Document 7MaYMygezanzXbRykNwo7X7Lg

t/ UNION CARBIDE CORPORATION 39 dlo nocEBunv roao. danbuy, ctdbbi7-0001 To |Momo| Ovoon LoqBtort Aroo SREB Coc'i to R. C. Wise H. L. Greenberg Dot* O1V> iota IU Aroa SkAaet September 22, 1986 HS&EP J3 VINYL CHLORIDE EPIDEMIOLOGY STUDY Attached 1b a copy of CMA's "FYI" submission of September 11, 1986 to EPA concerning a "Summary of Draft Results of an Epidemiology Study of Vinyl Chloride Workers". SREB reviewed this document at its August 27, 1986 meeting and Union Carbide sent a "FYI" report concerning this study to EPA on September 9, 1986. W. C. Kuryla Secretary, SREB VCK:vm Attachments UCC 083967 B % P 1 y E ft I>. X^ ^V, " ---* SEP 19 986 tt.C.MMUti v Xftk'C Crf iib -*r. A -* C A. A+n iffv W . v*j ,*. fa C g<r; ^.C tJ*ZitezY s,pt'rab'r " 1986 / 'ecAt: ExpreeS*-44ail- r r- To: Member*, Vinyl Chloride Special Programs Panel From: Has Shah, Program Manager<M ,i Gabrielle H. Williamson, Assistant General Counsel 6.H.Us. Re: Informational Submission to EPA: Summary of Draft Results of an Epidemiology Study of Vinyl Chloride Workers Enclosed for your information and' review for possible .> individual company notification to EPA is a copy of the "* referenced submission CMA made today on behalf of the Panel. Pursuant to Has Shah's request for your reactions, ten Panel m mber companies indicated that CMA should file an FYI notice with EPA on this study, while two believed the results of the study were inconclusive and that a filing was, therefore, not warranted. Has's earlier communication to you included only a r quest for your reaction on the emphysema finding. You willnote that the enclosure also refers to the excess liver and biliary cancer shown in the study above the observed mortality from angiosarcoma of the liver, with a statement that it r mains unclear whether vinyl chloride is related to this d velopment. This statement was included in CMA's informational filing to EPA at the request of your Panel Chairman, Bill Gaffey of Monsanto, who also drafted this portion of the letter. We also note that CMA's enclosed filing was sent only as an informational notice to EPA; it was not a Section 8(e) filing on behalf of the Panel, nor does it refer to Section 8( ) anywhere in its text. Given the general content of the notice, the timeliness of submission, etc., EPA may decide, as a practical matter, that CMA's informational notice provides thAgency with adequate data to avoid the need for additional FYI or Section 8(e) filings of the same information by Panel m mbers. * However, since the CMA FYI notice is not formally a Section 8(e) submission, EPA might determine that the compani s which manufacture (including import), process, or distribute vinyl chloride in commerce remain technically liable for filing individual S ction 8( ) notic s if th y b li ve that th information contain d in th study reasonably supports th conclusion that "substantial risk" xists. W urg you to UCC 083968 \ r 2 review EPA'a Statement of Interpretation and Enforcement____ Policy. Notification of Substantial Riak, 43 Fed. Reg. 11110 (March l6# 1^765 in making your individual company deciaiona on whether or not to fila additional FYI or Saction 8(a) noticaa c ncarning raaulta of thia atudy. Plaaaa call aithar of ua (Haa Shah (202/887-1192); Gabrialla H. Williamson (202/887-1356)) if you have any quaationa or commanta on thia matter. UCC 083969