studies have shown that PVC pipe is less expensive to install and maintain than competitive materials. Medical goods and pharmaceutical packaging made from vinyl help provide a higher, safer standard of health care. Wiring made from it makes electrical service safer and more dependable. Construction products made from it make housing more affordable. Packaging made from it reduces food spoilage and waste, and helps package designers create innovative "downsized" packaging that reduces landfill waste. The industry's position The vinyl industry is proud of its environmental performance and welcomes an examination of its record. Any such review, however, should be based on sound science and conducted in the public interest. The IJC's recommendations, as currently formulated, will not improve the Great Lakes environment and does society a disservice by potentially restricting the use of products that have demonstrated their value for years. September 1993 CTL006545 Note to VI members: This letter is designed for you to send to your customers. Feel free to modify the contents to fit your particular situation and customer relationship. Dear: In just a few weeks, a event of enormous significance to the vinyl industry is going to take place. The event is the seventh biennial meeting of the International Joint Commission, the group that is responsible for identifying activities that the U.S. and Canadian governments can undertake to improve water quality in the Great Lakes region. Recently, the group has focused its attention on eliminating persistent toxic substances from the Great Lakes. Through an involved (and not very scientific) process, the IJC has decided that chlorine-based products constitute the main source of those persistent toxics. We have been unable to convince the Commission to reconsider this position, or to subject it to a thorough, scientific examination. As a result, on October 21, the IJC will meet in Windsor, Ontario, to consider a recommendation to "sunset" the manufacture and use of chlorine-based industrial feedstocks in the Great Lakes region. What's this mean to our industry? Obviously, as the largest chlorine-based industrial feedstock, vinyl is the main target of this effort. Moreover, while the IJC can only make recommendations, not law, legislators can, and there's a real possibility one of them might try to do so using the IJC's recommendation as justification. That's why I'm writing to you today. First, even at this late hour, we need to make the IJC's commissioners aware of the severe economic impact this recommendation could have on the Great Lakes region. Thousands of jobs and hundreds of companies could be at stake as the result of something that is not based on sound science and which would do little to improve the quality of the Great Lakes environment. Second, it's important that your state legislators know about this issue and its potential impact. We need them to voice their concerns to the commissioners as well. With this letter. I'm asking you to write your state legislator, your governor and the IJC, and protest this action. Materials are enclosed to assist you in this activity. Feel free to adapt them to your own particular situation. At (name of company), we're doing the same thing. Hopefully, if enough of us speak out against this recommendation, we'll be able to stop it from influencing legislation. If we do nothing, we'll have only ourselves to blame. (First name of customer), I know you're busy. We all are. But I assure you, nothing else demands your attention as much as this report. Thanks in advance for your support of our efforts, and please call me if you'd like to discuss this issue further. Sincerely, CTL006546 Draft letter for legislators and governors. Provided as a model only. Please adapt this to vour own circumstances and put as much of the letter as possible in your own language. Dear Senator/Representative/Assemblyman/Govemor: My company is located in (name of city and state), employs XXX people and pays wages totally SXXXXX. In just a few weeks, a event is going to occur that may put my company out of business. The event is the seventh biennial meeting of the International Joint Commission, the group that is responsible for identifying activities that the U.S. and Canadian governments can undertake to improve water quality in the Great Lakes region. Recently, the group has focused its attention on eliminating persistent toxic substances from the Great Lakes. Through an involved (and not very scientific process), the IJC has decided that chlorine-based products constitute the main source of those persistent toxics. Unfortunately, this is not true and industry has been unable to convince the Commission to closely examine the science that would prove it. Instead, on October 21, the IJC will meet in Windsor, Ontario, to consider a recommendation to "sunset" the manufacture and use of chlorine-based industrial feedstocks in the Great Lakes region. My company relies (very heavily/entirely) on (one/a number) of those chlorine-based feedstocks for (most/all) of its production. This recommendation could have a (serious/fatal) impact on my business, our employees, their families, and our entire community, and would not do anything to enhance the quality of our environment here in the Great Lakes region. The impact in our state would be even greater statewide, over (number) jobs are connected to the chlorine industry, and we generate (dollars) in wages. If this recommendation goes forward, all of that could be lost, without justification. Industry has tried very hard to present its story to the IJC commissioners and their staff. However, little of that information appears to have been considered in their move toward virtual elimination. This is a grave injustice to the people and companies that strive every day to operate in an environmentally responsible manner. While the IJC cannot make laws to eliminate the products my company uses and makes, state legislatures can. And I am concerned that the recommendation coming out of the Windsor meeting will be used to formulate such a law in (name of state). Therefore, I am asking your help to make sure that such legislation does not surface in (name of state capital) and that any effort to improve Great Lakes water quality by limiting or eliminating specific industrial products will have the full, serious, scientific hearing it deserves. If the IJC's pending actions concern you as much as they concern me, I also hope you will take the time to express your concern to the commissioners directly. Our economy is a fragile one, and I do not believe it can withstand the type of assault this recommendation represents. I have enclosed a brief backgrounder on this issue for your information, and would be happy to provide more if you're interested. Thank you for giving this issue your most serious attention. Sincerely, CTL006547 Draft letter for IJC commissioners. Provided as a model only. Please adapt this to your own circumstances and put as much of the letter as possible in your own language. Dear Commissioner My company is located in (name of city and state), and I am deeply concerned about the recommendation to sunset chlorine-based industrial feedstocks, which you will be considering at your upcoming biennial meeting. This recommendation could have a serious impact on my business, our employees, their families, and our entire community, and it would not do anything to enhance the quality of our environment here in the Great Lakes region. My company employs (number) people, but the impact in our state would be even greater: statewide, over (number) jobs are connected to the chlorine industry, and we generate (dollars) in wages. If your recommendations go forward, all of that could be lost, without justification. I know that industry has tried very hard to present its story to you and your staff. However, little of that information appears to have been considered in your move toward virtual elimination. This is a grave injustice to the people and companies that strive every day to operate in an environmentally responsible manner. I hope you allow industry to state its case again at your meeting in Windsor, and that you will seriously reconsider your recommendation to sunset chlorine-based industrial feedstocks. Our products make an important contribution to society, and their elimination will do nothing to improve our environment. Sincerely, CTL006548 Vinyl Industry Response to the IJC Talking Points for Legislative/Regulatory Correspondence Here are some suggested points about the IJC's plan to recommend the phase-out of chlorine-based products that you can include in your letters to your state legislators, your governor and the IJC commissioners: The IJC's recommendation to sunset chlorine-based industrial feedstocks would eliminate most applications for vinyl plastic, a product that has been safely produced and used for over 50 years, and is found in hundreds of industrial and consumer goods. According to a recent study conducted by Charles River Associates, about XXX jobs in (name of your state) could potentially be lost if this recommendation were adopted. This includes those workers at the (name of your company) facility in (name of city or location). (See the attached fact sheet for economic data that pertains to your state.) Much of the IJC report is based on questionable science, and many specific recommendations are incorrectly based on broad generalizations. The recommendation to phase out chlorine-based industrial feedstocks is a good example of this. Banning the manufacture of vinyl products is unlikely to achieve the water quality objectives the IJC hopes to achieve. Moreover, it would deprive society of many valuable products that help make life safer and healthier, and contribute to an enhanced standard of living. The vinyl industry has invested millions of dollars to make sure that its products are manufactured safely. It is one of the most stringently regulated industries and operates safely throughout the Great Lakes region. Before the IJC proceeds further with this process, the concept of virtually eliminating any chlorinebased product needs to be subjected to a thorough scientifically based analysis that examines the economic, societal, human and environmental impacts. Additional points for legislators and governors: This issue is of extreme importance to this state's future welfare. I need your assurance that you will monitor it closely and will take action to make sure that legislation based on these ill-conceived ideas does not develop in (name of state). Please join my company in voicing your concerns about the work of the IJC as it relates to virtual elimination. A letter or phone call from your office expressing concern to the commissioners would be enormously helpful. CTL006549