Document M6okjbyq20NvRwV1vDL5gpE9

UNION CARDIOL CORPORATION CHEMICALS AND PLASTICS >70 CAIM'. AVl.NUI . Nt W VOK, N. V. 10017 July 18, 1974 Dr. Robert W. Cairns Executive Director-Amcrican Chemical Society 1155 Sixteenth Street N.W. Washington D. C. Dear Dr. Cairns: 1 an writing you this letter in part, to protest the position of the Anericen Chemical Society in its statement to the Occupational Safety and health Administration on the proposed standard for occupational exposure to vinyl chloride and, in part, to ask that you give public notice of the fact that the position of ACS in this matter does not represent consensus of the membership b"t rather the view of a limited group of committeemen having only a most limited understandin'- of the facts related to .his most sensitive matter. Perhaps had you or your a sedate, Dr. S. T. Quigley, attended t:io regular sessions of the Pearing, you would have seen first-hand how inert was the presentation of the ACS; the ACS' presented no farts or experimental evidence as to the biological activity of VCM; produced no study as to the value of the proposed monitoring, assay, medical surveillance, and protective equiptment recommendations; put on the record no information as the engineering or economic feasibility; offered no epidemiological evidence. As the record now show's, the ACS offered opinion in support of the "no detectable" standard proposes by OSHA while the evidence presented in fact contravenes the need of such a drastic standard , Support of the OSHA proposal by the ACS is especially unrealistic in light of tiie massive contrary evidence presented by various industry spokesmen (including well-informed ACS members) that: 1. Not even continu:1 us exposure to vinyl chloride monomer in high cone out radons over a period of time will necessarily result in any deleterious effects in humans. No evidence of any such effects at levels be-low 2-JO parts per million exposure were, shown. 2. The enimal data on vinyl hloride monomer exposure which is the only possible basis ciLcd for imposing any exposure liv.its is not only sc 1f-<outiadiclory. inconclusive and non-prohative in itself hut also cannot he and has not been related or translated into human c-yporieui e . The: testimony on the human experience as for example that of Dr. IVmold, shows ihaL lit Lie if any harm has if fact come (rom employee exposure to vinyl chloride monomer, even over ext on led period:1, at high concent rat. i or.:;; sec also the Dow Chemical 'Ampany Lest imony tliaL no ill eilecLs on 'unmans at less OLI 2172 (2) than 200 parts per million exposure levels were ascertainable fr m their extensive studies. 3. As to the issue of feasibility, the critical facts are, as the hearing testimony clearly showed without meaningful rebuttal, that there is no way for the industry, with existing technology, to neet the standard proposed by OSHA. The fact that many companies including Union Carbide, arc able to meet an employee exposure level for vinyl chloride monomer lower than 50 parts per million does not mean that they can achieve levels below 25*30 parts per million and achieve a no detectable level. The companies arc the only ones that have the facts on this phase of the problem and arc the only ones In any position to make this sort of assessment. They conclude unanimously, as all have emphatically stated, achieving a no detectable level is simply not possible at the present time, even enough tney are all willing so make the attempt. Statements by ACS that the OSUA proposal car. be net arise wholly out of ignorance or a self-serving desire to justify a position otherwise unsupportable. The evidence OSUA possesses and noted by ACS merely shows that a statistically insignificant number of employees, exposed continuously for prolonged periods of time to high vinyl chloride monomer concen tration. could possibly get angiosarcona; even that result is not a proven cc-rtair.ty. The evidence sr. wed nothing else, nor will a re view of the CSHA r.nd N'lOSU presentations r.t the herring show any warrant for any such stringent regulations as is proposed. If there is truly a hazard ever, iron unregulated vinyl chloride monomer exposures it at best is slight; limited to a workplace, producing or using vinyl chloride monomer and, indeed, to a very few areas in any such work place, without any impact on the environment outside; and a hazard in tbe workplace enb at continous exposure levels far beyond those OSHA limits either in effect at this time or proposed. Perhaps the ACS position peper might have given notice that there will be a severe environmental impact resulting from the economic consequences of adopting tbe proposed standard, wholly unwarranted by the hazard sought lr ho mot, and which ought not to be imposed either on employers; on the employee:; affected by job loss; or on the con sumers who ore vinyl chloride wonor.or-related products in many harmless forms. The Directors of the ACS as a minimum, might have sought advice and comment from ACS numbers who are working in the midst of this sensitive natter before the Directors issued a position paper in behalf of these members. In summary, it is my view that the ACS did a dis-srrvicc to its membership by participating at the Hearing, on occupational exposure to vinyl chloride in support of the proposed OSHA Standard without OLI 2173 (3) providing factual evidence generated by the ACS through research or survey on which to enlarge the total understanding of the sensitive matter of V(M toxicology. The participation implied that the ACS position was that of its membership which, by my standards, is a gross misrepresentation. As a minimum corrective action, 1 ask you to put on the public record the fact that the presentation by ACS. at the Hearing Is the view of a limited number of Director members and not the consensus of the ACS membership. Additionally. I would hope that the ACS refrains from continuing to create a public record on the matter of VCH toxicity until such time as the ACS itself has a factual contribut ion to make to the issue. With kindest personal regards and the hope that the views of an active ACS member of more than 35 years will be heard. Very truly yours. AES /nn A. B. Steele OLI 2174