Document KJd6V4XzDB6exdj7B8M7KGgn6

DEC-20-1994 12: S4 FROM DRfiYDEN UYCHE & WOOD LIP TD i2129062021-02030005 P. 28 20B'd M. Legator, Pmiasnt ________ _69EStt. 60S* uL INC. To* ttlogy Consultants Mutagekn-#-- < m__ ______ sSnsZrSsltTeeRxZle!.otd'gy 1.0. #74 218 499f 70 Colony Park 3rci# Galveston. Texas 77661 Tele opler - <400) 744-6369 Z>:&2 fr66T-ST~03G Williasie, Bailey i Weaner Catherine,Been Esq. 8441 Gulf Freeway Suite 600 Houston, Tx 77017 HE* Briven ve Union Carbidi December 16, 1904 X an currently Profea lor and Director .of the Division of Toxicology at the Univereit y of Texas Medical Branch in Galveston, Texas* My major area of interest is toxicology, and especially genetic toxicology* Genetic toxicology has to do with the effect of chemicals on our genetic material. This effect could lead to cancer, or developmental 4 normalities (transmitted either through germinal cells or during in utero exposure). I Have conducted extensive research in thi area of ohemical carcinogenesis, and developed many of the proes^dures currently used to detect the early stages la chemically induided neoplasms. X have served on several Government committees havi ng to do with the extrapolation of animal data to man (risk asisssment), and the interpretation of epidemiology studies as tl ay relate to the known animal toxicology frequently teach and routinely advise tsedioal students and Physicians concerning their patients who may 1 UCC 073587 DEC-28-1994 12:54 FROM DRfiYDEN UYOE & unnp 1 1 P TO 12129062021-02030005 P.29 30'd 69E9FW, 60t 2^:80 *6*1-91-330 have been exposed to toxic Chemicals* I vaa recently a aitunkjex. uf the National. Academy of 54ienoe Committee on animal monitoring, a member of the Office of technology Committee on Human Biological Monitoring, and a past me nber of the NATIONAL LIBRARY OF MEDXCXNB SCIENTIFIC REVIEW PANEL, Efor 10 years I edited the international journal, Teratogens*ia, C' Lrcinogeneeis and Mutagenesis - I am the 1994 recipient of the Roll ender award which is given to-scientists who have made an outeta ruling contribution the field of Genetic Toxicology. I. ASSIGNMENT In the above r gferenoed case, I have been asked to review the biological inf< rmation pertaining to Vinyl chloride and furnieh ay opinion as to fc ie scientific probability that Mr* Birvan exposure to Vinyl ChloJid* eignifioantly contributed to his development of Adanocarcl ioma and subsequent death* ab&SM toe MV opinions In reaching ay opini^ns I have utilized a number of studies, texts end other materials that have evaluated the hazardous effects of Vinyl chloride I haI-V B utilized information generated by the national library of meClcine database services such ae the Hazardous Substance Dat ibank ("HSDB"), Toxline, RTEC3 (the database for OSBA) mate als generated from regulatory agencies such as the Occupation il Safety and Health Administration 2 UCC 073588 BK*aB'1"4 12:55 P&Q`d DRftYDEN LiYOE S. LCOD LLP TO 1212^33331 -02330005 P. 30 69&SPS& &Qp c^iaa sssT-gj-aaa ("OBHA"), the National Institute of Occupational Safety and Health ("KIOSB") and the AiwriotA (jonfertoce of Governmental Industrial Hygienists (*ACCJH") . Primariily, however, my judgment is based upon my years of research and other experience in this area of toxicology. nu Yira .cgraRiPSs. Vinyl Chloride is me of the meet potent known human carcinogens it has eapee rally been identified as a Liver aercinogen- Several epidemic logy studies aasociate vinyl Chloride with cancers of the liver as veil as other organs. Metabolism, distribution studies ,as wei 1 as cancer bioassay studies indicate that one of the primary orga is fallowing inhalation exposure is the liver, and that this che*d< al can produce cancer of the liver at extremely law ooncentratloi s. 1 will be prepared to testify that Mr. Eirvsa'e exposure to Vinyl Chloride during his employment at Union Carbide, in all probability, caused or eon; ributed to his malignonay and death* Marvin 6. Legator,Ph.D. Toxicologist* 3 ucc 073589