Document 3QoyDz78gqVqa8b1jYLOQaXrJ

Medical, &2&A June 6, 1974 Mr. Dr. *sr. Mr. H. J. Corbett - 3Sii George Roush, Jr.,~A.2SA n. c. Throdahl - DID t. ?. Wheeler - A2SA Mr. ?hocion S. Park A3SH The following are y recommendations on changes in the proposed Monsanto response to the OS[LA Permanent Standard for VCM Exposures; I would add this sentence at the end of the third paragraph on the first page, "we know that the level of VCM in the working area during thin time was considerably over the no detectable level." I would change the tense of the verb ''endorse" in the fourth paragraph on the first page to the past tense if you are going use it at. all. That sentence would read, "we endorsed OSILA*s temporary standard, etc." to X would remove the two last sentences from paragraph one, pago three. The implication of the sentence starting "Were it not for the extremely rare nature of angiosarcoma, etc.* would lead one to the conclusion that if the tumors are not found there is really no great problem. The last sentence, "The level of 19 deaths during this span of time represents an insignificant number** would kill us if it -a/ere taken out of context. A Nader type could say with some logic, 'Monsanto considers 19 deaths from cancer an insignificant number. " The first sentence in paragraph two on page three is open to somo argument. Taher3hav Cooper found an excess amount of angiosarcomas in the workers and it would bo hard to say this is not ar. adverse effect. I think, it would be safer for us to substitute the phrase "from the standpoint of increased mortality* at the* end of that first sentence in paragraph two. On page four in paragraph four, wc advia-e continuing exposing worker a to 50 ppm. I don't see how we can sweep the animal data at 50 ppm under the rug. I think we can change the last part of the sentence trout "At bu& current exposure limit of 50 ppsa* to "under 30 ppm tiut not o." On page five we are again equating econoutic loss to the occurrence of cancer. This is stated in the sentence .starting "'In view of this economic loss, etc." I think we can accomplish tho san?e purpose by taking out the phrase "the low incidence of angiosarcoma in PVC woiKers15 and substitutine? "tne general good health record of PVC workers and the absence of angiosarcomas in raany PVC manufacturing locations.a a,.re recommend maximum reduction of VCM exposure con sistent with feasible manufacturing practices." I would drop the last sentence entirely. ve nave no oasis to state that 50 ppm is RSV 0016912 Hr. Phocion s. Park -2- June 6, 1974 safe for workers. we know we are fighting 4 losing battle to try to keep it at that level. we night substitute' 'we recommend the adoption of a permanent standard at a level similar to those currently occurring in Industry where no cases of angiosarcoma have occurred." we have to realise that this is going to he a public document and will not be guoted in whole# but in part. Me will just have to be as circumspect as we can in not getting out on a limb in making statements that sight show we are on the sloe of cancer when dollars are concerned, or that wa are advocating a standard for which we have no basis. AiiK/ln H,a. kismet Kelly, i>. RSV 0016913