Document 3ewM1L9MVm8qznqEQkbRwYJKE

A.*/ OO J./& CMA CM Chemical Manufacturers Association Vinyl Chloride Health Committee FAX Match 11,1998 TO: COMPANY: Dr. James Barter PPG Industries, Inc. Mr. Ed Beeler The GEON Company Mr. John Gamble Westlake Polymers Mr. Mark Gruenwald Borden, Inc. Dr. Steve Phillips Occidental Chemicals Mr. Caffey Norman Patton Boggs, L.LJ?. Dr. Colin Park The Dow Chemical Co. Dr. David Penney CONDEA Vista Company Mr. David Pun Formosa Plastics Mr. Jay Strange Georgia Gulf Corp. PHONE: (412)434-2801 (440) 930-3030 (713) 960-9111 (614) 225-3459 (972) 404-2413 (202)457-5270 '(517m5tt9 (281) 588-3059 (973) 716-7279 (504) 685-2642 Lee Larson/ GEON Company Woody Ban for E. Beeler FROM: Wendy K. Sherman CMA (703) 741-5639 FAX: (412) 434-2137 (440) 930-3034 (713) 960-1540 (614) 225-7639 (972) 404-3287 (202)457-6315 (517) 638-2425 (281) 588-3478 (973) 716-7283 (504) 687-0294 (440) 930-3830 (703) 741-6091 MESSAGE Attached is the draft verification letter from Caffey Norman. Please make any changes/comments directly to Caffey Norman (phone and fax listed above) by Monday, March 16,19^8,12:00 noon. Due to Panel members7 traveling schedules, this letter will be sent to EPA on Monday (3/16) late afternoon. If you have any questions, please call me at 703/741-5639. Thank you. SENDER: Cynthia Barrett PHONE: 703/741-5642 PAGE(S) 5 (including cover) 004602.001 Innovation, Technology and Responsible Care At Work 1JQ0 Wilson Blvo., Arunci*, VA 22209 Tm>phonc 703-741-5000 Fax 703-741-S000 a/ jl.L/aa PAUL 2/5 CMA PATTON BOGGS, L.L.P. 2550 M STREET. N.W. WASHINGTON. D.C. 20037-1350 (2021 457-6000 FacsimileKOfi *576315 WRITER'S DIRECT DIAL (202) 457-5270 March 10,1998 MEMORANDUM FOR THE VINYL CHLORIDE PANEL Re: AEI Results As discussed on the conference call this morning, attached for your review is a draft letter notifying EPA of AEI's baseline results under 8(e) of the Toxic Substances Control Act. Please let me know right away if you identify any changes needed. Wendy intends to submit notification to EPA by the end of this week. Attachment UL W. Caffey Norman, in 004602.002 lwa 3/11/98 PAGE 3/5 CMA March 1998 3/10/98 DRAFT Document Processing Center Environmental Protection Agency Room E-G99, Mail Code 7407 Office of Pollution Prevention and Toxics 401 M Street, S.W. Washington, D.C. 20460 Attention: TSCA 8(e) Coordinator Dear Sir: The Vinyl Chloride Panel of the Chemical Manufacturers Association submits the enclosed preliminary results from an ongoing update of an epidemiology study of vinyl chloride last followed up by Wong et al., Am. J. Ind. Med. (1991) 20(3): 317-34. These results are submitted pursuant to Section 8(e) of the Toxic Substances Control Act. The enclosed tables represent the study contractor's baseline results compared to the results reported by Wong et al. According to the contractor, the current cohort differs from that analyzed by Wong et al. in that numerous errors are identified and corrected, several hundred cohort members not included in Wong et al. 's analyses have been restored, and some additional deaths have been discovered. Three columns of results are presented in each table; the first column contains results based on the cleaned and expanded cohort using U.S. mortality rates as the reference (methodologically most comparable to Wong et al. 's results); the second contains results using rates for the states in which each plant was/is located; and the third reflects Wong et al. 's results. Almost universally, the update results mirror those of Wong et al. Most exceptions are due to some rearrangement of specific causes of death within broader disease categories, often reflecting the way deaths are coded over different time periods and in different states (e.g., liver cancers and cardiovascular disease deaths). 004602.003  CPIA ** 3/11/98 PAGE 4/5 CMA 2- - The standardized mortality ratio (SMR) for "connective and soft tissue" cancers is significantly elevated (SMR=381 using the U.S. reference rates (95% confidence interval (Cl) 153 to 785) and SMR=367 using state reference rates (95% Cl 147 to 755)), based on seven observed deaths due to these cancers. This association has not been reported elsewhere to date. Biologically, the observed excess might be related to the well-known association between vinyl chloride exposure and angiosarcoma of the liver, as angiosarcomas (tumors of the blood vessels) occurring outside of die liver are classified as soft tissue sarcomas. On the other hand, deaths due to angiosarcoma of the liver but erroneously recorded on a death certificate simply as "angiosarcoma" without specifying "of the liver" will be classified as a soft tissue sarcoma as well. Unfortunately, it is not possible to determine from the death certificate whether this has occurred. The SMR for cancers of the "peritoneum and other digestive organs" is also significantly elevated (SMR=302 using U.S. reference rates (95% Cl 98 to 706) and SMR=274 (95% Cl 89 to 640)), based on five observed deaths due to these cancers. The study contractor has indicated that each of the five cancers observed is a different type of cancer with a different etiology. In light of the absence of consistency of these cancers, the contractor advises that this observed excess is unlikely to have any biological significance. The member companies of the CMA Vinyl Chloride Panel on whose behalf this submission is being made include: Borden Chemicals and Plastics 180 E. Broad Street, 15th FI. Columbus, OH 43215 Panel Contact: Mr. Mark Gruenwald Telephone: (614) 225-3459 CONDEA Vista Company 900 Threadneedle P.O. Box 19029 Houston, TX 77079 Panel Contact: Dr. David A. Penney Telephone: (713) 588-3059 004602.004 unA * 3/11/98 PAGE 5/5 CMA -3- The Dow Chemical Company 1803 Dow Center Midland, MI 48674 Panel Contact: Dr. Colin Park Telephone: (517)636-1159 The GEON Company One Geon Center Avon Lake, OH 44012 Panel Contact: Mr. Ed Beeler Telephone: (440)930-3030 Occidental Chemical Corp. P.O. Box 809050 5005 LBJ Freeway, Room 904 Dallas, TX 75380 Panel Contact: Dr. Steve Phillips Telephone: (972) 404-2415 Fonnosa Plastics 9 Peachtree Hill Rd. Livingston, NJ 07039 Panel Contact: Mr. David Pun Telephone,: (973)716-7279 Georgia Gulf Corporation 26100 Highway 405 P.O. Box 629 Plaquemine, LA 10165 Panel Contact: Mr. Jay Strange Telephone: (504)389-2642 PPG Industries, Inc. One PPG Place - 36W Pittsburgh, PA 15272 Panel Contact: Dr. James Barter Telephone: (412)434-2801 If you have any questions regarding this letter, please contact Wendy Sherman of my staff at (703) 741-5639. Sincerely, Enclosure Courtney M. Price Vice President, CHEMSTAR cc: Vinyl Chloride Panel Director, Office of Compliance Monitoring 004602.005