Document 3QrGMJyomNM3rbO4XN7gO2pey

PLASTICS DIVISION ' .Ji 73 <^tkfyoctuc& and Ce*nica& INC. CHEMICALS GROUP F ive Executive Mall, Swedesford Road, Wayne, Pa. 19087 <55 <55 r<-5>5 <S3 <55 O' 4s- 10 January 1975 A. R. Adams. General Manager Tel: (215) 687-6150 Twx: Mtl. Ralph L. Harding, J*. The. Society oh the Plastics Industry, Inc. 250 Park Avenue New Vo>tfe, New York 10017 Dear Ralph: Please hind enclosed correspondence hfu>m P*. B. G. GAeenbeAg, DeanSchool oh Public Health, University oh NoAth CaAolina. The estimated budget hA the Feasibility Study oh CanceA Nortality and Norbidity among vinyl chtoAide exposed woAkeAS is signihicantly fugheA than that authoAized by the lull membership oh the Ad Hoc Committee oh I/CM and PVC PAoduceAS. BehoAe formally inviting Da. GAeenbeAg to conduct the Feasibility Study las outlined in youA dAaht letter to him dated DecembeA 19, 1974) 1 leel we must obtain support hAom the hull Committee to lund this project. 7 am sure you understand Air Products' position on the necessity oh this study. A. Die believe that there is a need to develop a statistically meaninghul vinyl chloride dose response curve hr humans. B. That such a study must be designed and carried out by an agency whose credentials are unquestioned and the re liability oh the data will be accepted on a worldwide basis. C. That there is a need hor this study irrespective oh the status oh various pending legislative actions. I have requested hrom Dr. Greenberg authority to circulate the pro posal to the voting representatives oh the Ad Hoc Committee oh VCN and PVC Producers. Very truly, ARA/dh Enclosures cc: Nr. R. Flaming A. Ross Adame SCHOOL OF FUBUC HfAlTH OMC9 0 ?*f OtA* THE UNIVERSITY OF NORTH CAROLINA AT y*J< /V C++****^ +p>/?SrT+-u-vS*C*3 ' CHAPEL HILL 27914 January 3, <<5353 TELEPHONE^ AREA 919. 966-lffS CSS O'* 1975 <-1 o> Dr. A. R. Adams Air Products and Chemicals Chemicals Group 5 Executive Mall East Swedesford Road Wayne, Pa. 19087 Dear Ross: JAri 0 6 1975 A. ROSS ADAMS In reply to the draft letter of December 19, 1974 from Ralph L. Harding, Jr., I enclose a proposal for a feasibility study to investi gate mortality and morbidity data from workers exposed to vinyl chloride. The proposed budget for the feasibility study is $72,971 - considerably more than our earlier "off-the-cuff" estimates. The higher estimate is the result of three factors. Firstly, based on our experience in setting up the occupational health study for the chemical rubber union-management contract, our advisors state that the feasibility study will require a minimum of two full time research associates for eight months, and ten percent time of three senior level faculty for the same period. This amount of effort is necessary if we are to obtain a good grasp of the data base for a dose-response study, and produce a report that includes a sound study protocol as well as intelligent cost estimates. Secondly, because of the large number of plants potentially involved in a full scale study, we allocated considerable funds for travel and per diem expenses. Thirdly, since a substantial amount of personnel effort will be required, we must negotiate this feasibility study as a regular University contract, thereby incurring the usual 48.12 percent overhead expense on direct salaries. I am reluctant to handle this large a contract as a letter of agreement outside of the University channels. - I believe that the importance and scope of the full scale study deserves a well planned and carefully researched feasibility effort. By allocating an adequate amount of personnel effort to the feasibility study, we can be much more realistic about the limitations of a full scale study and, hopefully, save the industry the burden of investing in a poorly planned research endeavor. I will be happy to discuss personally with you any aspect of our proposal and I look forward to your reaction to the attached research plan. Sincerely yours, BGG/fwa . Enclosure - Proposal for Feasiblity Study cc: Dr. Carl M. Shy Am B. G. Greenberg Dean . IUJIU 1 uu kui yuiiiii OR CITE' LIVER Af!GI0SA.w0tl,\ CASES A/GHG VC PGLYKERIZATiCKI CORiCERS2 Case Co. Country Date of Death i West Germany ' 1969 Years after First Exposure ' 11 ' Years of Exposure 11 . <53 <53 1 ...... fO<53 .Aqc Gt --" Diagnosis . w--r,J 39~ 2 United States Alive - 12 12 r - ."45 3 United States 1971 _ - 13 . -37 4 West Germany 1971 14 14 40 5 United States 1968 . I5 6 United States 1961 15 15 15 44 41 7 United States 1958 8 United States 1959 17 17 18 ' .:4- 54 ' 41 9 Sweden 1970 19 '*18 ` 43 10 United States 1969 20 - v ~ - - 15 i; 50 . 11 United States 1964 20 18 - . 52' 12 United States .1973 13 Norway - 1972 -22 . -- 16" i:.. 51/...... 22 - 1 21 -- ' ' ' 56' 14 United States 1970 23 23 6a 15 United States 1968 24 18 45 16 United Kingdom 1972 17 United States 1973 26 . . 28 - - V?0 . " 71 . 28- * 59 18 United States Ailive . / 29 *" . 43 19 United States 1974 30 " - ' 30 20 Czechoslovakia Awaiting Details * 21 Czechoslovakia ' - .Awaiting Details # 52 -o- ] Y KU BUBtBVOJyO* u n n r* rr f> fs .rr r* f r j n ( Table 2. ! 1 Comoarisen1 1 ; ! Number of Plants Study Population a) Yrs. exposed b) Onset since first exposure A COMPARISON OF MORTALITY STUDIES. AMONG VINYL CHLORIDE WORKERS i ' Tabershaw/ . Study ; :. * ,. ' . j' --- ---- ---------------- 1------------- Cooper '. Dow' ; ; `1 " NIOSH ' Niicholsdn' \i % 33 *. ' * .i ' , ' : . /" 1V- '| -2' ' '. 1 1 yr or more 1'yr or'more .. '5 yrs'1 of more , 5 yrs or more . ' ' ** No restriction No restrict!05 Af least 1.0 yrs At least 10 yrs c) Size of cohort . 8,384 ` . , 522 v * ' V 930 257 . , H) No.' successfully ' . followed up 7,128 . (85%) . ,505 ' ; r ' 1 (97%) 1 / ' .. 645 , . (69%) 255 ! (99%) e) No. of deaths SMR's or ' Relatii! ve Risk All causes of death All cancers 1 i ! I. : . 352 75 110 (total 114 (only those with 5 yrs or mere exposure) i Multiple cancer sites suggested Angiosarcoma of the liver found Yes Yes 8a. - 109 .. ; 24 * * . , ` . ,s. 91 . , ' 103 4 126 . 84 (total) 1 ' 1574s* 1 231 . 250 (only those ' with high expo-. . *1 1 * ` *^ 1 . I * f 1 , 1 sure with at 1 least 15 yrs :* . .v<- ; , t i* 1| ,after onset of. -1 . - 1 exposure . > `. . ! 4 * Yes . ' ' 1 :. , .f , * ; -* . Yes . ,i Yes ! No , . Yes (?) : Yes 1 Monson . 2 No Restriction No Restriction _-- . * .. 161 f " V \* * ' __ . OI* ` '1 150* Yes Yes * Statistically significatn at p <0.05 ** Statistically significant at p:<0.01 1. Classification of exposure levels according to process Process A. Monomer manufacture Polymer manufacture C. Fabrication of end products Exposure Levels by Job Low Middle High fl If II 1 ` - i ' - t - <33 <<S33> .Note: A full time employee (industrial hygienist), x 8 months will be . required to obtain familiarity with these process and job classifications. The researcher will determine the"feasibility of obtaining substantiating ^measurements of vinyl chloride .especially at .various fabricating operations. 2. Computation of number of"workers'within each process'artdjob category, .and inventory of medical records available.in each plant. Feasibility and methods to obtain death records on retirees and industry drop-outs must ;also.be_investigated. " This-function'will"also require a full-time employee (epidemiology associate) x 8 months. . 3.^_ Each of-the above employees, will be. required to_spend_ considerable time visiting industry-headquarters" and plant locations. Fifty percent of the employees time will be spent in the"fieldV'Tor a total of 170 man-days of per diem. Each of the two employees are likely to make 3 trips/month, for a total of 48 trips. ' '" ............ '' -- . --4. ^Evaluation of--data sources identified by the above researchers and plan . _ning, design and protocol development for a full scale mortality and morbidity survey. This effort will require 10% of the time of each of three senior level persons: a biostatistician, epidemiologist and industrial hygienist. VRD 0002006550 -4 5 . The final product of the feasibility study will be a written report on the data sources, quality of data, research^desigiTTnciuding a protocol, level of effort and cost of conducting the mortality and morbidity survey of vinyl chloride exposed workers. 6. The estimated time interval for performance of the feasibility study, from contract award to completion of the final report, is eight months. Estimated Budget for Feasibility Study Salaries 1. Senior level faculty consultants in epidemiology blostatlstics and industrial hygiene @ 10% level for 8 mos. each = 2.4 man mos. 2. Two field investigators (industrial hygienist and epidemiology associate) @ 100% x 8 mos. =* 16 man mos. @ $15,000 per year 3. Secretary @ 40% level x 8 mos 3.2 man mos. @ $7,000 per year 4. Clerk @ 20% level x 8 mos. * 1.6 man mos. @ $7,000 per year Subtotal II. Fringe benefits @ 15% of salary III. Travel 1. 170 man-days @ $35 per diem 2. 48 trips @ $200 travel fare/trip . IV. Miscellaneous expenses 1. Telephone, duplicating, office supplies, computer services V. University overhead @ 48.13% of direct salaries Estimated Total Budget $ 10,000 20,000 2,240 1,120 $ 33,360 $ 5,004 $ 5,950 9,600 $ 15,550 $ 3,000 $ 16,057 $ 72,971 APPENDIX `` . 5M C3 <3? <5}5 LITERATURE REVIEW ON VINYL CHLORIDE INDUCED CANCERS IN HUMANS "" . - ' " S CJ1 r*o In January 1974, the B.F. Goodrich Company in Louisville reported to the National Institute of Occupational Safety and Health that three deaths from hemangiosarcoma of the liver had occurred in polyvinyl chloride production workers (JL Creech, J. Occup. Med 16:150-151, 1974). Subsequently a total of 15 cases of hemangiosarcoma of the liver was identified among workers with a history of occupational exposure to vinyl chloride. These associations are significant because_of. the experimental evidence that vinyl chloride, administered to rats and mice at concentrations of 50ppm and greater, induced angiosarcoma of the liver, and other tumors including pulmonary adenomas and mammary'carcinomas (in mice) and zymbal gland carcinomas and nephroblastomas (in rats). (References: C. Maltbni, Envir. 'Res 7-:387-405, 1974; P.L. Viola, Cancer Res. 31:516 519, 1971). "' : . Prior to these observations, vinyl chloride has been treated as a relatively Innocuous gas. Exposure to high concentrations exceeding 500ppm resulted in a mild anesthetic action and a reversible lung irritation. In 197i, the threshold limit value was lowered from 500 to 200ppm, based largely upon the increased occurrence of acroosteolysis in occupationally exposed workers and evidence of liver toxicity in animals. Shortly after the discovery_of_the;human carcinogenic properties of vinyl chloride, the TLV was lowered to 50ppm, and an ultimate limit of lppm was proposed. Under contract from the Manufacturing Chemists Association, Tabershaw and Gaffey (J Occup. Med 16:509-518, 1974) computed mortality rates of workers from 33 plants who had worked for at least one year in a job involving exposure to vinyl chloride. -2- C3 ' <S3 Eighty-five percent of workers, or 7128 individuals, were traced, and standardized mortality ratios were computed against the mortality experience of U.S. males of the same ages. Overall mortality of the study population was significantly lower o' (75% of expected) than that of the U.S. male population. However, for several malignant neoplasms the SMR increased with increasing exposure (measured by level, duration, or both). In the high exposure group with 5 or more years of exposure, the SMR for total malignant neoplasms was 141; for malignant neoplasms of digestive organs and peritonsum: 151; for malignant neoplasms of respiratory system: 144; for malignant neoplasms of other and unspecified sites: 204; and for lymphomas: 222. Workers with low estimated exposure levels were found to have SMRs less than 100 for all cancers except those of the buccal cavity and pharynx (SMR=30) and of other and unspecified sites XSMRt=i46). However, cancer of the buccal cavity did not correlate with duration or intensity of exposure. The authors concluded that mortality from digestive and"respiratory"cancer, cancer of other and unspecified sites, and lymphomas appeared to be related' to duration-and intensity of exposure. About 40% of the observed deaths in the category of "other and unspecified" cancers were due to brain cancer. With the exception_of buccal cavity.and "other and unspecified" cancers, workers having lower level exposures to vinyl chloride revealed SMRs less than 100 for all cancerous and non-cancerous causes.,.. I I" The distribution of causes-of-death among 161 deceased workers in two plants, a vihyl chloride" monomer and a polymer manufacturing plant, were compared with propor tional mortality ratios for U.S. white males (Monson, Lancet ii:397-398, 1974). A 50% proportional'excess of deaths due to all cancers was found, with the greatest excess in cancers of_the,liver and.biliary.tract,.lung-and-brain. These data were supportive of findings.from the.larger-studybyTabershawand Gaffey. -3- ' - 3CW5 <53 . r 3 Current manifestations of angiosarcoma of the liver are generally the result el <33 high occupational exposures beginning 15-20 years ago. Table 1 (taken from an un-^ published EPA report on vinyl chloride) provides data suggesting a latent period 11-20 years between first exposure and clinical manifestation of tumor. This latent period suggests that the full impact of vinyl chloride exposure may not be realized for 10 or more years, unless current reductions in occupational exposure exert an immediate beneficial effect. --- - - - - - -------- r~: . : ... - With respect to general community exposures, two confirmed angiosarcoma cases have been reported from Connecticut (EPA report, op. cit), one in a 73-year old man who had lived his entire life within 2 miles of an electrical products factory which processed electrical insulation made of polyvinyl chloride. The other case was an 83-year old woman who resided for 35 years within one-half mile of the vinyl chloride products plant. The old age and long-term low level exposures of these non-occupational cases suggest that low level exposures may not be entirely innocuous and that the latent period may be greatly increased under these circumstances. -- --Ben Holder of-'the"Dow1 Chemical Company (testimony'presented at-public-hearing on the proposed standard for occupational exposure to-vinyl chloride, U.S. Dept. of Labor, Washington, D.Ct, June 25', 1974 - cited in EPA report, op. cit.) reported results of a long-term mortality study of 594 chemical workers exposed to vinyl chloride between 1942 and 1960. Each job classification was assigned a vinyl chloride exposure rating based on actual air measurements. A low exposure group consisted of persons with time weighted average concentrations below 25ppm vinyl chloride, an intermediate group with 25-200ppm exposures, and a high group with 200-300fppm exposures. The authors con cluded that an apparent increase above expected (U.S. white male mortality rates) in overall malignancy rates occurred only in the high exposure group. Angiosarcomas were not found at any level of exposure. However assignment to exposure groups was determine "TO 11 w -4- . \- ' <S5 V< <S> ' ..... . _ _ _ - _ - . ^ .. ...... ~ - r- 3 ~ CS5 by the highestexposureexperienced forone or more months.Only- 19 of163 members^ O'! in the highexposuregroup had high levelexposures for10 or more years.Therefore' the group as a whole had time weighted average exposures below 200ppm. However, the low exposure group should have included only individuals with exposures less than 25ppm. - Nicholson and colleagues (Mortality Experience of a Cohort of Vinyl Chloride- Polyvinyl Chloride Workers. Paper'-presented at a Working Group on "Toxicity of Vinyl Chloride-- Polyvinyl Chloride sponsored by the New York'Academy of Sciences, New York City, May 10-11, 1974) identified a cohort of 257 individuals with at least a:five year history-(subsequent fee-1946):of occupational-exposure to vinyl chloride in-a -polymerization plant.- All'individuals employed ih the plant from i946-1963 and meeting the above'criterion were included. The mortality status of these individuals was evaluated from the 10th year of- their employment through April 1974; 2:55 men, or 99% of individuals, were traced. - No measurements-of actual exposures were available and no effort was made to categorize level of exposures. A total of 24.deaths was identified, 25% above expected (U.S. white male population). Cancer deaths were 131% in excess, and included three confirmed cases of angiosarcoma, one brain cancer and two lymphomas. The study cohort was relatively young at the time of entry to the study, since over half of the men were under age 37 at entry. ._ - N1QSH. conducted -a study of mortality and morbidity among 930 current'and past employees at-two vinyl chloride polymerization-^plants- (reported in'EPA~reportop. ' " cit-). ; The study population was restricted -to "workers' with 5 or- morer years employment wha had been empIoyed-:in the" polymerization- process- at least 10 years'prior to'the study-- _ Unfortunately- 31% (2S& Individuals ) - were- notesuccessfully contacted," and" these individuals^-were conservatively assumed to be aHver:In spite"of'this^assumption",'a > , 1 ;; C3 <x? <3? <55 , . . _ '` .... '' -- ... <55 <55 O' significant 57% excess in cancer deaths above expected (U.S. white male population)S was observed. Excess deaths were found for cancers of the liver, respiratory, hematopoietic, brain and central nervous systems. Liver cancers were 12 times expected. The majority of cancer deaths (25 of 31) did not occur until at least 15 years following first exposure to vinyl chloride. The attached Table 2 is taken from the previously cited EPA report and summa rizes the findings of the above described studies. . wi ic, _ _ e: SSUH T1 Z JLV7. . Z. N Proposal for a Feasibility Study of Cancer Mortality and Morbidity Among Vinyl Chloride Exposed Workers 3b ' <53 5 CS3 |s> <53 S3 O'* <jr\ --J I. Objectives In this feasibility study, investigators from the University of North Carolina would obtain information from operating plants concerning existing records and data that would be required (1) to classify vinyl chloride exposures of workers by process (monomer or polymer manufacture or fabrication of end products) and by job within each plant, (2) to -compute mortality rates for specific disease-categories among actively employed, retirees and rdrop-outs from the industry"". From these- data sources the investijgators, would detejcmine ..the jcast-and feasibility of-mortality:ahd :-- morbidity surveys of vinyl chloride exposed.workers-at-all stages-of1vinyl-chloride manufacture and fabricatiqn._intQjzend-products^ andzwould -develop a protocol^ for such surveys, ifv-deemed to .be feasible. _t v; _r: z. ::"zi_- z:-:z zzz~- :: II. Background. - . ... -__ r-_-. : :: zz --=_ : _z z.^ Five mortality studies: ofr vinyt chloride -exposedworkers -have been-conducted to date. These.studies are. summarized in -the" appendix-to :this proposal. ~-The important points to note from these studies are the following: . 1. Most tumors: werezmanifested T1 to 20 years- after-onset of exposure to ~ ' vinyl: chloride. z-z- ~zr rzz._z--zzz zr-r-.z ff -zzz.zz.zl: ir z: z z--- 2. Excess'deaths-'are'not attributable only to angiosarcoma bf the liver, but include cancers of the respiratory and hematopoietic systems and brain. _ 3. Some - angiosarcomas (two, to- date) may be attributable _to "low level non-- occupational exposures. The possibility of excess lung cancers, lymphomas and brain cancers associated with low level occupational and bon-occupational exposures must be seriously* considered. /w.. ; .-w--- * * z. o Greenrerr  -i- i . 4. Clear excesses of cancer mortality were demonstrated only in persons with exposures exceeding 100-200ppm,_when such measurements were __ available to categorize work exposures. ' III. Scope of Work '. . 33 C5 O' U1 oo A. The following factors must be considered in a mortality study of vinyl chloride exposed workers: 1. Date of onset of exposure to vinyl chloride; age, race and sex of exposed : person. -.......... - ----------- -------- - --- - . 2. Duration of employment in vinyl chloride process.---- -- - -; - - --- ' . - 3. -Estimates of-exposure-level for each job classification-in-the-vinyl chloride process, including monomer, polymer and fabrication processes. 4. Measurements of vinyl chloride concentrations to substantiate some of the _ - above work exposures.----- .... i--------- --- ~ -. r - r: Ji. r Measurement of vinyL chloride concentrations in-various polyvinyl chloride fabricating processes. ' 6. Important covariate information: smoking history, alcohol history, history : r . . of chronic .respiratory disease and liver disease, history of exposure to solvents in other jobs and in home hobbies. 7. Death records of persons who died while employed or after-retirement. 8. Names of individuals who left the industry before retirement, and follow : _ up contact with -these individuals--- - .ecr. - . . 9. ..Validation of liver and-other gastrointestinal deaths by pathological tissue examination. .. B. In the proposed feasibility study, investigators would ascertain data sources, quality of data,-;level of effort and cost of obtaining information on the factors identified above (in III A) ^."'Specifically^- the following activities would be undertaken: THE UNITED STATES COURT OF APPEALS FOR THE DISTRICT OF COLUMBIA CIRCUIT No. 74-2071 OIL, CHEMICAL AND ATOMIC WORKERS ` INTERNATIONAL UNION, AFL-CIO, Petitioner, v PETER J. BRENNAN, SECRETARY, UNITED STATES DEPARTMENT OF LABOR, and JOHN H. STENDER, ASSISTANT SECRETARY OF LABOR FOR OCCUPATIONAL SAFETY AND HEALTH, Respondents. <53 <53 <53 to <55 <53 as -n O' ro PETITIONER'S OPPOSITION TO MOTION OF FIRESTONE . PLASTICS COMPANY AND UNION CARBIDE CORPORATION TO DISMISS PETITION FOR REVIEW Firestone Plastics Company, a Division of The Firestone Tire & Rubber Company ("Firestone"), and Union Carbide Corporation ("Union Carbide"), filed a joint motion to intervene in the above case on January 13, 1975, and simultaneously filed a Motion to Dismiss the Petition for Review. As grounds for dismissal. Firestone and Union Carbide allege that since petitioner's principal place of business and general offices are in Denver, Colorado, this Court lacks venue under section 6(f) of the Occupational Safety and Health Act, 29 U. S. C. 655(f)(l970) Section 6(f) of the Act states in pertinent part: , "Any person who may be adversely affected by a standard issued under this section may at any time prior to the sixtieth day after such standard is promulgated file a petition challenging the validity of such standard with the ' United States Court of Appeals for the Circuit wherein such person resides or has his principal place of business, for a judicial review of such standard . . . (Emphasis added. ) The Motion to Dismiss totally ignores the statutory language providing for the filing of a petition for review in any Circuit wherein the petitioner "resides." The Supreme Court has held that an unincorporated association, such as a labor union, "resides" for venue purposes wherever it is "doing business" and not just where it maintains its principal place of business. Denver & Rio Grande Western Railroad Co. v. Brotherhood of Railroad -Trainmen, et al., 387 U. S. 556 (1967). The petitioner. Oil, Chemical and Atomic Workers International Union, does business in the judicial district of this Court. It maintains offices at 1126 Sixteenth Street, N. W. , Washington, D. C. 20036. It has a full-time staff at that office, and transacts business in the District of Columbia on behalf of its members. It therefore "resides" within the District of Columbia. WHEREFORE, the Motion to Dismiss should be denied. January 22, 1975 Lachtnian, Abeles, Anker & Nagle, P. C. 1730 M Street, N. W. - Suite 900 Washington, D. C. 20036 Attorney for Petitioner CERTIFICATE OF CERVICE The undersigned hereby certifies that a copy of the foregoing Petitioner's Memorandum in Opposition to the Motion of Firestone Plastics Company, A Division of The Firestone Tire & Rubber Company, and Union Carbide Corporation to Dismiss Petition for Review Filed by Oil, Chemical and Atomic Workers International Union was served by first-class mail, postage prepaid, this 22nd day of January, 1975, on the following counsel: Stephen F. Eilperin, Esq. Assistant Chief, Appellate Section Civil Division, Room 3547 U. S. Department of Justice Washington, D. C. 20530 Allan J. Topol, Esq. Covington and Burling 888 Sixteenth Street, N.W. Washington, D. C. 20006 George H. Cohen, Esq. Bredhoff, Cushman, Gottesman & Cohen 1000 Connecticut Avenue, N.W. Washington, D. C. 20036 John J. Cassidy, Jr., Esq. Vedder, Price, Kaufman, Kammholz & Day 1750 Pennsylvania Avenue, N.W. Washington, D. C. 20006 Jerome H. Heckman, Esq. Keller and Heckman 1150 Seventeenth Street, N.W. Washington, D. C. 20036 J. Albert Woll, Esq. Woll, Mayer & Gold 815 Fifteenth Street, N.W. Washington, D. C. 20005 Donald L. Morgan, Esq. Cleary, Gottlieb, Steen & Hamilton 1250 Connecticut Avenue, N.W. Washington, D. C. 20036- A73 C3 <S5 <S) O' S' Ms. Donna Roberts Legal Department Dow Chemical 2030 Dow Center Midland, Michigan 4 8640 Lawrence D. Lenihan, Esq. Arthur, Dry & Kalish 1230 Avenue of the Americas New York, N. Y. 10020 John T. Ronan, III, Esq. Stauffer Chemical Company Law Department Westport, Conn. 06880 Patrick F. McCartan, Esq. Jones, Day, Cockley & Reavis 1750 Union Commerce Building Cleveland, Ohio 44115 George Rowe, Jr., Esq. Fulton, Walter & Duncombe 30 Rockefeller Plaza New York, N. Y. 10020 Marshall Lee Miller, Esq. Reavis, Pogue, Neal & Rose 1100 Connecticut Avenue, N.W. Washington, D. C. 20036 Dale Martin, Esq. Goodyear Tire & Rubber Co. 1144 E. Market Street Akron, Ohio 44316 Harold J. Fast, Esq. The B. F. Goodrich Company WHB 6, 500 South Main Street Akron, Ohio 44318 . ,=4 CJ ^ o' 0*1 ' '