Document yrbZYXrwbKzxvyxmZNNRJZren

TO: Distribution TgQ; JOt: ESJ: MJH: AJO: RF Interoffice Communication FROM: DATE: SUBJ: T. G. Grumbles February 15, 1990 RESPONSIBLE CARE\ENVIRONMENTAL HOUSTON: RDG MEMO OF 2/8/90 POLICY COMMUNICATIONS VtSIA IN The sed to accomplish the communication of the subject items is discussed in RDG' s memo. I have enclosed a copy of the support materials that have been sent to the plants and R&D. Although the involvement of Houston staff in some of the program areas may be less than plant personnel, the need to communicate the Company's direction and involvement in industry efforts is important. The feedback mechanism described in this package is as important to use in headquarters as the plant locations. I can assist you in the communication if you need help. .1008 Enclosure Distribution: R. J. Andersen, R. V. Dale, J. A. DeBernardi, G. G. Draper, H. R. Flammer, N. C. Frost, T. H. Huffman, G. W. Inbody, B. R. Johnson, B. E. A. Larsen, W. J. B. Vogel, V. tt. Weiss VVV 000011055 To: Plant Managers, Virgil Weis nterofflc* Communication From: Tom Grumbles Date: Feb. 2, 1990 ' 1" Subject: Environmental Policy/Responsible Care Communication Content and Timing Enclosed is a proposed communication text and overheads to help you with the introduction of Responsible Care at your location. Please call me or Mike Reynolds with your comments by Feb. 14. We will make any necessary changes and distribute final packages to you that week. At that time, you'll receive a completed script, pre pared overheads, enough survey cards for all your em ployees and copies of the vista environmental policy. You already have a plaque of the policy as well as the videotape to use with the presentation. As part of your introduction, we're asking you to col lect some feedback on your employees' opinions about Vista's efforts to protect the environment. This initial information will be the beginning of a "di alogue" with employees and will help us focus some of our future efforts on what employees think is important. While the rest of the presentation is largely suggested, we'd ask that you stick closely to the instructions in these portions of the script to ensure the quality of the data we collect. When presentations are completed, I ask that you return the completed cards to me in Hous ton and I'll prepare compilations of the data for all of us to use. Also enclosed is an Executive Alert from CMA describing their national communication program for Responsible Care. This will occur the first weeks in April, so our goal should be to complete our introduction of Responsi ble Care by then. cc: Tom Huffman Jim DeBernar n Debs Gambli:. John Weidner Mike Reynolds Environmental Coordinators Safety Directors VVV 000011056 (Please have this slide on when people begin entering die room. Take it off only when you are ready to begin the program.) Protecting the Environment... Tha alt, watM n* tan* An* in* h**Kh an* safety of: Employ*** e Plant n*iflfeb*ra Tn* community vvv ooooU57 1 Good morning (afternoon). In just a moment. I'm going to pass out a card to each of you. I'd appreciate it if you would take a few moments and fill it out. (Don't pass out the card until you finish the explanation) The front of the card looks like this, and I'd like you to answer each of the three questions shown here. For example, the first question says: What kind of a job do you think Vista is doing protecting the environment? To answer the question, please circle one of the numbers below. If you think we're doing a very good job, circle one of the higher numbers. If you think we're doing a bad job, circle one down at the lower end of the line. If you think the answer is somewhere in the middle, then pick one of the middle numbers. Then go on to the next question. How is Vista doing protecting employees' safety and health? Again, circle one number to indicate how we're doing. Finally, circle one number to give an answer for the third question: How is the company doing protecting the health and safety of people who live near our plants? Pleas* let us know how we're doing lt49TU VkylalN Veyd-- ii058 vvv 00001 Don't forget the back of the card. We're not going to ask you to sign the cards, but when see how the answers stack up, we want to be able to tell something about the people who answered the questions. First, we want you to tell us your age. Circle one of the groups: Under 25 25-34 35-44 45-54 or Over 55 Then circle either Male or Female The next is length of service in years: 0-5 6-10 11-15 16-20 21-25 or 26+ Then your general work classification, either salaried or hourly. Finally, write in your work location. That means (tell them specifically, Houston, Saddlebrook, Lake Charles Chemical Plant, LAB Plant, R&D, etc.) (Now pass out the cards, put overhead number one back up, and wait until all cards are completed. Then collect the cards and go on with your presentation.) Don't forget the back of the cardlll Tlat M U-M Ml tal M fM U-U M U-B !+ tU IMl 9 vw* 000011 ,, ^ Thanks for your help. The results of our little survey will be reported in ChemNews later this year and will be used to help us plan further communication with you. Well, as you probably guessed, we're here today to talk to you about Vista's concern about the environment. But as you can see, we want to listen, too. I'm sure you're well aware that making and shipping our products can impact the environment in the communities where we live and work. But you may not be aware that Vista is committed to improving our environmental protection efforts and achieving performance levels exceeding those required by law. And we're doing something about it. We've just adopted a new environmental policy to establish basic goals and operating philosophies for everything we do. Why aro w here? Talk about Ylata'a concern lor tha environment Vlata proOucee, tfenepone ohemieete that can imparl tha nvlronment in tha oommunKiee where we Uva and work Tha Company la csmraiOad to improving It* environmental protaction atforts Naw onvironmantal policy Support * a now ehamical intfuatry initiative known aa Reeponolbie Cara And we're giving our full support to a new chemical industry effort known as Responsible Care. The Vista policy and the programs of work we're planning will take the form of a continuous effort to improve our performance. The policy isn't just words on paper. These actions are supported by top management and are important because our efforts will impact the company's bottomline, and ability to continue to operate our business. VVV 000011060 4 Today we're going to watch a short video that talks about Vista's environmental protection efforts, as well as our efforts to protect your safety and health, and the safety and health of the community. The video will also cover how these efforts relate to the new chemical industry's program known as Responsible Care. Then you'll find out more about what we're doing to make Responsible Care a part of our daily work practice. And later, we'll give you a copy of Vista's new environmental policy, You'll have an opportunity to ask questions, and you'll have an opportunity to give us some more feedback on the Company's environmental efforts. What will happen In today's mooting? A short vldto on: Vista's invlniuwntil protection and tdity and health allone CMA'a Responsible Caro Program What you can do to make Responsible Caro a pan erf our daily work praetlao You'll got: A copy of Vlota'a environmental policy An opportunity to aek questlone Opportunity to give feedback on how we're doing First the video. (show video) VVV 000011061 5 Okay, any questions so far? (answer ones that seem pertinent, ask that others be held if later discussion covers them) First, let me cover some of the items in the video one more time, to make sure we all understand one another. By the way, when I talk about environmental protection. I'm not only talking about protecting our surroundings. I'm talking about the health and safety of all of us at Vista and the health and safety of the people in the communities where Vista does business. What do w itmn by environment? Net only our surroundings AIM oil rnptoyoM' ItaattTi and aafsly And ih* haalth and salary of ptopl* In surrounding eommuniilaa WV 000011062 6 As part of the Responsible Care Program, Vista, and other chemical companies across the nation, will be: --Developing codes of management practices aimed at improving our performance in protecting the environment, our employees and our plant neighbors. --We'll be establishing public advisory panels to keep us informed of the public's concerns. --We'll be measuring quantitatively the company's performance against the codes we develop. --And we'll be sharing our experiences with other companies so we can learn from each other. Responsible Care What Industry Is Doing Developing code# of management practice* EetabUahlng public advisory panda Measuring company performance Sharing experleneea with others vvv 000011063 7 Now for the high points of what Responsible Care means to Vista. To Vista it means the company recognizes the responsibility it has to all employees, the surrounding What dow Hwpomlbk Car* mean? Tp conduct our business Mtlvftlee according to o hoot of environmental principles To reduce chemical rclcaaoa To comply with Vioto policy, government permits, regulatory requirements To Investigate how product* can be made, u**d, handled and disposed ef white protecting employee safety, public health and the environment communities, customers, carriers, contractors and government agencies to conduct our business To make safety, health, environmental control and waste minimisation part of procea* and faelllty design, construction and operation To bo aware of and using environmentally sound,eafe work practices activities according to environmental principles. To our plants, it means reducing the chances of emergency chemical releases to the environment. It also means making sure that our operations are in full compliance with Vista policy as well as government permit limitations and regulatory For Vista engineers and researchers, it means making safety, health, environmental control and waste minimization and early and important part of process and facility design, construction and operation. For all employees, it means being aware of and using requirements. environmentally sound, safe work practices. To you, the employees, it means a lot. And we have a responsibility to For R&D, it means investigating how each new or existing product can be made, used, handled and disposed of while protecting keep our communities informed of our environmental activities and to reduce the risk to which they are exposed. employee safety, public health and the environment. VVV 000011064 8 Here are some examples from around the company about how Responsible Care is changing the way we do business. For example, there's a project team working on guidelines defining the level of protection required in the construction or updating of equipment. Here's another. A process has been developed to make sure new products are developed in a manner that assures compliance with all laws and regulations, and consideration is given to product liability concerns. Another example is the corporate environmental audit program for our plants which checks our compliance with laws and regulations, and tries to find problems before they occur. One other example is a group formed in R&D to explore and develop environmental control technologies, and ways to cut down on the production of waste during the production of our products. Acropp th# company Environmental Engineering Guidelines Teem New Product Development/Product UiUltr ProetM Environment*) Audits RAD Environments) Technological Group vvv ooooir065 9 (Make up a slide showing examples of efforts at your own plant and talk about them. These might include: --waste minimization projects --voluntary emission reduction --work with the community to cut down on their risks --efforts to cut employee exposure to hazardous chemicals.) 0OOOU066 10 To help each of you understand more clearly how important protecting the environment is, Vista has adopted and the board of directors has approved an Environmental Protection policy. You'll see it hanging on the wall in some of our offices. But I want to give each of you a copy of the policy now. (Pass out the policy) Now lets read through it and see what it has to say. (read policy, comment on it, answer questions) (Conclude discussion with the following) If each of you takes this policy seriously and makes it part of your work every day, Vista will succeed in its efforts to protect the environment, your safety and health, and the safety and health of those in the communities in which we operate. wv 000011067 11 Now, before you go. I'd like to ask you for some more input on Vista's efforts to protect the environment. Plas 1st us know how ws'rs doing I'm going to pass out another card. We'd like you to take a few minutes and pick three (3) things that concern or worry you the most about Vista's efforts to protect the environment, about our efforts to protect your health and safety, and our efforts to protect the health and safety of the communities around our plants. It may be things you think we should do that we're not doing. Or it might be something we're doing that you think we ought to stop or change. (Don't suggest specific things that they might use. Please avoid this. People who have no ideas will be influenced by your suggestion, and we'll find it coming back to us 4-5 times.) It can be something that's been on your mind for a while, or something that you thought of during the presentation. Once you've thought of something, list it on the card. If you can only think of one thing, put it down. If you need more cards because you run out of space. I'll give you another. And if you need help, please ask. We really do need your help and information. VVV 000011068 12 Pas* out the cards Fhen put up this slide. After everyone seems to be finishing up, put up this slide and say ...) I want to thank you again for listening, and your input. You'll be hearing more about the feedback you gave us. And you'll certainly hear more about Responsible Care. The CMA is planning to start a nation-wide advertising campaign very soon. ,. nen you've finished your cards, your free to go. Remember, let's do our jobs with Responsible Care. Thanks, and remember. Handle wlthr Care VVV 0011069 13 o a m o o o o aaa Protecting the Environment The air, water and land And the health and safety of: Employees Plant neighbors The community .CS s sc oB 3 o- ft o3 2 c&/s3 2 n' * sr C/5 a o sMs oc 3o 33 CA CCrA* &9 3 CA *1 SPT w 3s vvv 000011071 Please let us know how we're doing VVV 0 0 0 0 1 1 0 7 2 Don't forget the back of the card!!! Please circle one answer for each question Age: Under 25 25-34 35-44 45-54 Over 55 Sex: Male Female Length of Service (years): 0-5 6-10 11-15 16-20 21-25 26+ Work classification: Salaried Hourly Work location VW 000011073 Why are we here? Talk about Vista's concern for the environment Vista produces, transports chemicals that can impact the environment in the communities where we live and work The Company is committed to improving its environmental protection efforts New environmental policy Support of a new chemical industry initiative known as Responsible Care vvv 0000110 What will happen in today's meeting? A short video on: Vista's environmental protection and safety and health efforts CMA's Responsible Care Program What you can do to make Responsible Care a part of our daily work practice You'll get: A copy of Vista's environmental policy An opportunity to ask questions Opportunity to give feedback on how we're doing VVV 0 0 0 0 1 1 0 7 5 What do we mean by environment? Not only our surroundings Also all employees' health and safety And the health and safety of people in surrounding communities yyy 000011076 Responsible Care____________ What Industry is Doing Developing codes of management practices Establishing public advisory panels Measuring company performance Sharing experiences with others VVV 0 0 0 0 1 1 0 7 7 What does Responsible Care mean? To conduct our business activities according to a host of environmental principles To reduce chemical releases To comply with Vista policy, government permits, regulatory requirements To investigate how products can be made, used, handled and disposed of while protecting employee safety, public health and the environment To make safety, health, environmental control and waste minimization part of process and facility design, construction and operation To be aware of and using environmentally sound,safe work practices g tO IIO O O O AAA Across the company Environmental Engineering Guidelines Team New Product Development/Product Liability Process Environmental Audits R&D Environmental Technological Group vvv ooqx1Q79 At our facility 00011080 Vista's environmental policy Vista Chemical Company ENVIRONMENTAL POLICY Vista Chemical Company produces and transports chemical products that can potentially impact the environment in the communities in which we conduct business. Vista believes that compliance with all laws and regulations related to environmental quality and public health protection is a minimum standard of acceptable practice. Vista Chemical Company is committed to improving Vista's environmental protection efforts to achieve performance levels exceeding those required by law. Vista recognizes the responsibility we have to our employees, the surrounding communities, customers, carriers, contractors and government agencies to conduct our business activities according to the following environmental principles: * Vista will inform and educr employees, surrounding 00011081 Please let us know how we're doing Take a few minutes and pick three (3) things that concern or worry you the most about Vista's efforts to protect the environment, to protect your health and safety, and the health and safety of the communities around our plants. Then list the three things below. If you need help, ask: 1. 2. 3. VVV 000011082 Thanks, and remember Handle with!Care Executive Alert January 23, 1990 BOARD APPROVES NATIONAL ADVERTISING EFFORT TO ANNOUNCE RESPONSIBLE CARE COMMITMENT PRIOR TO EARTH DAT TO EXECUTIVE CONTACTS OF CMA MEMBER COMPANIES Dear Executive Contact: At the recommendation of its Public Perception Committee, CMA's Board of Directors has approved a one-time advertising effort to publicly introduce Responsible Care before Earth Day, April 22, 1990. The double page advertisement will appear in the national editions of four newspapers (USA Today, Wall Street Journal, New York Times and Christian Science Monitor), seven major regional newspapers (LA Times, Sacramento Bee, Chicago Tribune, Houston Chronicle, Baton Rouge Advocate, Newark Star Ledger and Washington Post), four national magazines (Time, U.S.News and World Report, People and Business Week), four trade magazines (Chemical Processing, Chemical and Engineering News, Chemical Engineering and Chemical Week) and three specialty magazines (Smithsonian, National Geographic and Natural History). The advertisements will appear in the first three weeks of April. They will feature the names of all CMA members who have signed the Responsible Care principles. Funding for the effort ($2.9 million) will be taken from CMA reserves. Several considerations have convinced the Board that it is important to communicate now about Responsible Care. o CMA's Public Advisory Panel has unanimously advised the association to tell the public sooner rather than later. They are convinced it is more credible to say what one is going to do, then do it, than to try to claim credit after the fact. CHEMICAL MANUFACTURERS ASSOCIATION 2501 M Street. NW 2C2-E57 '100 Washington. DC 20037 Telex 83617 iCMAWSH) VVV 000011083 Executive Alert January 23, 1990 Page 2 The CERES (Valdez) Principles are being brought forward as a basis to judge a company's commitment to ethical health, safety and environmental management practices. It is important that employees, customers, neighbors, shareholders and the general public know that the chemical industry has been listening closely to the public and is responding forcefully and positively with its own long term initiative to improve performance. The 20th anniversary of Earth Day will assure that many members of the public are going to be especially sensitive to how members of the business community respond to health, safety and environmental challenges. Our industry's commitment will be seen and discussed. A draft of the proposed double page advertisement is attached as an example. Work is not complete. Messages have been tested with one focus group and three more test groups are scheduled. The approach indicated in the attached ad received the most positive reaction from the first group. Should members wish to consider placing and paying for the same advertisment in a plant community or city not in the CMA media schedule, advertising mechanicals will be made available. Inquiries already indicate several companies are planning to place the ads in plant communities. We expect materials to be ready by the second week in March. Actions to take before Earth Day. It will be important that employees of the industry are not blindsided by the advertisements they will be seeing about Responsible Care. It is not necessary that all facilities be able to demonstrate specific activities related to the initiative (although those already involved in the five-year old voluntary CAER program will have something to discuss). But employees and shareholders should understand what Responsible Care is and the commitment their company has made to carry out the initiative. IMPORTANT: As noted earlier, the advertisements planned prior to Earth Day will feature the names of all CMA member companies. We believe this sends the strongest possible signal about our collective and individual commitment. However, if you prefer not to have your company name listed please let me know in writing by no later than February 15. At the next Board meeting, April 6, a longer term commitment to an advertising program will be considered. The Board's Public Perception Committee has recommended a five year effort which, if approved, would call for significant additional funding from the membership. The Board has asked for a detailed proposal to include a plan for paying for a campaign. As further information is developed it will be sent to you. VVV 000011084 Executive Alert January 23, 1990 Page 3 If you would like someone from your staff to be directly involved in the development, planning and implementation stages of this proposal please let me or Jon Holtzman know. CMA Contacts: Jon Holtzman, Vice President-Communications (202)887-1200 and Dr. Lori Ramonas, Director-Responsible Care (202)887-1264. Robert A. Roland President Attachments WV 000G11G35 170 leading companies jtr saying "He1r responsible." h ' nostun lli.n jt>l puipli- au-iiiiIm|i|m uli I liiilr->|>ik-llii I.ii i ili.il < Ili um j|-.|i.ivclxiuim im t' siim-miI iiumIti ii liuni; In I.ii l.H m-miiii.iIc iIiIi.u imi i til', <l( (.ul.ll v|>|axlltl iMlHlIll lim la lll.llllll.il llill ll H|||| miIiImiiiii .il' I alii, iluis -m luuitlvnl'v| i Iivhui .ilvii.miil.il imii' liltin'L inuclsi.ilo .miliImiiviihIm41liiniii.il|>i<liui< iluilii l|> van l.nnili i ii|in llirIn nrlil' i,| |j|n"i< Mill till ||I|.|||I1 ill Lull Ilk 1'IIK jyilriiln moll lli.nl |.imi;ii-'> VsiIi.iK .1 ughl |i>iA|nil iIh Infill >i |nmI.|i'I.IIII I.ii I- >1 -IKI .ill- m I loin mu |i .in iiii|niH.nil no In'll I lli.ii'i.In tin niniiIm i <oiii|MimM-iilH < lamn jJ MjiiiiI.iiiiiiiii \vu. i.iliim Imii joim ilio^ iIivi in A|jilisliini> ili<-guiding |niiiii|ik sol iIm Ki 'I'IimIiIi < jii liiili.iliu Torecogniieand respond locommunits concerns about chmucah and our oprral'ioua 1b develop and produce chemical* lhat ran be manu factured. Iranspontd. used and disposed ofsafely. To make hrallh, safely and rnv mmmenial consider ations a priority in our planning for all existing and nes produrlsandprocesses. To repon prompth loofTWi*K.rmploirrs, customers and ibe public, informal inn on rbemiral-rrUsed health and environmemal haiardsand lorecommeud protec tive measures To counsel customers on the safeuse. transportalion and disposal ol chemical products, To operate ourplants and facilities in a manner that protects the environment and thebeakbandsafely ofoor employees and the public lb extend knowledge by conductingor supporting research on heahb, safety and environmentaleffects ofour productt, processesand rate materials To work with others to revolve problems created by past handling anddisposal ofhazardous substances. 1o participate villi government and others in treating responsible laws, regulationsand sundatris to safeguard Ibecommunity, workplace and environment. 1o promote Ibe principles and practices of Responsible Care by sharingexperiences and affering assistance Mothers whoproduce,handle, use; transportordispose ofchemicals. Hk-( IMA has ahead' hn-n.ijuiineiiHK-i in ini|Jiiii<nl mg Ink III -- '"Ui KiglilloFvniiu alxinllial>hcniM jlv ale Iwnig pNHlutcil and nysl in tool iH tglilvrilkxid \<m K< irnMiinimui|'i>iii re-u*ifii`Mnrhiiniirc Hmhi Jiicurar ji Iiciiim j|i<iiii|uih ni I. mill ihtni mix'ana. nil-(Mils liiaiil in Ki-.|khimIiIi'(..iu'. Ilii ki>ikli'jl>.i)'iii |>l.ui IIm-jHoliluii'jictiiy; \V< all have In Mill Ingi'llu'i Ui jinm-i I il For a free brochure wiih more information en the fletpoatible Care Initiative, write today: CMA Responsi ble Care, Dept- 001. Box 7777. Washington. DC OOOMl Member Companies of ihrChrnitcal Manufacturers Association Was*a...i in^yi, aaeiwiFWawsrafa4a.aMi aalaa aafU^aws arf|.*iaa.,j awaWM^aa-rfvrf -wa ,wv .1 aa. f1*1 Rj MMtmt-i Fi.dti<Md.l<dah>sll llM--*-- V-a>Vr lara--.x., La,-t.--.-kH--^ Isev^em.hp R|V.A m...i kltds.MiM^.aal l*r n eimfkldww M, har-t--. **--** 1*-*~-* uMrip aUi.^flkardllkel aids t**-w.tv, k* ***'h, 0-yl'.vdNkh., w.wmalp.tqte U|UeU|IU<*ni tdkvm*lt k^nmr^tyid.im. d-'-h-- - .r*d|ALhv i.yid-i'u i lilt'd~*a kAin-*-dMktasnwadV s^-k-- aAnv Uh---t~_rfkm^at.. `t----- *k (kern ^um^lr^rii pfMlUiMgldl *_..|Uw.t,R*w. h^u^bMvtlbg *it I**. 9BOUOOOO AM Respunubk Care; Membership ha* its obligations. 170 leading companies are saying "Were responsible." lfs no secret that a lot of }x*ople are unhappt with c hemical companies. This despite the fact that chemicals have Ixrome iu*crv sities of tn<*lem living In fact. it'sestimated tlut over Ii0<7 oftodav s products nmldnotfiemantiiac lured with out chemicals. liidav. there are hundreds ot chemical mamitacuireiv in the L nited Slates, and tiunivindsof'chemicai products that helpvoui tumilv ejo\ ihvhemTii>nl progress. Still, the ijualitc of com life is measured In more than progress. You have a right to expect the highest possible standards <if operatiim trmi such an imp*? umi industry Hut s win the member ci mipanies < f the ( henmal Manufacturers Association havejoined together in establishing the guiding principles of the Responsible (.'are Initiative: To recognize and respond to community concerns about chemicals and our operations. * To develop and produce chemicals that can be manu factured. transported, used and disposed of safely. * To make health, safety and environmental consider* ations a priority in our planning for all existing and new' products and processes. * To report promptly to officials, employees, customers and the public, information on chemical-related health and environmental hazards and to recommend protec* five measures. To counsel customers on the safe use, transportation and disposal of chemical products. * To operate our plants and facilities in a manner that protects the environment and the health and safety ofour employees and the public * To extend knowledge by conducting or supporting research on health, safety and environmental effects of our products, processes and waste materials. To work with others to resolve problems created by past handling and disposal ofhazardous substances. To participate with government and others in creating responsible laws, regulations and standards to safeguard the community, workplace and environment. To promote the principles and practices of Responsible Care by sharing experiences and offering assistance toother5 who produce, handle, use, transport or dispose of chemicals. TheCMA has already been a prime mover in implement- ingTitle 111 -- your Right To Know about what chemicals are being produced and used in your neighborhood. Non. we re committing our resources to do more If vou live near a chemical company work with them to be an active participant in ResponsibleCare. The world is a fragile place. The problems are big. We all have to work together to protect it. For a free brochure with more information on the Responsible Care Initiative, write today: CMA Responsi ble Care, Dept. 001, Box 7777, Washington, DC 00000. Oo0iio87 Interoffice Communication TO: FROM: DATE: SUBJ: Distribution : BffniBSr pt6: RF XF: Vb.sL T. G. Grumbles February 15, 1990 RESPONSIBLE CARE CODE OF MANAGEMENT PRACTICE: SAFETY .VISIA PROCESS The attached draft code is for review and comment. Please have the appropriate person or persons review and return comments to me by March 16. This Code is for process safety. It should be noted that references to safety performance or auditing are referring to process safety not occupational safety and health. These issues will be addressed in the future. Based on the scope of this Code, it is not clear to me who should review at the plant locations. Also, some of the aspects of the Code may be a corporate engineering function. Based on this, I am sending the draft code to you to determine who should review it at your location. Please let me know who will be reviewing it at your location. There is a response form with 7 specific questions to assist in your review. This can be completed if you choose or free form comments can be submitted. The self-evaluation form is not to be completed at this time, but is provided for review in terms of content and form. Also, an open forum is being held on March 1 to review this draft Code. A tentative agenda is attached. Please let me know if someone from your location is interested in attending. Once again, I need you to tell me who is reviewing this at your location, and I need comments by March 16 so I can develop a consolidated Vista response to CMA. T. G. Grumbles dlj .1007 Attachment Distribution: PLANT MANAGERS R. W. Seymour-Aber, L. R. Bauer-Balt, G. D. Williams-Blane, J. B. Maher-Hmd, J. Friend-LCCP, J. W. Ware-LCLAB, R. A. Conrad-LCVCM, H. D. Garrison-Okc, P. L. Foote-Prem, V. W. Weiss-Austin V. Messick, G. Inbody, R. T. Ferrell yyy 000011088 R. Poe-Austin