Document NX8r3mjYkZQxJvVndQDOwa0g

( 2^ crfiA. *PAj?duc& Air Products and Chemicals. Inc. Bok38 Allentown PA 18105 <215)461.4911 10 August 1982 Mr. R. C. Barnard Cleary, Gottlieb, Steen & Hamilton 1250 Connecticut Avenue, N.W. Washington, O.C. 20035 Dear Bob: Further to my note of 2 August on the Zeise, Wilson and Crouch pro posal, I have tried, without success to follow their mathematical examples. The raw data are missing, and there seems to be some errors in the draft. Thus, I have prepared a simple table of toxlcitles and made a few calculations based on their reported risk from vinyl chloride. The results are attached. W JohjfJ. Barr-' Manager, Regulatory Response JTB/sjw Enclosure AP00051456 Substance Vinyl Chloride Sucrose Saccharin Ethanol Citric Acid Sodium Chloride Acetic Acid Vitamin A Aspirin Urea Ascorbic Acid Ammonia Formaldehyde TCDD Oral Rodent LDj-o.g/kg 26-39 30 14-18 6-8 5-12 3-8 3-5 2-4 1 0.5 0.5 (1v) 0.35 0.06 0.02-0.04xl0"3 io Wilson Potency 10'4 0.08-1.7 765-5800 AP00051458 A me CHEMICALS GROUP Pm* Cateuttv* M*M, 9w*dMferd Read. Way**, Pa. 10087 December 28, 197S Jerome Beckman, Esq. Keller and Heckman 1150 17th Street N.W. Washington, D.C. 20036 Gary H. Baise, Esq. Ruckelshaus, Beveridge, Fairbanks & Diamond One Farragut Square South Washington, D.C. 20006 John Lawrence Society of the Plastics 355 Lexington Ave. New York, N.Y. 10017 Industry, Inc* Gentlemen: I thought you would be interested in the attached letter we received from Barry White of OSHA in response to our request for a redefinition of "fabricated product." The third paragraph of the letter ia very significant, and means that PVC resins and compounds with very little residual VCM will be "fabricated products" and will, therefore, be exempt from the labelling requirement. It also means that fabricators who use such low residual VCM product exclusively will be exempt from the OSHA standard. Vary truly yours, RHS*swc cc: A. R. Adams J. T. Barr Raymcpid H. Schenck Attorney AP00051464