Document 39jLZ29eZm1XQQw6zeR7nQaE

Redwell 1 INDEX (Box 31) Dendinger v. UCC (background material #2) Total amount and percentage of sales for 9 defendants Letter dated 03/31/88 to counsel from Robert Bunda (Fuller & Henry) regarding Dendinger and Wallace Letter dated 12/02/74 to John Stender (OSHA) from R.N. Wheeler, Jr. (Union Carbide) regarding OSHA standard for exposure to Vinyl Chloride under standard promulgated 10/04/74 Letter dated 02/01/88 to Peggy Whipple (Fuller & Henry) from R.N. Wheeler, Jr. commenting and correcting errors in the deposition of R.N. Wheeler, Jr. Letter dated 03/17/88 to Robert Hollingshead (Pitney, Hardin, Kipp & Szuch) from Robert Bunda (Fuller & Henry) forwarding a copy of the transcript of, exhibits to and comments to the deposition of R.N. Wheeler Memorandum dated 02/02/88 to Robert Bunda from Marcia Haase attaching 3 charts regarding summaries of Stauffer, Diversitech, Shintech and Schulman responses to discovery Index to deposition of Roscol Nicholas Wheeler taken 12/09/87 Chart on sale of PVC materials to Chrysler (1968-1981) Article on "Occupational Cancer" by Michael Alderson, Chief Medical Statistician, Office of Population Censuses and Surveys, London Article on "IARC Monographs on the Evaluation of the Carcinogenic Risk of Chemicals to Humans" (1979), Volume 19 Article from "Encyclopaedia of Occupational Health and Safety," volume 2 (Technical Editor: Dr. Luigi Parmeggiani) on polyvinyl chloride Material Safety Data Sheet on vinyl chloride Toxicological Profile for Vinyl Chloride from U.s. Public Health Service (draft for comment) Material Safety Data Sheet on vinyl chloride UCC 060394 Redwell 2 Article on "Mortality Among Employees on PVC Fabricators" by Leonard Chiazze, Jr., Sc.D., William E. Nichols, Ph.D.; and Otto Wong, Sc.D. from the Journal of Occupational Medicine. Volume 19, No. 9, 09/77 Article on "Poly(vinyl Chloride) Processes and Productions" by R.N. Wheeler, Jr. from Environmental Health Perspectives. Vol. 41, 10/81 Letter dated 04/17/86 to counsel from Robert Bunda reporting on status of developments in the 2 pvc actions arising out of the Sandusky, Ohio Chrysler Plastic Products plant Printout from Thomas Reitz of all PVC, VC and VCM cases (active and closed) Article on "Small airways function in workers processing polyvinylchloride" by J. Nielsen, C. Fahraeus, I. Bensryd, B. Akesson, H. Welinder, K. Linden, and S. Skerfving from International Archives of Occupational and Environmental Health (1989) Redwell 3 EPA Vinyl Chloride Standard -- Leak Detection/Elimination Internal Union Carbide memorandum dated 06/13/84 from J.F. Erdmann to S.M. Norwood attaching a letter of approval for the leak detection and elimination plan for the Texas City Plant (TACB letter dated 06/05/84) Handwritten note dated 05/16/84 regarding background VCM within plant area Internal Union Carbide memorandum dated 05/15/84 from Thuy T. Do to J.J. Erdmann replying to Sabino Gomez's letter of 04/20/84 concerning UCAR Solution Vinyls Leak Detection and Elimination Program Handwritten note dated 04/27/84 and 05/01/84 to "provide info we need" Letter dated 04/20/84 to F.S. Provensano (Union Carbide) from Sabino Gomez (Texas Air Control Board) Letter dated 04/20/84 to F.S. Provensano (Union Carbide) from Sabino Gomez (Texas Air Control Board) with handwritten comments thereon Letter dated 10/05/83 to Cecil Bradford (Texas Air Control Board) from Robert E. O'Bryan (Union Carbide) attaching an updated copy of the Solution Vinyl Resins Leak Detection and Elimination Program [2 copies] UCC 060395 Redwell 4 Handwritten note dated 09/28/83 to Bob O'Bryan from Jack commenting and Thuy Do's leak detection program for svr unit for vcm Letter dated 12/03/76 to O.W. Lively (EPA) from Robert O'Bryan enclosing leak detection and elimination program for Texas City Plant Plant emergency procedures effective 09/01/77 Internal Union Carbide memorandum dated 04/10/79 to Plant Letters Lists A, B, C, and D from D.L. Engle attaching Fire Watch Procedures (effective 05/01/79), Bicycle safety procedures (effective 05/01/79, and revised Plant Emergency Procedures (effective 09/01/77) Handwritten note dated 12/18/78 to Dean Smith from Jack Eromann regarding frequency patrol monitoring Letter dated 12/14/76 to Jim Tarr (Texas Air Control Board) from J.F. Erdmann (Union Carbide) attaching a copy of the leak detection program report required by VCM regulation Handwritten notes on description of equipment Pamphlet on some new monitoring technology (1986) Handwritten note dated 09/23/85 to check with Ernie Saldua to show point at which an alarm condition occurred and the time it happened Vinyl Chloride Article on "Case Studies in Environmental Medicine: Vinyl Chloride Toxicity" from Clinical Toxicology (1990) Article on "Persistent Liver Dysfunction among workers at a Vinyl Chloride Monomer Polymerization Plant" by S.F. Ho, W.H. Phoon, S.L. Gan and Y.K. Chan from Journal of soc. occup. Medicine (1991) Article on "Case Studies in Environmental Medicine: Vinyl Chloride Toxicity" from Clinical Toxicology (06/90) Article on "Persistent Liver Dysfunction among Workers at a Vinyl Chloride Monomer Polymerization Plant" by S.F. Ho, W.H. Phoon, S.L. Gan and Y.K. Chan from Journal of Soc. Occup. Medicine (1991) UCC 060396 Letter dated 08/29/88 to H.C. Lewinsohn, M.D. from B.H. Avashia, M.D. enclosing an article on systemic sclerosis which pertains to the South Charleston Plan and a rebuttal of same prepared by a Carbide consult in rheumatology Article on "Vinyl Chloride: Updated Study Finds Low Cancer Rates Among Workers Previously Seen as HighRisk" from Occupational Safety & Health Reporter. 09/14/88 Article on "Systemic Sclerosis Secondary to Occupational Exposure" by Gregory R. Owens, M.D., Thomas A. Medsger, M.D. from The American Journal of Medicine. Volume 85, 07/88 Letter dated 11/14/85 to Dr. Hilton Lewinsohn (Union Carbide) from William J. Nicholson, Ph.D. (The Mount Sinai Medical Center) enclosing a final version of the EPA Asbestos Health Effective Review Note from A. A. Lang, M.D. discussing differences between progressive systemic scleroderma and VC disease Book on Vinyl Chloride - Associated Disease sent to Andy by Dr. Lang Database printout dated 06/17/83 of bibliographic citation list generated by MEDLARS II on sclerodermapsoriasis (requested by Dr. Land and sent to Shirley Conner at Union Carbide) (search performed on Back 66) Database printout dated 06/17/83 of bibliographic citation list generated by MEDLARS II on sclerodermapsoriasis (requested by Dr. Land and sent to Shirley Conner at Union Carbide) (search performed on Back 71) Note from A. A. Lang, M.D. discussing differences between progressive systemic scleroderma and VC disease Article on "Incidence of cancer among vinyl chloride and polyvinyl chloride workers" by S. Storetvedt Heldaas, S.L. Langard, and A. Anderson from the British Journal of Industrial Medicine (1984) Letter dated 08/09/83 to Robert Maynard (Squire, Sanders & Dempsey) from Dr. A.A. Lang (Union Carbide) commenting on review of records concerning Edith Bumbarger's diagnosis of progressive systemic sclerosis or VC disease Note dated 09/06/83 to Dr. Lang and R.W. Holland from T.A. Lincoln enclosing article in The Lancet dated 08/20/83 regarding latency UCC 060397 Redwell 5 Redwell 6 Chart on Erosion of Multiple Terminal Phalangeal Tufts (acro-osteolysis) Articles from A.A. Lang, M.D. Articles on birth defects Article on "Electron Microscopic Observations of Hepatic and Subcutaneous Hemangiosarcomas Inducted in Mice Exposed to Vinyl Chloride Monomer" by Yasunosuke Suzuki, M.D. from American Journal of Industrial Medicine (1981) Author's abstract on generalized morphea-like scleroderma occurring in people occupationally exposed to organic solvents Article on "Use of Serum Bile Acids in the Identification of Vinyl Chloride Hepatotoxicity" by Gar M. Liss, M.D., M.S., Richard A. Greenberg, Ph.D., and Carlo H. Tamburro, M.D. from The American.Journal .of Medicine. Volume 78 (01/85) Vinyl Chloride -- Pre-1980 First page of Amended Complaint in Maliko First page of article on "Vinyl Chloride and Human Reproduction" by Brian MacMahon, M.D. (08/11/77) Safe Handling Guide for Chemicals (vinyl chloride (issued 01/04/72) First page of report on accident occurring 03/26/51 to worker who was exposed to mixture of vapors of vinyl chloride, vinyl acetate and acetone Inter-company (UCC) correspondence dated 01/14/49 to Dr. A.G. Kammer from Medical Division (Carl) discussing allergic response from vinyl chloride unit following exposure to a mixture of vinyl chloride and hydrogen chloride Inter-company (UCC) correspondence dated 11/21/49 to Dr. A.G. Kammer from Carl enclosing case history on Robert E. Saunders Letter dated 01/29/90 to Mary Szollasy (Union Carbide) from Robert Bunda (Fuller & Henry) returning documents provided for use in connection with the Dendinger case and noting that these documents put the actions of the company in the early 1970s in proper context and can be helpful in litigation UCC 060398 Redwell 7 Vinyl Chloride Monomer Impurities (1971) Internal Correspondence (Union Carbide) dated 12/03/71 to R.N. Wheeler from R.M. Arnold regarding the amount of residual vinyl chloride in Union Carbide's suspension and solvent vinyl resins and attaching 12/05/67 memo from J.L. Heckersmith regarding same Internal Correspondence (Union Carbide) dated 03/14/73 from W.B. Ackart regarding controversy over liquor packaged in PVC bottles and possible fallout from this incident that may extend to other applications Internal Correspondence (Union Carbide) dated 06/11/73 from W.B. Ackart regarding latest developments in PVCalcoholic beverages situation Informal Report dated 06/12/73 by H.T. Bias and R.A. Bleidt on analytical determination of residual vinyl chloride monomer in PVC resins in relation to the bottles made from PVC used as containers for alcoholic beverages Internal Correspondence dated 07/24/73 from W.B. Ackart attaching a copy of the letter to be sent to customers with questions on the food additive status of vinyl resins in contact with alcoholic beverages Letter dated 08/07/73 from W.B. Ackart to I.R. Cutler (Bakelite Xylonite Ltd.) summarizing the status of the PVC liquor bottle situation Letter dated 08/30/73 from W.B. Ackart to Joseph Pilgrims (Union Carbide) summarizing the status of the PVC liquor bottle situation Internal correspondence (Union Carbide) dated 05/18/73 to Dr. R.J. Keer from R.E. Gulick discussing the possibility of the FDA banning the packaging of alcoholic beverages in PVC containers Internal correspondence (Union Carbide) dated 03/27/74 to Dr. W.B. Ackart from R.M. Arnold discussing recent data on residual vinyl chloride levels found on various suspension/non-solvent vinyl resins and anticipated evaluations on solvent vinyl resins Internal correspondence (Union Carbide) dated 04/24/74 to M.E. Eisenhour from R.M. Arnold reporting on residual vinyl chloride content of suspension/non solvent vinyl resins [2 copies] UCC 060399 Internal correspondence (Union Carbide) dated 05/30/74 to R.N. Wheeler from J. John Brezinski attaching and discussing the VCM analyses of 6 samples from the Ottawa Plant study Internal correspondence (Union Carbide) dated 06/06/74 to M.E. Eisenhour from R.M. Arnold attaching table showing content of suspension/non-solvent vinyl resins blends produced during May Internal correspondence (Union Carbide) dated 06/06/74 to R.N. Wheeler from J. John Brezinski discussing analysis of VSKK resin labeled "treated" and "untreated" by Don F. Guyette of the Ottawa Plant Internal correspondence (Union Carbide) dated 06/18/74 to M.E. Eisenhour from F.L. Johnson and R.M. Arnold discussing the program to study the amount of residual VCM in suspension resin outlined in a letter dated 05/14/74 Note dated 06/20/74 to Ruth Anderson attaching a copy of the letter sent to customers regarding solution vinyl resins/dispersion resins in connection with vinyl chloride Internal correspondence (Union Carbide) dated 06/12/74 to M.E. Eisenhour from R.M. Arnold attaching table giving resin produced during 02/74 - 06/74 and discussing results of same [2 copies] Article on "Dynamics of Hygienic Working Conditions and Occupational Disease Incidence Among Workers in Suspension Polyvinyl Chloride Production Over a Number of Years" by V.S. Filatove, et al., National Institutes of Health, Bethesda, Maryland, 07/74 Internal correspondence (Union Carbide) dated 08/05/74 to M.E. Eisenhour from R.M. Arnold attaching summary of the VCM content of suspension vinyl resins produced during 07/74 Known VCM Emissions from Later Manufacture Letter dated 11/04/74 to Bruce Euchner from W.P. Miller (Union Carbide) discussing attached report on VCM content of UCAR Latex 1000 shipments Project Report dated 11/22/74 on a gas chromatographic analysis for the measurement of low levels of VCM in vinyl latexes. UCC 060400 Letter dated 12/03/74 to Robert Eller (Arthur D. Little, Inc.) from R.N. Wheeler answering various VCM questions Internal correspondence (Union Carbide) dated 12/18/74 to Rill Roeh from R.M. Arnold attaching analysis for VCM content of samples taken during bagging at Building 124 of various vinyl resin types Article on ''Monitoring the Concentration of Vinyl Chloride in the Work Place or Ambient Air" Exhibit VI -- Union Carbide Corporation Vinyl Chloride Monitoring in Fabrication Operations Internal correspondence (Union Carbide) dated 06/13/74 to R.M. Arnold from A.B. Steele discussing standards Solution and Dispersion Vinyl Resins Vinyl Chloride Monitoring Study Analysis of QSAN-7 for residual VCM content by R.M. Arnold Letter dated 03/25/75 to R.N. Wheeler to Grover C. Wrenn (U.S. Department of Labor) discussing vinyl chloride standard Letter dated 04/28/75 to Dr. Walter P. Miller from John W. Whittlesey discussion sale and distribution of latexes for the paint industry Analysis dated 04/29/75 by R.M. Arnold of suspension vinyl resins for VCM content following storage Letter dated 06/12/75 to M.E. Eisenhour, et al. from W.R. Manning and R.N. Wheeler enclosing excerpts from the Arthur D. Little Report which implies that there is little need for regulation of the PVC processing industries Article entitled "Union Carbide Reports PVC Coating Resins Obviating Controls Now Available" appearing in American Paint Journal & Coatings dated 05/19/75 Minutes from NSF Task Force Committee meeting 03/17/76 Internal correspondence (Union Carbide) dated 03/08/76 to G.T. Scott from G.F. Tacquard regarding VCM in suspension resins [2 copies] Internal correspondence (Union Carbide) dated 03/12/76 to A.E. Gabany from R.M. Arnold regarding samples to be tested by head space technique recently proposed by EPA ucc 060401 Internal correspondence (Union Carbide) dated 03/22/76 to M.E. Eisenhour from G.E. Vaughan regarding non solvent shrink wrapping Internal correspondence (Union Carbide) dated 03/15/76 to G.F. Tacquard from G.T. Scott regarding using extended blending to reduce the monomer content in "Q" resins below 10 ppm Internal correspondence (Union Carbide) dated 07/22/76 to J.B. Hollingsworth from G.C. Shipston regarding PPIVCM Meeting - Chicago, 07/21/76 Internal correspondence (Union Carbide) dated 03/22/76 enclosing letter and table sent to Gifford-Hill & Company, Inc. on 03/22/76 regarding results of tests on samples of resin, powderblend and pipe Letter dated 07/16/76 to R. Durazo (Plastics Pipe Institute) from G. Carl Shipston (Union Carbide) discussing methods being considered by the PPI VCM Committee for controlling RVCM in PVC potable water pipe and fittings "Specialty Vinyl Chloride Resin Processes Effects of Governmental Regulations" by R.N. Wheeler dated 09/01/76 Handwritten notes on VCM level in vinyl suspension resins Internal correspondence (Union Carbide) dated 12/19/77 to Dr. F.G. Willeboordse from W.B. Ackart regarding residual VCM in vinyl coatings, FDA analysis Internal correspondence (Union Carbide) dated F.G. Willeboordse from W.B. Ackart attaching analytical procedure for residual VCM in PVC resins sensitive to about lppb, developed by the FDA Internal correspondence (Union Carbide) dated 12/08/78 to R.N. Wheeler from W.B. Ackart discussing residual VCM in Bakelite solution vinyl resin VAGH Project report dated 11/20/78 on solvent vinyl resins for coatings -- determination of VCM at the parts-perbillion level -- part I Memorandum dated 12/12/78 by G.S. Peacock (trip report on solvent vinyl resins for coatings -- meeting with FDA on RVCM content 12/01/78) ucc 060402 Redwell 8 Internal correspondence (Union Carbide) dated 11/02/79 to Dr. R.A. Gregory from G.S. Peacock attaching initial results of RVCM measurements on production resins Internal correspondence (Union Carbide) dated 04/02/79 to R.N. Wheeler from T.B. Gibb on determination of VCM in PVC resins Statements and disclaimers on VCM Internal correspondence (Union Carbide) dated 11/02/79 to Dr. R.A. Gregory from G.S. Peacock attaching initial results of RVCM measurements on production resins Internal correspondence (Union Carbide) dated 01/15/80 to R.N. Wheeler from G.S. Peacock attaching a draft of the proposed memo for OSHA describing work done measuring RVCM content of vinyl resins Internal correspondence (Union Carbide) dated 04/17/85 to Jose Colucci from R.N. Wheeler setting forth the regulations covering residual VCM in PVC Status Report dated 02/18/65 on Exploratory Vinyl Resin Screening: Evaluation of Plasticized QXSC-11 Resins by J.J. Brezinski, B.A. Price and J.W. Fields Status Report dated 11/22/65 by J.J. Brezinski and J.W. Fields of comparative evaluation of 2 QXAM-11 samples, QEX-1197 and QEX-1198 prepared at Texas City Final Report dated 01/28/66 by D.E. Richardson and G.G. Harkreader concerning a series of polymerizations to determine the capabilities of existing production autoclaves to repair vinyl chloride-ethylene copolymers Status Report dated 04/22/66 by P.T. McCoy and A.W. Conkling comparing the performance of 3 ethylene modified vinyl chloride resins in an unfilled vinyl tile formulation to conventional poly(vinyl chloride) resin Memorandum date 06/30/66 from W.R. Manning transmitting memorandum dated 06/30/66 by Marion Johnson and W.S. Lanier pertaining to industry-wide meeting sponsored by the Pfaudler Company to discuss general aspects of safety in PVC plants Status Report dated 11/07/66 concerning comparison of the unfilled compound physical and processing characteristics of ethylene modified vinyl resins QSOM7 blend 3 and QSOM-7 QEX-1197 and conventional homopolymer QYTQ-7 IJC-C 060403 Memorandum dated 03/13/67 to employees regarding possible health hazard connected with manufactur of vinyl chloride resins -- employees may be asked to have hands X-rayed and fill out a questionnaire Internal correspondence dated 05/21/69 to Dr. Carl Dernehl from A.B. Steele discussing meeting with Goodyear representative and stating that "buildup of polymer in the reactors was a major problem." Internal correspondence dated 04/07/70 to Kenneth Lane, M.D. from R.E. Joyner, M.D. stating that in light of favorable VC1 levels, it is present intention to discontinue most aspects of surveillance program Informal report dated 07/09/74 by G.T. Waggy regarding biodegradability of vinyl chloride Internal correspondence dated 08/01/74 to Drs. A.B. Steele and N.L. Zutty from W.B. Ackart regarding FDA conference on VC1 monomer on PVC resins Internal correspondence dated 12/13/74 to J.S. Novak from W.C. Roch regarding UCM monitoring Letter dated 12/19/74 to R.V. Welty from John W. Whittlesey regarding hiring of females in VC regulated areas Memorandum dated 12/20/74 by J.C. Chaty and J.W. Fields entitled "VCM - The Processor's Perspective" Union Carbide pamphlet entitled "Monitoring the Concentration of Vinyl Chloride in the Work Place or Ambient Air" (outdated) Internal correspondence dated 06/18/75 from R.N. Wheeler regarding 2-year polyvinyl chloride resin feeding study Epidemiologic study of vinyl chloride workers employed by Union Carbide, South Charleston plan [2 copies] Partial report of studies conducted at a chemical manufacturing plant in Louisville, Kentucky (after 1980) Report (draft) entitled "Lung Cancer at PVC Polymerization Facility" by H. Falk, M.D., R.J. Waxweiler, Ph.D., J. Herbert, M.D., M. Kuschner, M.D., O. Auerback, M.D., L. Makk, M.D., and C. Tamburo, M.D. stating "now clearly established that workers exposed to VC monomer in process of polymerizing PVC plastics UCC 060404 are at a markedly increased risk for the development of the rare tumor hepatic angiosarcoma." (drafted '1978?) Report entitled "Carcinogenicity of Vinyl Chloride and Vinylidine Chloride" by C.C. Lee, J.C. Bhandare, J.M. Winston, W.B. House, R.L. Dixon and J.S. Woods (1977) Internal correspondence dated 12/05/67 to R.N. Wheeler from J.L. Heckersmith regarding residual vinyl chloride content of suspension vinyl resin stating significant concern regarding the safe use of our suspension resins in captive and customer process equipment Report entitled "Carcerogenic Effect of Vinyl Chloride" by P.L. viola dated 05/70 presented at the Tenth International Cancer Congress Internal correspondence dated 12/03/71 to R.N. Wheeler from R.M. Arnold regarding amount of residual vinyl chloride in Union Carbide's suspension and solvent vinyl resins Internal correspondence dated 03/27/74 to W.B. Ackart from R.M. Arnold attaching recent date on residual vinyl chloride levels found in various suspension/non solvent vinyl resins produced at Texas City plant Internal correspondence dated 07/09/74 from A. B. Steele stating that exposure to VCM concentrations has not yet been fully proven/demonstrated to cause angiosarcoma, so Union Carbide holds that OSHA must base its limits of exposure on proof of a demonstrable hazard Report dated 03/03/75 entitled "VCM Analysis of Vinyl Resins Produced at Texas City Plant January - February 1975" by R.M. Arnold UCC 060405