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/r Public Affairs Committee of The Society of The Plastics Industry, Inc. 250 Park Avenue, New York, New York 10017 2121687-2675 3C" C3 ' Public Affairs Bulletin! a c: Please route: <s a --* <_u 4*- No. 6 - July 1974 VIRAP-l^ OF THE OSHA HEARINGS ON VCM As promised, here is a summary of the second week of OSHA hearings on the subject of Vinyl Chloride Monomer. As in the past, this issue will contain a direct copy of a news release on the subject (beginning on the next page). CHEMICALS RESEARCH JUL23 '074 OUR NEW LOOK This is the first issue of the Public Affairs Bulletin to use our newly designed letterhead. It is our intent to set these public affairs communiques apart from the rest of your mail and make it easier for you to identify. We hope you like it. REMINDER TO PROCESSORS Until OSHA issues their new permanent standard, you are obliged to comply with their emergency temporary standard which went into effect last April 5th. W? / / y V M I B B I M B (MAT SUMMARY OF SECOND WEEK OF OSHA HEARINGS ON VINYL CHLORIDE July 8 The B.F. Goodrich Chemical Company was the lead-off witness for the second week of hearings. In its testimony, Goodrich stated that a no-detectable level is technologically infeasible, and that it is not safe to require employees to wear respiratory protection for full eight-hour work shifts. According to John L. Nelson, Vice President Manufacturing, "peak exposure levels ten and twenty years ago were 100 times today's emergency standard, and probably averaged forty times today's average levels." This year, average exposure levels in Goodrich plants have been reduced from about 35-40 ppm to about 12-14, with some excursions over 50. Nelson also said that construction of a new PVC facility at the Louisville plant will begin about mid-1975. Preliminary engineering work on the new plant was started in 1972.- Dr. Condict Moore, Director of the Cancer Center, University of Louisville School of Medicine, reported on a new three-part research program being sponsored by Goodrich to investigate the health effects of vinyl chloride. In other testimony, Johns-Manville, the nation's largest manufacturer of PVC pipe, asked OSHA to exempt manufacturers of PVC pipe and pipe fittings from the proposed standards, or, as an alternative, to develop a separate standard for the pipe industry. J-M submitted the draft of a proposed alternative standard with its comments. The Armstrong Cork Company requested OSHA to exempt from coverage under the standards any manufacturer using PVC resin containing less than 0.2 percent uncombined monomer. July 9 The International Association of Machinists and Aerospace Workers supported the proposed standard, and warned that the VCM situation is creating a psychological problem among long-term workers, who are worried about what may be happening to them as a result of their past exposure. Anthony Mazzocchi of the Oil, Chemical and Atomic Workers International Union questioned industry claims as to the technical infeasibility of the proposed standard and urged that fabricators be included in the coverage. -2- Goodyear recommended the establishment of separate standards for the producers of VC monomer, the producers of PVC res-in, and for fabricators. In its testimony, Goodyear said that it "fails to see how OSHA can scientifically conclude that exposure to vinyl chloride at concentrations of 50 ppm can constitute a serious health hazard to humans." The American Chemical Society endorsed the proposed "no detectable" standard because of the lack of available data establishing a safe level of exposure to vinyl chloride, but recommended periodic review of the standard in light of new data. The Society provided no details as to the scientific basis for its recommendation, but indicated that it relied heavily on advice from the National Institute for Occupational Safety and Health, which made the original "no detectable level" recommendation to OSHA earlier this year. In cross examination, VCM and PVC company repre sentatives, themselves members of ACS, were sharply critical of the claim that the ACS position was truly representative of its membership's opinion, since no one from the vinyl industry, as far as could be determined, had been consulted. Representatives from the Health Research Group also supported the proposed standard. July 10 The Firestone Plastics Company was the principal witness of the day. Its president, Todd C. Walker, supported an exposure level of 25 ppm Time Weighted Average (TWA) coupled with a 40 ppm ceiling, but disagreed with SPI's recommendation of stepped reductions over the next two- years. "This exposure level should be maintained as the permanent standard until further ongoing medical experimentation and study -- of the human as well as animal experience -- is completed and more definitive conclusions have been reached concerning the nature and consequences vinyl chloride may have on industry employees," he said. Firestone, who had retained an independent organization to conduct an exten sive feasibility study based on known technology, estimated that it might cost as much as $20 million for it to meet the 25 ppm TWA and 40 ppm ceiling which it recommended. A number of PVC processors and fabricators testified that if a "no detectable level" standard forced a shutdown of the PVC resin industry, they too would be forced out of business. July 11 On the final day of the hearings, the Calgon Corporation described laboratory experiments showing that vinyl chloride can be totally removed from air by filtering it through beds of activated carbon. Calgon is a major manufactur er of activated carbon. -3- S3 OS rO J S3 00 6M B B ZB B 8 fflWl / / / 4 V Under questioning, Calgon admitted that the installation costs of such a system would be quite high, and that the system would be most useful in limiting VCM emissions to the ambient air, but that it would have a minimal effect on worker exposure. At the close of the hearings, presiding Administrative Law Judge Gordon Myatt fixed August 23 as the final day for submission of post-hearing com ments and exhibits. He also announced that the Foster D. Snell Company has been retained by OSHA to conduct a technological and economic feasibility study to determine the effect on the vinyl chloride industry if the final standard were set at a level greater than zero. Various levels of exposure will be used by Snell in their study, the results of which will be made available to the public for comment. In an impromptu post-hearing press conference, Daniel P. Boyd, Director of the OSHA Office of Standards Development, said the final standard would not be so tough as to force a shutdown of the vinly chloride industry. He indicated that the standard would be "somewhere between zero and 25 ppm." ##### 4- - JOSEPH E. KELLER JEROME II. HECKMAN CHARLES M. EEHAM WILLLi> II DOROHKSANI.JH ROBERT R.TIERNAN WAY ME V BLACK DAVID L HILL MARTIN W. BERCOVICI EDWIN B 5PIEVACK PETER M.SEHKOV JOSEPH E HADLEY CAROLE C HARRIS WILLIAM W. PUGH Law offices Keller and Heckman 1130 17T" STREET, N.W. SUITE lOOO WASHINGTON, D. C. 2003G July 17, 1974 TELEPHONE COS 2UG-SIOO CABLE ADDUESS"KCLMAN Mr. David R. Bell Office of Standards Development Occupational Safety and Health Administration U.S. Department of Labor Room 500 1726 M Street, N.W. Washington, D. C. 20210 Re: Draft Environmental Impact Statement on Proposed Action to Limit Exposure of Workers to Vinyl Chloride Dear Mr. Bell: Responsive to Assistant Secretary John H. Stendc's June 17, 1974 "Memorandum for Recipients of the Draft En vironmental Impact Statement on Proposed Regulation--Vinyl Chloride", the following Comments are hereby submitted to the Office of Standards Development of the Occupational Safety and Health Administration (OSHA) on behalf of our client, The Society of the Plastics Industry, Inc. (SPI) and its Vinyl Chloride and Polyvinyl Chloride Resin Pro ducers Committee. 1/ 1/ The Society of the Plastics Industry, Inc. (SPI) is a Corporation organized under the Not-For-Profit Corporation Law of the State of New York. It is composed of approxi mately 1400 member companies and individuals who supply raw materials; process or manufacture plastics or plastics products, engineer or construct molds or similar accessory equipment for the plastics industry: and engage in the manufacture of machinery used to make plastics products or materials of all types. SPI is the major notional trade association of the plastics industry, its membership being responsible for an estimated 755 of the total dollar volume of sales of plastics in this country. A more complete (cont'd) vf0^ 8002007355 I tT> O XJ G 0 XJ K>r-.f. X P H 0 P XJ 0 0 H P Gp 0 1^ Oi 0 o -P Q G co H P o H O p G G X 1 G P E GX Pp cH r--\ . co Qj rH CO H P tn 0 0 id o 'J O 0 P Q G G G P p c >i >1 P G P (0 \ P O 0 G CJ . o-1 O*\ X P a H > 0 0 (N | G tpP X Oi to 0 x H` 4J id G0 0X PP 0 Px 0 cX CP 0 > P O 0 0 U G O u & rH p p G o G > G H 0P 0o o Q-i G O 0 *H p 0) P G XJ rH x0 . 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X * <n rP X 3 *3 * X X X X * 0 X X X 0 G 0XX\X H p 0 0 G G hi Eh cn| -4 A I--> <sa <59 CJJ " ` <-n change, the conclusion that the proposed standard is technologically feasible, and a presumption that the animal toxicology data mitigates against human exposure at levels above "non-detectable". SPI takes exception to these general propositions and urges that they be revised in the final Environmental Impact Statement insofar as evidence adduced during the Hearing and otherwise con tained in the record illustrates that these premises are invalid. 6. With regard to the outline of the proposed standard at Pages 53-60 in the Draft Environmental Impact Statement, the Society's specific comments on the details of the proposed standard are a matter of record and can be found in the transcript of the Hearing. 3/ 7. The Society, herein addressing the Draft En vironmental Impact Statement rather than the proposed standard, takes strong exception, as enumerated below, to the sections in the Draft Environmental Impact Statement dealing with: "VI. Probable Impact of the Proposed Standard" at Pages 60-65 and "VIII. Alternatives" at. Paqes 73-75. 8. The Probable Impact section begins with the conclusion that adoption of the proposed standard wii; result in a workplace free of vinyl chloride exposure and result in less vinyl chloride escaping into the ambient air. It is state 1 also that compliance costs will threaten marginal firms, raise the price for PVC, and encourage the substitution of other materials but that high reliance on PVC wi.ll reduce demand elasticity despite these price changes. The Draft likewise postulates that other costs assc dated with compliance are deemed capable of internal ization. 9. While understanding that the Draft Environmental Impact Statement was prepared prior to the conduct of the above-referenced Hearings and that the evidence adduced at those Hearings consolidated considerable background and expertise upon which OSHA's ultimate decision will be reached, the Society is compelled tc note that, in its view, the Draft Statement itself offers no documentation 3/ Tra script at 300-685, June 26-27, 1974 (and elsewhere throughout the record). 0002007358 5 or supporting evidence for the conclusions reached. In fact, it is respectfully submitted that the evidence gathered through the hearing process just completed in dicates that it is technologically infeasible to achieve the proposed "no detectable" level of exposure in the workplace, that this technological infeasibility is not primarily economically related, and that substitutes for PVC are not in adequate supply. 4/ 10. At Page 62 in the Draft Statement it is in dicated that the proposed standard fave's engineering and work practice methods that would reduce the exposure level and, at Page 04 and elsewhere, it is indicated that these engineering and work practice methods should include im proved ventilation, air filtration, and housekeeping. Testimony at the Rearing indicates that engineering and work practice methods could reduce but not eliminate ex posure J-o vinyl chloride in the workplace. It is sub mitted that the record is replete with information on these points and that such should be reviewed in great detail prior to the finalization of this Statement so that the environmental analysis will be baser1 on a mere accurate, a; sessment of the state of the technology. 11. On the same page the Draft addresses supply problems, specifically with regard to personal protective equipment, that should be expected to occur with the im plementation c a regulation such as is now proposed. Supply shortages, and lead-time for ordering and instal ling various types of equipment to r'duce vinyl chloride concentrations in the workplace were addressed at length throughcut the course of the Hearings. SPI submits that, since indications were that order placement and installa tion lead-time are currently running in excess of 20 months, this factor must be addressed in more detail in the final Statement. 12. Again on Page 62, the Draft states that pre liminary assessments of the cost of comp1nance indicate that the expenditu:. os to achieve such co. alienee will not be prohibitive. Without addressing the economics involved in detail here, reference should again be made to the statements in the record concerning ability to comply 4/ Transcript at 350 et seq. , June 26, 1974 and at 455 et seq., June 26, 1974. 6S U B ilttB p A -6- with the proposed standard? the testimony simply does not support the conclusion that economic consequences may not be prohibitive. Moreover, review of the Draft does not indicate that the preliminary assessment of cost of complian' - is supported by the data in Appendix C. This Appendix indicator., at Page 6, that control technology is available, and in some cases installed, for limiting vinyl chloride exposure. However, we have found nothing in Ap pendix C to indicate that technology which would eliminate exposure to vinyl chloride is either available or mstclXed. 13. We hasten to emphasize this point because, on Page 63 of the Draft, it is stated that since the technology appears to be readily available and existing practices already result in low exposure levels, some hazardous function operations, housecleaning and maintenance improve ments required notwithstanding, the conclusion is that substantial development costs for vinyl chloride control technology will not be incurred. Continuing on the same page, there is a statement that no evidence exists to date indicating that the promulgation of the proposed standard will stop vinyl chloride production and use. Again,' Ap pendix C does not support this conclusion and the evidence now in the hearing record as a minimum tends to controvert it almost completely. As a conclusion, its only support seems to stem from the statement on Page f indicating that pyc-reliant customers can be expected to sustain the industry despite the increased costs of polyvinyl chloride enu products. 14. However, as pointed out above, industry members repeatedly pointed out during the course of the Hear bigs that the technology required to achieve a "no detectable" level of occupational exposure to vinyl chloride simply does net exist. Consequently, it is respectfully submitted that the final Statement should address the question of available technology in depth and in a more realistic light. Since compliance with the proposed standard would be abso lutely prec ; cated upon the existence of technical knovz-how, SPI submits that it is essential that the final Statement address and resolve these questions and the probable effects of such a standard on an industry unable to achieve compliance. 15. Turning now to the treatment of "Alternatives" at Pages 73 through 75, the options OSIIA sees available fD 0002067360 7 could be simply restated as (1) a ban on vinyl chloride production, (2) adoption of the current proposal, (3) re tention of the Emergency Temporary Standard, (4) complete reliance on personal protective equipment and (5) an oc cupational exposure limitation somewhere between 1 and 50 parts per million (ppm). 16. The first alternative, a ban on polyvinyl chloride production, is not, it-is submitted, a viable alternative because (1) such action would be contrary to the public interest as a matter of common sense, and (2) the Occupational Safety and Health Act does not contemplate elimination of any industry. It is, therefore, urgently submitted that, since legal authority for such an action is lacking, further consideration of a ban as an alterna tive is inappropriate. 17. Insofar as the second alternative deals with the instant proposal, the comments in the preceding para graph hereof on Probable Impact are wholly applicable and indicate the inaptness of this approach. 18. Alternative number 3, retention of the cur rent 50 ppm exposure level specified by the Emergency Temporary Standard, is state!, on Page 73, to have been rejected as inadequate because animal tests "indicate that exposure to vinyl chloride at 50 ppm may well constitute a serious health hazard to employees." Th.'s statement im plies that the conclusion is justified not only by animal toxicity studies hut that such animal experience can be directly extrapo' ited to human experience. 19. It is respectfully suggested that this con clusion is no longer supported by the available evidence. During the referenced Hearings, considerable new evidence, interpretations and further reports on animal studies being conducted and their relationship to human experience were introduced into the record. It is'the SPI position that in addition to the ongoing animal studies being con ducted, some of which were referenced in the Draft Environ mental Impact Statement, careful attention in the final Statement must be directed to the human experience data presen Led 5/ ar.d the new toxicological research studies reported. 6/. 5/See, e.g,, Transcript at 500, et seq., June 26, 1974. 6/ See, e.g., Transcript at 955, et seq., June 28, 174. vffe 0802007361 8 20. At Page 74, the last alternative offered in the draft Statement refers to the "judgemental!f [sic] selection of an exposure level between 1 and 50 ppm. Such an alternative is stated to be viable only assuming that disease in man from vinyl chloride exposure is dose related and low levels are not hazardous to man. 21. Since this is precisely the essence of the medical and scientific evidence given in the Hearings, it is respectfully submitted that such evidence, entered into the record subsequent to the time when the Draft Environmental Impact Statement was prepared, should be thoroughly reviewed and given great weight prior to prepara tion of the final Statement. It is our view that the medical and scientific data specifically indicate a dose related response and that industry will do everything feasible to reduce the dose/exposure levels of vinyl :hloride. This "Alternative," therefore, appears a feasible one, as does alternative three. 22. Finally, Appendix C, the Industrial Hygiene Survey Report on Vinyl Chloride and Polyvinyl Chloride Manufacturing Facilities, states, at Page 6, that vinyl chloride control technology is available and installed in some cases but that a reasonable time should be allowed for implementation of furthe. engineering control methods such as local exhaust ventilation systems. It is important to note that this report does not and should not stare or be interpreted to imply that the VCM exposure control technology currently available and implemented by the industry is capable of eliminating vinyl chloride exposure or making it possible for producers ar.d manuf . :turers to reach a "no detectable" exposure level in the foreseeable future. * ** THESE PREMISES CONSIDERED, it is respectfully submitted that the Draft Environmental Impact Statement should be revised extensively so that the final Statement more completely and accurately addresses all of the issues as they have now been more fully developed. It is the fRD 0802007362 ~9- Society's viev.T that unless the draft is so changed, the final Environmental Impact Statement may well lack the balance and objectivity required by the National Environ mental Policy Act. Respectfully submitted, THE'SOCIETY OF THE PLASTICS INDUSTRY, INC. General Counsel for The Society of the Plastics Industry, Inc. 0002007363 U.S. DEPARTMENT OP LABOR Occupational Safety -tiki Health /ViniinLirution WASHINGTON', D.C. 20:10 t= MEMORANDUM FOR RECIPIENTS OF THE DRAFT ENVIRONMENTAL IMPACT STATEMENT ON PROPOSED REGULATION VINYL CHLORIDE This is to inform you that the final date for submission cf comments on the draft environmental impact statement on vinyl chloride, previously announced as July 17, 1974, has been extended to August 5, 1974. The increased time period for public comment allows 45 days from the Council on Environmental Quality's notice of receipt of the draft document in the Federal Register. Comments should be sent to David R. Eell, Office of Standards Development, Roc -. 500, 1726 M Street, N.YM , Y.'ashington, D.C. 20210, by August 5, 1974 to assure their consideration. Any inconvenience caused by the change in comment Office of Standards Development Government ij/ljbtllltit'f iiiiiltl< Li L vk3 u u k*s Ui?lUr;;u,^.i is\;:\I ]nJ' 33 C3 SS <sa S <55 03 O' Industry decries OSHA's For example, we do not know the mecha number of liver cancer cases being 10 nism by which a chemical carcinogen times those expected in a similar unex- no-detectable level rule as unnecessarily harsh; opjerates or whether a safe level of ex posure can be set." Much of the testi mony presented at the hearing dealt post'd population. He stressed that these studies, though preliminary, show that multiple cancer sites are in both labor and ACS with industry's, labor's, and research volved and cancer is increasing over workers' effort to resolve the latter .time in the population. Dr. Peters support proposed standard question. agreed with Dr. St'tknff in that he The initial impetus for the vinyl said, "I do not believe we will know the chloride industry came during World full cancer-causing potential of vinvl War [I when it was used as a substitute chloride for several yi >:s. At this point Mere mentioning of the w- -Is vinyl for natural rubber. According t<> Dr. the only way to assure an end to this chloride to Occupational Safety and Irving ). Selikoff, professor of medicine serious hazard is to eliminate the expo Health Administration officials who at City University of New York's sure." presided over public hearings on the Mount Sinai School of Medicine, "This The vinyl ch!oride-''YC industry, in agency's proposed permanent work ini mediately points to a problem of general, took the opposite view. Harry place standard for the chemical may current vinyl chloride-polyvinyl chlo K. Conners, vice president of Diurm rid well lead to mut'.enngs that enough is ride investigations; the industry is a Shamrock Chemical, uT, the hearings. enough. In nine days, the officials lis relatively vnung one. and the late ef "In our iudgme; \e crises of worker tened to -to hours of direct testimony fects of toxic exposure have only begun illness recently ch vered in indumrv by 41 panels of witnesses--and many to appear; most of our experience is are the delayed re-ait of conditions additional hours in question and an still ahead of us." He told the hearings that were common many years ago but swer sessions--and received 80 written that clinical field studies are being are no longer present in today's st]!>inis>i<ms for the hearing record. conducted that include examinations plants." Dr. Richard \Y. McHurnty, Much of the data presented OSHA is of more than 1200 vinyl chlnride-PVC corporate medical director (if Diamond conflicting All this is of little co: "art polymerization workers, Although all Shamrock Chemical, pointed out that to the officials as OSHA has until Oct. the results g.c not yet in. he reported "(luring the early years of PVC produc f> to come up with its final version of a that studies of -'At current and former tion attention was given to vinvl chlo permanent standard. workers at Goodyear's plant in Niagara ride vapors only because of the anes It s likely that OSHA may well pick Falls. N.Y.. "demonstrated a signifi thetic qualities and the explosion haz some middle ground standard--tougher cant prevalence of liver abnormalities, ard. Since the explosion hazard occurs than that proposed by industry, softer peripheral vascular changes, and lung at upward of 30,000 p.p.m. and the an than that initially proposed by the abnormalities." esthetic effect at 1000 to oizu p.p.m. Government --which, if either labor or Information on deaths from two the vinyl chloride levels in work areas industry is unhappy about it, may well plants, one which produces monomer were undoubtedly quite high." beehalleu.. in tht courts anyway. and the other polvmr.. was presented Dr. Carl U. Derncnl, associate medi Data presented at the hearings tend by Dr. John M. Peters of the Harvard cal director of Union Carbide, told the ed to coalesce, in effect, into two posi School of Public Health. He said that hearing of a health survey conciucti ;1 tion': that of industry and that of Gov- studies on 1 f> 1 deceased white males by SI'l covering 16 plants employing crmnent-kihnr-ACS For instance, a showed "a o07c- excess of deaths due to 2372 persons whose current work per spokesman for the Society of tire Rlas- cancer." There was a "60% excess of mits exposure to vinyl chloride, plus iics Industry maintained that OSHA's lung cancer (13 cases with 7.9 expect 471 who had worked with it in the proposed work-place standard--which, ed) anti a 3207c- excess of brain cancer past. He said that the study identified among other tilings, calls for a no-de (five cases with 1.2 expected) with the 1402 men who were e: posed to vinyl tectable level of vinyl chloride--"is not technologically feasible and, if adopt Sri's vinyl chloride rules would differ sharply froi 3 OSHA's ed, would shut duv n the industry. ' In contrast. Peter Bnnimarito, president of the United Rubber Workers, said that the "OSHA prop j.-al comes closer to the ideal standard than any yet proposer.1 or promulgated for any work place hazard." However. Or. Daniel P. Boyd, direc tor of ti.e nince of standards develop, t A no-detectable level for employees * exposure as determined by a sampling f: " and analytical technique capable of de- j J tccting vinyl chloride concentrations of 7 < 1 p.n.m. with on accuracy of 1 p.p.m. ;j ? 3= 5CTo- This would apply to monomer, 4 j; polymer, arid fabricating operations. ' ' For polyvinyl ch.srice resin plants,,'; ;0 ceiling of 40 p.p.m. of vi.,y: chloride.' : fthis year, 25 p.p.m. in lSD. For vinyl ; f chloride plants, a ceiling of 25 p.p.m. 7 J this year, lu p.p.m. in 1575. PVC fabri-U <catir: plants would tu excluded from 5 i the standard. > meat f,-r (JS[I\, although emphasizing that tlii* proposed standard is just that -- a [iroposal --s,ik{ that "it repre sents our best judgment based on the inhumation available on Mav 10 . . . our t Lnheliiv~ for regulated areas and ; ! Labeling should provide those who . - vinyl chloride-polyvinyl chloride con-'-j j need the information - i methods for '.' tamers with the warning to include the j j dealing with the problem; it should not * words "cancer suspect agent.V, " jibe a basis for panic because of a dis- J f- . ' - ' "J k ease characterization, .. present judgment is that vinyl chloride is a carcinogenic agent," Dr. Bowl pointed out lli.il in protecting employees from a earcirogenic material. "We are v* Use of air-supplied respirators in j ! Use of air-supp!,:cd respirators is im- ' cases of emergency and when vinyl 'practical except for short periods cf I chloride concentrations rise above de- 1 > time. Air-supplied breathing apparatus f tectable levels.___ _ , v. -r. , J.also should be allowed.. j operating in the area of many unknown;-;. .lulv ?? i7A r.f.rri Q chloride at least JO years* ago, of which 416 1 ' a latent period of more than 20 year, dso identified were 787 men ex posed continuously to vinyl chloride for more than 10 years, with 101 being ex posed for more than 20 years. Dr. Dernehl said. "Examinations of these men have failed to show the existence of ab normal liver function tests in greater proportion than would be found in a control population. There is no case of angiosarcoma of the liver among these men even though their exposure time is sufficient for the disease to hove oc curred and exposures are believed to have been in excess of 50 p.p.m." He concluded that "these data fail to sup port the need for an exposure level as drastic as that proposed in the stan dard." The SPI survey's findings were sup ported by Diamond Shamrock. Dow Chemical, B. F. Goodrich. Tenueco Chemicals, and Firestone. All reported that despite extensive surveys of their current and former vinyl chlnride-PVC workers, no further cases of or deaths due to liver earner have been found, other than the Id previously reported to OSHA. Industry also felt that the proposed stand .rd was too far-reaching. Accord ing to Anton Vittone. president of R. F. Goodrich Chemical, "The produc tion of vinyl chloride, its polymeriza tion into PYC resin, and the processing of PVC' resin into semifinished or fin ished products is treated in the pro posed star, lard as one industrial health problem." However, he contended, "bach is an entirely different operation p'-ing it- ov. n problems, permitting and requiring cliff* ''"tit solutions." Of particular concern :o many in iustry witnesses was the inclusion oi PVC processors and fabricators, such as phonograph record makers, under the proposed standard. Monitoring data on vinyl chloride exposure in processing plant.- were p. ,ued by several wit nesses, including h'hiHp -j. Weaver, di rector of industrial affairs fur R. F. Goodrich. In a conclusion that agreed with those of oilier witnesses, he said, "Our data does not support this con cept of inclusion of processor opera tions" under the proposed standard since "we find no detectable '-.els of vinyl chloride in most of the p; cessing work place-." In addition to urging that fabricators and processors ivt be included under the permanent standard, the Society of the Plasties Indus' ry propo-cd (bat in vinyl chloride and l'Y(.' piar.ls there he a stepped reduction in worker expo sure. This is in .-harp contrast to the American Chemical Society position presented at the bearings bv Dr. Ste phen T. Quigley, Innd of the Society's department of ehemi-try and public af fairs, and Howard 11. Fav.irtt, chair man of 1110 ACS Committee on Chemi cal Safety. ACS, in essence, supports the OS11A proposed standard, asking PVC fabricators should not be included under the exposure standard, SPI urges only that the standard be defined as a minimum practical level capable of de tection by a recommended method rather than as a no-detectable level. SIM's proposed standard drew sharp criticism from Anthony Maz/.occhi, citizenship-legislative director of the Oil, Chemical and Atomic Workers In ternational Onion. He said. "It will be a tragedy if OSHA adopts the so-called `common denominator' kind of stan dard that SPI . ponsored. Under this approach a standard is adopted that everybody can meet. Hut those plants that can go further are under no incen tive, at that time, to do anything more." Most companies at the hearing said that although it would be difficult, they could live with SPI's proposed standard. Two companies, however, re ported that they are already operating at much lower levels. Dr. V, K. Rowe, Dow director o: toxicological research in health and environmental affairs, said that tire company, "is generally operating within an eight-hour time- weighted average (TWA) concentration of 10 p.p.m.; however, brief malfunc tions and other temporary situations occasionally result in short-term excur sions in excess of 10 p.p.m." And Air Products am! Chemicals' John T. Barr reported that his company has an eight-hour TWA in the 20- to 25-p.p.m. range for workers in its polymerization building and even lower levels fur those in other job locations. Tenncco Chemi cals, however, estimated that it would have to spend m excess of $11) million to reach the exposure levels recom mended by S1'[. Vinyl chloride-PVC industry u it- nesses contended thr> ughout the hear ings that meeting the proposed .-Mil liard was just not technologically feasible, unless workers ... re air-sup- plu-d respiratory equipment all the time. However, Calgou Uorp., which was moved from L'lith tn last on the witness declared that technology was available to remove vinyl chloride from the- air. William l.ovetl of the companv's activated carbon division said that t he-HM^'iner can readily he adsorbed on activated carbon in con centrations ranging from 1 p.p.rfS it more than 30VC by volume in air YT said laboratory results show that ttuT- removal of vinyl chloride from df? n: nitrogen streams is technically po^blt using dual beds. <sj Earlier in the hearing Tetffibce Chemicals testified that it has included carbon adsorption to recover the mmio- mer from two small process slrcWiis. neither of which contains air. in plans for its new PVC plant in Pasadena. Tex. However, it pointed out that it considers this activated carbon method tn be "wholly impractical" where large volumes of air and small concentra tions of vinyl chioride are involved. Mr. Bommarito expressed the belief that the standard cog be met, saying that where "enginc-f. mg < -.trols may not be applicable, person;.i protectiveequipment can be used." He added that especially in newer plants the problem is "characterized by the will, not the ability, to do the job." He con cluded that "the ir. iical facts are in a i the problem is now in the social and political arena." International U.S. reactor design loses out in U.K. U.S. reactor de.-ign has lo-t out in its bid for the next generation nf nuclear power stations in the U.K. 'The British government has opted instead for the steam-gener. mg heavy-wait : reactor (SGHWItl sy.-tem. The immediate plan is to build three twin-reactor sta tions with an overall capacity of about 401)0 Mw. of electricity. The fir.-t of these stations should be operating by 1982. The decision, taken by Brio Vnrlev, U.K. Secretary of State for Energy, bucks the trend in other countries, where planned nuclear power programs center on U.S. designs for light-water reactor (LWR) systems, either General Electric's boiling-water reactor iBWR) or Westinghouse's pressurized water reactor <P\V . Inh-ed. at public bear ing? before the Eniggy Resources Sub committee of the 1 louse of Cnimiiuiw Sc-lc-t Committee on Science and Technology last December, both Ar thur Hawkins, chairman of the Central Electricity Camerai Board, who.-;: supplies power to England and 'Aaie-, and Sir Arnold Weimto'. k nr-.r.a.gv.g director of Br.tih General El-utrn. which has a oO'T slake in U.K. .V.tmnsi Nuclear Corp., came nut sironglv in favor of lAVll's, primarily hceau-e the technology is alvendv proven and can lie fairly quickly brought into uperat inn without major design and development effort ((,'& KN. Feb. 18. page 11). Mr. Yariov cites a number >f rrason.fnr deciding on the SGI i\\ W route. "In the government's judgment, i: will pro- vide power reliably and we- tan proceed in rs.rM io-> l July 21, 1974 4 iiU IVLjt/ X O'ivii. i PC w /* Education, Religion, Mental Health W!xxcn :-S fn* Done About lobs That Can Kill By JANE E. ERODY Tha recent disclosure that four workers in a vinyl chloride plant had developed a rare and fatal liver cancer Ip-1 to an industrywide search and the cdscovcry, so far, of 21 such ca: :c. The Department of Labor has con cluded hearings on new limits to worker exposure to vinyl chloride, which is a chemical that forms the basis for thousands of plastic rroducts, ranging from tablecloths and phono graph records to water pipes and in sulation. The vinyl cloride findings are only the latest of many instances of oc cupationally caused cancers. The first was in 1773, when Percivalt Pott, an English surgeon, published a medical report describing a high incidence of cancer of the scrotum among the chimney sweeps of London. Dr. Pe t's report inspired a ruling three years later by the Danish Chimney Sweep ers G'.uld that its members should have duiiy baths to prevent accumula tion of ctncer-cr-using soot. Relatively few subsequent discoveries of jobrelated cancers or other occupational diseases have resulted in prompt pro tect- ; action. Danger and Delay Benzidine, a chemical used in the dye industry, was first describe.! in 1929 by a British factory doctor as suspected of causing cancer of the bladder. In 1933. an American doctor. Mitchell R, Zavon, began compiling bladd.r cancer cases among workers .in a Cincinnati plant. Hut it was not until 1972 ..',st Dr. Zr.von disclosed his finding.'; to Federal authorities responsible for protecting the heailh of American workers. And it was not until a year rjo that Federal rules took effect to prevent worker ex posure to benzidine and 13 other known and suspected occupational carcinogens. Asbestos is a ubiquitous fibrous mineral used fc- everything from food processing filters to construction ma terials to brake linings. It lias been known for two decodes to cause in variably fatal cancers and disabling lung disease. Workers are still not protected.dcspiis a Government ruling. Two years ago, the Department of Labor's Occupational Safely and Health Administration decided to lower the worker exposure standard from five to two fibers pc-r cubic centimeter of air. But at the indus.ry's urging, the agency delayed the effective date of the ruling until 1076. As a result workers may be Inhaling as many as 12.5-billion potentially lethal fibers each year \vh n a level one-fifth that has alreocy been s..,wn to produce !< cancer in man. --1[ This week a Senate subcommittee^, is holding hearings on alleged Labor a.1 Department foot-dragging on asbestos standards. The charges are that the Nixon Administration deliberately went easy on indu- -y in return for campaign pledges. The Government is now proposing that the exposure* limit of 500 pirts of vinyl chloride per million parts of air be lowered to "no detectable level," or one part per million parts of air. The proposal is based on the scientific. tenet that there is no "safe" level of a cancer-causing agent. 1 ' "" At the hearings, company represen tatives asserted the ruling would bs "economically not feasible.'' It would, they said, shut down the entire in- dustry and result in the loss of perhaps TO'-.DOO jobs. Labor sources condemned the conclusion as "bvsterical," and Dr. Irving J. Sclikoff of Mount Sinai Hospital, an authority on occupational diseases, pointed out that the Dow Chemical Company had a!ready brought its levels down to below 10 parts r..-r million, with eterv indica tion that tney can be readily reduced sull further. j I r |u. p j> | I , j A Classic Battle Until the hearings, industry had been extremely cooperative in helping researchers defin: and control tV. vinyl chloride hazard. But now th; fight is shaping up along classic lines: labor vs. industry and industry vs. Government regulation. And there is every* in "cation that similar battles will be ...ged in tiie years to come. Some 15,000 chemical and physical agents are in industrial use now; hundreds are introduced each year, most of which are untested for disease-causing potential. Assistant Secretary of Labor Juhn II. Slender, head of the three-yc-ar-old Occupa tional Safety and He:;', h Administra tion, has warned Ur.:. Gover-mcnt action to protect worker kcalm has only just begun. As he put it reccrVv: "RcseamVi -? enthusiastically peered into fm*..: profitable uses for new substances must be expanded to include (loLcrnv,,- ing how safe then: substances arc. 'Any doubt must 1 esoived on the side of the employee." (More Ideas & Trends, Page 16.) ,. mmr' 1 .. , f John Met ling ' --------------------- ^ . SATURDAY, JULY 20, 1974 Protecting Workers--" " And Their Jobs Like '.'rod's angry man. Peter1 Rom- marito, president of the Rubber Work_ ers Union, stunned at leaders in the chemical and plasties industries for resisting stronger safeguards against ' ca: er-producine vinyl chloride, a sub! st ..-e usi`d in the manufacture of a i wu.d variety of products. ' "There are millions of workers-- ;l frightened men and women -- who don't want to die for thru' jobs,'' said Bommarito, who is chairman of the oc cupational safety and health commit tee of the AFL-CIO Industrial Union Department viv.ch rene-cuis (i.GuO.C'.M : workers in 00 unions. 'They want to be l told tnat. industry management and un ion and the government, federal and slate, can assure them of job and ' their lives. They certainly \v,.nt boln." he continued. "But if this is not pos sible then they . hoose lile." ,1/r. llrrlinp urites frct/ucntly on labor topics for thvsc (inpes. -------------- , management's tactics of delay and poor-mouthing of its financial ability to cover the costs of protection. What it amounts to. he said, is that the `'nation is being blackmailed'' by managements resisting the application of new effective health standards. They raise the specter of "an end to 1.6 mil lion jobs and national disaster/' Bommarito's voice grew sharper: "lie made it clear he had no intention of bargaining with the health Bommarito spoke to an occupational safety confer once on vinyl chloride. The hushed audience in the Labor De rr partment auditorium included repre.! sentatiws of management, government *; aud unions. He made it clear he had * no intention of bargaining with the health and safety of union men and women--although this has sometimes happened in the pa:-1. Often, when stricter standards are advanced for the protection of the health and safety of workers in plants and/or mines, two tilings take place. Fir.-.t, the prospect of greater protec tion for work-.s scares the industry because of the expenses of implement ing safety standards. Second, manage ment warns that the cost ot such im provements will be so prohibitive that . plants will bo closed and workers thrown out of their jobs. i What it comes down to is that work ers arc confronlcd wiih a dread ' choice: "Your wages or your life." j Based on experience, employers are ' confident \hm unhms and their lev. i- ers, threatened with unemployment. -(will make some l'ace-savir.- comprn- mi'^s. Those are often filtered through TM a screen of confusing statistics, to reus- sui e workers thnl at least for urn time being tiny have no medical cause tor alarm. But FSommarito was having none nf Uuu. Like the Oil. Chemcial and At omic Workers, his union has been one of the pioneers in insisting that iii.-ni. agemcnl must not duck responsibility 4 maintaining -a'c work places. Hum' mariio sa>s he inis had a bellyful of and safely of union men and women" "This country survived for nearly 200 years without pol\ vinyl chloride fPVC) and we can survive in the fu re with out it. If PVC cannot be made or used safely, then the proposed standard must bo replaced by an orderly proce dure !:. phase out vinyl chk-r.ide pro duction and find substitutes for its products, or to phase out the products themselves. This is not an easy posi tion to take. But there is no alterna tive." The battle over vinyl chloride is the latest confrontation between labor and industry on the subject of protection, for worKers against cancer-producing chemicals. Battles over asbestos and carcinogens continue to be fought in Congress and in the courts. Labor, said Bommarito. has listened to experts from all over the world and "we have concluded that the proposed govern ment standard of `no detectable level' for vinyl chloride is both necessary and feasible.'' Bommavii n rr>nchidcd:"Thc issue betore us ), really not the control of vi nyl chloride. The issue is whether life lias a higher value than dollars, whether we will permii corporate structures to run the country without control. The language and the intent <jf the Occupational and Safely and *-i4#..Lih Art mean lha! workers' lives no lunger can be sacrificed for financial gain. The vital organs of our bodies are not fur sale".