Document 0LLmdvVO7jBmOy53aoMZGxbNO

\ .. t; /93SJ*e-l* %/7r/to -i_ai 9 MANUFACTURING CHEMISTS ASSOCIATION 1825 CONNECTICUT AVENUE, N, W. WASHINGTON, 0. C. 20009 (202) 483-612^ June 16, 1975 JUN 30 t9?$ R. N.WH*fiW* TO: Technical Panel on vinyl Chloride Research SUBJECT: Enclosures with Minutes of May 22 Meeting ii 1. Response to May 16, 1975 "Science" article letter of Mr. A. C. Clark to editor, June 2, 2. Experimental design changes with letter to Dr. Torkelson May 6, 1975 from Dr. Hehir;. Consumer Product Safety Commission. 3. "Angiosarcoma of the Liver in Vinyl chloride/ Polyvinyl Chloride Workers" by J, W. Lloyd, Sc.D,, journal of Occupational Medicine, Vol. 17, No. 5, May 1975. (Courtesy of Dr. Torkelson) 4. N10SH Tables dated April 10, 1975 I, "Report d Cases of Angiosarcomaof the Liver Among Vinyl Chloride Poly merization Workers," and II, for non-polymerization workers received via Dr. Mayo Smith. 5. Letter from Dr. D. I. Mount, Environmental Protection Agency, May 19, 1975 to M. Freifeld on aquatic studies with VCM. Sincerely, MF/etv Attachments * Milton Freifeyd Project Manager ucc s 001132 INFORMATION COPY "St * - ALBERT C. CLARK VICE PRESIDENT TECHNICAL DIRECTOR MANUFACTURING CHEMISTS ASSOCIATION 1825 CONNECTICUT AVENUE. N,W. WASHINGTON, D.C. 20009 (202) 483-6126 June 2, 1975 Philip H. Abelson, Editor "Science" 1515 Massachusetts Avenue, N. W. Washington, D.C. 20005 Dear Dr. Abelson: The Edsall article, "Scientific Freedom and Responsibility" (J. T. Edsall, "Science," May 16, 1975) requires comment. I presume Dr. Edsall is not responsible for the content of the arti cle, but merely prepared it from the AAAS committee report. How ever, scientific freedom and responsibility are as important for AAAS committees as they are for other scientists. The "case of data suppression concerning the carcinogenicity of vinyl chloride" (pg. 690) is a melange of omissions and untruths inconsistent with scientific freedom and responsibility. Since so much pertinent information has been omitted concerning this matter readers may be misled into believing Dr. Edsall's report. Edsall states that, "up to that time (May 1970) there had apparently been no research in the plastics industry concerning the possible hazards of vinyl chloride...". This is untrue, in fact, the basic published data on vinyl chloride toxicity came from American industry, (references 1-7) The information in refer ences 4, 5, 6, and 7 had been publicly disclosed and presented prior to their publication dates. Furthermore, the investigations of Dr. P. L. Viola and Dr. Maltoni have been supported by European industries. Edsall correctly states that Manufacturing Chemists Association (MCA) member companies entered into an agreement with the European sponsors of Maltoni's work not to reveal preliminary- Italian data. The agreement was not dissimilar to that between American sponsors (Government, Industry, and Academic) and research institutions that new data remain the property of the institution and not be disclosed until the study is completed and evaluated prior to disclosure of final results in proper scientific channels. There was no intention to withhold adverse data. Under MCA rules, all data developed under its auspices must be promptly reported publicly. Without exception, this has been done with all data on vinyl chloride. IJCC 001133 Philip H. Abelson, Editor "Science" June 2, 1975 page 2 U. S. Government scientists knew of Maltoni's preliminary results early in 1973 but considered it as preliminary as did U. S. industry. At the Second International Symposium on Cancer Detection and Prevention in Bologna, April 9-12, 1973, Dr. Maltoni showed a table of preliminary results linking vinyl chloride with cancer formation8 (not published until 1974). Dr. Umberto Saffiotti, Associate Director of carcinogenisis. National Cancer Institute, was present at the meeting and subsequently discussed the results with Maltoni at his Italian laboratory.8 Saffiotti felt that the work needed to be included in "a well documented report" to be assessed by the World Health Organization (Review Panel of the international Agency for Research on Cancer of which the United States is a mem ber) . This committee also considered Maltoni's data preliminary at that time and "decided to postpone compilation of the definitive review to the next meeting of the committee."8 , Following a period in which epidemiological and animal studies were being established, MCA on April 17, 1973 asked the Europeans to jointly make presentations to United States and European Govern ment authorities. The Europeans readily agreed, and on June 15, 1973 MCA called the National Institute for Occupational Safety and Health (NIOSH) and requested an opportunity to bring new information to that agency's attention. The appointment was set by NIOSH for July 17. Five European and American industry representatives presented to NIOSH the information that tumors had been observed at concentra tions below that reported by Viola. At that time, human cases had not been reported; therefore, no special significance could be attached to the types of tumors observed by Maltoni. The MCA suggested label referred to by Edsall was illustrated in the Chemical Safety Data Sheet (SD56) on vinyl chloride, revised April 1972. Section 10.1 on Health Hazards refers to Viola's pub lished studies. The Data Sheet states "Recent research studies reported from Italy indicate that repeated, long-term high level exposures of rats to vinyl chloride monomer vapor can result in the development of malignant tumors. However, many years of in dustrial experience with human exposures to concentrations frequently far above current standards have not demonstrated any carcinogenicity to humans." Thus the statement by Edsall that MCA "...appears to have deliberately deceived NIOSH regarding the true facts." is inac curate and misleading. Sincerely, UCC 001134 References: (X) Torkelson, T. R., P. Oyen, and V. K. Rowe. The toxicity of vinyl chloride as determined by repeated exposure of laboratory animals. American Industrial Hygiene Association Journal, 22(5) . 354-361. 1961. (2) Wilson, R. ii., w. E. McCormick, C. F. Tatum, and J. L. Creech. Occupational Acroosteolysis, report of 31 cases. The Journal of the American Medical Association, 201(8). 577-581. 1967. (3) Baretta, E. D., R. D. Stewart, and J. E. Mutchler. Monitoring Exposure to vinyl chloride vapor: breath analysis and continuous air sampling. American Industrial Hygiene Association Journal, 30. 537-544. 1969. (4) Dinman, B. D., W. A. Cook, W. M. Whitehouse, H. J. Magnuson, and T. Ditcheck. Occupational Acroosteolysis: I. An Epidemio logical Study. Archives of Environmental Health, 22, 61-73. 1971. (5) Cook, W. A., P. M. Giever, B. D. Dinman, and H. J. Magnuson. Occupational Acroosteolysis: II. An Industrial Hygiene Study. Archives of Environmental Health, 22., 74-82. 1971. (6) Dodson, V. N., B. D. Dinman, W. M. Whitehouse, A. N. M. Nasr, and H. J. Magnuson. Occupational Acroosteolysis: III. A.clinical study. Archives of Environmental Health, 22., 83-91. 1971. (7) Kramer, C. G., and J. E. Mutchler. The correlation of clinical and environment measurements for workers exposed to vinyl chloride. American Industrial Hygiene Association Journal, 33(1). 19-30. 1972. (8) Maltoni, C. Occupational Carcinogenisis. Proceedings of the Second International Symposium on Cancer Detection and Prevention. Bologna, April 9-12, 1973. Excerpta Medica, Amsterdam. 1974. (9) Hearing before the Subcommittee on Environment of the Committee on Commerce, United States Senate, August 21, 1974, (Serial No. 93-110) on Dangers of Vinyl Chloride, pages 54-56. UCC 001135 MAY 14 1975 U.S. CONSUMER PRODUCT SAFETY COMMISSION WASHINGTON, D.C. 20307 ' May 6, 1975 Dr. Theodore R. Torkelson Corporate Medical Department The Dow Chemical Company Bennett Building 2030 Dow Center Midland, Michigan 48640 Dear Dr. Torkelson: Thank you for your letter dated April 23, 1975, regarding CPSC's proposed protocol for Inhalation studies on vinyl chloride. As I remember, you have a copy of the original protocol scheduled to be performed at Edgewood Arsenal. Attached is a copy of the proposed changes. In regard to the schedule, the .acute study of 1 hour only with rats and mice and holding for 24 months is now in its second month. The three generation reproductive studies are now in the 60 day exposure stage. The sub-acute Inhalation stage is entirely new and is just beginning. If I can be of any further help, do not hesitate to call or write. Attachment Robert M. Hehir, Ph.D. Director Bureau of Biomedical Science UCC 001136 CONSUMER PRODUCT SAFETY COMMISSION During a visit to Biomedical Laboratory by Drs. McLaughlin and Wyer on 27 March 1975, It was mutually agreed by the contract project officer, Dr. McLaughlin and Dr. McNamara, Edgewood Arsenal Contract Administrator, that the-following technical changes would be made in the toxicological testing of Vinyl Chloride monomer: 1. No biochemical or enzymatic work would be performed in the vinyl chloride studies. 2. The three generation reproductive studies will be changed as follows: a. The number of animals per dose will be Increased from 10 to 25. b. The exposure concentration and time of exposure will be 50 and 500 ppm, 5 days week/10 weeks. c. The parent generation will be held and observed for 2 years. d. No teratology studies will be performed. 3. A sub-acute inhalation study will be added to the acute work. The exposure schedule is as follows: Dose Level 50 500 Control Sub-Acute Vinyl Chloride Inhalation Study (Exposure Schedule) Species (Strain) Number Exposed Frequency of Exposure Rat (Fisher) Mouse (A/J) 180 180 5 dy/wk - 20 wka II It Rat (Fisher) Mouse (A/J) Rat 50 ppm 500 ppm Mouse 50 ppm 500 ppm 180 180 100 100 100 100 5 dy/wk - 2 wks II II _ -- __ -- UCC 001137 The observation and sacrifice schedule is as follows: Sub-Acute Vinyl Chloride Inhalation Study (Observation and Sacrifice Schedule) Dose Level (ppn) Time of Observation & Sacrifice (Months) 8 Rat Mouse 50 20 20 500 20 20 Controls 50 ppm level 10 10 500 ppm level 10 10 Totals 120 20 20 20 20 10 10 10 10 120 Total Animals: Rats - 560 Mice - 560 16 Rat Mouse 20 20 20 20 20 20 20 20 10 10 10 10 10 10 10 10 120 120 24 Rat 50 50 50 50 30 30 30 30 320 Mouse 50 50 50 50 30 30 30 30 320 UCC 001138 Current Intelligence Angiosarcoma of the Liver in Vinyl Chloride/Polyvinyl Chloride Workers In the December, 1974, issue of the |OM (76:809), 26 cases of angiosarcoma of the liver were reported. As of January 22, 1975, 38 cases have been collected. The new data are given in this report. ). William Lloyd, Sc.D. wn January 22, 1974, the National Institute for Occupational Safety and Health was advised of three deaths from angiosarcoma of the liver at a single vinyl chloride polymerization plant. Since that time, 29 additional cases among polymerization workers in the United States and nine other nations have been reported. Details are given in Table 1. Review of these cases according to date of diagnosis shows that ail but three were diagnosed within the last seven years. Although the cases have clustered since that time, it is probable that the high risk of this disease for iroiymeriza* tion workers might have gone unnoticed except for the observation of a case in 1973 by a plant physician who reviewed earlier records and identified four cases during the prior ten-year period. The dif ficulty of making an early determination of an association of such a rare disease with an occupational exposure, even when the exposed worker is at very high risk, is also pointed up by the distribution of cases over time. Of the first eight cases diagnosed between 1961 and the end of 1968, six were from four plants in the United States, one was from France, and one was from West Germany. While an exact estimate of the in cidence of liver angiosarcoma among polymerization workeis cannot Ijo deter mined until exposed-to-risk figures become available, it is already apparent that these workers are at very high risk of Ur. t *t>y*l in Director, (Vikt of ()u u|Mti<>rvtl M'.'jlih ftiHViill.intf* and Rioim-im s, MIOSH, Kor.k- vtllc, Mr! Ri-fwnt ro KJOSM, Rm 1 -111, n<V)0 FisIkmn Ljnr. RotkvilJr. MO JOBS* Tebtn L -- ttt**rteU Cist* tf Anritartoa* *1 tht Uwr Amonf Vinyl Chloride Pclyratriutin* Vtcrken, Cflnntry Cat* Birth Date lit VC v nt Emeewt OX llffr Strceau Alt Yn Tat At l*t Ei Yn DX T* 01 tr Ciu*< Caudl Canada Camtt 01 AWAITING 0E7AILS 07 AWAITING DETAILS 03 AWAITING DETAILS 04 AWAITING DETAILS CrrcHoilonku Czcctaslovafcia 01 AWAITING DETAILS 02 AWAITING DETAILS Ffltet OP ooocoo 00 0009 Great Britain Greet Britain Ql* 000091 0003-44 03 OS 00 37 0700 50 Italy 02* 1113 79 000057 liomt 01* 177315 03 0050 Rumania 01 AWAITING DETAILS Sweden 01* 06 2127 M14 51 Undid Statu Undid States Undid Statu Umiad Statn United States Unites Suite UtiteS States UnHad States United State* Uae4 States Unite* Slates United State! United State* Undid State* United State* 01* 1017 23 1209-41 or* 0919-31 tl 15 55 03* 05 75 15 117*45 04* 0115-74 0700-57 OS* 01-7517 06-1944 0** 0040-79 01-17-07 07* 0543-72 09-C944 0B* 0500-20 100740 09* 1I-0S-3I 00 09 54 10* OS-1613 05-1751 II* 05-27-09 10 1440 17- 11-17-18 09-13 40 13* 12-0121 00 IS 44 11-04 27 0500-50 17 05 0S-31 05-73-55 W. Germany W. Germany it. Germany W, Germany 01* 07 26 31 10-14-57 02* 06 24-30 100157 04* 00-00-00 009000 05* 00 00GO G0-P000 Tail ttwale* CMtti.-IZ Median Values: IS US. Ceces 10 Non US. Case? 75 Total Cases 000090 1700-77 CO 00-74 12-13-72 17 70-71 070070 03-03-73 050070 17,1073 001047 - 040944 02-00-74 000041 030041 0341-74 05-00-61 03-00-70 05-02-69 05447* 004041 1-3-1174 0975-70 0919-68 0040-CQ 030000 43 71 . 35 A3 56 43 49 36 56 43 57 45 45 41 43 55 61 50 53 41 43 40 36 44 49 450 43.9 44.0 13 76 i 15 3? 19 22 14 28 15 70 13 24 15 17 17 23 20 30 17 19 11 13 17 11 19,0 15.0 17.0 13 2C 4 6 21 IB 16 13 28 15 11. 12 ii 15 17 17 23 15 30 4 19 11 13 11 u 17.0 12.0 160 Me * Death 0000-67 17 CO-72 12-74-1* 1709-72 0104-72 10-79-70 0303 73 09 21-71 12-1973 010766 040964 ALIVE ' 03-73-66 092961 ALIVE 05-1066 03-1670 050269 0704-74 03-7769 ALIVE 121471 01 2569 000900 ALIVE 1 Indicates miooscweedy fonfiinutd injur atcoma at th ttver "00" InArjtts untflcv'i data. Journal of Occupational Medicinu/Vol 17, No. 5/May 19/5 333 ucc 001139 Tab!* 2. -- SepnrhJ f.ai*j of * th* Livtr Among Nofl-Potymoruitijn Workers foposjd to Vipyj Chloride. Count*! hi K Pi rut Cast girth PVC Angir At la Eif Trs Da'c o1 ft* Halt Eipttur# Sarcunti ox Tf 01 Erp Death Great Britgifl Italy 02- tmu oo con GZ 00/0 ss zi u 12 00 70 Not* t 01 o$;vu 0CD0 6S mu n IS 6 3 0116/1 Not* 2 1 7 Sweden United Stiles United SUM W, German* 02' 11 2711 oj oa is OS IS 12 SI 27 14 00 00 13 03 Its 33 oooo/i so IS IV 0OC0 2S CO CO 00 o7 mn 00 01* 0M5-3Q 0QQQ0Q 02 00 ill s ' 14 2J oi i6 n Note 3 oo` 07 03 /3 Not* 4 16 00 02 IS 73 Not 5 u 1010-13 Not* S Not* 1 Not* 2 Not* 3 Not* 4 Not# 5 Not* 5 Not* ? Pouring PVC Oil mature onto fabric bat** Production of PVC sacks Production of Vin>f Chtortd* Machne Operator coverir.f electrical ww* with PVC plastic MnoUbOP Accountant if plant making PVC fabric loading pest'Cida cam with VC propellant Arwosarcoma rwoMfig hver. !(it *nd p*riardw*r. dilctft to dttomiM, primary sits strut (o b* pericar dium. Not* * Oiifnwr Sarcoma fpOSaWy "intiQumm*"). truer. PmMtf of pMMnirnrf Moptacm of the rctfotkemMttefref ceH sytttm cannot be ruled out. ' Indicates rmcrttcopoify coofcrmed anposarcoma of tko liver. "CAT Indicates uuJuknmi data. this disease. Approximately 5,600 men are coming from the older plants is seen are currently employed at 36 facilities in in the distribution by date of initial ex the United States. To date, IS cases of posure. All but one case was initially angiosarcoma of the liver have been employed prior to 1958 and more than reported from four of these facilities, all 70% of the cases were initially employed of which have been in operation for 20 or more years ago. Since the average more than 25 years. Nine cases have latent period from first exposure to been reported from a single facility diagnosis is about 19 years, we would which employs less than 300 workers. A not expect to see many cases at this time further indication that the earliest cases from the newer plants. Preliminary findings from continuing epidemiological investigations of u S polymerization workers indicate that these men also may be at high risk for other malignant neoplasms, particularly of the brain where a> significant excess has been noted. Details of reported cases of angiosar coma of the liver among other workers with exposure to vinyl chloride are shown in Table 2. It should be noted that in two of these cases primary angiosarcoma of the liver cannot be definitely confirmed. While too few cases have been reported to draw any definitive conclusions regarding a cause and effect relationship, the age of diagnosis for these cases, which like that for the polymerization workers is con siderably lower than that observed for cancer of the liver in the general population, suggests the possibility of a common etiology. It also should be pointed out that with such a rare disease it may be some time before we can determine whether workers exposed to lower levels of vinyl chloride are at ex cess risk for angiosarcoma of the liver or other malignancies. It is, therefore, im perative that the non-polymerization workers be kept under continued sur veillance. 334 Angiosarcoma of the UverAJoyd ucc 001140 TABI.E I - REPORTED CASES OF ANGIOSARCOMA OF THE LIVER AMONG * v> VINYL CHLORIDE POLYMERIZATION WORKERS COUNTRY CASE # BIRTH DATE 1st VC DX AGE YRS TOT or PVC ANGIO AT 1st EXP YRS EXPOSURE SARCOMA DX TO DX EXP Canada 01* Canada 02* Canada 03* l Canada 04* Canada 05* Canada 06* Canada 07* i Canada Canada 08 09 i Canada 10 Czechoslovakia 01 Czechoslovakia 02 France 01* Great Britain 01* i i Great Britain 03 Italy 02* Norway 01* Sweden 01* United States 01* United States 02* United States 03* United States 04* United States 05* United States 06* AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS AWAITING DETAILS 00-00-28 00-00-57 00-00-26 00-00-51 04-15-24 01-00-46 00-00-01 00-00-46 06-00-37 02-00-66 11-13-29 00-00-57 12-23-15 03-00-50 06-23-27 10-17-23 08-14-51 12-09-48 08-19-33 11-15-55 05-25-15 01-15-24 01-25-12 11-28-45 07-06-52 06-19-44 00-00-29 01-17-62 % 00-00-73 46 16 00-00-66 40 15 02-18-67 43 . 21 12-00-72 71 26 00-00-74 38 8 12-13-72 43 15 12-20-71 56 22 02-00-70 43 19 03-03-73 49 22 05-00-70 ,36 14 12-19-73 58 28 08-19-67 43 15 04-09-64 52 20 02-00-74 ' 45 12 16 15 19 20 4 6 21 18 16 13 28 15 18 12 10, 1975 DATE OF DEATH 00-00-74 00-00-66 02-19-67 12-00-72 12-24-74 12-00-72 01-04-72 10-20-70 03-03-73 09-28-71 12-19-73 01-07-68 04-09-64 ALIVE \ ucc 001141 jar-">ggqHPW.' nFn,,,"r>i ma* T T COUNTRY CASE f United States 07* United States 08* United States 09* United States 10* United States 11* United States 12* United States 13* United States 16* United States 17 United States 18 W. Germany 01* W. Germany 02* W. Germany 04 W. Germany 05* U. Germany .06* TABLE I (cortinued) REPORTED CASES OF ANGIOSARCOMA OF THE LIVER AMONG VINYL CHLORIDE POLYMERIZATION WORKERS BIRTH DATE 05-03-22 05-06-20 11-08-31 08-16-13 05-27-09 11-17-18 12-01-21 11-04-27 05-06-31 00-00-29 07-26-31 06-24-30 09-04-30 04-28-25 01-01-32 1st VC or PVC EXPOSURE 08-00-44 10-07-46 09-09-54 06-12-51 10-14-46 09-13-49 08-19-44 . 05-08-50 06-23-55 00-00-54 10-14-57 10-01-57 04-16-57 02-00-57 07-26-62 DX ANGIO SARCOMA 00-00-68 08-00-61 03-01-74 05-00-68 03-00-70 05-02-69 05-00-74 00-00-69 10-11-74 00-00-75 09-25-70 09-19-68 00-00-74 07-00-74 00-00-75 AGE AT DX 45 41 43 55 61 50 53 41 43 46 40 38 44 49 43 YRS 1st EXP TO OX 24 15 17 17 23 20 30 17 19 21 13 11 17 17* 13 TOT YRS EXP 18 15 17 17 23 15 30 4. 19 13 12 11 11 12 12 DATE OF DEATH 03-23-68 08-29-61 03-00-75 05-10-63 03-16-70 05-02-69 07-04-74 03-27-69 ALIVE ALIVE 12-14-71 01-25-69 11-25-74 ALIVE 01-09-75 Total Reported Cases 39 Median Values: 16 U.S. Cases 13 Non-U.S. Cases 29 Total Cases. 45.0 43.0 44.0 * Indicates microscopically confirmed angiosarcoma of the liver "00H Indicates unknown data. 19.0 16.0 17.0 16.0 12.0 15.0 TABLE I-. REPORTED CASES OF ANGIOSARCOMA OF TEE LIVER AMONG NON-POLYMERIZATION WORKERS EXPOSED TO VINYL CHLORIDE COUNTRY CASE # Great Britain Italy Sweden United States United States W. Germany 02* 01 02* 14 15* 03* ' BIRTH DATE 09-08-14 06-15-34 11-27-11 00-00-13 00-00-25 07-16-30 1st VC or PVC EXPOSURE 00-00-46 00-00-65 00-00-45 08-18-38 00-00-00 06-09-52 DX ANGIO SARCOMA AGE AT DX 02-00-70 04-19-71 05-15-72 06-00-73 07-00-72 03-00-73 ` 55 36 61 60 47 43 YRS 1st EXP TO DX 24 6 27 36 00 . 21 TOT YRS EXP 11 3 23 00 00 14 NIOSH Aprii 10, 1975 4% b8 *H DATE OF DEATH Op`M, i Mr. 12-00-70 04-16-71 08-16-72 07-03-73 02-15-73 10-10-73 Note 1 Note 247 Note 3 Note 468 Note 5 Note 6 Note 1 Note 2 Note 3 Note 4 Note 5 Note 6 Pouring PVC oil mixture onto fabric bases Production of PVC sacks Production of Vinyl Chloride * Machine operator covering electrical wire with PVC plastic insulation Accountant at plant making PVC fabric Loading pesticide cans with VC propellant Note 7 Note 8 Angiosarcoma involving liver, lung, and pericardium. Although difficult to determine, primary site seems to be pericardium. Diagnosis: Sarcoma (possibly "angiosarcoma"), liver. Possibility of generalized neoplasm of the reticuloendothelial cell system cannot be ruled cut. * Indicates microscopically confirmed angiosarcoma of the liver. "00" Indicates unknown data. ' ucc 001143 _HO MAY i i b/o UNITED STATES ENVIRONMENTAL PROTECTION AGENCY national WATER QUALITY laboratory 6201 CONGOON BOULEVARD DULUTH, MINNESOTA 55804 May 19, 1975 Dr. Milton Fraifsld, Project Manager Vinyl Chloride Research Manufacturing Chemists Association 1835 Connecticut Avenue, NW Washington, D.C. 20009 Dear Dr. Freifeld: Your letter of May 5, 1975 to Dr. Walter Sanders has been referred to me for additional comment, since we have an assignment to examine the toxicity of vinyl chloride to aquatic organisms. At the present time, we have only done an exploratory bioassay at our Corvallis, Oregon laboratory and in that test we did not measure vinyl chloride concen trations, so we do not know what the exposures really were in our test chambers. This is a particularly important question with vinyl chloride, since it doesn't stay in water for very long periods of time, at least according to the chemists. We are presently trying to negotiate an agreement with Bob Metcalf to prepare some labeled vinyl chloride so that we can make some analyses in these bioassays. At the moment we really do not have any information on vinyl chloride toxicity, but we hope to have some within the next few months. I would suggest that you contact John Eaton of my staff some time in August or September to ascertain the status of our work by that time. Very truly yours, Donald X. Mount, Ph.D Director cc: Mr. Walter Sanders SERL, Athens ucc 001144