Document Ne10djr56BYza1K8wDmJv9kbw

minutes PVC SAFETY CROUP STEERING COMMITTEE Tuesday, February 28, 1978 8:30 A. M. Sheraton Hopkins Hotel Cleveland, OHIO SUMMARY: 1 - PVC Safety Group has been designated by The American Industrial Health Council (AIHC) to represent them at the EPA meeting to review its carcinogen policy on March 23. PVC Safety Group members are urged to to be present. 2 - Nominating Committee recommends present officers of Steering Committee to serve for a second year. 3 - The next meeting of the full PVC Safety Group is March 31, 1978 in Arlington, Virginia. ATTENDEES: D. C. Nuechterlein - CHAIRMAN - Dow Chemical USA, 2020 Dow Center, Midland, Mi 48640 E. G. Ackerman - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 A. Ross Adams - Air Products & Chemicals, 400 Orchid Circle, Emraaus, Pa 18049 Gary H. Balse - Beveridge, Fairbanks 4 Diamond, One Farragut Square South, Wash. D.C. J. T. Barr - Air Products & Chemicals, Box 538, Allentown, Pa 18105 R. W. Fortenbach - Shell Chemical Co., One Shell Plaza, Houston, Texas 77001 Ralph L. Harding - SPI - 355 Lexington Avenue, New York, NY 10017 Francis Hor - Firestone Plastics Co., P. 0. Box 699, Pottstown, Pa 19464 Jack Jaglora - The Pantasote Co., of N.Y. 26 Jefferson Street, Passiac, NJ 07055 R. W. Laundrie - General Tire & Rubber Co., One General Street, Akron, Ohio 44329 John R. Lawrence - SPI - 355 Lexington Avenue, New York, NY 10017 William Rupp - Tenneco Chemicals, P. 0. Box 365, Piscataway, NJ 08854 Dick Savage - B. F. Goodrich Chemical Div., 6100 Oak Tree Blvd., Cleveland, Ohio 4413; Steve Schaefer - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 Don K. Spencer - Shell Chemical Co., One Shell Plaza, Houston, Texas 77001 Dale W. Sullivan - Ethyl Corp., 451 Florida Blvd., Baton Rouge, La 70801 Todd Walker - Firestone Plastics Co., Firestone Blvd., Pottstown, Pa 19464 Professor Richard Wilson -- Harvard University. THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 Lexington Avenue New York. N Y 10017 (212)573-9^00 BR 0l2il6 2- - 1- Chairman Nuechterlein opened the meeting by calling on Messrs. Schaefer and Barr to review the results of the meeting held with the AIHC Steering Committee relative to the review of liPA's carcinogen policy. The conclusion of this meeting was that AIHC wishes the PVC Safety Croup Lo act for AIHC at the EPA hearing scheduled for March 23. In doing this, AIHC would make available any of their background preparations that have been made for the chemical industry's response to the OSHA Generic Carcinogen proposals. 2- Mr. Baise presented a Proposal Work Plan for an SPI presentation at the EPA March 23 meeti.ig on its generic regulation of carcinogenic air pollutants. (Attachment A). With respect to broadening the SPI comments to cover materials other than just vinyl chloride or plastics related chemicals, he suggested it would be difficult to do this adequately by March 23. Reference was made to two reports that might be cited to EPA as a basis for any changes in the EPA's carcinogen policy: . Principles for Evaluating Chemicals in the Environment National Academy of Sciences, 1973 . Decision Making for Regulating Chemicals in the Environment - National Academy of Sciences, 1975. In discussing the policy consideration, the group reached the following decisions: i) Seeking a delay in the March 23 hearing would not be advisable. ii) The AIHC's Alternatives document can be used as a basis for critiquing the EDF proposal. However, legal counsel pointed out that there are some fine points of differences between the legislative authority of OSHA and EPA and these should be taken into account. iii) It will be important to coordinate the approach used in the AIHC proposal with prior industry positions at EPA. iv) It will onyl be necessary to make reference to industry's previous comments on EDF position on vinyl chloride and provide a summary of the industry's position on these points. BOR 012117 -3- 3 - Risk-Benefit Concepts Professor Richard Wilson of Harvard University was introduced by l)r. Adams He gave a brief statement on his risk-benefit concept as related to vinyl chloride and other carcinogen risks. He pointed out that because it breaks down in the atmosphere rapidly that the concern should be the primary contact (i.e., exposure in the workplace). On the basis of EPA's 1976 regulation, the risk projects to perhaps one case in 20 years. Several references were made to Professor Wilson's position papers on this subject: . Risk-Benefit Analysis for Vinyl Chloride (ACS Meeting, September 1, 1976) . Magnitude of the Chemical Cancer Problem: A Review of Some Opinions and Numbers. NOTE: Copies of these papers can be obtained from John Lawrence at the SPX office. 4 - Committee Reports (a) PVC Fire Safety Committee - Mr. Dan Kent reviewed the activities of the committee making specific reference to the minutes of the January 5 meeting. He also called attention to the toxicity studies proposed to be conducted at the University of Michigan on off gases from burning materials. The Steering Committee recommended that PAC be urgently requested to support this study because it involves all types of plastics. (b) Financial Report - Mr. Walker distributed the report on expenses through December 1977. (Attachment B). It was also indicated that approximately 50% of the January assessment of $400,000 has been received. In response to a request by the Chairman, Mr. Walker indicated that a budget projection will be prepared for the full Committee to review at the March 31 meeting. (c) Communications Committee - On behalf of this committee Mr. Ackerman reported that activities have been at a low level pending EPA's action on the proposed VC amendments. It was agreed that the Communications Committee should be ready to provide appropriate backup to the Group's participation at the EPA meeting on March 23. A summary of Hill & Knowlton's activities for the month of January on behalf of the Group is enclosed. (Attachment C). BOR 012118 -4- 5- 67- Nominating Committee - Dr. Adams reported that the Nominal ing commit u-e recommends that Messrs. Nuechterlein, Schaefer and Walker be re-nominaied to their present offices and that their respective companies be nominated to the Steering Committee for a three year term. It was agreed that these nominations should be directed to the attention of the full PVC Safety Group for action at the March 31 meeting. Health Committee - Mr. Nuechterlein reported on behalf of Dr. Torkelson that the Health committee was still searching out an organization main taining complet, records on VC health studies and related information. It was urged that one of the several organizations under consideration be retained for a trial period of 6-12 months. EPA Hearing Plans Beveridge, Fairbanks & Diamond will prepare a draft of an industry presenta tion to cover legal, technical and health considerations. It was agreed that we should make it clear that comments were preliminary in reponse to the "meeting" context rather than a "public hearing". Further, that we should reserve the right to make further comments relative to any un resolved technical considerations. Plans were made for Messrs. Baise, Laundrie and Barr, to meet with the AIHC's Scientific Committee on March 7. Final plans for participation at the March 23 meeting are to be reviewed with the AIHC Steering Committee in Chicago on March 15. A draft of the presentation material will be sent to the full PVC Safety Group by March 20 of it is at all possible. It is urged that all PVC Safety Group member companies try to be represented at the March 23 meeting. The next meeting of the Steering Committee will take place at 8:00 a.m. just prior to the meeting of the full committee on Friday, March 31, 1978. The meeting adjourned at 2:40 p.m. ATTACHMENTS 3/8/78 Respectively submitted, sfL O '' John R. Lawrence Technical Director BOR 012119 Beveridge;, Fairbanks & Diamond 2/24/78 ATTACHMENT A Proposed Work Plan for the SPI Presentation at the EPA March 23 Hearing on Generic Regulation of Carcinogenic Air Pollutants I. Overall Approach EPA has announced that it intends in its March 23 hearing to solicit recommendations leading to possible development of a proposed generic cancer policy for airborne carcinogens. It may be desirable simply to put EPA on notice that SPI intends to be heard force fully on EPA's cancer policy, address the eight questions EPA posed in its amendment, and then raise the literally dozens of questions posed by EDF's petition. We should indicate that the Agency needs far more time and addi tional meetings before it could possibly consider pro posing any new scheme. II. Committee Work Needed Before March 23. A. Policy Considerations 1. Whether to seek a delay of the March 23 hearing or to press for prompt EPA action because EPA's current policy is acceptable. 2. Development of an approach to EDF's proposal for a classifi cation scheme for airborne carcinogens; consider how to distinguish EPA concerns from OS HA. 3. Coordinate approach of the AIHC proposal with prior industry position at EPA. 4. How to challenge EDF's presen tation of the "Vinyl Chloride Story." How to treat EDF's statistics and such issues as substitutes, threshold, zero emissions, extrapolation of animal data to humans, repli cation, and offset. BOR 012120 2 B. Technical and Health By March 10, 1978, SPI should have papers pre pared analyzing the EDF proposal in detail (state ment by statement), raise all of the questions necessary to challenge that proposal, and consider an appropriate answer or alternative to the EDF proposal. Among the overriding issues are: 1. To what degree and in what manner should EDF cancer statistics be . challenged? 2. What information is available to rebut, correct, supplement the studies relied upon by EDF? 3. What position should be taken with re gard to EDF's non-threshold and zero emission theories? 4. What implications are there to the off-set policy? 5. What assumptions/facts does EDF rely upon which are erroneous? 6. What is wrong with EDF's proposed regulatory scheme both thcoretically and, assuming implementation, from a practical standpoint? C. Legal The Legal Committee should complete by March 10 a review of the legal questions which arc posed by the EDF petition. Among the issues are: 1. What is the interrelationship of KPA's authority under the Clean Air Act and the Toxic Substances Control Act, the Federal Insecticide, Fungicide and Hodcnticide Act, the Federal Water Pollution Control Act and related laws and regula tions? i BOR 012121 # /\ V -3- 2. Can EDF's scheme of relying on Section 111 to regulate new sources of Category II substances be effectuated? 3. What procedural safeguards are necessary under any regulatory scheme? III- Presentation at Hearing A. Background. Establish setting for the hearing; identify the key parties; establish SPI stature/ experience and standing. B. Present policy statement, consistent with overall approach outlined above. C. Consider having tecnnical, medical, scientific and legal experts available to testify. D. Consider submission of key policy, factual and legal issues and questions raised by EDF petition and the prospect of EPA action. E. Call for further informal meetings before decision on whether to even propose regulations. F. Establish groundrules if regulations are proposed, such as right of cross-examination. IV. Other Issues A. Consider filing a Freedom of Information Act request to obtain (a) all EPA cancer policy docu ments which led to its May 1976, statement, and (2) any new information the Agency has received on this subject relevant to the EDF proposal. B. Establish procedures for liaison with AIHC. C. Schedule of meetings. D. Establishment of committees and selection of chair persons. E. Coordination of expert witnesses with AIHC. 1. Oral presentation. 2. Written submission. BOR 012122 SPI-PVC & VCM PRODUCERS GROUP SOURCE & DISPOSITION OF FUNDS AS OF 12-^1-77 ATTACHMENT B SOURCE: \ 1. Carryover (Loss) From 1976/77 Operations-Per Ledger Print-Out Plus: Duplicate Entry of Allied Chem.Payment Less: Assessments Paid-Not Recorded on Ledger Great American Chemical Booker Chemical Net (Loss) Carryover from 1976-1977 AMOUNT $(28784.58) ( 2460.00) 912.00 167.. 50 ^ $(30165.0 2. Assessments: Total Assmt. Net Assmt. Agff^t.Paid ____________ Due. _ & 1976/77 Assessment No.3 $100000.00 $100000.00 b. 1977/78 Assessment No.1 250000.00 244512.50 c. 1977/78 Assessment No.2 394100.00 - Total Assessment Income $344512.50 Net Assessments Receivable Per Attached Detail $ 5487. 50 3 94100. 00 344512.5 $399587.50 399587.5' 3. Meeting Income: 380.C T tal Funds Available - 12-31 -77 $714314.9- DISPOSITION: 1. Current Year Expenses: Legal Expense - Paid thru 12-31-77 - Accrued for December Public Relations Expense-Paid thru 12-31-77 -Accrued for December Meeting Expense (Incl. Travel) Research & Development Expense Office Supplies & Expense Telephone & Telegraph Expense Total Expense thru 12-31-77 $204711.76 12^66.60 $ 95076.52 10756.7^ Hat Funds Available at 12-31-77 $217078.56 105833.25 6777.92 33018.67 896.47 1502.45 #365107.3; #3W?Q7.6< BOR 012123 HILL and KNOWLTON, Inc. ATTACHMENT C Memo to: Robert B. Downey, Chairman Date: February 28, 1978 PVC Communications Committee The Society of the Plastics Industry, Inc. Subject: PVC "Action Program" Bill and Activities -- January 1978 Copies: (See below) Following is a breakdown of H&K staff time charges and out-ofpocket expenses billed at cost, and a summary of activities on behalf of the PVC "Action Program" for the month of January 1977: 1. Political Education ------ o No activities in this category during the month. 2. Radio-TV Training ------ o No activities in this category during the month. 3. Washington Activities $ 1,667.00 o Continued liaison with SPI's Legal Counsel in Washington. o Continued to monitor Washington press and regulatory agencies for developments on VCM/PVC-related issues. o Discussed with SPI's Legal Counsel actions by EPA re: vinyl chloride (they may not repropose the standard). o Discussed with SPI's Legal Counsel impact of Supreme Court decision on asbestos and EPA on PVC or other air pollution actions. o Discussed with SPI's Washington Represen tative, SPI's Legal Counsel, members of Communications Committee and H&K-New York re: Sen. Moss hearings touching on ethylene dichloride. o Assembled information on International Trade Commission-U.S. Treasury action re: dumping of PVC sheet and sent to SPI1s Legal Counsel. BOR 012124 Robert B. Downey February 28, 1978 2- 4. Intra-Industry Communications S 1,791.00 o Researched and prepared draft of copy for "Management Summary" Vol. Ill, No. 1. o Monitored national, international, trade, medical and environmental press for mention of VCM/PVC. Sent major stories to SPI. 5. Staff and Committee Liaison $ 2,060.00 o Prepared activities report for PVC Safety Group covering communications activities from April through November 1977. o Preparations for and participation in meeting of PVC Communications Committee on January 9. o Preparations for and participation in meeting of PVC Steering Committee on January 10. o Developed detailed budget and program outline for communications activities for PVC Safety Group thru end of May 1978. 6. Intelligence and Document Development and updating $ 1,553.00 o Discussed a series of updated papers to be written on PVC and occupational health. Began researching background materials on papers. o Researched and began drafting new version of the paper "Vinyl Chloride and Birth Defects 7. Media Contact and Response, including Positive Publicity $ 1,893.00 o Story on system to reduce theft of books from libraries, composed of sensing element and special check-out gate made of rigid PVC was carried by Associated Press (All 1,500 newspapers, periodicalanc( broadcast outlets). o Story on how the housewife can stretch her household budget by using certain kinds of items made out of PVC was placed with Lady's Circle (Circulation - 750,000). BOR 012125 Robert B. Downey February 28, 1978 3 o Story on how the homeowner can save money and energy by heeding the advice of government energy engineers working to combat energy waste in the home featuring uses of PVC to effect these savings was placed with the Los Angeles Times Syndicate (100 newspapers - readership, 3,000,000). o Continued contact with the following magazines/news services on stories which have been placed with them in the past few months: Associated Press Features 1001 Decorating Ideas Mechanix Illustrated Women's News Service Lady's Circle Enterprise Science News (NEA) o Awaiting approval on service piece for consumer magazine or syndicated column entitled "Six Ways to Prevent Fires in the Home" focusing on the use of smoke and heat detectors to signal an alarm before smoke overcomes the occupants of the house. o Continued work on consumer story pitched for garden columns about the growing use of plastics in gardening, focusing on PVC for use in automatic water sprinkling system for the garden; also use of PVC for lining ornamental pools in the garden. o Continued working on stories previously listed on activities reports for which additional data is being researched. 8. Out-of-Pocket Expenses Telephone and telegraph Miscellaneous publications Multilithing and photostats Postage charges Travel and expenses $ 78.86 7.75 128.80 194.81 105.22 9. Editorial Briefings o Prepared draft of "VCM-PVC Summary" for the press, Vol. Ill, No. 1. $ 515.44 $ 261.00 BOR 012126 Robert B. Downey February 28, 1978 4 10. New Jersey Carcinogens Bill ------ o No activities in this category during the month. 11. PVC Conduit/FDA ------ o No activities in this category during the month. 12. Fire Safety Program Development $ 1,213.00 o Preparations for and participation in meeting of PVC Fire Safety Subcommittee in Cleveland on January 5. o Prepared memo on PR problem for fire safety and submitted to you. 13. Out-of-Pocket Expenses (for 11 and 12) $ 196.85 Travel and expenses $196.85 TOTAL $11,150.29 If you have any questions on the breakdown or activities, please give me a call. Cordially, MMS:j mv Matthew M. Swetonic cc: PVC Steering Committee PVC Communications Committee Messrs. Harding, Collins, Lawrence, McGrath, Nuspliger, Titus, Haley, Heckman, Burleson, Hadley, Durbin, Kiss, Hearle, Bochat, McLoughlin, White BOR 012127 minut s Thursday, March 9, 1978 9:30 A.M.__________________ PVC SAFETY GROUP COMMUNICATIONS COMMITTEE The International Club Washington, D.C. ATTENDEES: Robert C. Downey - CHAIRMAN - B. F. Goodrich Chemical Co., 6100 Oak Tree Blvd. Cleveland, Ohio 44131 Ed Ackerman - Diamond Shamrock Corp., 1100 Superior Avenue, Cleveland, Ohio 44114 M. C. Carpenter - Dow Chemical, 2020 Dow Center, Midland, Michigan 48640 Joe Hadley - Keller & Heckman, 1150 17th Street, N.W. Washington, D.C. 20-36 Gary Baise - Beveridge. Fairbanks & Diamond, One Farragut Square South, Wash. D.C. Jerry Blizin - Hill & Knowlton, Inc., One McPherson Square, Vermont at K. St. N.W. Washington, D. C.20005 Matt Swetonic - Hill & Knowlton, Inc., 633 Third Avenue, New York, N.Y. 10017 John R. Lawrence - SPI - 355 Lexington Avenue, New York, NY 10017 Ed Collins - SPI - 355 Lexington Avenue, New York, N.Y. 10017 it it it it 1 - Chairman Downey opened the meeting by calling on Mr. Baise to review the background of the assignment AIHC has tentatively given to SPI/PVC Safety Group to represent them at the March 23 EPA meeting on its cancer policy and the EDF petition on a suggested new carcinogen policy. Mr. Baise reported on the actions leading to the preparation of a draft statement to represent the PVC Safety Group, SPI and/or AIHC. This statement was presented to the AIHC Scientific Committee on March 7 and will be presented to the AIHC Steering Committee on March 15. The final version will be available for review at various stages before the March 23 meeting. 2 - Public Relations Consideration After considering various alternatives, the committee agreed that the following elements should be developed for PR support to the industry's participation at the March 23 hearing. (a) Press Conference (b) Radio Actuality (c) Press Release (d) Coverage Washington Media . TV . Papers National Media . All normal channels THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 355 Lexington Avenue New York NY 10017 f?l 21573-9400 BOR 012X28 2- - General strategy would be to set up a defensive position to avoid being pre-empted by environmental groups. Presenters Two tier AXHC Steering Committee member SPX - PVC Representative - ^Fleming, *Walker Press Conference - March 22 (11:00 A.M.) Brian McMann ) Experts Richard Wilson ) (No press conference if experts are not available) (Briefing of experts on March 20, 21 or before) *Clearance by John Lawrence as soon as possible 3 - Background Documents Mr. Swetonlc will update various PVC/VC background papers for hand-out if necessary. 4 - Mr. Downey will prepare a recommendation for presentation of the PR Progr to the AIHC Committee on March 15. 3/10/78 Respectfully submitted, SW'4'-- fat '-s John R. Lawrence Technical Director BQR 012129 agenda PVC SAFETY GROUP Friday, March 31, 1978 10:00 A.M. Crystal City Marriott Hotel Arlington, VIRGINIA 1. EPA Activities . Report on Cancer Policy Review . Report on Hearing of March 23 II. Committee Activities . Health Committee . Communications Committee . PVC Fire Safety Committee . Manufacturing Technology Committee III. Nominating Committee Report IV. Financial Report V. Other Business VI. Date and location of next Meeting VII. Adj ournment BOR 012130 The Society of the Plastics Industry, Inc. 355 Lexington Avenue Ne.vYork Ne --vcrx ICO' (212)573-9400 ON THE REGULATORY FRONT Vol, II, No. 7 EPA: SPI Submits Comments on Proposed Revisions to VC Standard On September 27, SPI submitted additional written documents to the Environ mental Protection Agency (EPA) on the proposed revisions in the VC air emissions standard ... commenting on the health-related issues raised by the proposed amendments, the SPI stated ... "we know of no information, old or nev, that would justify lowering the existing standard ... the existing standard provides at the very least an ample margin of safety to protect the public health." ) I The SPI document pointed out that in a recent study of 7717 workers exposed to vinyl chloride in the manufacture of PVC in Great Britain, four cases of liver cancer were found, only two of which were angiosarcoma and these cases "were associated with exposure to very high concentrations of VC" ... as to whether vinyl chloride exposure causes cancers other than those of the liver, the study found "no evidence to support this suggestion." In an analysis of the EPA's "Risk Assessment Document,"the SPI filing pointed out that a modeling study by Dames and Moore which it submitted to the agency on August 9, confirmed EPA's estimate that "implementation of the existing standard would result in roughly a 95 percent reduction in ambient vinyl chloride concentrations" ... that study indicated the mean vinyl chloride concentrations within five miles of EPA's typical vinyl chloride plant in compliance with the existing standard would be "on the order of 0.15-0.25 ppb." and that the proposed amendments would further reduce ambient concentrations bv less than 0.1 ppb ... the average ambient exposure before installation of controls was about 17 ppb, according to EPA estimates. Stating that the calculated risk of getting cancer from the emissions is ex tremely small, the SPI paper reported that Professor Richard Wilson of Harvard, in a document already submitted to the EPA, said the risk of living within five miles of the polyvinyl plant for one year is "equivalent to the risk of contracting cancer from v eating one-half tablespoon of peanut butter, or the risk of contracting cancer from increased cosmic radiation during a three-day visit to Denver, Colorado, or the hazardsfrom smoking 1/15 of a cigarette." BOR 012131 SPI Meets With EPA on VC Standard On September 29, SPI again met with officials of EPA to determine if the agency would consider withdrawing the proposed "zero emission" goal and the proposed offset requirements ..- EPA indicated no willingness to drop the "zero emission" goal .. SPI now is seeking a personal meeting with EPA Administrator Douglas M. Costle. SPI Renews Request For "Hybrid" Hearing on VC Standard On August 19, SPI renewed its request to the EPA to provide "hybrid" public hearings which would provide more opportunities for the industry to present its case with greater accuracy ... EPA replied on September 13 that the request was being evaluated and a reply would be forthcoming. MCA Challenges EPA on VC "Zero Emission" Approach On September 23, The Manufacturing Chemists Association (MCA) challenged the EPA's "zero risk/zero emission" approach to regulation of vinyl chloride emissions as being "contrary to nature's laws of conservation of mass and energy" ... in a letter to EPA Administrator Costle, MCA President William J. Driver said EPA's reasoning that the only "adequate margin of safety" for vinyl chloride is zero emission was spurious ... better approach would be close cooperative monitoring and continued exchange of scientific engineering and economic data ... in meanwhile MCA recommends that proposal be withdrawn. SPI Receives Documents Under Freedom of Information Act On August 30, SPI received from the EPA a number of documents that had been submitted to or produced by the Agency in the period when the revised vinyl chloride standards were being considered ... documents requested by SPI were obtained under provisions of the Freedom of Information Act ... the papers are now being analyzed for possible use by the SPI in opposing the proposed revisions in the VC air emission standard. EPA Names Tcxic Substances Advisory Committee On September 28, EPA announced the appointment of 16 members to the Agency's newly-created Toxic Substances Advisory Committee ... three industry representatives are from Du Pont, Eastman Kodak and Hardwicke Chemical Company ... others are from conservation and environmental groups, medical schools and institutes, local government agencies, the League of Women Voters and the AFL-CIO. FDA: BOR 012132 FDA Issues Final Order Banning AN Beverage Containers On September 19, the Food and Drug Administration (FDA) issued a final order banning the use of acrylonitrile (AN) in the fabrication of beverage bottles ... ban takes effect 90 days after its September 23 publication in the Feceral Register ... -3- order signed by FDA Commissioner Donald Kennedy said that contention that packaging material was not a "food additive" is inconsistent with the statute's language and the Congressional purpose in enacting the food additive provisions ... also that the statutory language "does not require the amount of the migrating substance be analytical] detectable or quantifiable or exceed some minimum threshold level before the substance can be considered a component of food". Hardline AN Ruling by FDA Mav Presage PVC Action Hardline action by FDA Commissioner Donald Kennedy in banning the use of acrylonitrile (AN) beverage bottles on the "migration issue" may lead to rapid action on FDA's PVC proposal, the Sep amber 26, Food Chemical News reports. OSHA: SPI Calls OSHA Proposal on Carcinogens a "Quick Fix" On October 3, SPI President Ralph L. Harding, responding to a 278-page proposal announced by the Occupational Safety and Health Administration earlier that same day, said that SPI "is in fundamental disagreement with OSHA's apparent intent to rush unequivocal enforcement judgments on the basis of limited scientific knowledge of car cinogens" ... the OSHA plan for controlling worker exposure to toxic materials would set up a procedure for identifying, classifying and regulating various types of car cinogenic substances posing hazards to workers ... SPI said "we feel OSHA ... is placing undue reliance on limited animal tests to demonstrate carcinogens ... also OSHA assumes there is no safe threshold for potential carcinogens -- a premise with which we totally disagree." OSHA Safety and Health Committee Members Named On September 23, OSHA announced the appointment of five new members to the National Advisory Committee on Occupational Safety and Health (NACOSH) ... among the new members were Andrea Hricko, formerly with the Health Research Group and now with the University of California in Berkeley, and Marcus M, Key, formerly director of NIQSH and now with the University of Texas ... also named were Dr. Ernest M. Dixon of Celanese Corporation. Professor Don B. Chaffin of the University of Michigan and Claudia Miller, a private consultant ... the other industry member of the Committee is Dr. Paul Kotin of Johns-Manville Corporation. ON THE LEGISLATIVE FRONT In the States In New Jersey, the Cancer Control Bill (S.3035), which would have banned 14 known chemical carcinogens, plus asbestos and vinyl chloride, was amended to delete the ban provision. BOR 012133 i4 3 ON THE TECHNICAL FRONT Employees of PVC Fabricators Studied for Angiosarcoma A cross-section mortality study of 4,341 deaths among current and former employees of 17 PVC fabricators during 1964-73, revealed "no angiosarcoma deaths were found among the study group," it was reported in the September 1977 Journal of Occu pational Medicine ... in a proportionate mortality analysis -- the ratio of "observed" to "expected" deaths for the total U.S. specific for color, sex, cause and age -- the study found that excesses in cancer mortality appear concentrated in "cancers of the digestive system and, in particular, in cancers of the intestine for both men and women." ' The article's authors warn that while the current study suggests an excess in D total cancer ... it does not point to marked excesses for cancers of the liver, lung, and brain among white men, although the PMR's (proportionate mortality ratios) for these cancers are greater than one ... such results, the authors say, must be interpreted with caution, but since they appear to be consistent with previously studied workers, they suggest the need for continued investigation. EPF Submits PVC Study to EPA On October 4, the Environmental Defense Fund (EPF) submitted a copy of the PVC Mortality Study to the EPA with a covering letter containing EDF's interpretation of the findings ... the study was being submitted, the EDF said, because it "contains potentially significant new information on the health effects of vinyl chloride" and the EDF requests that "it be included as a part of the Agency's public record on the proposed amendments to the vinyl chloride standard." ON THE MEDIA FRONT Ten Groups of Chemicals Face EPA Tests The Interagency Testing Committee, an eight-agency task force set up under the Toxic Substances Control Act (TSCA), has recommended immediate testing of 10 widely used groups of chemicals "because they pose a potential threat to human or environmental safety" the October 6 Washington Post reports ... among the chemicals and chemical groups on the list are toluene and xylenes ... selected groups are to be listed for possible cancer-causing properties, mutagenic effects and the potential of possible embryonic malformations in women exposed to them .. the task force is working its way through a list of 330 chemical substances singled out for study in July. If Money Causes Cancer ... Ban It? Two medical doctors from Denver General Hospital concerned about the "inane pronouncements" by the FDA on cancer dangers, report on an unusual experiment they con ducted in a letter to the editor in the August 1, Journal of the American Medical Asso ciation (JAMA) ... ten months after inserting sterilized dimes into the peritoneal cavity of 35 rats the first cancer was noted ... by 1^ months nine rats had cancer and nine had distinct abdominal masses ... based on their findings, the doctors estimated that "malignant neoplasms will develop in more than 50 percent of the rats." BOR 012134 I -5- % In view of their findings, the doctors said "the FDA and Consumer Products Safety Commission (CPSC) "should convene an emergency meeting for the purpose of removing all coins from circulation" *.. since there is an excellent probability that folded paoer money, government paychecks, bills and credit cards will produce cancer, the doctors said, "they should be banned immediately" ... stating that a proper grant request for cancer research was being prepared, the doctors concluded, "We hope that no political demerits will be associated with our use of the Roosevelt dime." ### October 1977 BOR 012135