The idea behind the strategy is to give Greenpeace a strong lead on the issues but to use various groups--some of which are more acceptable to the mainstream--to appear to lead specific issues, thus giving the overall campaign the appearance of a widespread, generally accepted grassroots uprising against chlorine chemistry.

**" _ Scumisn Snemoimm General Construction OONTBAOT 6 Drrmxos h t v t i i Painting DIVISION XXVIII PAINTING Seeth* 1--GENERAL 1- The Contractor for 'work under this Division is referred to the "Instruction* to Bidders", "Pom of Proposal", "Pom of Contract", "General Conditions", "Special Conditions* if any, and "Contract Drawings", all of which are hereby made part of this Division of the work.

Much insight has been gained that will lead to more reasoned and better prevention, interven- tion, and treatment for the reduction of environmentally caused cancers.

**" _ Scumisn Snemoimm General Construction OONTBAOT 6 Drrmxos htvti i Painting DIVISION XXVIII PAINTING Seeth* 1--GENERAL 1- The Contractor for 'work under this Division is referred to the "Instruction* to Bidders", "Pom of Proposal", "Pom of Contract", "General Conditions", "Special Conditions* if any, and "Contract Drawings", all of which are hereby made part of this Division of the work.

Routine dosimetry results for the month were: Chemical VGM Lead Total Particulates _________________________ Number 72 9 4 97.3 81.8 100.0 > PEL Number Percent 2 2.7 2 18.2 00 Maintenance Contusion and laceration of forehead.

PLAINTIFF'S EXHIBIT Sun City Analytical Inc.

Howev er, several businesses in which Shell has leading market positions--including high er olefins, thermoplastic elastomers (TPEs), and epoxy resins---were classified as "trans form or exit."

/ / / ( CHEMICAL MANUFACTURERS ASSOCIATION March 30, 1994 Dear Vinyl Chloride Research Coordinators: A calendar to determine your availability to attend the next VCRC meeting is enclosed.

This interrogatory seeks information not relevant to the matters involved in this action and is not calculated to lead to discovery of admissible evidence.

Such an indirect route could only occur for nonvolatile chemical agents such as lead.

Additional data DDTDDEJDDD, di(2- recommendations ofthe Interagency needs are being addressed through an ethylhexyl)phthalata, lead, mercury, Testing Committee established under - Interagency agreement with NTP, by methylene chloride, nickel, section 4(e) of the Toxic Substances ATSDR's Great Lakes human health polychlorinated biphenylcompounds Control Act on the type of reseerdi that effects research program, and other (PCBs), polycyclic aromatic should be done. - Agency programs.

The newsletter is being developed and distributed by PRO, the Pipe Resource Organization, an operating unit of the Vinyl Institute, the national trade association representing the leading manufacturers of PVC plastics including feedstocks, additives and film and sheet products.

Therefore, this Interroga tory is overbroad, irrelevant, immaterial, and is not reasonably calculated to lead to the discovery of admissible evidence.

One recent paper reported on the enforcement of medical requirements in the lead, ethylene oxide, and formaldehyde standards [Schwartz et al,, 1992], Two papers have reviewed the content and implementation of medical requirements in the hazardous waste operations and emergency response standard [Melius, 1990; Udasin et a!.

ABOUT THE VINYL INSTITUTE The Vinyl Institute is a national trade association representing the leading manufacturers of vinyl (polyvinyl chloride, or PVC) plastics, as well as makers of vinyl feedstocks, additives, and film and sheet products.