In Summary, He Would Not Recommend This Project Since It Will Not Only Duplicate Efforts

Response to ‘Isocyanate Regulation Challenge’ Enquiries from Customers

Huntsman is proactive in addressing upcoming regulations by all government authorities, at a regional, national and state level – including Canada, Michigan and California. Huntsman representatives have an open dialogue with the relevant agencies and over the years have made good progress in addressing issues before they become regulations.

Huntsman is aware of the Canadian Institute for the Relief of Pain and Disability (CIRPD) project, but does not intend to support it financially, as we see it as being duplicative of good quality work that has already been done elsewhere e.g. ACGIH, ICCA SIDS, III TDI RA, etc.

A few recent examples of industry working successfully with government agencies further illustrate this point.l

1 Medical doctors from various manufacturers met with Michigan OSHA (MIOSHA) on the recent occupational health standards. Physicians worked together to develop a medical surveillance guide for MIOSHA and the MIOSHA director decided to send the proposed rules back to the MIOSHA Commission for further review, in light of industry recommendations.

2 In Feb 2010 ACGIH announced that TDI will be retained on the Notice of Intended Changes List for the fourth consecutive year. This is unprecedented and we feel that it is due to the comments made by industry experts every year challenging the scientific basis for the proposed changes and requesting a meeting with the TLV Committee.

3 The European Union has recently published a risk assessment on MDI and the industry has worked together on the REACH dossiers, which contain all current published and unpublished work. It is highly unlikely that work done by CIRPD would be as complete as these evaluations, because all data may not be released to CIRPD.

In conclusion, Huntsman remains committed to providing support to address industry issues, but we don’t support this project since it will not only duplicate existing work but it will do so by trying to instruct non-expert consultants on isocyanates, with no guarantee that the government agencies will use the outcome or continue to do their own evaluation.

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