1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271

Comments from Allen Blakey

Vice President, Industry & Govt. Affairs

The Vinyl Institute

To the U.S. Environmental Protection Agency

Re: National Emission Standards for Hazardous Air Pollutants

For Polyvinyl Chloride (PVC) and Copolymers Production

June 7 & 9, 2011

On behalf of the Vinyl Institute, I appreciate the opportunity to speak at 

today’s hearing on EPA’s proposed Maximum Achievable Control 

Technology regulations for PVC production facilities. As you heard earlier, 

the Vinyl Institute is the trade association for manufacturers of polyvinyl 

chloride resin and copolymers in the United States.

I am speaking today not to address technical issues in the proposed 

regulation but to underscore the value of vinyl to the national economy, as 

well as this industry’s commitment to protecting the health of our workers, 

plant communities and the environment. Our stewardship commitment is 

altogether fitting given the nature and purpose of so many critically 

important PVC products. Vinyl is the material of choice for blood bags and 

medical tubing, for pipe delivering clean, safe drinking water, and for 

insulation on building wire protecting against catastrophic electrical failure. 

It is the material of choice for food wrap and tamper-resistant packaging. It 

is the material of choice for home-owners interested in the most affordable 

and energy-efficient window frames and commercial roofing. And the list 

goes on.

The PVC resin manufacturing industry supports this MACT rule-making. 

The industry has long-operated under the vinyl chloride standard, a 
1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271

precedent-setting rule in both its scope and stringency. To support the 

current rule making, the industry has expended significant man-hours and 

millions of dollars to generate the information EPA needed to develop the 

proposed rule. We know that the agency is working hard, under a very 

short deadline, to finalize this regulation. We intend to bring our best 

thinking to the comments we will file in order to help develop the most 

effective, manageable rule that is fully compliant with the Clean Air Act and 

related precedents.

I’d like to share some facts with you that I think clearly show this industry’s 

success in practicing environmental stewardship, conserving energy and 

reaching for sustainability.

 Our vinyl chloride emissions were reduced 80% between the years 

1987-2007. 

 Our dioxin emissions were reduced 80% simply between 2000-2007. 

Our emissions are a small fraction of the emissions from all man-made 

and natural sources. And, by the way, data compiled by EPA shows 

that overall dioxin emissions to the environment have plummeted since 

the 1960s, falling well over 90%, even as production and use of vinyl 

ramped up and soared.

 The collection of federal U.S. regulations governing the industry sets 

global standards for human and environmental safety, health and 

performance. 

Manufacturing plants also have community advisory boards that meet 

regularly with management for dialogue on operations and community 

issues. These plants strive to be good neighbors. After all, they draw their 

employees from the community, and provide jobs and taxes.

And, the evidence shows that our plants are by and large good neighbors, 

managed responsibly in accordance with regulations designed to protect 

health. Government studies at both the federal and state levels have 

compared key health indicators in PVC plant communities and non-plant 

communities and found no significant differences. 
1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271

We are concerned that EPA get this rule right. Regulation is important and 

necessary, but as Congress intended for the Clean Air Act, other 

considerations matter too. We all want a clean, healthy environment, but 

we also want products that bring value to our lives, and we want jobs and a 

strong economy. How does the PVC industry help?

 Our industry generates an estimated $50 billion a year in products. 

Federal taxes from producing the raw material alone amount to $230 

million.

 The 13 billion or so pounds of PVC manufactured in 2010 created highpaying jobs for tens of thousands of American manufacturing workers, 

and many times more jobs for transporters, distributors, installers, and 

recyclers. Vinyl products are made in hundreds of plants in almost 

every state. 

 U.S.-made vinyl resin is in high demand as an export product, 

accounting for as much as 35% or more of industry revenues. 

Abundant natural resources and an efficient manufacturing process 

account for this success 

We look forward to providing additional details in our written comments. 

Thank you.