Document Lpv7xBN8Jm5B253kanzagnnmg

UC T,49-2 INTERNAL CORRESPONDENCE ALL <'9 VITALS DIVISION To (Name) Division Location Mr. E. J. Kleber UCC - Metals Division Niagara Falls, NY 14302 Copy to Messrs. File C. R. Allenbach R. E. Byrne, Jr. J. F. Collins R. F. X. Fusapo J. L. Myers**'' C. F. Raeburn W. C. Thurber J. W. Whittlesey P.0. SOX 579-4625 ROYAL AVE., NIAGARA FALLS, NEW YORK 14302 Date July 6, 1977 Originating Dept. "Calidria" Asbestos Answering latter date Subject NIOSH Letter Requesting Information re R6-244 This confirms our discussion of the attached NIOSH request for information. Basically, Union Carbide has decided that a response is not required and has elected not to respond. If your customers inquire about the letter, you may inform them of the Union Carbide position. Any comments or statements which would advise the customer what he should do should be care fully avoided. f\Js^trzt~3 H. B. Rhodes HBR:dal Attachment UCC 014062 A0859? DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE PUBLIC HEALTH SERVICE CENTER FOR DISEASE CONTROL NATIONAL INSTITUTE FOR OCCUPATIONAL SAFETY AND HEALTH 5600 FISHERS LANE ROCKVILLE. MARYLAND 20852 UNION CARBIDE CORP 4625 ROYAL NIAGARA FALLS, Ny 14302 J Over the past five years the National Institute for Occupational Safety and Health (NIOSE) has been conducting the National Occupa tional Hazard Survey, pursuant to Sections 8.20(a) and 20(b) of the Occupational Safety and Health Act of 1970. By visiting approxi mately 5,000 companies throughout the United States, our engineers inventoried the basic substances used by American workers. Much of this information was recorded by brand name, however, and had to be clarified as to chemical ingredients. In a small number of cases, manufacturers submitted product ingredi ent information which indicates the presence of one or more of the sixteen substances (see Table 1) currently regulated as human carcin ogens by the Occupational Safety and Health Administration (0SHA). In these cases, NI0SH took the position that information on the presence and percentage of the carcinogenic substance in a product should be made available to those who may come into contact with the product. Thus, NI0SH intends to make information as to the presence and per centage of an 0SHA regulated carcinogen in a brand name product available to the public where such information, has not been desig nated as a trade secret. It will Also submit this information to those companies identified by the Survey as users of these brand name products. Your product formulations on the enclosed copies of response forms show the presence of one or more human carcinogens. We think the manufacturers of brand name products containing 0SHA regulated car cinogens have an obligation to their employees;and customers. Please . UCC 014063 A08598  -2- indicate the measures you have taken to ensure that people coming into contact with, the product will be informed regarding its carcin ogenic potential and advised of appropriate protective measures. Specifically, we are requesting information on the procedures you have developed to guarantee that employees in your plant who may be engaged in formulating the product(s) are educated with respect to possible health risks, and what steps have been taken to design sys tems to reduce exposures to those employees. Additionally, we are requesting evidence of whatever steps you may take to warn users of these product(s) of the presence of a carcinogenic substance, and guidelines to ensure safe usage of the product. We thank you for your cooperation. Sincerely yours. Enclosures Director UCC 014064 A.08599 r f TABLE 1 SUBSTANCES REGULATED AS HUMAN CARCINOGENS BY OSHA Asbestos Vinyl chloride 4,4T-Methylene-bis (2-chloroaniline) beta-NaphthylamLne 4--Nitrobiphenyl N-Nitrosodimethylamine - beta-Propiolactone bis (Chloromethyl) ether .. Chloromethy1-methyl ether 2-Acetylaminofluorene 4-Aminodiphenyl Benzidine 3,3r -Dichlorobenzidine 4--Dimethylaminoazobenzene alpha-Naph thylamine Ethylenemine (MOCA) ` UCC 014065 CALIDPA RFSTN GPADF 2^4- ASSURANCE OF CONFIDENTIALITY - Any NIOSH contractor having access to this information is legally required by contract to hold all such infor mation confidential. /2<Patent exists on this product, This product analysis contains trade secret information. The nature of this information-is described on an accompanying sheet. ' U you have used supplemental sheets, please indicate how many. CDC 2.1 (NIOSH) 10/73 A0860 t UCC 01,4066 Form Approved OMB No. 68-R-1337