Document 2RkYb455N7J3kq9q2R9xNvLVL

U.S. Department of Labor MAR i 6 1981 Occupational Safety and Health Administration Washington, O.C. 20210 Reply to the Attention of: Howard L. Kusnetz, Manager Safety and Industrial Hygiene Shell Oil Company One Shell Plaza Post Office Box 4320 Houston, Texas 77210 Re: Vinyl chloride, 1980 Candidate List, Comment No. 7-11-1, Docket No. " rkr'rtA Dear 1 We are responding to your letter of concern about 0SHA placing vinyl chloride (VC) on its Candidate List. OS^A did notyplace VC on its 1980 list of candidate substances for further scientific evaluation of carcinogenicity, however, VC does appear on the EPA Carcinogen Assessment Group's list of carcinogens. As you know, OSHA promulgated a health standard in 1975 based on the carcinogenicity of VC. The purpose of our cancer standard is to establish which substances found in the occupational setting are carcinogens and then to regulate in a systematic manner those substances that would result in an achievement of the greatest reduction in adverse effects on human health. As indicated in OSHA's cancerstandard, priority assignments will not be based on health hazard alone, but will be based also on consideration of population at risk, current employee exposure levels, existing regulations, existing means of exposure control, nature of the operation, etc. OSHA will not pursue regulatory activity where these other factors demonstrate that it is neither necessary ngjf* appropriate to do so. 533. Sincerely co UJ CD Bailus Walker, Jr., Ph.D., M.P.H. Director Health Standards Programs cc: Dr. Peter Infante Docket Office