Document JNRKmBkOyLX0a65boJzwvg266
RECEIVED
OCT 3 1974
S* L DANU
Attached are two stories from today's (Oct. 2 Wall Street Journal on Vinyl Chloride plus a statement that Dow is releasing to the press today,
Jim Case
tt'
/
Dow Chemical 7 S.A.
Texas Division
Dot*: October 2, 1974
For Additional Information
Contact:
Jtim C- ,as,, e 238-2276
DOW STATEMENT ON NEW OSHA STANDARDS FOR VINYL CHLORIDE
NEWS
For Release: Immediately
, The standards on vinyl chloride emissions announced Tuesday,
October 1 by the Occupational Safety and Health Administration were described as "unnecessarily stringent" by The Dow Chemical Company
i
140606
and not supported by the data on Dow workers which was presented at
the public hearings.
C. B. Branch, Dow president, said, "Our data, based on nearly 25
years of experience without any cases of liver cancer, indicates that
the new standard is more restrictive than necessary to protect the
health of our workers.
"We had as early as 1961 dropped from the then accepted exposure
standard of 500 to 50 ppm voluntarily as our Dow standard and Dow
Chemical U.S.A. is currently operating under conditions which generally
limit worker exposure to less than 10 parts per million on an eight-hour
time weighted average. These low levels of 10 ppm or less which are
being experienced can only be achieved through advanced engineering
methods and good work practices on- the- part of- our employeesv"' Brancir''a:i"d.
"We question," Branch said, "the ability of the industry to develop
the technology to meet the level of one part per million TWA (time weighted
average) and a five ppm ceiling in the time specified and we will seek
remedies through the judicial process."
PUBLIC RELATIONS DEPARTMENT
FREEPORT. TEXAS 77541
bham Drop in v uijl c/uo/tuu uxpu^ut e Is Ordered by Labor Agency Jur Workers
R&S 140607
TH E W A L L STREET JOURNAL, Wednesday, Oct. 2,1974
By a Wail STHkkT Journal Sin// Hfporirt
ent 50 parks per million. Also, it gave Us en
WASHINGTON-The Labor Department forcement staff discretion to determine how
ordered a sharp reduction in workers' expo the companies must meet the standard.
sure to vinyl chloride, a widely used indus While the goal is to reach the new levels
trial gas that has been linked to liver can through "engineering and work practice
cer. controls." such controls must be deemed
The ruling, which comes alter nine "feasible." and companies can deal with
months of controversy, brought a lawsuit any exposures produced by inadequate con
from the plastics industry, which contends trols by giving workers respirators.
the standard can't be met. and criticism
A date wasn't set in the ruling for im
from organized labor, which contends the proving plant engineering and practices to
rule contains too many loopholes. Vinyl the point where respirators won't be needed.
chloride is a basic ingredient in making What's more, until January 1926 workers
many everyday plastic products.
may refuse to wear the respirators when ex
The new standard, issued by the Labor posures don't exceed 25 parts per million,
Department's Occupational Safety and even if they exceed the one part per million
Health Administration, requires that, start over eight hours specified in the regulation.
ing Jan. 1, vinyl chloride levels in the air
Despite this attempt at compromise,
that workers breathe be held to one part however, the Society of the Plastics Indus
vinyl chloride per million parts of air, aver try and some producers sued the Labor De
aged over an eight-hour period. Actual partment to overturn the ruling only mo
levels may exceed one part per million for ments after it was issued yesterday. And
short periods, but they must average out to no more than five parts per million for any 15-minute period within the eight-hour time
Firestone Plastic Co., a unit of Firestone Tire ir Rubber Co., said it will ask a court to stay enforcement of the standard while the
span.
suits are being tried.
Since last April, companies handling
Ralph Harding, president of the industry
vinyl chloride have been under an emer gency restriction of 50 parts per million, without any time period.
The emergency standard was issued after the discovery, beginning last January, of cases of a rare and fatal liver cancer, an giosarcoma, among workers exposed to
group, said the standard is "unrealistic, probably will be impossible for most, if not all, of the industry to meet and appears to have been developed on some basis inconsis tent with recorded facts." The job-safety agency "may believe that it has adopted a compromise position." but the result is un acceptable to the industry, he added.
vinyl chloride. Nineteen deaths among such
Todd C. Walker, president of the Fire
workers in the U.S. and other countries stone unit, asserted that the standard "puts
have been attributed to liver cancer caused the vinyl plastic industry on a collision
by long exposure to the chemical.
course wilh economic disaster." He said it
Vinyl chloride is a gas that is processed "is compilable to a law aimed at stopping
to form a powdery substance known as poly automobile deaths by lowering the speed
vinyl chloride. Polyvinyl chloride, in resin limits to one mile per hour."
or pellet form, is then fabricated into a wide
variety of finished plastic products.
In Midland. Mich., Dow Chemical Co.
Though only about 6,500 workers are em ployed in plants that make vinyl chloride and polyvinyl chloride, about 350.000 others, who work in facilities that create finished products from the polyvinyl chloride, will
said the standards were '.'unnecessarily stringent" and unsupported by the data on Dow workers that was presented at public hearings.
Organized labor expressed some immedi
also be covered by the new ruling. Workers ate reservations of its own.
who handle only finished products, and don't have any chance of contact with "raw" vinyl chloride or polyvinyl chlonde, are the only ones exempted.
The Labor Department initially proposed
In Akron, Ohio. Peter Bommarito. presi dent of the United Rubber Workers union, which represents many vinyl chloride work ers, s;ud "it would appear this thing has a number of loopholes in it." Mr. Bommarito reserved final judgment until he has seen a
that exposure be limited to "no detectable level," without any averageing over lime. This proposal pleased organized labor and some key researchers in the field of occupa tional health. But the Society of the Plastics Industry, a trade group, and many compa
full text of the regulations, but he was quick to take issue with the decision to let workers decline the use of a respirator until 1976. "We can't make a guy put on a respirator, and while he's not wearing one. he may be endangering himself." What is more, he
nies using the chemicals, denounced it ns teclmologically impossible and- warned it
addl'd. "The respirator situation is going to be even worse in nonunion plants." *'
would dnve the industry out of business.
Union safety experts have been heavily
In selecting as its final standard one part per million over eight hours and five parts per million over [5 minutes, the department
involved in the rule-making process, and one of their major contentions has been that protection from the gas should be derived
apparently was trying to reach a compro mise between Us original idea and the toughest proposal offered by the industry, which would have left oxjiosures as high as
primarily from controlling exposure through engineering and work-rule changes rather than from respirators, which workers often
10 parts ]H'r million in some plants and 25
balk at wearing because they can be bulky and unreliable
parts |K-r million in others.
The unions are expected In sludy the rul
The depart incut sought to smooth further ing in depth, and they, too. could file a law
the adjustment fur industry by delaying suit if they conclude the final standards arc
until next January the drop from the pres inadequate
T IU : VVAl.l. S T R E K ^ P L k N A I!,
Wednesday. O ct. 2. 7-tH
Health lh cirds . Vinyl-Chloride Risks Were Known by Many Before First. Deaths
Hindsight Shows Weakness In Finns' Systems Aimed At Protecting Workers
The Tip of a Large Iceberg
By BAKKV KRAMKR
SInil Rr/wirtfT nf THE Wai.L STREET JOI'RNAL
I
A few weeks before Christmas in 1948, Earl Parks, then 26 years old, signed on as
a helper-trainee at the large B. F. Goodrich
Co. plastics factory in Louisville, Ky. The
plant had been making polyvinyl-chloride
plastic from vinyl-chloride gas since before
the war. using a process developed by Good rich in 1937..
It was a growing industry that Mr. Parks
joined. Polyvinyl chloride--dubbed PVC for short--had found special, but limited, appli
cations in the war years, especially as a
fireproof coating for electric wiring in
fighter planes and ships. But in the late
1940s, so-called vinyl consumer products,
made from PVC, began coming into vogue: and by the time the 1950s were under way
polyvinyl-chloride products such as contain
ers, phonograph records and curtains were
staples in American households.
The basic Goodrich process, still in use
today, pipes vinyl-chloride gas into large re-
This is the first of tico stories concern ing implications of the discovery thnt vinyl chloride can cause cancer.
actor vessels; there, the gas is agitated to gether with a liquid and catalysts The pro cess causes polymerization, a linking to gether of the molecules of the gas (a mon omer) Into the long chains that give PVC la polymer) its strength and other desired characteristics.
The First Years
In his first years with Goodrich, it was Earl Park's job to crawl inside the reactors after each batch of PVC was drained off and to chip away that portion of the polymer that had congealed During the hour-long task, repeated several times in the course of an eight-hour shift, Mr. Parks and other workcrs"who performed the same function would unaviodably inhale the heavy, sweetsmelling fumes of vinyl-chloride gas that had escaped polymerization.
As the 1950s went by and the 1960s began, Earl Parks was working his way up to the job of foreman, a post that he had attained by the time that ill health forced his early retirement in the late 1960s. In the years that he had worked with Goodrich, the PVC industry flourished as thousands of new uses were discovered (or the polymer.
On March 3, 1973, at the age of 50. Earl Parks died of angiosarcoma of the liver, a type of cancer that is invariably fatal. His ' death attracted scant public attention at the time, but today the significance of Mr. Park's illness is unquestionable and shatter ing in its implications, For Earl Parks cargo
Deadly Statistics The link between angiosarcoma and
vinyl chloride is further buttressed by other deadly statistics Seven of Mr. Park's fellow workers at Die Goodrich plant also con'1 traded the disease, and five have died. In all, there have been 16 documented angios arcoma cases in the U.S. in recent years, all of them linked to vinyl chloride. In addition, 10 other cases have been reported in Eu
rope. While the total number of cases is small,
the industry has been shaken to its roots. The disease now is known to work insidi ously, slowly, during decades of exposure, the implications being that the cases thus far are quite likely only the tip of an ice berg. Nine companies, with 14 plants and 940 employes, currently produce vinyl chlor ide monomer from ethylene, a petrochemi-' cal. The monomer, in turn, is used by 21 companies operating 36 major plants and employing 5,000 workers, to make more than five billion pounds of PVC annually. (World-wide production is some 18 billion pounds annually. I,
Even the five billion pounds of PVC an nually produced in this country isn't enough to meet the domestic demand for the plastic into which PVC is formed. From 3,000 to 4,000 processors, employing an estimated 700,000 workers, fabricate the plastic into a wide variety of products ranging from vinyl floor tiles to shower curtains. According to a study done for the Society of the Plastics In dustry by Arthur D. Little Inc., as many as 2.2 million jobs depend on polyvinyl-chloride plastic. If PVC were banned, the study says, the annual loss to industry in sales and pro duction would be some S65 billion to S90 bil lion. (The Manufacturing Chemists Associa tion es^mates the wholesale annual value of all PVC products is S3 billion, i
Emergency Decree At the moment, no one believes the in
dustry will suddenly come .to a screeching halt. However, after the first human cases of vinyl chloride-induced angiosarcoma were disclosed, the Labor Department's Oc cupational Safety and Health Administra tion imposed a temporary emergency stan
dard for PVC factories; thenceforth, OSHA decreed, the permissible level of vinyl chlor ide in the air of such factories would be 50
parts per million. That level was far below the industry standard, in effect for years, of 500 parts per million.
OSHA's emergency decree v/as made last May Since ttien, animal research found that tumors develop at 50 parts per rmllion. Yesterday, OSHA issued a new permanent standard requiring employers after Jan. 1. 1975. to reduce exposure to one part per mil lion in. factory air. averaged over eight hours, and five parts per million averaged over any period no longer than 15 minutes. (Sec story on page 14.1 While considerably more stringent than the emergency decree, the new permanent standard-- particularly with its fivcparts-per-million provision and its allowance of averaging-nevertheless falls short of the "no detectable" limit advo cated by unions, many medical experts and
Please Turn to Page V,. Column I
R&S 140608
rmuiu nazards: v/myi-^liloncie itisk. ''Yas ivnown By Many People Even Before the First. Deaths
Continued from First /'ut;e
about an abnormally high number of Good- ! m-Is, leading to degeneration of t!i bones at
such groups ns lhe National Institute for Oc rich workers who had liver disease When tile tip- -if the fingers and toes in those e\-
cupational Safety and Health, and the he heard that Mr. Parks had died, he re (VimxI to high levels of the monomer (Emis
American Chemical Society. This no-dolecl- calls, he asked to see the autopsy refiort,
sions of vinyl chloride are generally lower I
ablc limit would have constant, not average,
it was m August 1973 that Dr. Creech at plants where the monomer, or igas, is |
adherance to one-part-per-million levels. learned that Mr. Parks had died the pre made, since the process is less complex., | Therefore, It seems certain that the argu vious March of angiosarcoma of the liver. and there is less change for leaks than at I
ment won't abate.
The doctor says lie then realized that some the [mlymerizillion plants; none of the re- i
As the controversy continues, it is reveal thing was seriously wrong, since another ported angiosarcoma eases in this country
ing to examine how the link between vinyl Goodrich PVC worker, a private patient of has occurred among workers making vinyl-
chloride and cancer was established, If Dr. Creech, had succumbed to the same chloride monomer, and only one of the 10
nothing else, such an examination points out type of cancer in 1971. Dr. Creech says he deatlis in Europe was in a monomer plant, I
the grave weaknesses of the present system knew that liver angiosarcoma is exceedingly
In early 1967, the Manufacturing Chem
-- or lack thereof --of protecting workers and rare and that two cases among such a small ists Association arranged with tile Univer
others from industrial hazards.
plant population was abnormal. (In fact, sity of Michigan to study acroostcolysis
The judgment is made in hindsight, but medical men estimate that fewer than -30 among vinyl-ehlonde workers, particularly
the history of vinyl chloride shows that evi cases occur each year in the U.S., striking those who cleaned the reactor vessels and
dence of its toxicity was often ignored. only one in 900.000 persons, i
others who were exposed to large concentra
What's more, the chemical companies
Dr. Creech met with Goodrich's occupa tions of vinyl chlonde in the air. The Michi
knew, but kept secret for at least six tional health director. Dr. Maurice N. John gan scientists reported in 1970 that although
months, the fact that Italian researchers son, who subsequently decided to ask Tabor- they couldn't pinpoint vinyl chloride as the
had shown that rats develop tumors, includ shaw-Coopcr Associates Inc., a Berkeley, cause of the disease, worker exposure to the
ing angiosarcoma, when exposed to low Calif., epidemiolugical-studies concern, to monomer should be cut to 50 parts per mil
levels of vinyl chloride monomer. European do a survey of Goodrich death records. But lion or below.
companies, which paid for the animal re the study was hardly needed; on Dec 19, a
Other than Dow, which had already insti
search, knew of these research findings for third PVC worker at the Louisville plant tuted reductions in air level of the mon
more than a year before the first human died at the age of 58; he had been at the omer, the rest of the industry in the U.S. ig
cases were reported but didn't reduce the plant for 28 years.
nored the recommendation. Nor was there
exposure of their workers to vinyl chloride. But Dr. Irving J. Selikoff, an expert on
environmental carcinogens, or cancer-caus ing agents, claims that blame shouldn't be placed at industry's door alone. "We're all a bit responsible," he says. "None of us did our homework." Culpability, he says, should be shared by scientists, government agen cies and labor unions.
The case of Earl Parks is illustrative. Mr. Parks first came to the attention of Goodrich medical people in 1961, when the company, concerned about the known liver toxicHy of ethylene dichlonde (a chemical from which vinyl chloride is madci tested the liver function of workers in the Louis ville plant.
Mr. Parks's readings were abnormal. Nevertheless, he continued to work at the same job. In October 1964, however, he was hospitalized with what was initially diag nosed as a bleeding ulcer. Doctors treated the "ulcer" without surgery, and Mr, Parks was released.
He was readmitted to the hospital the fol lowing May, and the decision was made to operate. But when the operation was begun, surgeons, instead oi finding an ulcer, found instead that Mr. Parks's problem resulted from severe liver damage, which had caused blood to back up in the portal vein leading into the liver. The surgeons cor rected the vein problem with a shunt and took a sample of liver tissue for analysis. The analysis showed that the liver had been damaged by exposure to "chemicals." Can cer wasn't mentioned.
(According to testimony at OSHA's hear ings on vinyl chloride, held last June and July, Mr. Parks received a total of almost S6.000 in workmans compensation from Gootlrich before be died, but only after Goodrich protested that his illness couldn't have resulted from exposure to the chemi cal. )
Public Announcement
On Jan. 22 of this year, Goodrich officials met in Washington with officials of the Na tional Institute for Occupational Safety and Health and informed them of the three an giosarcoma deaths. The following day, Kentucty occupational-health officials also were informed and Goodrich made its first public announcement.
Almost since its first commercial intr^ duction. there have been reports that vinyl chloride is toxic above certain levels. In deed, during World War II, vinyl chlonde was rejected as a surgical anesthetic be cause animals developed heart irritation when exposed to it. In 1949, Russian scien tists reported "hepatitis-like changes" in the livers of 25% of the workers in a small PVC plant.
Then, in the late 1950s, research toxocologists at Dow Chemical Co. showed that ani mals exposed to as few as 100 parts per mil lion of vinyl chloride (or 100 molecules of vinyl chlonde in every one million mole cules of air I developed slight liver damage. Based on its research, Dow began a pro
gram in the 1960s to reduce the level of vinyl chloride monomer in the air of its plants to below 50 parts per million.
Dow published its results in 1961. But the rest of the industry chose to rely on a Yale University study that recommended 500 parts per million as'a safe level. This same level had been recommended by the Manu facturing Chemists Association since 1954, was affirmed in 1962 by the American Con ference of Governmental Industrial Hygien ists and was given the force of law by OSHA in 1971, However, evidence at the OSHA hearings indicates that this level was regu larly exceeded until this year in many plants. (The hygienists' group didn't recom mend lowering the level to 200 parts per million until 1972, four years after Dow con cluded from further tests that repeated ex
any significant reaction to findings by Euro pean industry that animals developed ad verse effects from vinyl chlonde. This was at least partly because the Europeans down graded the importance of some of their find ings. For example. Prof. Pier Luigi Viola, a medical director employed in Italy by Solvay & Cie., the Belgian chemicals company, found bone changes in rats exposed to air levels of 30,000 parts per million of vinyl chloride; even more important, he found that vinyl chloride at that level caused ma lignant tumors in the ear canals, lungs and
bones of rates.
Prof. Viola reported his findings before an international cancer congress in Houston in 1970. It was the first reported link be tween cancer and vinyl chloride. But the professor expressed doubt about the purity of the vinyl-chloride gas he had used and staled that the rat cancer findings, because they occurred at such high levels of the monomer, had no human implications.
(Prof. Viola subsequently found tumors in rats exposed to 500 parts per million; but this fact wasn't revealed until well after the first human angiosarcoma cases were re vealed. I
The Research Goes On
Based on Prof. Viola's early cancer find ings in rats, Montedison S.p A,, the hug Italian chemicals company, in 19?0_ askccL Cesare Maltoni, a respected researcher at the Institute of Oncology in Bologna, Italy, to do more extensive animal studes. By Oc tober 1972, Prof. Maltoni says, he had found that 250 parts per million of vinyl chloride produced tumors in rats in three parts of the body; the ear canals, kidneys and the liver. The liver tumors included angiosar coma. The professor immediately informed his sponsors.
The Europeans offered their information to the Manufacturing Chemists Association in the U.S., but only if the Americans guar
It was an alert I-ouisville doctor who first posure by workers to vinyl-chloride mon anteed confidentiality. With great reluc
made the connection between angiosarcoma omer at an average of 300 parts per million and vinyl chloride Dr. John L. Creech, who or above for a working lifetime could cause for years has treated workers sent to him changes in the liver. I
tance, the association says, it finally agreed to the secrecy condition "because of the vital importance of learning o! any indica
by Goodrich on a fee-per-palient basis, had
During the 1960s. there were reports of a tions from the European research
-with-
followed Ear! Parks's rise for some time. disease railed- nrronstentvsis .minor vi.nv-1 out (ho del ivs vd-v-h could h ivi- re-aitl'-d
R&S 140609
i
On Jan. 30, 1973, a year before the first human angiosarcoma cases were reported by B. F. Goodrich, the MCA finally got the Maltoni data. For five months, the secrecy restrictions were such that government agencies, PVC workers exposed to vinyl chloride and even company doctors were kept in the dark. Then, in the late spring, the F.uropeans agreed that the Chemists As sociation could pass the information on to the U.S. National Institute for Occupational Safety and Health, the Labor Department agency that monitors worker safety. On July IT, 1973, representatives of the associa tion and the agency met.
One Certainty
There is some dispute as to what tran spired at the meeting. The Labor Depart ment agency claims it wasn't given the full story; the chemists' association claims that the agency misunderstood the findings. But one thing is certain; The agency, and OSHA, made no move to change the stan dard of 500 parts per million and didn't do so until after the human angiosarcoma cases were announced. In Europe, by con trast. Great Britain had lowered the. maxi mum level to 200 parts per million following the cases of acroosteolysis in the `60s; and. West Germany had set a level of 100 parts per million in 1970, based on Dow s 1961 re sults with animals. According to New Scien tist, the British science journal. "No other section of the U.S. or European industry fol lowed Dow's lead. The reasons for this in ternational confusion arc obscure."
Tliis all changed quickly, of course, once the first human cases of angiosarcoma were reported by Goodrich. Indeed, the swiftness with which new research has been carried obt since Jan. 23 is perhaps without prece dent in the world of medicine and science.
Much of this recent research is con cerned with studies of the incidence of dis ease of all types among vinyl-chloride work ers. Thus far, some studies show that work ers exposed to high levels of vinyl chloride show greater than expected incidences not only of angiosarcoma but certain other can cers as well. The ramifications of these find ings for the future .of the .industry and its workers remain to be seen. However, for the veteran PVC workers, whatever changes the findings produce will be useless in counteracting the insidious effects of working day after day. year after year, in what now is generally viewed as a contami nated atmosphere.
R&S 140610