Document 4awozq0mEJ3nqe3156LR9rypV

SOCIETY OF PLASTICS ENGINEERS, INC. Palisades Section * Vinyl Plastics Division New York City October 31, 1974 VINYL CHLORIDE: TEE TIP OF THE ICEBERG? Glenn E. Schweitzer Director, Office of ,Toxic Substances Environmental Protection Agency 401 M Street, S.V7. Washington, DC 20460 BFG26816 3673003 VINYL CHLORIDE: THE TIP OF THE ICEBERG? CHEMICALS, INDUSTRY, AND THE ENVIRONMENT About 20, 000 chemical substances are commercially produced and used in the United States, wiLh 500-700new substances entering commerce annually. They find a v/ide variety of uses as industrial chemicals, in consumer products, and in specialized uses such as drugs, food additives, and pesticides. We esti mate that about ten percent of U. S. industry is directly involved in introducing chemical changes into its products. The problems resulting from the presence in the environment of some chemical substances are all too well known. Others are believed to pose a latent health or environmental threat, while the effects associated with many of the remaining chemicals, acting individually or synergistieally, are almost completely unknown. However, it seems clear that the problems associated with the presence of many chemical subsLanccs in the environment will undoubt edly continue to grow in number, severity, and complexity in the years ahead. Some of the hazards associated with chemical substances have boon recognized and are controlled by the Government, o.g. pesticides and drugs. Other aspects of the problem have only recently'been identified, and appropriate regulatory measures do not yet exist. Still other pieces of the problem have yet to be identified. Many gaps remain in understanding why, how, and when a sub stance can have a negative impact on health or the environment, and how best to control or prevent such hazards. Thus, our concern is two-fold: Identification and assessment of the risks associated with the manufacture, distribution, use, and disposal of chemicals which could adversely affect health and environmental quality'; and practical steps, including regulatory actions as appropriate, to prevent or mitigate the problems posed by such chemicals. In addressing these concerns v/e must, of course, maintain an appreciation of the role of these chemicals in our economy and of the societal benefits that chemicals have brought to all of us. THE CASE OF VINYL CHLORIDE: BETTER LATE TIL\N NEVER Thu Emergence of the Problem In January 1J7-R the B. E. Goodrich. Company, the largest U. S. producer wift P* V> C *reWsWiAnlk#, nnuottMifuie.vd. Lhe ,,N..o. tional I..n.wswti.tvuv.tve. o..f.O___c_c:uupp:a-itionaail bSHHeeLty and Health that four workers from its PVC polymerisation plant in Louisville, Kentucky, apparently had died from a rare cancer, angiosarcoma of the liver. AJ.l four BFG26817 `w o 2 workers had been closely associated for many years with the production of WC resins. 'The rarity of the tumor and the clustering of deaths at a single plant raised suspicions that an occupational disease related to vinyl chloride orposurc had been found. Since that time, at least 10 additional ruses of this tumor', which developed in U. S. PVC polymerization workers since 100 1, have been confirmed. This tumor has also been reported in a number of workers at ICuropcan polymeri zation and monomer plants, one worker at a U.S. PVC fabrication plant, two workers at European fabrication plants, and two residents in the general popula tion near U.S. fabrication plants. Concurrently, toxicological data from animal studies became available which further strengthened the suspicion of vinyl chloride as the etiological agent in the formation of the liver cancer. A broad spectrum of cancers was reported by Professor Cesare Maltoni of Italy in different animal species at various exposure levels. His inhalation studies of rats exposed to 50 ppm at repeated intervals approximating occupational exposures have produced angiosarcomas of the liver and abdomen as well as tumors of the kidney and skin. In mice exposed to vinyl cliloride the same tumors have been observed, with the addition of lung tumors. Animal studies sponsored by U.S. industry have confirmed Maltoni1 s observations at 50 ppm. Recent epidemiological studies also suggest the possibility of multiple cancers attributable to exposure to vinyl chloride. Meanwhile, statements by industry and Government officials indicated that the material loss to the environment during the PVC polymerization process may be about nix percent, with more than 75 percent of the losses being vinyl chloride air emissions. Also, it soon came to light that vinyl chloride was being used as a propellant in aerosol sprays, and we were becoming more aware of railroad accidents involving vinyl chloride tank cars. This scries of events finally stimulated a broad range of corrective .actions by Government and industry -- actions that should have been taken many years ago. Given the long history of PVC production which in the past resulted in much higher levels of exposure to workers and to the general population than are encountered today -- together with the long latency period between exposure and the development of angiosarcoma -- we obviously are very concerned that many of the consequences of I he somewhat reckless handling oi vinyl chloride in the past will continue to be uncovered for some years to come. The Fabrication Process Many of you may be particularly concerned with the possibility oi a vinyl chloride hazard associated with PVC fabrication activities. Initially, the Government's primary concern and investigative activities centered on fro poly merizatio.i process. Only very recently, with the reports of angiosarcoma among former fabricators, has attention been directed to the more than 8,UG0 fabrication plants. A first step obviously is reliable monitoring -- and I emphasize reliable -to determine existing levels. I regret to report that at present we do not have gooc BFG26818 'ormntKm vdbeh \wnild unable ;;.s to provide guidance <>n (lie Mindy huv.urd, it' any, or around fabrication plants. Since the only source of vinyl chloride most of [hose plants is Iho tinreorled monomer that may be present in the PVC resin, we would nol. export Iho air- omissions lo be high. At the snme linv1, howevor, those facilities arc often in metropolitan areas which could result in exposure? to very large numbers of people. At the outset the major concerns of the* Environmental Protection Agency with regard to fabrication activities related to other chemicals. For example, information is not readily available indicating whether any substantial risk might he involved from the ingestion or inhalation of l'VC particulate. Also, a largo number of chemicals are used in PVC products as antioxidants, antistatics, colorants, fillers, plasticizers, and stabilizers, and many of them can reach man through a variety of routes. The health effects of some of these chemicals are reasonably well known; the effects of others have yet to be explored. Several of them are particularly good candidates for more detailed investigations, e.g. cadmium, barium. Disposal of Products Containing PVC Hydrogen chloride is the major toxic material released when PVC is burned. On the order of 32, 000 tons of PVC are burned annually, releasing approximately Jo, 500 tons per year of I1C1 as air emissions. At the same time much more IIC1 is probably now emitted to the atmosphere, from co'd-burning power plams than r*-om municipal incinerators. However, there still could be a hazard in the iinmcdi- > vicinity of on incinerator as a direct result of its HC1 emissions. JIC1 c;m also bo major factor rcluLnd to corrosion during incineration at cer tain tempera hires. Specific".] Iv, incinerators with heat exchangers will have corrosion problems on flic* fire side of flic exchange equipment when the combustion gases conviLct 1 lie outer motel surface. Also, about 95 percent of our incinerators have some type of air pollution control equipment that is exposed to the high chloride environment resulting from refuse combustion. The cooling and precipitat ing water from the scrubbers that contacts the flue gas contains large quantities of chloride and is extremely corrosive to the structure. It is highly unlikely thai large quantities of vinyl chloride will be emitted during incineration of PVC. There is no evidence that PVC will chemically revert to vinyl chloride. Some small amounts of entrapped monomer might conceivably survive incineration, but these quantities would be very low. Other air, water, or soil contaminants could result during disposal of PVC products. The types of additives of particular concern are: antioxidants -- phenols, aminos, phosphorus, and sulfur compounds; antistatics -- amine derivatives, quater nary ammonium salts, phosphate esters, polyethylene glycolesters; colorants -salts or oxides of rnolais, aluminij^n, copper, and inorganic pigments; fillers -- *0C BFG26819 M C; c: O - 4 - v ] ;.i r.y , i .'iltiinn rd i ! u!; i f <', mci.'iljir i n r'S , < arhn:;, ec I! (i 1m y.i I'lllr-, .'isbestos; plasticizers - - phthiiJaloy, organic phospiiafos; stabilizers -- lead seJm of acids, barium, cadmium, calcium, zinc, eikyl tin compound';, Reconm'Cndn'uonr of the PPA Tayk Force Fust month the EPA Vinyl Chloride Task Force, which had been established in February, submitted its Report to the Administraior. This Report'included the results of our initial monitoring program at ten PVC resin and two monomer plants, preliminary analyses of iho health effects of vinyl chloride, studies on the fate and environmental effects of vinyl chloride, and investigations of industrial practices. Upon receipt of the Report, Mr. Train announced that he had accepted the recom mendation for the Agency to establish an air pollution emission standard for monomer and PVC resin plants and concurrently to investigate further the need l'or a. standard applicable to fabrication plants. The eighteen other recommendations for Agency action are currently in various stages of implementation. The process of setting an air emission standard under the Clean Air Act will involve several months of additional monitoring and other investigations, data collection, public hearings, and oilier regulatory steps as required by the Act. An environmental impact statement will be prepared, and public hearings held, to insure full public participation in the development of tills standard. The current timetable is to promulgate the standard within about one year. Initial estimates indicate that using available control technology emissions could be reduced by about 75 percent from PVC resin plants and 90 percent from monomer plants, with a concomitant cumulative increase in the cost of PVC resin of about four percent. Also, it is estimated that the available control technology, which includes a variety of control measures applicable to the multiple emission points within ihe plants, could be in place from within several months to two years after promulgation of appropriate regulations. With retard to fabrication plants, monitoring of the vinyl chloride levels in the ambient air near five plants is planned as an early step to determining the need for an air emission standard. I do not plan to list the other recommendations set forth in the Task. Force Report. However, recent activities directed to carrying out several of the recommendations may be of interest. Studies nre currently in progress to determine the amount of vinyl chloride migrating out of PVC products used in water distribution systems, sucrh as PVC pipe or storage tank liners. In laboratory experiments, 3/4 inch PVC pipe simu lating household installations is being used. Also, v/atcr samples : rom a reservoir that had recently installed a new PVC liner arc being analyzed. BFG26820 Add GL327, 'orinn (.ion which wovilu : nr.1.' !.c au U> proviuc r,i:ic!;>n(.'0 on Iho iilo-ly rh , i^r> or around fabrication pluuls. .Since (Ik? only source of vinyl chloride a' most of .Ihrsr plants is (In' unreucled monomer that may be present in the PVC : osm, we would JU'l iripri L (ho air- oni isePe>s fo be.- high. At thn same Limn, however, ihesc facilities arc olj.cn iji metropolitan areas which could result in exposure to very lorgc numbers of people. Al Hie outset (he major concerns of the LYmronmonlal Protection Agency with regard to lubrication .'activities related to other chemicals. For example, ini'c>rmntion is not. readily available indicating whether any substantial risk might be involved from the ingestion or inhalation of PVC particulate. Also, a largo number of chemicals are used in PVC products as antioxidants, antistatics, colorants, fillers, plasticizers, and stabilizers, and many of them can reach man through a variety of routes. The health effects of some of these chemicals arc reasonably well known; the effects of others have yet to be explored. Several of them are particularly good candidates for more detailed investigations, c.g. cadmium, barium. Disposal of Products Containing PVC Hydrogen chloride is the major toxic material released when PVC is burned. On the order of 32, 000 tons of PVC arc burned annually, releasing approximately 1 3, 500 tons per .year of T1C1 as air emissions. At the same time much mor e I1C1 is probably now emitted to the atmosphere from eo'd -burning power planis than fr,om municipal incinerators. However, there still could be a hazard in the immedi- : vicinity of an incinerator as a direct result of its 1-IC1 emissions. I tCfl can also be major factor related lo corrosion during incineration at cer tain temperatures. Specifically, incinerators with heal exchangers will have corrosion problems on (her fire side of the exchange equipment when, the combustion gases contact the outer melnl surface. Also, about 95 percent of our incinerators have some type of air pollution control equipment that is exposed to the high chloride environment resulting from refuse combustion. The cooling and precipitat ing water from the scrubbers that contacts the flue gas contains large quantities of chloride and is extremely corrosive to the structure. It is highly unlikelv that large quantities of vinyl chloride will be emitted during incineration ol PVC. There is no evidence that PVC will chemically revert to vinyl chloride. Some small amounts of entrapped monomer might conceivably survive incineration, but these quantities would be very low. Other air, water, or soil contaminants could result during disposal of PVC products. The types of additives of particular concern are: antioxidants -- phenols, aminos, phosphates, and sulfur compounds; antistatics -- amine derivatives, quater nary ammonium salts, phosphate esters, polyethylene glycolestors; colorants -salts or oxides of metals* aluminum, copper, and inorganic pigments; fillers -- BFG26821 A; l; o Li r> 'i'oxico / og ica l 7nr. i, i uy Uni.il recently, the eiforis of U.S. industry to clarify the chronic toxicity of vinyl chloride: .ere Pearly negligible, despite the commercial ijnpoi'tancn of this chemical. The mudies to date liavc not boon adequate, in terms of direction, scope, or quality. Cron the additional toxicological studies which have been pro posed callin'; for animal exposures down to 1 ppm may not bo sufficient. Tooting for Uc'csisicncc and Environmental Effects A rel.iii.od area is industry's responsibility to clarify the environmental into and c.*fiV*rLs of the chemicals it: manufactures, and in tins case the behavior of vin.yJ chloride in wafer and air (including degradation products) and the fate amt effects of product::; containing PYC in soil and water. The research by EPA should help structure such tests, bul the primary responsibility rests with industry. Testing for Levels of Unreacted t-lonomov In view of the likelihood that FDA will limit the levels oi unrcaeled monomer allowed in PVC food packaging, industry has recently accelerated efforts to analyze the levels of vinyl chloride that are present in PVC resin used for food packaging and in the packaging itself. This procedure should be extended to other typos of products as well. It is particularly important that the manufacturers of resin, who in general are well equipped to carry out the necessary sampling and analysis, advise their customers (i.e. , the fabricators) of the quality of the resin in terms of unrcacled monomer in addition to the usual quality criteria. The fabricators in turn have a responsibility to be aware of the levels of unreacted monomer that persist in the products that eventually reach the marketplace. LESSONS LEARNED FROM THE VINYL CHLORIDE EXPERIENCE Many environmentalists arc convinced that the problems of vinyl chloride arc but the ! b> of a chemical iceberg -- an iceberg of problems that will continue to float to the surface during the decades ahead. It eerlairdy appears that except for continuing concern over spills and acci dents, Government and industry have been rather complacent with regard to die potential environmental throat from the high volume industrial chemicals. This complacency is in large measure attributable to the relative absence of visible ar:cl uncontrolled dangers from exposure to the chemicals during thc-ir long histories. In addition, since each of these chemicals is manufactured by a num ber of companies, firms may lack incentive to invest individual company resources to clarify the safety aspects of their usage. Clearly, the experience with vinyl chloride -- the twenty-second leading chemical in terms of production under scores the problems that can result from such complacency. 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