Document 8RZ0zQkxOJxeemvkYpL5b2R8k

DEC 19 '94 04J10PM SIDLEY AUSTIN NY DBi_19"1994 14:31 m P.7 TD 12129062021^203^ Rfr? d M> legator, Pwld+nt _ CSCTtott 5 INC. Tostojogy Cenauftant* Mulagant ! -jKCaarolwnosssnr*ij-pTsrtioosn* 7D Colony Par* 3rei0 GiJvton, Tam* 77551 Tale eptar- {400) 744-ttig 2*iSG ^T9v*3S(3 Williams, Ballsy 6 Wsaner CatberlMffBaen saq. 8441 Gulf Preavay Suits SCO BcUsten, Tx 77037 m Briven vs union Carbidi D ember 16r 3S94 2 am currently Profs* lor and Director-of the Division of toxicology at the Univeraii y of Texas Kediaal Branch in Galveston* tens* Hy major ares of interest is toxicology, and especially genetic toxicology. Genetic toxicology has to do vlfch the effect of chemicals on our genetic material. This effect could lead to saucer* ox developmental a Hiornalitiss {transmitted either through germinal cells or durini in utaro exposure) - X have conducted extensive research in tin area of chemical carcinogenesis, and developed many of the pree idures currently used to detect the early stages in chexiically indu< ed neoplasms. I have served oxs several cwernmeat comitteea havj ag to do with the extrapolation of animal e data to man (risk as aastoent), and the interpretation of epidemiology studies as tl ,ay relate to the known animal toxicology of specific chemicals. 1 frequently teach and routinely advise medical students and Phya Lcians concerning their patients who may 1 ucc 073612 DEC 19 '94 04:ilPn SIDLEY AUSTIN NY P.8 DGC-19-1994 14:32 FROM DRfiYDEN UYOE & UQOD LLP TD 12129062^1-02030004 su'd 693fcVi *2P 2PI00 V66T-9T-333 hive been exposed to toxic ehflBieildt 2 vab recently! a mmnlmr cl i the national Academy of Sc lanoe Comwlttaa on animal monitoring, a member of the Office of ecbaology Committee on HOibb Biological Monitoring, and a past me obar of the K&TXOMaL LIBRARY OP KEDICIHB BCIEHTZFIC BBVIBW PANEL, 1 IQ years Z edited the international journal, Teratogens sis, C Lxcinogeneei* and Mutagenesis, X am the 1994 recipient of the Boll^under award which is givea bu-scientists who have made an Utahan ling contribution the field of Genetic Toxicology. I* bsmmmm Zn the above rfereneed case, z have been asked to review the biological infqxm&tlon pertaining to Vinyl chloride and furnish my opinion as to e scientific probability that Hr* Eirven exposure to vinyl Chlosfide significantly contributed to his development of Adaaocareiiiioxa and subsequent death* MV OftinAann In reaching my op inif3 ns Z have utilised a number of studies, texts and other materials bhat have evaluated the hazardous affects of Vinyl Chloride. I hK utilised information generated by the national library of medllcine database services -Buoh as the Hazardous Substance Satkbanfc {"HSDB" |, Torline, htscs (the database for OHHA), matesjials generated from regulatory agencies O. such as the Occupation Safety and Health Administration *gg*fe$k SOBJ&CtoJ0EH" UCC 073613 DEC 19 '94 04:ilPfl SIDLEY AUSTIN NY DeC-19-1994 14:32 FROM DRAYDEN LM>E a IXOD LLP . we-* P.S ID 12129062021-0203^84 P.09 r:S0 ^66T-9T-3aH < "OSHA-) r the nation*! Instit te of Occupational Safety jd. Health (*2fZOS5*) ius tDo Anerieu) t eafaraao* of Govnssntal 3)ndatrUl Hygienists (acciH") # Primer! Ly, however, ay Judgment in ba*d upon ay years of research and other ezprU&e in this' aru of toxicology* vm, emomipg. Vinyl Chloride is sue of the sect potent kziown human carcinogens, it has especially been identified os' & liver carcinogen* Several epidemiology studies associate Vinyl Chloride with cancers of the liver as veil as other organs Hetaboliam, distribution studies ,** v: 1 as cancer bicassay studies indicate that one of the primary ergs is following inhalation exposure is the liver, and that this ehee&li al can produce osscer of the liver at extremely leer ooneentratiof s* X will be prepared tc testify that Hr. Sirven's exposure to Vinyl Chloride during hie employment at Union Carbide, in all probability, caused or eon iributed to hi* malignancy and death* Xarvio St legator,Ph-D* Toxicologist* "CON^oeNTfAL mAND Su^aCTTOpRnrJEmL oroe^TEct,Ve UCC 073614