Document xzjj97ZLLEjym42akrb0ja2KQ

CRAC-55 CHEMICAL MANUFACTURERS ASSOCIATION Minutes of Meeting Chemical Regulations Advisory Committee CMA General Conference Room 2501 M Street, NW Washington, D.C. 20037 Wednesday April 28, 1982 9:30 a.m. - 2:20 p.m. Members Present Company E. Hamilton Hurst (Chairman) F. . Bentley Bruce H. Brubaker Earl G. DeWitt Fred D. Hoerger Harold K. Latourette Dean E. Leib August B, Lindquist John P. McCarthy Thomas W. Mooney (Part Time) Robert Polack Barbara J. Price Curtis W. Smith Carl W. Umland Nalco Chemical Company Texaco Chemical Company Diamond Shamrock Corporation Ethyl Corporation The Dow Chemical Company FMC Corporation Rohm and Haas Company Stauffer Chemical Company Koppers Company, Inc. The Procter & Gamble Company Reilly Tar & Chemical Company Phillips Petroleum Company Shell Chemical Company Exxon Chemical Americas Invited Guest John Craddock (Part Time) Monsanto Company - CMA Staff Present D. Christopher Cathcart Stacia A. Davis Robert J. Fensterheim (Part Time) Timothy F. O'Leary (Part Time) H. Christopher Nolde - (Part Time) Randal P. Schumacher (Part Time) Janet A. Steel (Part Time) ******** * CMA 083348 CRAC Minutes Page Two April 28, 1982 Action Items CRAC will propose a letter for CMA to send to EPA recommending ` a two-year sunset provision for automatic Section 8(d) reporting. CRAC members will review memoranda on automatic Section 8(a) and 8(d) reporting and will send their comments to Janet Steel prior to the May 19, CRAC meeting. B. Price (Phillips Petroleum) will keep CRAC members informed on API's program on xylenes and toluene which are in ITC's list of chemicals designated for testing. The Testing Task Group will consider the propriety of ITC designating three esters (resembling DEHP) for testing. H. Hurst (Nalco) will talk with J. Todhunter or D. Clay (both of EPA) regarding release of draft EPA documents for comment prior to publishing in the Federal Register. R. Schumacher will see if other EPA Assistant Administrators are limiting release of EPA draft documents. CRAC members will review the legal aspects of a "quick release" procedure for certain PMN chemicals under Section 5 of TSCA. The members will provide their comments to C. Smith or C. Cathcart prior to the May 19, CRACmeeting. - CRAC approved the IATG proposal for obtaining an outside consulting firm to conduct phase I of the CRAC survey project. C. Smith (Shell), H. Latourette (FMC), C. Cathcart and R. Sussman (C & B), will meet with Ed Klein (EPA) on May 13, to discuss the "delayed trigger" and "quick release" issues. CRAC members will review the memoranda on EPA's proposed "delayed - trigger" Section 5(e) order and a proposed CMA recommendation that EPA use a Section 5(e) order and a significant new use rule T for controlling new chemical development. Members will send thexr comments to C. Cathcart prior to the May 19, CRAC meeting. - B. Brubaker will send D. Leib a copy of a questionnaire EPA sent to hexachlorobutadiene manufacturers and processors regard ing use practices. CMA 083349 ......i I CRAC Minutes page Three April 28, 1982 R. Schumacher and C. Catheart will arrange a luncheon for the next CRAC meeting. C. Cathcart will forward CRAC's recommendation that PCBs be viewed as an industry-wide issue to CMA's officers for appro priate action. 1. Chairman Hurst convened the meeting at 9:30 a.m. 2. CRAC members approved the March 17, 1982, meeting minutes with the following change: page 3, item 3.B. "intergrated'* should be "inte grated" . 3. Special Announcements A. The following individuals have been appointed to the Chemical Regulations Advisory Committee for the term June 1, 1982, thru May 31, 19B5: 1. Calvin Benning, Essex chemical Corporation 2. J. Ronald Condray, Monsanto Company 3. Anthony Di Battista, CIBA-GEIGY Corporation 4. Gerald A. Hapka, E. I. du Pont de Nemours & Co. 5. Thomas J. Robichaux, Petrolite Corporation E. Hamilton Hurst will serve as committee chairman, and Thomas W. Mooney will serve as vice chairman. B. Gordon Strickland has been named Deputy Technical Director. Randal Schumacher assumed G. Strickland's former position as Division Director, Health, Safety, and Chemical Regulations. Christopher Cathcart assumed R. Schumacher's former position as Staff Executive to the Chemical Regulations Advisory Committee. Timothy O'Leary is now Staff Executive to the Regulatory Impact Special Committee. C. B. Price briefed CRAC members on American Petroleum Institute's program on xylenes and toluene. Both are on the ITC-'s list of chemicals designated for testing. She will keep CRAC members advised as additional information becomes available. D. H. Hurst indicated that EPA (at least the Office of Pesticides 1. and Toxics Substances) continues to withhold from the public draft documents for comment prior to Federal Register publica i tion. H. Hurst will talk to Don Clay or John Todhunter (both of i EPA) about this problem. R. Schumacher will determine whether other EPA Assistant Administrators adhere to this EPA policy. "**" T ' CMA 083350 * CRAG Minutes Page Jour April 28, 1982 E. R. Schumacher and C. Cathcart will arrange a luncheon for the next CRAC meeting. 4. Reporting Task Group Report -- D. Leib A. The final Section 8(a) reporting rule was sent to the Administrator EPA, for signature. EPA and OMB are still negotiating the Section 8(d) rule. EPA might publish the rule in the Federal Register by mid-July, CRAC members will review the memoranda on automatic Section 8(a) and 8(d) reporting and provide their comments to J. Steel prior to the May 19, CRAC meeting. CRAC proposes that CMA send EPA a letter recommending a two-year sunset provision for automatic Section 8(d) reporting. B. B. Brubaker expressed concern about EPA sending a questionnaire to hexachlorobutadiene manufacturers and processors. EPA may have circumvented TSCA and the Paperwork Reduction Act. He will send a copy of the questionnaire to D. Leib. 5. Testing Task Group Report -- J. Steel A. CRAC agreed with the following proposed EEC language change modi fying the minimum pre-market data draft OECD decision language: "....that the Minimum Pre-Marketing Set of Data (MPD), together with its provisions for flexible application set forth as inte gral parts of this text in the Annex to this Decision, can serve as a basis for a meaningful first assessment of the potential hazard of a chemical to health and environment." B. CRAC approved the draft CMA comments on an EPA project to develop test data reporting formats, and recommends that the comments be forwarded to EPA. C. T. mooney and C. Smith will consider a set of questions developed by F. Hoerger. The questions deal with issues on existing chemicals (excluding testing). They were developed as a result of F. Hoerger meeting at the Conservation Foundation, which addressed voluntary testing. D. The Testing Task Group will consider the propriety of ITC desig nating three esthers (resembling DEHF) for testing. 6. Control Regulations Task Group Report -- C. Smith A, C. Smith learned from Ed Klein of EPA, that publication of the proposed PMN exemption rule for low-volume chemicals and CMA 083351 I T CRAC Minutes fage Five April 28, 1982 site-limited intermediates may be delayed until EPA clears the proposed PMN exemption rule for polymers. B. CRAC members will review the memorandum on EPA's proposed "delayed trigger" Section 5(e) and a proposed CMA recommendation that EPA use a Section 5{e) order and a SNUR for controlling new chemical development. Members will send their comments to C. Cathcart prior to May 19. C- CRAC will review the memorandum concerning the legal aspects of a "quick release" procedure for certain PMN chemicals under Section 5. members will send their comments to C. Smith or C. Cathcart prior to May 19. D. C. Smith (Shell), H. latourette (FMC), C. Cathcart, and R. Sussman (C & B) will meet with Ed Klein of EPA, on May 13, to discuss the "delayed trigger" and "quick release" issues. 7. Communications Task Group Report -- B. Price CRAC members decided not to hold the June 17, CRAC TSCA Informational Meeting. The next Informational Meeting is tentatively scheduled for September 16, at the Ramada Renaissance Hotel in Washington, D.C. PCB Briefing John Craddock of Monsanto, briefed CRAC on the CMA PCB program. He explained that SFAC believes incidentally generated PCBs should be considered a broad-based industry issue and submitted as a priority item to the CMA Executive Committee. CRAC agreed to support SPAC on this issue. C. Cathcart will forward CRACs position to CMA's officers for appropriate action. Impact Analysis Task Group Report -- C. Umland CRAC members agreed to commit $20,000 to complete phase I of the ques tionnaire. The questionnaire is intended to survey chemical companies' activities to reduce unreasonable risk. Phase I includes developing a management plan and reviewing the draft questionnaire. CSIN Task Group Report - A. B. Lindquist Due to insufficient time, a CRAC decision on the proper "Information Systems under TSCA" will be deferred to the next CRAC meeting. I .i CMA 083352 ----j CRAC Minutes Page Six April 28, 1982 11. Legislative Update -- C. Nolde There are no new developments in Congress on TSCA. Congressman Florio continues to be occupied by other matters including RCRA, Superfund, Ground Water, the Clean Air Act debate, and general over sight of EPA and its budget cuts. 12. State Activities Update -- B. Brubaker H. B. 841, which would alter the burden of proof in occupational diseases covered under workman's compensation, passed the House in Ohio. It does not appear the bill will go any further this year. 13. H. Hurst reminded the members that the next CRAC meeting is scheduled for May 19, at 8:30 a.m. 14. The meeting was adjourned at 2:20 p.m. CRAC members were invited to stay for a special presentation on EPA's program Integration Project (PIPJ. The presentation was made by Walt Kovalick and covered inte grating EPA activities on toxic chemicals. Minutes subject to approval. DCC:pja C01 051082 Associate Director Health, Safety and Chemical Regulations '* CMA 083353 ----- ! CRAC-56 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting Ramada Renaissance Hotel Board Room 1143 New Hampshire Avenue, Washington, DC 20037 NW Wednesday May 19, 1982 8:30 AM - 3:05 PM Member s Present E. Hamilton Hurst (Chairman) F . E. Be n t ley George Y. Brokaw Ear 1- G . Dewitt Fred Hoerger H. K. Latourette Dean E. Leib A . B. Lindquis t John P. McCar thy T. W. Mooney Robert Polack Barbara J. Price Curtis W. Smith Carl w. Urnland Nalco Chemical Company Texaco Inc. Tennessee Eastman Company Ethyl Corporation The Dow Che mi cal Company FMC Corporation Rohm Haas Company Stauffer Chemical Company Koppers Company, Inc. Procter Gamble Company Reilly Tar Chemical Co. Phillips Petroleum Company Shell Chemical Company Exxon Chemical Americas Invited Guests J. Ronald Condray Gerald A. Hapka T. J. Robichaux Monsanto Company E. I. du Pont de Nemours Company Petrolite Corporation CMA Staff Present D. Christopher Cathcart Geraldine V. Cox (part-time) Stacia Davis Le Blanc George W. Ingle (part-time) H. Christopher Nolde Timothy F. O'Leary (part-time) Robert A. Ro.land (part-time) Randal P. Schumacher Janet A. Steel Gordon D. Strickland (part-time) *** CMA 083354 ......1 C RAC Minutes Page Two May 19, 1982 ACTION ITEMS The Repor ting Task Group will prepare and distribute a newsletter explaining the May 13, Federal Register notice, "TSCA Chemical Substances Inventory, Intent to Remove Certain Incorrectly Reported Substances." The Repor ting Task Group will develop a position for CMA regarding the proposed TSCA Section 8(c) rule. The CSIN Task Group will distribute to CRAC revised copies of its paper, "Information Systems Under TSCA." The task group will seek CRAC's approval to forward the paper to Dr. John Todhunter, EPA. Upon EPA's announcement of a proposed low-volume chemicals and site-limited intermediates PMN exemp tion rule, - the Communications Task Group will send out a newsletter outlining CMA's position and requesting member companies to develop comments and submit them directly to EPA; and - the Control Regulations Task Group will establish a workshop with CSMA and SOCMA to develop coordinated industry responses to the proposed rule. C. Cathcart will contact the approptiate staff executives of those associations to arrange the workshop. The Control Regulations Task Group will develop a' letter for CRAC approval to inform EPA that CMA does not support the TSCA Section 5(e) "delayed trigger" pr oposal. H. Hurst will present the CRAC survey concept to the CMA Executive Committee on June 2. Upon approval by the CMA Executive Committee, the Impact Analysis Task Group will initiate the pilot survey phase; this effort will be coordinated with CSMA and SOCMA. R. Schumacher will inform the CMA Communications Committee of the CRAC survey concept. s. Davis leBlanc will review draft CMA comments on the EPA proposed PCB rulemaking to ensure that they are consistent with previous CMA positions. CMA 083355 C RAC Minutes Page Three May 19, 1982 All CRAC task group chairmen will review and update their task group charters and provide copies to C Cathcart prior to the CRAC Steering Task Group meeting on June 16. C. Cathcart will provide a CMA activities orientation to new CRAC members, C. Benning and T. Robichaux on June 15. ***** Chairman Hurst convened the meeting at 8:30 a.m. 2. CRAC members approved the April 28, 1982, meeting minutes with the following changes: A. Page 3, item 3.A., . . will serve as vice chairman." should read . . . will serve as vice chairman for 1982-1983; and B. Page 4, item 5.D., "esthers" should be esters. 3. Special Announcements A. An ad hoc work group composed of Control Regula tions, Reporting and Testing Task Group members will begin discussing the existing chemicals control policy for EPA. The new CRAC Existing Chemicals Task Group will assume this activity. B. C. Cathcart will provide a CMA activities orienta tion to new CRAC members C, Benning and T. Robichaux on June 15. The other new CRAC members are alreaay familiar with CMA. 4. Reporting Task Group Report -- D. Leib A, A final TSCA Section 8(a) rule has not been releas ed. The TSCA Section 8(d) rule is still in red ' border review. B. The task group will prepare and distribute a news letter explaining the May 13, Federal Register notice, "TSCA Chemical Substances Inventory, Intent to Remove Certain Incorrectly Reported Substances," The notice indicated 27 substances were incorrectly CRAC Minutes Page Four May 19, 1982 reported, but only 15 were listed. will follow-up on this with EPA. The task group C. The Depar tient of Commerce and Department of Sta te are reviewing a U.S. Hazardous Goods Exports Policy, The document has not been signed. D. Publication of a TSCA Section 8(c) rule is unlikely this year. The task group will develop a proposed recommendation to EPA (e.g., requesting the Agency to withdraw the rule). E. The task group) raised the question of industry liability to report toxicity data intiated by other government agencies to EPA under TSCA Section 8(e). CRAC decided not to elevate this as an issue. 5. Testing Task Group -- T. Mooney A. The task group welcomes comments from CRAC members regarding generic concerns raised in EPA's proposed test rule for diethylenetriamine (April 29, Federal Regis ter ) . 6. CSIN Task Group Repor t -- R. Lindquis t A. The task group wi Tl' distribute to CRAC revised copies of its paper, "Information Systems Under TSCA." The task group believes that the Chemical Information System (rather than CSIN) currently operating in EPA, meets Congress' intent. Upon CRAC * s approval the paper will be sent to Dr, John Todhunter, EPA. B. The Data Quality Workshop Planning Committee is re vising its draft report and will send a final copy to CRAC. C. The CSIN Task.Group recommended to CRAC that it disband upon completion of its paper. That activity would be monitored by a work group under the Repor ting Task Group. CRAC accepted the recommendation. A CMA 083333557 1 CRAC Minutes Page Five May 19, 1982 7. Control Regulations Task Group Report -- C. Smith A. The low-volume chemicals and site-limited inter mediates proposed PMN rule should be released for publication in the Federal Register in a few weeks. In anticipation of that notice, the CRTG plans to establish a workshop with CSMA and SOCMA to develop coordinated industry responses. C. Cathcart will contact the appropriate staff executives of those associations to arrange the work shop. The wor kshoo will meet no later than July 13. B. The Communications Task Group will prepare a news letter outlining CMA's position and requesting member companies to develop comments and submit them directly to EPA. C. At this time, CRAC decided not to recommend to EPA a "quick release" procedure for certain PMNs under Section 5. D. The CRTG will prepare a letter for CRAC approval informing EPA that CMA does not support the TSCA Section 5(e) "delayed trigger" proposal. 8. Impact Analysis Task Group Report -- C. Umland A. CRAC voted to support the survey plan and to proceed with the pilot survey. The pilot will involve 30 to 50 companies and will cost approximately 524,000. CRAC Minutes Page Six May 19, 1982 B. The EPA Adminis tr ator, Anne Gor such, addressed a SOCMA luncheon meeting on April 2. Her views on TSCA appear to be more in accord with Congressional intent than the previous Administration's. C. Congressman Gore's House Science Subcommittee will hold a hearing on EPA's decision not to take pri ority action against formaldehyde under Section 4(f) of TSCA. The hearing is scheduled for May 20. 10. PCS Update -- S. Davis Le Blanc A. Sufficient funding exists to develop comments through the entire rulemaking process. Comments on the first proposed rule are due May 24. The publication of the second proposed rule is imminent. B. The law firm of Kirkland and Ellis will help the project panel prepare the comments. CMA's Legal Department will review the proposed comments to ensure they are consistent with previous CMA positions. 11. CRAC Future Activities -- H. Hurst A, CRAC approved the following task groups: Task Groups Chairmen ! Steering T. Mooney Control Regulations C. Smith Existing Chemicals F. Hoerger Repor ting R. Condray Impact Analysis j. McCar thy Communications B. Pr i c e The CSIN Task Group will disband. The Reporting Task Group will monitor that activity. The Planning and Audit Task Group will disband. Those functions will be assumed by the new Steering Task Group. B. The Steering Task Group is composed of all CRAC task group chairmen. The task group chairmen will review and update their task group charters. They will provide copies to C. Cathcart prior to the CRAC Steering Task Group meeting on June 16. ^4 CMA 0813333559 I ~| CRAC Minutes Page Seven May 19, 1982 12 * Next Meeting H. Hurst reminded the members that the next meeting is scheduled for June 16, at 9:30 a.m. 13. The meeting was adjourned at 3:05 p.m. Associate Director Health, Sa-fety and Chemical Regulations Minutes Subject to Approval DC C:bal 060782 CMA 083360 CRAC 57 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advis or y Committee Minutes of Meeting CMA Board Conference Room A 2501 M Street, NW Washington, DC 20037 Wednesday June 16, 1982 9:30 AM - 2:30 PM Members Present E. Hamilton Hurst (Chairman) Calvin J. Benning Bruce P. Brubaker J. Ronald Condray Gerald A. Hapka Fred D. Hoerger H. K. Latourette John P. McCarthy T. w. Mooney Barbara J, Price T. J. Robichaux Curtis w. Smith Nalco Chemical Company Essex Corporation Diamond Shamrock Corporation Monsanto Company E. I. du Pont de Nemours & Company .The Dow Chemical Company FMC Corporation Koppers Company, Inc. Procter & Gamble Company Phillips Petroleum Company Petrolite Corporation Shell Chemical Company CMA Staff Present D. Christopher Cathcart Stacia Davis Le Blanc Robert J. Fensterheim (part-time) H. Christopher Nolde (part-time) Timothy F. O'Leary (part-time) Randal P. Schumacher (part-time) Janet A, Steel (part-time) ACTION ITEMS* The CRAC task groups will review their charters and have them ready for committee approval at the August CRAC meeting. The CRAC task group staff executives will ensure that the charters conform to a consistent format. CRAC Minutes June 16, 1982 Page Two T. Mooney, F. Hoerger, R. Condray and C. Cathcart will propose an agenda, place and time for a CRAC retreat. -V The Communications Task Group will invite Don Clay, EPA, to have lunch with CRAC members at the July 21 meeting. The Testing Task Group will develop comments on EPA's proposed test rule for diethy1enetriamine . H. Hurst will contact Don Clay (EPA) to request CMA opportunity to comment on TSCA Section 4 testing guidelines before they are published by the National Technical Information Service. The Existing Chemicals Task Group will prepare comments on EPA's proposed TSCA Section 4 rule for test cost reimbursement. The comments will be developed jointlyvith the Impact Analysis Task Group. The Reporting Task Group will develop comments on a draft version of EPA's final rule under TSCA Section 8(d). CRAC approved the CSIN Task Group's paper, "Informa tion Systems Under TS'CA" and will send it to EPA. The Reporting Task Group will follow the EPA CSIN activity. On June 21 the Impact Analysis Task Group will send the CRAC pi lot survey to 22 CMA members who have agreed to participate in this initial effort. J. McCarthy and T. O'Leary will meet with CSMA and SOCMA Staff to arrange final details of their participation in the survey. CRAC will review a draft letter regarding EPA's pro posed "limiting" TSCA Section 5(e) order. Comments should be sent to C. Cathcart by June 25. Upon ap proval of the letter, C. Cathcart will forward it to Don Clay, EPA. CMA 083362 --1 CRAC Min ure s June 16, 1982 Page Three CRAC members will develop positions recommending polymer systems which should be eligible in EPA's. proposed polymer FMN exemption rule. Their comnents and supporting data will be sent to C. Cathcart prior to the July 19 Polymer Work Group meeting. The Testing Task Group will review the mutagenicity and human health effects concerns in the draft ERA PMN exemption rule for low-volume chemicals and sitelimited intermediates. C. Cathcart will ask the AIRC Science Committee if it has a position on these issues. The impact Analysis Task Group will review the risk assessment and economic impact segments of the rule. These groups will provide responses to C. Cathcart prior to the July 20 New Chemicals Task Group meeting. The New Chemicals Task Group will arrange an informa tion exchange meeting with other trade associations on July 29. The subject will be the proposed PMN exemption rules. * #*** 1. Chairman Hurst convened the meeting at 9:30 AM. 2. The May 19, 1982, CRAC meeting minutes were approved with the following change: add Testing Task Group and Chairman T. Mooney to paragraph 11A. 3. Steering Task Group Report -- T. Mooney A. The CRAC task groups will review their charters and have them ready for committee approval at the Auqust CRAC meeting. The task group staff executives will ensure that the charters conform to a consistent format. B. CRAC agreed to hold a retreat in the fall or early winter. T. Mooney, P. Hoerger, R. Condray and C. Cathcart will propose an agenda, place and time. 4. Testing Task Group Report -- T. Mooney A. The task group will develop comments on EPA's pro posed test for diethylenetriamine. Comments are due June 28. A key question is whether the Agency CMA 083363 --! CRAC Minutes June 16, 1982 Page Four can require testing under TSCA Section 4 where there are no meaningful techniques. B. The EPA TSCA Section 4 guidelines have gone to the National Technical Information Service for publica tion. Copies will not be publicly available until August. H. Hurst will talk to Don Clay about CMA opportunity to comment on these guidelines before they are published. 5. Existing Chemicals Task Group Report -- F. Hoerger A. The task group will prepare comments on EpA' s proposed TSCA Section 4 rule on test cost reimbursement. The comments will be developed jointly with the 1ATG. B. Jeanette Wiltse (EPA) expects to complete her exist ing chemicals project for Don Clay by mid-June. She indicated portions of her project will be available . for review outside EPA. 6. Reporting Task Group Report -- R. Condray A. The Reporting Task Group will work with the Communi cations Task Group to convey reporting procedures information regarding the TSCA Section 8(a) rule to CMA member companies. The task group is planning a section 8(a) workshop for the CRAC information meeting in September. B. The task group will develop comments on a draft ver sion of EPA's final rule under TSCA Section 8(d). This version appeared in the May 21 issue of Inside EPA EPA plans to require automatic reporting of health and safety studies whenever ITC designates certain chemicals for TSCA Section 4 testing. C. The Departments of State and Commerce recommended ` changes to the US policy on hazardous exports. The report could imply that TSCA be amended. The key issue is export-specific (TSCA 12(b) rule) versus generic reporting. 7. pcb Update -- S. Davis Le Blanc EPA proposed a rule on June 8 which would exempt all closed and controlled incidental PCBs from regulation "1 CRAC Minutes June 16, 1982 Page Five if owners certify that "no quantifiable releases" into the environment result from their use. Comments are due by July 8. The CMA Special Programs PCB Panel is developing the comments. . 8. Legislative Update -- C. Nolde A Th e Humane Care and De velopment of substitutes for Animals in Re search Act -- H.R. 6245 -- was cleared by a House Science Subcommittee. However, the funding was cut. B. There are no forecasted TSCA oversight activities. 9. Chemical Substances Information Network (CSIN) Task Group Report -- J. Steel A. CRAC approved the CSIN Task Group's paper, "Informa tion Systems Under TSCA" and will send it to EPA. B. Having accomplished its mission the task group will disband. The Reporting Task Group will follow the EPA CSIN activity. 10. Impact Analysis Task Group Report -- J. McCarthy On June 2 the CMA Executive Committee approved the CRAC pilot survey project. The committee wants the histori cal questions separated from the main questionnaire and organized as an appendix. The IATG made the change. On June 21 the task group will send the pilot survey to 22 CMA members who have agreed to participate in this ef fort. J. McCarthy and T. O'Leary will meet with CSMA and SOCMA staff to arrange final details of their participation in the survey. 1 1 . Control Regulations (New Chemicals) Task Group Report - C . Smith A. CRAC will review the draft letter which suggests to EPA that its "limiting" TSCA Section 5(e) order concept is inconsistent with the Act. Comments are due to C. Cathcart by June 25. Upon approval, the letter will be sent to Don Clay, EPA. B. CRAC members will develop positions recommending polymer systems which should be eligible in EPA's proposed polymer PMN exemption rule. Their comments CMA 083365 T CRAC Minutes June 16, 1982 Page Six and supporting data will be sent to C. Cathcart prior to the July 19 Polymer Work Group meeting. C. The Testing Task Group will review the mutagenicity and human health effects concerns in the draft epa PMN exemption rule for low-volume chemicals and sitelimited intermediates. C. Cathcart will ask the AIHC Science Committee if it has a position on these issues . The Impact Analysis Task Group will review the risk assessment and economic impact segments of the rule. These groups will provide responses to C. Cathcart prior to the July 20 New Chemicals Task Group meeting. D. The task group will arrange an information exchange meeting with other trade associations on July 29. The subject will be the proposed PMN exemption rules . 12. Communications Task Group Report -- B. Price The task group will invite Don Clay (EPA) with CRAC members at the July 21 meeting, he discuss the proposed reorganization of Toxic Substances. to have lunch and suggest that the Office of 13. CRAC Budget Update -- C. Cathcart CRAC Minutes June 16 , 1982 Page Seven 15. The meeting adjourned at 2:30 PM. >her Cathcart 'Associate' Director Health, Safety and Chemical Regulations Minutes Subject to Approval DCC:bal 070882 CMA 083367 T CRAC-SC CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting CMA Terrace Conference Room 2 S 01 M Street, NW Washington, DC 20037 Wednesday July 21, 1982 9:35 AM - 3:40 PM Members Present E. Hamilton Hurst (Chairman) Calvin J. Benning George Y. Brokaw Bruce H. Brubaker J, Ronald Condray Earl G. DeWitt Anthony Di Battista Gerald A, Hapka Fred Hoerger John P. McCarthy T. w. Mooney Curtis w. Smith Invited Guests Don Clay Marcia Williams Nalco Chemical Company Essex Chemical Corporation Eastman Kodak Company Diamond Shamrock Corporation Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E. I. du Pont de Nemours S Company The Dow Chemical Company Koppers Company, Inc. Procter & Gamble Company Shell Chemical Company U.S. Environmental Agency U.S. Environmental Agency Protection Protection CMA Staff Present D. Christopher Cathcart Geraldine V. Cox (part-time) Robert J. Fensterheim (part-time) H, Christopher Nolde (part-time) Timothy F. O'Leary (part-time) Randal P. Schumacher (part-time) Janet A. Steel Gabrielle H. Williamson CRAG Minutes Page Two July 21, 1982 ACTION ITEMS The Steering Task Group will provide at the August committee meeting a concrete proposal for a CRAC retreat. The Testing Task Group will review and comment on the Data Interpretation Guidelines. Comments are due Oc tobe r 31, J. Steel will send CRAC the TSCA Section 8(c) docu ment acquired at the July 8 ATSAC meeting. The Testing Task Group will review the Section 8(c) documents paying particular attention to the economic analysis. It will consider providing comments to ATS AC. The Reporting Task Group will develop an agenda for a TSCA Section B(a) workshop to be held at the Septem ber 16 CRAC Informational Meeting. G. Hapka, C. Smith and J. Steel will rework the lan guage regarding EPA's definition of processor in the proposed TSCA Section 8(a) comments. C. Smith, G. Williamson and C, Cathcart will meet with EPA officials to discuss the Subcommittee on Commerce, Transportation and Tourism of the House Committee on Energy and Commerce requested access to all information on PMNs submitted under TSCA Section 5(a). On July 29 members of the New Chemicals Task Group will meet with representatives of other trade associ ations (API, SPI, SOCMA, CSMA, NPCA) to discuss the two proposed PMN exemptions rules for site-limited intermediates, low-volume chemicals and polymers. H. Hurst will testify for CMA before the Senate Sub committee on Toxic Substances and Environmental Over- sight on August 4, 1982. The Subcommittee will hold an oversight hearing on EPA's implementation of TSCA. G. Hapka, E. Dewitt, B. Price and B. Brubaker will comprise a work group to develop a written testimony for the hearing. CRAC will review and comment on the draft by July 29. CMA 083369 CRAC Minutes Page Three July 21, 1982 H. Hurst, C. Smith, G. Ha pka , T. Mooney, C. Cathcart and C. NoIde will hold a hearing preparation session with Michael Scott and Pat Waldo of SOCMA. ' C. Smith will invite Ed Klein, EPA, to have lunch with CRAC at the August 18 meeting. *** 1. Chairman Hurst convened the meeting at 9-.30 AM. 2. The June 16, 1982, CRAC meeting minutes were approved with the following change: on page 1, Bruce P. Brubaker should read Bruce _H. Brubaker. 3. steering Task Group Report -- T. Mooney The task group is planning a CRAC retreat for November. Task group members have suggested that the retreat be held in conjunction with a CRAC meeting. The proposed agenda will focus on future planning and take a fresh look at the CRAC charter. The task group will provide concrete proposal for the CRAC retreat at the August committee meeting. 4. Testing Task Group Report -- T. Mooney A, The task group will meet with Mr. Steven NevburgRinn, EPA, on August 10 to discuss his negotiated testing document. B, The task group will review and comment on the Data Interpretation Guidelines. The guidelines are for each of the tests included in the MPD battery. Comments are due October 31. C, The task group recommended and CRAC agreed to continue supporting the June 1982, proposal "can serve as a basis for" in the MPD decision language T. Mooney will relay the decision to the IAG. D CRAC approved the Testing Task Group charter. CRAC Minutes page Four July 21, 1982 5. Reporting Task Group Report -- r. Condray A. The task group will develop an agenda for a TSCA Section 8(a) workshop to he held at the September 16 CRAC Informational Meeting. B. CRAC reviewed the draft comments on the proposed amendments to the final Section 8(a) rule. Concern was expressed about the definition of processor in the preamble of the rule. G. Ffapka, C. Smith, and J. Steel will rework the language in draft comments regarding EPA's definition of processor. C. J. Steel will send CRAC the TSCA Section 8(c) documents which were distributed to the public at the ATSAC Meeting. D. The task group will review those Section 8(c) docu ments paying particular attention to the economic analysis. It will consider providing comments to ATSAC. 6. New Chemicals Task Group Report -- C, Smith A. . c. Smith, G. Williamson and C. Cathcart will meet with EPA officials to discuss the Subcommittee on Commerce, Transportation and Tourism of the House Committee on Energy and Commerce requested access to all information on PMNs submitted under TSCA Section 5(a). B. On July 29 members of the task group will meet with representatives of other trade associations (API, SPI, SOCMA, CSMA, NPCA) to discuss the two proposed PMN exemptions rules for site-limi ted intermediates, low-volume chemicals and polymers. 7. Legislative Update -- C. Nolde A, H. Hurst will testify for CMA before the Subcommit tee on Toxic. Substances and Environmental Oversight of the Senate Environmental Public Works Committee. On August 4, the Subcommittee will hold an over sight hearing on EPA's implementation of TSCA focusing on negotiated testing; the PMN process in general and CMA's exemption petition; section 8(a) reporting; and international harmonization (OECD/MPD). 1 CMA 083371 ^ CRAC Minutes page Five July 21 , 1982 B. G. Hapka, E. Dewitt, B. Price and B. Brubaker will comprise a work group to develop a written testi mony for the hearing. CRAC will review and comment on the draft by July 29. C. H. Hurst, C. Smith, G. Hapka, T. Mooney, C. Cathcart and C. Nolde will hold a hearing preparation session with Michael Scott and Pat Waldo of SOCMA. 8. State Activities -- B. Brubaker B. Brubaker reported on the following state proposed rules : Hew York Assembly Bill 11917 -- to establish indus trial chemical survey on types of raw materials used, stored, manufactured or transported; California Assembly Bill 726 requires employers to respond in writing within three working days to written requests by employees for information re garding whether a work condition is dangerous to employees ; Rhode Island 7813 Registration -- creates a regis tration system for industries engaged in potential ly hazardous procedures; and Michigan Regulation 5762C -- concerns employee medical record and trade secrets. 9. Existing Chemicals Task Group Report -- F. Hoerger A. The task group is circulating the EPA concept paper on risk management advisories to CMA Special Programs panels for their views on this voluntary negotiated approach to controlling risk. B. The task group will review draft comments on the proposed EPA test cost reimbursement rule at its ' next meeting, 10. Communications Task Group Report -- C. Cathcart C. Smith will invite Ed Klein, EPA, to have lunch with CRAC at the August 18 meeting. CRAC Minutes Page Six July 21, 1982 11. Impact Analysis Task Group Report -- J. McCarthy The IATG recommended and CRAC authorized the additional ' funding of 33,700 for costs associated with Phase II of the pilot survey. These costs were incurred in resolv ing the CMA Executive Committee's concerns about the survey. 12. The meeting adjourned at 3:40 PM. Christopher Cathcart Associate Director Health, Safety and Chemical Re gu la ti on s Minutes Subject to Approval DCC:bal 081082 CMA 083373 CRAC-59 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting CMA Board Conference Room B 2501 M Street, NW Washington, DC 20037 Wednesday August 18, 1982 9:40 AM - 3:35 PM' Members Present E. Hamilton Hurst (Chair man) George Y. Brokaw Bruce H. Brubaker J. Ronald Condray Earl. G. DeWitt Anthony Di Battista Gerald A. Hapka H. K. Latourette John P. McCarthy T. W. Mooney Barbara J. Price T. J. Robichaux Curtis W. Smith Nalco Chemical Company Eastman Kodak Company Diamond Shamrock Corporation Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E. I. du Pont de Nemours & Compan y FMC Corporation Koppers Company, Inc. Procter & Gamble Company Phillips Petroleum Company Petrolite Corporation Shell Chemical Company Invited Guests Edward Klein Margaret Stasikowski U.S. Environmental Agency U.S. Environmental Agency Protection Protection R. Sussman (part-time) Covington & Burling CMA Staff Present D. Christopher Cathcart Stacia Davis Le Blanc H. Christopher Nolde (part-time) Timothy F. O'Leary (part-time) Randal P. Schumacher (part-time) Langley A. Spurlock (part-time) Janet A. Steel (part-time) * CMA 083374 CRAC Mi flutes Page Two August 18, 1982 ACTION ITEMS H. Hurst, B. Price and C. Cathcart will develop and implement a plan to convey CMA's position on TSCA as stated at the oversight hearing -- that it should not be amended at this time -- to top EPA officials. T. Mooney and C, Cathcart will select a location for the November CRAC planning meeting and report to CRAC. T. Mooney will develop a plan to let EPA know CRAC's concerns regarding coordination difficulties between the Health and Environmental Review Division and the Test Rules Development Branch. The Testing Task Group will review and critigue OECD's Data Interpretation Guidelines. S. Davis le Blanc will inquire as to the Interagency Testing Committee's (ITC) capability to handle con fidential business information. The Testing Task Group will comment on the testing issues raised in the PMN exemption rules. The New Chemicals Task Group will send draft com ments on the low-volume, site-limited intermediates to CRAC for its review prior to the September CRAC meeting. A work group was formed to develop and implement a plan to market the need and benefits of the PMN exemption rules to various audiences. Members are H. -Hurst, B. Price, C. Smith, C. Umland (Exxon) and C. Cathcart CRAC will send comments to EPA on its proposed test cost reimbursement rule. CRAC will send a letter to Don Clay (EPA) outlining CMA's concerns about the inclusion of certain chemicals in the final Section 8(a) rule. . CRAC will send comments to ATSAC on EPA's Section 8(c) concept paper. CMA 083375 CRAC Minutes Page Three August 18, 1982 The Reporting Task Group will review the Section 8(e) issues raised by EFA in the recent American Cyanamid case. The Impact Analysis Task Group (IATG) will review the economic analysis and risk assessment positions of the PMN exemption rules, and will provide input for comments by the New Chemicals Task Group. The IATG will review the economic portion of EPA's proposed test cost reimbursement rule. It will provide its input for comments to the Existing Chemicals Task Group. T. Mooney will invite a member of the Interagency Testing Committee to join CRAC at its September meeting. 1. Chairman Hurst convened the meeting at 9:40 AM. 2. The minutes of July 21, 1982, CRAC meeting were approved with the following change: page 3, paragraph 4.D., should read: "CRAC reviewed and commented on the Testing Task Group Charter." 3. Legislative Update -- C. Nolde On August 4, Senator Slade Gorton's (R-Wash.) Subcom mittee on Toxic Substances and Environmental Oversight (Committee on Environment and public Works) held a hear ing on TSCA Oversight. Hamilton Hurst, Vice President of Nalco Chemical Company, testified on behalf of CMA. Michael Scott, General Counsel of Mooney Chemicals, appeared on behalf of SOCMA, and EPA's Dr. John Todhunter, NRDC's Jackie Warren and CP's Terry Davies also testified. . The hearing went smoothly for CMA and we accomplished our objectives in providing a balanced review of the accomplishments of EPA in recent months. The issues raised were the ones we expected and there were no sur prises, Chairman Gorton learned of the real progress the Agency has made in implementing TSCA, and particu larly the advantages to the public and EPA, as well asu * CMA 083376 CRAC Minutes Page Four August 18, 1982 to industry, that will result from negotiated testing programs and PMN exemptions. This was strictly an oversight hearing, and the Subcommittee apparently sees no need at this time to consider amendments to TSCa. Ah work group consisting of H. Hurst, B. Price and c. Cathcart will develop and implement a plan to convey CMA's position on TSCA as stated in the oversight hearing -- that it should not be amended at this time to top EPA officials. -- 4. PCS Update -- S. Davis Le Blanc CMA urged EPA to withdraw the second proposed regulation on closed and controlled waste processes, given the in adequacy of the Agency's specification of analytical methods to determine nonquantifiahility. CMA proposed that EPA establish a 50 ppm or higher regulatory cutoff. The Agency must report to the court on November 1, 1982, on the uncontrolled PCB generation proposal. CMA main tains that risks posed by incidental generation are de minimis. 5. Steering Task Group Report -- T. Mooney A. CRAC approved the Steering Task Group charter. B. CRAC approved the Task Group's committee retreat proposal (attached)^. The retreat is scheduled for November 17-19, and will be held in conjunction with a CRAC meeting. T. Mooney and C. Cathcart will select a location for the retreat and report to the committee. 6. Testing Task Group Report -- T. Mooney A. CRAC approved the Testing Task Group charter. B. The task group met with Messrs. Steven NewburgRinn, Douglas Bannerman, and Joe Merenda (EPA), to discuss a way of notifying companies of ITCdesignated chemicals early. . C. T. Mooney will develop a plan to let EPA know CRAC's concerns regarding coordination difficulties between the Health and Environmental Review Divi sion and the Test Rules Development Branch. 1 < j i ' j j I j L CMA 083377 CRAC Minutes Page Five August 18, 1982 D. The task group will review and critique OECD's Data Interpretation Guidelines. Comments are due to EPA by October 4, 1982. , E. S. Davis Le Blanc will inquire into ITC's capabil ity to handle confidential business information (CBI). CRAC believes the ITC needs access to data containing CBI in order to effectively designate chemicals for further testing. F. The Testing Task Group will comment on the testing issues raised in the PMN exemption rules. The New Chemicals Task Group will include these issues in CMA's comments to EPA. 7. New Chemicals Task Group Report -- C. Smith A. The task group plans to send draft comments of the low-volume, site-limited intermediates to CRAC for its review prior to the September CRAC meeting. B. A work group was formed to develop and implement a plan to market the needs and benefits of the PMN exemption rules to various audiences. Members are C. Smith, H. Hurst, B. Price, C. Uml&nd (Exxon) and C. Cathcart 8. Existing Chemicals Task Group Report -- J. Steel CRAC approved the comments (with changes) regarding EPA's proposed test cost reimbursement rule. Comments are due to EPA by September 2, 1982. 9. EPA's Program Integration Project (PIP) Update -E. DeWitt E. DeWitt will meet with Walt Kovalick (EPA) on August 18 to discuss PIP. 10. Reporting Task Group Report -- R. Condray A. CRAC approved the Reporting Task Group's charter (with changes). B. CRAC plans to send a letter to Don Clay (EPA) out lining CMA's concerns about the inclusion of cer tain chemicals in the final Section 8(a) rule. I CRAC Minutes Page Six Augu st 18, 1982 C. CRAC will send comments to ATSAC regarding EPA's Section 8(c) concept paper. D. The task group will review the Section 8(e) issues ,, raised by EPA in the recent American Cyanamid case . 11. Impact Analysis Task Group Report -- J. McCarthy A. To date, 19 out of 20 CMA member companies (and one member each from SOCMA anti CSMA) have completed the pilot survey. The task group is evaluating the results of the pilot survey. B. The task group will review the economic analysis and risk assessment portions of the PMN exemption rules, and provide input for comments by the New Chemicals Task Group. C. The task group will review the economic portion of EPA's proposed test cost reimbursement rule, and provide input for comments by the Existing Chemicals Task Group. 12. Communications Task Group Report -- C. Cathcart A. The CRAC Informational Meeting brochure was mailed August 13. * B. T. Mooney will invite a member of the Interagency Testing Committee to join CRAC at its September mee ting. 13. The meeting adjourned at 3:35 PM. *6. Christopher Cathcart Associate Director Health, Safety and Chemical Regulations Minutes Subject to Approval 090782 ii y;; i DCC:bal i Attachment CMA 083379 * "T CRAC-60 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting CMA Terrace Conference Room 2501 M Street, NW Washington, DC 20037 Wednesday September 15, 1982 9:00 AM - 3:10 PM Members Present E, Hamilton Hurst (Chairman) C. J. Banning George Y. Brokaw J* Ronald Condray Earl G. Dewitt Anthony Di Battista Gerald A. Hapka Fred Hoerger H, K. Latousette John P. McCarthy T. w. Mooney Barbara J. Price Curtis W. Smith Nalco Chemical Company Essex Chemical Corporation Eastman Kodak Company Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E> I* du Pont de Nemours & Company The Dow Chemical Company FMC Corporation Koppers Company, Inc. Procter fi Gamble Company Phillips Petroleum Company Shell Chemical Company Invited Guests Martin Greif Carl W. Umland Interagency Testing Committee Exxon Chemicals America CMA Staff Present D. Christopher Cathcart Robert J. Fensterheim (part-time) Thomas J. Gilroy (part-time) Stacia Davis Le Blanc H, Christopher Nolde (part-time) Randal P. Schumacher (part-time) Langley A. Spurlock (part-time) Janet A. Steel (part-time) **** ------t- CMA 083380 CRAC Minutes Page Two September 15, 1982 ACTION ITEMS CMA will forward comments to EPA by October 4 re garding the proposed PMN exemption rules for lowvolume chemicals, site-limited intermediates and polymers. The CMA Communications Department will distribute copies of the PMN exemptions information package to members of the press in Washington, DC and New York City. The CMA Government Relations Depa r traen t will dis tribute copies of the PMN exemptions information package to selected members of Congress and staff * C. Cathcart wilL apprise SPI, CSMA and SOCMA of CRAC's position on the polymers PMN exemption rules. CRAC will forward comments to EPA by September 29 regarding the Agency's change in policy concerning the substantiation of confidentiality claims for information contained in PMNs. C. Nolde plans to seek Hill staff judgment on how we best proceed on various TSCA issues. R. Fensterheim and 5. D. Le Blanc will prepare a paper addressing the scope of future CMA involvement in the PCS issue. The paper will be given to CRAC on or before the October CRAC meeting. On October 4, K. Hurst will recommend to the CMA Executive Committee that it approve the proposal to initiate the full CRAC survey. T. Mooney will invite Mr. Irwin Baumel, Director, HERD, EPA, to meet with the CRAC members at the. October committee meeting. C. Cathcart will distribute to CRAC an information package about the November Committee Retreat. 033381 CRAC Minutes Page Three September 1 5 1982 1. Chairman Hurst convened the meeting at 9:00 AM. 2. ` The minutes of the August 18, 1982, CRAC meeting were approved 3. Communications Task Group Report -- B. Price All arrangements for the September 16 CRAC Information Meeting have been made. 4. EPA's Program Integration Project Update (PIP) -- E. DeWitt On August 18, E. DeWitt met with Walt Kovalick, Project Director for PIP to discuss that program. His office, which deals primarily with chemical-specific issues, tries to ensure that draft rules are consistent with other statutes. E. DeWitt will provide an update on this EPA project every other month. 5. Hew Chemicals Task Group Report -- C. Smith A. CRAC approved the comments on the low-volume, site-limited PMN exemption rules with some edito rial changes. In addition, it approved the Poly mers Work Group's recommended major changes in EPA's approach to PMH exemption for polymers. The work group advised CRAC that the current BPA pro posal would be of little value to industry unless substantial changes are made (see attached memo randum). C. Cathcart will apprise SPI, CSMA, and SOCMA of CRAC's position on the polymers PMN ex emption rule. CRAC will forward comments on both PMN exemption rules by October 4. B. CRAC approved the concept of distributing a PMN exemption information package to selected audien ces. The CMA Communications Department will dis tribute copies of the package to members of the press in Washington, DC, and New York City. The Government Relations Department will distribute copies to selected members of Congress and staff. C. CRAC will forward comments to EPA by September 29 regarding the Agency's change in policy on the substantiation of confidentiality claims for in formation contained in PMNs (47 Fed. Reg. 28969). CMA supports EPA's decision to eliminate advance --, CMA 083382 V. CRAC Minutes Page Four September 15t 1992 substantiation of confidentiality claims for pmn information. Legislative Opdate -- C. Nolde A. The PMN exemption information package will go to selected members of Congress and staff. The pack ages should be released the same time CMA submits its comments to SPA. B. Industry ha3 lost ground on several issues lately. Congress appears to be sending industry a message. C. Nolde plans to seek Hill staff judgment on how CRAC should proceed with various TSCA issues. PCB Opdate -- R. Feasterheim R. Fensterheim and S. D. Le Blanc reviewed the status of the three PCB rules. They will prepare a paper ad dressing the scope of future CMA involvement in the PCS issue. The paper will be given to CRAC on or before the October CRAC meeting. Testing Task Group Report -- T. Mooney A. Several work groups have been formed to review and comment on the OECD Data Interpretation Guide lines. U.S. State Department and EPA will be responsible for collating all D.S. comments for submission to the OECD. B. EPA officials believe that coordination will be improved between the Agency's Test Rules Develop" sent Branch and the Health and Environmental Heview Division- This was accomplished by shiftin'? some of the workload between these groups. C. The tJ.S. state Department will soon forward an official response regarding the MPD revision language to EEC. Existing Chemicals Task Group Report -- F, Hoerger A. F. Hoerger and J. Steel will meet Jeanette wilts and Joe Merenda CEPA) , on September 15 to discus3 the Agency's planned assessment activities on existing chemicals. CMA 083383 "1 CRAC Minutes Page Five September 15 1982 B. The task group is reviewing chemical hazard in formation profile documents for 1,3-dichloropropane and neopentyl glycol diglycidyl ether. The members are reviewing these documents to gain at better understanding of the Agency's thinking in developing this type of assessment document. C. CRAC approved the Existing Chemicals Task Group's charter . 10. Impact Analysis Task Group Report -- J. McCarthy A. The results of the pilot survey were good. How ever, the historical data did not appear to be worth pursuing. B. CRAC voted to proceed with the full survey, H. Hurst will present to the CMA Executive Committee on October 4 a proposal to conduct the full survey. 11. Reporting Task Group Report -- R. Condray A. J. Steel presented CMA's comments on ERA *s Section 8(c) concept paper to ATSAC on September 9. B. There is concern that if the State and Commerce Departments proceed with their hazardous export policy, EPA may interpret that the policy would require amending TSCA. CMA has been advised (by outside counsel) that the matter could be handled administratively. Members of the CMA Internation al Trade Committee and the Reporting Task Group will meet to develop a strategy to handle this matter. 12. Steering Task Group Report -- T. Mooney A. The Hotel Hershey, Hershey, PA, was selected for the site of the November CRAC Retreat. C. Cathcart will distribute to CRAC an information package regarding the retreat and ho tel. B. T, Mooney will invite Mr. Irwin Baumel, Director, HERD {EPA) , to met with the CRAC members at the October committee meeting. CRAC Minutes Page Six September 15, 1932 13. Mr. Martin Greif, Executive Secretary, Interagency Testing Committee (ITC) met with members of CRAC. - Greif explained how ITC functions and specifically 'it designates chemicals for further testing. Mr. how 14. The meeting adjourned at 3:10 PM. Minutes Subject to Approval 101382 DCC : bal Attachment Associate Director Health, Safety and Chemical Regulations CMA 083385 I --i CRAC-61 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting CMA Terrace Conference Room 2501 M Street, NW Washington, DC 20037 Wednesday October 20, 1932 9s 35 AM - 3:10 PM Members Present E. Hamilton Hurst (Chairman) C. J. Banning Bruce H. Brubaker J. Ronald Condray Earl G. DeWitt Anthony Di Battista Gerald A. Hapka Fred Hoerger H. K. Latourette John P. McCarthy Barbara J. Price T. J. Robichaux Curtis W. Smith Nalco Chemical Company Essex Chemical Company Diamond Shamrock Corporation Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E. Z. du Pont de Nemours fi Company The Dow Chemical Company FMC Corporation Koppers Company, Inc. Phillips Petroleum Company Petrolite Corporation Shell Chemical Company Members Absent George Y. Brokaw T . w. Mooney Eastman Kodak company Procter Gamble Company CMA Staff Present D. Christopher Cathcart Robert J. Fensterheim (part-time) Stacia Davis L Blanc (part-time) H. Christopher Nolde (part-time) Timothy F. O'Leary (part-time) David F. Zoll (part-time) ** action items C, Nolde will seek to obtain copies of papers re cently approved by the House Democratic Caucus. The papers challenge the "unreasonable" test on chemical ri sk. CMA 083386 1... CRAC Minutes Page Two October 20, 1982 C. Smith and C. Cathcart will follow-up on the stat us of the OTA PMN data study with Ed Klein (EPA), and Michael Gough (OTA). CRAC members will review draft CMA comments on the proposed OMB rule to implement the Paperwork Reduc tion Act of 1980 and give their views to S. Le Blanc by October 22. e CRAC members will review draft CMA comments respond ing to EPA's final T5CA Section 8(a) Asbestos Rule. Members will bring their responses at the next crac meeting. e The Reporting Task Group will draft a Toxic Substan ces newsletter addressing the status of EPA's guid ance on TSCA Section 8(d) reporting. R. Condray will contact Doug Bannerman (EPA) to de termine when the Agency will distribute a question and answer fact sheet on Section 8(d) reporting. e Members of the Existing Chemicals Task Group will contact various EPA officials to get their views on an existing chemicals program. e CRAC members will actively urge prospective CMA/CRAC survey participants to complete the survey. T. O'Leary and C. Cathcart will send a letter to CMA member company TSCA contacts urging them to partici pate in the CMA/CRAC survey. e A panel of CMA representatives will participate in EPA's informal hearing on the proposed PMN exemption rules. C. Smith will serve as panel moderator and H. Hurst will present CMA's statements. e H. Hurst and B. Price will ask EPA's Notice ReviewBranch officials to give their presentation of the PMN review process to additional industry audiences. e Each CRAC member will propose the three most impor tant issues facing his/her company over the next two years dealing with chemical regulations and product safety. Each issue will be presented on a single page. CRAC members will bring 22 copies of each issue with them to the CRAC retreat. CMA 083387 "T ft m CRAC Minutes _ e Three ober 20, 1982 T. Mooney, H. Hurst and C. Catficart will complete during the week of November 1, the November CRAC meeting and retreat agenda. C. Cathcart will revise and distribute to CRAC ' copies of the CMA computer printout of CRAC issues. *** 1. Chairman Hurst convened the meeting at 9;35 AM. 2. The September 15, 1982, CRAC meeting minutes were approved. 3. Report on the Public Health Compensation Issue -- D. zoll The CMA Executive Committee is scheduled to decide CMA's involvement in this issue. The potential impact on industry and the Association could be substantial* 4. Legislative Ppdate -- c. Nolde A. TSCA is not expected to be an oversight issue in the "lame-duck" session expected to begin November 29 and end December 17 or thereafter. Any of the fol lowing issues could be considered during this ses sion: Clean Air, Clean Water, and Patent Term Res toration, Regulatory Reform, RCRA, and FIFRA. B. c. Nolde will seek to obtain copies of papers re cently approved by the House Democratic Caucus. The papers challenge the "unreasonable" test on chemical risk. C. C. Smith and C. Cathcart will follow-up on the status of the OTA PMN data study with Ed Klein (EPA} and Michael Cough (OTA). tn a previous telephone conversation, Gough told Cathcart that CMA and other interest groups will be able to review the study *prior to its release to the Florio subcommittee. 5. Testing Task Group Report -- c. Cathcart A. Despite EPA assurances, it appears that the Test Rules Development Branch (Newburg-Rinn) and Health and Environmental Review Division (Baumel) are still a t odds. The task group will continue to approach Don Clay (EPA) to resolve the problem. CMA 083388 T 1 CRAC Minutes Page Four October 20, 1982 ' j 1 , 3. CRAC reviewed and concurred with an overview policy s taternent regarding the OECD Data Interpretation Guidelines (DIGS 1 . The I AG prepared the policy statement for use at the OECD November High-Level Meeting. 6. Re porting Task Group -- R. condray A. CRAC members will review draft CMA comments respond ing to EPA's final TSCA Section 8(a) Asbestos Rule (see attached draft letter). Members will bring their responses to the next CRAC meeting. B. CRAC members will review draft comments on the pro posed 0M3 rule to Implement the Paperwork Reduction Act of 1980 and give their views to S. Le Blanc bv Octoher 22. c. The task group will draft a Toxic Substances News letter addressing the status of EPA's guidance on TSCA Section 8(d) reporting. R. Condray will con tact Doug Bannerman (EPA) to determine when the Agency will distribute a question and answer fact sheet on 8(d) reporting. D. The task group is preparing a paper outlining ways to improve the ITC process. There is a need to en hance industry input so that inappropriate chemical designations by ITC can be avoided. 7. Existing Chemicals Task Group Report -- F. Hoerger A. ERA does not appear to have a 'clear focus on TSCA Section 8 and existing chemicals assessment. Mem bers of the task group will contact various EPA officials to get their views on an existing chemi cals program. B. CRAC members were asked to suggest individuals who would be interested in joining the task group. C. * Committee members suggested that an individual knowledgeable about risk assessment in the insurance industry should be invited to a CRAC meeting. 3. Impact Analysis Task Group Report -- J. McCarthy The CMA Executive Committee approved the proposal for the full CRAC survey. The survey was mailed out 1:0 CMA 083389 "T CRAC Minutes Page Five October 20, 1982 all CMA members (except those who participated in the pilot survey) on October 19. CRAC members will actively urge the survey recipients to complete the survey. T. O'Leary and C. Cathcart will send a letter to all CMA member company TSCA contacts urging them to participate in the CMA/CRAC survey. 9. New Chemicals Task Group Report -- C. Smith A. On October 4, CMA filed comments on EPA's proposed PMN exemption rules for low-volume chemicals, sitelimited intermediates and polymers* On November 1, EPA plans to hold an informal hearing on the pro posed rules. A panel of CMA representatives will participate. c. smith will serve as panel moderator and H. Hurst will present CMA's statements. B. The task group developed PMN exemption information packages and distributed them to the media, selected members of Congress and staff and other trade associations. C. On October 7, EPA1 s Notice Review Branch gave a pres entation on the PMN review process to members of the IAG and CRAC. Many participants indicated that the presentation was very informative. H. Hurst and B. Price will ask EPA officials to give their pres entation of the PMN review process to additional, industry audiences. 10. States Activities Report -- B. Brubaker It appears that the New Jersey community and worker right-to-know state bill will get through the New Jersey Senate. This is viewed as the model state right-to-know bill. ' 11. Steering Task Group Report -- H. Hurst A. For the November retreat, CRAC members were urged to consider the course they wish to chart for the eommittee over the next several years. They should be particularly sensitive to the economic, legislative, . and international impacts on their companies, the chemical industry and TSCA. Bach committee member will propose the three most important issues facing his/her company over the next two years, dealing with chemical regulations and product safety. Each issue will be presented on a single page. Members CRAC Mi nutea page Six October 20, 1982 will bring 22 copies of each issue with them to the CRAC retreat and give them to H. Hurst, T. Mooney and C. Cathcart, Tuesday evening, November 16. Hurst Mooney and Cathcart will sort the issues into cate gories for presentation and discussion at the retreat. B. T. Mooney, H. Hurst and C. Cathcart will complete during the week of November 1, the CRAC meeting and retreat agenda* 12. Future Issues -- H. Hurst CMA staff has developed a preliminary computer list ing of various committee issues and associated resource costs. H Hurst reviewed the CRAC issues printout and recommended several improvements. C. Cathcart will re vise and distribute to CRAC copies of the CMA computer printout of CRAC issues. CRAC tasfc group chairmen can use these issue printouts as they guide their task groups' activities. Minutes Subject to Approval 110382 OCCibal Attachment cc: 5. Davis Le Blanc Randal P. Schumacher , H. Christopher Nolde Associate 'Director Health, Safety and Chemical Regulations CMA 083391 CRAC 62 CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Committee Minutes of Meeting Hotel Hershey Hershey, Pennsylvania . 17033 Wednesday November 17, 1982 8 s 35 AM - 1s 00 PM Members Present E. Hamilton Hurst (Chairman) George Y. Brokaw Bruce H. Brubaker J. Ronald Condray Earl G. OeWitt Anthony Oi Battista Gerald A. Hapka Fred Hoerger H. K, Latourette John P. McCarthy T, W. Mooney Barbara J. Price T. J. Robichaux Curtis W. Smith Nalco Chemical Company' Eastman Kodak Company Diamond Shamrock Corporation Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E. I.'du Pont de Nemours Company The Dow Chemical Company PMC Corporation Koppers Company, Inc. Procter s Gamble Company Phillips Petroleum Company Petrolite Corporation Shell Chemical Company Member Absent C. J. Benning Essex Chemical Company CMA Staff Present D, Christopher Cathcart . Stacia Davis Le Blanc Sandal P. Schumacher (part/time) ***** ACTION ITEMS At the next CRAC meeting, the Testing Task Group will submit its draft voluntary testing questionnaire for approval. T. Mooney, C. Umland and C. Cathcart will meet with 3, Newburg-Rinn to discuss voluntary testing issues. CMA 083392 1 --i CRAC Minutes page Two November 17, 1982 S . D Le Blanc will contact SPA' s General Counse1's office to challenge the basis that CMA does not have standing to request a generic extension of the TSCA Section 8{d) reporting rule deadline, CRAC will send a letter to EPA presenting its views on the Agency's final rule under TSCA Section 3(a) for Asbestos Reporting Requirements. The Reporting Task Group will develop an Interagency Testing Committee (ITC) designation proposal for CRAC approval at the December meeting. The Existing Chemicals Task Group will conduct an in-depth review of EPA's document, "Toxic Substances Control Act: Existing Chemicals Program, October 1982. - CRAC will file post-hearing comments regarding EPA's PMN exemption proposals. Comments are* due November 30, 1982. B. Price will contact EPA to arrange a PMN program * briefing for industry groups. CRAC members will develop TSCA reauthorization/ovarsight issues within their respective companies. They will discuss these issues at the December CRAC meeting. **** 1. Chairman Hurst convened the meeting at 8:30 AM. 2. The October 20, 1982, CRAC meeting minutes were approved, 3. Testing Task Group Report -- T. Mooney A. i The Testing Task Group is developing a brief (15 minute) questionnaire to determine how the voluntary testing process is working. The questionnaire will be sent to CMA Special Pro grams Panel chairmen and EPA representatives. The draft will be developed with L. Spurlock and the Special Programs staff's assistance. The questionnaire will be submitted to CRAC for approval at the next meeting. ------- , ] CMA 083393 CRAC Minutes Page Three November 17, 1932 B . T. Mooney, C. Umland and C. Cathcart will meet with Steven Sewburg-Rinn on November 29 to . discuss voluntary testing issues. C, The task group is developing draft comments on the OECD Data Interpretation Guidelines, Com ments are due to EPA by December 16. The task group plans to have comments to CRAC for appro val before the next committee meeting. 4, Reporting Task croup Report -- R, Condray A. CMA's request for an extension of the TSCA Sec tion 8{d) reporting deadline was denied. CMA received a verbal response indicating its re quest would not be considered because the Asso ciation was not a respondent party. S. D. Le Blanc will contact EPA's General Counsel's office to challenge the basis that CMA does not have standing to request a generic extension. B. The task group will develop an ITC designation proposal for CRAC approval at the December meeting. The proposal is designed to improve ITC listing procedures as a result of several deficiencies the task group has observed in ITC's present system. 5. Existing Chemicals Task Group Report -- F. Hoerger A On November 9, EPA released a document, en titled, "Toxic Substances Control Act: Exist ing Chemicals Program, October 1932." The document has various trigger points and flow chart/logic patterns for action. The task group will conduct an in-depth review of the document. It has requested S. D. Le Blanc and R. Sussman (Covington and Burling) to provide a legal analysis. B The task group members have contacted several EPA personnel to determine the status of the existing chemicals program. It appears that a special task force will assess existing chemi cals. The selection of chemicals will be simi lar to the ITC selection process. Presently there are chemicals under review. The task group will try to determine these chemicals' identities from EPA. CMA 083394 CRAC rtinutaa Page Pour November 17, 1982 C. CRAC will improve its common!cation/coordination efforts with the special programs Advisory Committee (SPAC) through committee members and staff. This should ensure that SPAC can effectively bring generic chemical issues to CRAC's attention. 6. Hew Chemicals Task Group -- C. Smith A. SPA seemed receptive to CMA's and other indus try representatives' comments at the Agency's November 1 public hearing on PMN exemptions. CMA will file post-hearing comments in response to EPA questions and public interest group as sertions. Comments are due to EPA by November 30. B. The task group expects to see the draft Office of Technology Assessment's study on the ade quacy of PMN data. CMA was asked to review the report. C. Editor's note: at the CRAC Retreat, C, Nclde reported that the General Accounting Office is studying the PMN process. 7. Impact Analysis Task Group Report -- J. McCarthy The task group will meet December 1S to discuss the strategy of the survey results. CRAC members are invited to attend. C. Nolde and Ms. J. Auraan (CMA Communications Department) will be present to ad dress the legislative and communications aspects of this effort. This meeting is particularly important because the TSCA reauthorization hearings could be scheduled in late February. This is earlier than originally anticipa ted. 3. PC3 iJpdate --S.D. Le Blanc CMA was granted intervenor status in the electrical equipment rule litigation. The second rule address ing closed and controlled waste manufacturing pro cesses was promulgated. The PCB Panel will petition the court to review the second rule. EPA has re quested a time extension to develop the third ru_e regarding the incidental generation of PCBs. CMA 083395 I CRAC Minutes Page Five November 17, 1982 9. EPA Program Integration Project (PIP) Update -- E. DeWitt W. Kovalick indicated that presently TSCA requires about one-seventh of PXP's efforts. He believes TSCA Section 8 should be used increasingly to gather data for action under other laws. 10. State Activities Report -- B. Brubaker The New Jersey right to know bill now has a companion bill (word-for-word) in the Assembly. In addition, the Texas Bar Association is planning a right to know bill next year. 11. Communications Task Group Report -- B. Price / B. Price will contact EPA's Notice Review Branch to arrange a PMN program briefing for industry groups. If feasible, thi3 presentation will coincide with a CRAC Informational Meeting. The meeting should be held in February. 12. The meeting adjourned at 1:00 PM. Xi. Christopher Cathcart Associate Director Health, Safety and Chemical Regulations Minutes Subject to Approval i20682 OCC:bal cc: J. Auman G. Baker S. Davis Le Blanc T, o' Leary C. Nolde S. Schumacher T I CMA 083396 I CHEMICAL MANUFACTURERS ASSOCIATION Chemical Regulations Advisory Coniittee Minutes of Meeting CMA Board Conference Room A 2501 M Street, Nw Washington, DC 20037 Wednesday December 15, 1982 9t40 AM - 4:40 PM Members Present T. W. Mooney (Vice Chairman) C. J. Benning George Y* Brokav Bruce H. Brubaker J* Ronald Condray Earl G. DeWitt Anthony Di Battista Gerald A, Hapka Fred Hoerger H. K* La tourette Barbara J. Price I, J, Robichaux Curtis W. Smith Procter Gamble Company Essex Chemical Company Eastman Kodak Company Diamond Shamrock Corporation Monsanto Company Ethyl Corporation CIBA-GEIGY Corporation E. I. du Pont de Nemours Compa ny The Dow Chemical Company FMC Corporation Phillips Petroleum Company Petrollte Corporation Shell Chemical Company Members Absent E. Hamilton Hurst (Chairman) John P. McCarthy Nalco Chemical Company Koppers Company, Inc. Invited Guests J. J. Bonin J. Kenney R. M. Sussjnan Shell Chemica 1 Company Onion Carbide Corporation Covington and Burling CMA Staff Present E. Jean Auman (part-time) R, Garrity Baker D. Christopher Cathcart Robert J. Fensterheim (part-time) Stacia Davis Le Blanc H. Christopher Nolde (part-time) Randal P. Schumacher (part-time) Gordon D. Strickland (part-time) Langley A. Spurlock (part-time) Richard L Wilson (part-time) 4 083397 CRAC Minutes Page Two December 15, 1 982 **** ACTION ITEMS J. Aaman will interview H. Hurst on December 16, for the CMA News. The interview will focus on CRAC activities under TSCA. The Steering Task Group will convene immediately after this CRAC meeting to develop a preliminary TSCA reauthorization/oversight strategy. In addi tion, it will organize itself to develop the appro priate supporting documents, such as issue papers that must be used in conection with anticipated congressiona1 hearings. These documents wi 11 be available for CRAC approval at its January 1983 neeting. e C, Cathcart will prepare a line item in CRAC's 1983/84 budget to ask for $30,000 in research and consulting fees for the CMA PCB Program Panel activ ity. The final sum to be committed will depend on the amount CRAC receives in its total fiscal year 1 983/84 budget. CRAC members will review a draft letter to be sent to J, Merenda (EPA). The letter objects to EPA's denial of CMA's request for extension of the Section 8(d) reporting deadline. CRAC members will have their comments to S. Davis Le Blanc by December 22. CRAC approved the Reporting Task Group's proposed changes to the Interagency Testing Committee (ITC) chemical designation process. The task group will develop and send its comments to EPA by early January 1983. The Existing Chemicals Task Group will develop comments about EPA's Existing Chemicals Program Report. The task group will have comments ready for CRAC review at the committee's January 1983 meeting. F. Hoerger, G. Hapka, C. Umland, S. Le Blanc and C. Cathcart will meet with D. Clay, M. Williams and J* Wiltse (EPA) on January 5, 1983. The meeting's purpose is to begin dialogue about EPA1s Existing Chemicals Program. 5 CMA 083398 CRAC Minutes Page Three December 15, 1982 CRAC approved the Testing Task Group's proposal to comment about the OECD's Data Interpretation Guide lines* Comments will be sent to EPA on December 22, 1 982. H. Hurst will brief the CMA Board of Directors on January 10, 1983. He will present CRAC's activities for 1982 and discuss the committee's future objec tives . *#** 1. Vice Chairman Mooney convened the meeting at 9:40 AM. 2. The minutes of the November 17, 1982, CRAC meeting were approved. 3. CMA Communications Program Report -- R. Wilson Mr. Richard L. Wilson, CMA Vice-President for Communications, presented CRAC an overview of CHA's communications program. Ms* Jean Atman will provide public relations/communications support to CRAC activi ties. She will interview H. Hurst on December 16 for CMA Sews. The interview will focus on CRAC activities under TSCA. 4. Legislative Update -- C. Nolde The General Accounting Office (GAO) is conducting studies about TSCA. In the House, Congressman Florio's subcommittee requested a study of the PMN review pro cess. The final report should be completed by the end of summer. In the Senate, Senator Gorton's subcommittee requested the GAO to study the legality of the voluntary testing program. The report is scheduled to be released December 22, 1982, and Is not expected to be unfavorable to EPA. 5. Steering Task Group Report -- T. Mooney CRAC spent a major part of the meeting identifying key TSCA issues which must be considered in preparing for TSCA reauthorization/oversight. The Steering Task Group will convene immediately after this CRAC meeting to develop the appropriate supporting documents such as issue papers that may be used in connnection with antic ipated congressional hearings. These documents will be available for CRAC approval at its January 1983 meeting. 6 CMA 083399 CRAC Minutes Page Four December 15, 1982 6. PCB Opdate -- R. Fens terheim The CMA PCB Program Panel needs an additiona1 $125,000 to support its efforts in fiscal year 1983/84. Specifically, the Panel requested $30,000 in research and consulting funds from CRAC. It will request the remaining $95,000 for legal fees from the CMA Legal Department. Depending on the amount of research and consulting funds CRAC receives in fiscal 1983/84, CRAC agreed to provide up to $30,000 to support the Panel's research and consulting activities. If CRAC has suf ficient funds to support the Panel, then two members of CRAC will serve as nonpaying participants on the PCB Panel. They will be from companies that are not Panel members. C. Cathcart will prepare a line Item in CRAC's 1983/84 budget requesting up to $30,000 in research and consulting fees for the CMA PCB Program Panel activity. This item will be in addition to normal CRAC budget requests. The final sum to be committed to the Panel will depend on the amount CRAC will receive in its total fiscal 1983/84 budget. 7. Reporting Task Group Report -- R. Condray A. EPA recently sent a second letter to CMA explaining its denial of the Association's request for exten sion of the Section 8(d) reporting deadline. That explanation does not appear to completely justify SPA's decision. Therefore, CMA members will review a draft letter to be sent to J. Kerenda (EPA). The letter objects to EPA's denial of CMA's request. CRAC members will have their comments to S. Le Blanc by December 22. B. CRAC approved the Reporting Task Group's proposed changes to the ITC chemical designation process* The task group will develop and send its comments to EPA by early January 1983. 8. Impact Analysis Task Group Report -- H. Latourette Eighty-eight companies have responded to the survey thus far. The IATG expects over 100 companies to re spond by the deadline. The task group and CRAC members will meet December 16 to develop the strategy for hand ling the survey data. 7 CMA 083400 CRAC Minutes Page Five December 15, 1982 9. New Chemicals Task Group Report -- C. Smith A. The task group is reviewing the Office of Technology Assessment's (OTA) draft report about the adequacy of data submitted on PMNs. The task group is developing draft comments responding to the OTA study. Comments are due to OTA in early January. B. C. Smith will be retiring soon. G. Hapka will become chairman of the New Chemicals Task Group. 10. Existing Chemicals Task Group Report -- F. Hoerger A. The task group will develop comments about EPA's Existing Chemicals Program Report. The task group will have comments ready for CRAC review at the committee's January 1983 meeting. B. F. Hoerger, G. Hapka, C. Omland, S. Le Blanc and C. Cathcart will meet with D. Clay, M. Williams and J. Wiltse (EPA) on January 5, 1983. The purpose of the meeting is to begin dialogue about EPA's Existing Chemicals Program. 11. State Activities Report -- B, Brubaker New York passed a law in its state building code to require toxicity testing of combustion fumes. Ten-other states are developing similar bills. 12. CRAC Communications Report -- B. Price A date has not been set for a PMN/CRAC information meeting. 13. Testing Task Group Report -- T. Mooney A. CRAC approved the Testing Task Group's proposal to comment about the OECD's Data Interpretation Guidelines . Comments will be sent to EPA on - December 22, 1982. B. The task group is proceeding with its voluntary/ negotiated testing survey. It is working with the CMA Special Programs staff to develop the survey. The survey will be limited to members of CMA Special Program panels and perhaps a few EPA staff. 8 CMA 083401 CRAC Minutes Page Six December 15/ 1982 14. Puture Activities -- T. Mooney H. Hurst will brief the CMA Board of Directors on January 10, 1983* He will present CRAC'a activities for 1982 and discuss the committee's future objectives. 15. The meeting adjourned at 4:40 PM. 'D. Christopher Cathcart Associa te'Director Health, Safety and Chemical Regulations Minutes Subject to Approval 010783 DCC:ba1 cc: J. Auman R. Baker S. Davis Le Blanc C. Nolde T. O'Leary R. P. Schumacher CMA 083402 9