Document OEkxnbdy62gQmqoYX6L02nwVp

MANUFACTURING CHEMISTS ASSOCIATION 1825 CONNECTICUT AVENUE, N.W. WASHINGTON, D C. 20009 (202) 483-6126 July 15, 1975 RfcCt!4fc2 JUL 17 1975 R. N. WHEELEK, JR. TO: Technical Panel on vinyl Chloride Research Gentlemen: Enclosed are Mr, A. C. Clark's letter and Dr. J. T. Edsall's reply as they appeared in the July 18, 1975 issue of "Science," Volume 189, No, 4198, pages 174-5. Sincerely, MF/etv Enclosure Mxlton Freifeld Project Manager Vinyl Chloride Research UCC 001209  ETTEBS Agency for Rcm .>iCh on Cancer (of which the United Stale. i\ a member). I his panel Vinyl Chloride and DDT: also considered M.dioni's data to he pre Environmental Effects liminary at that lone and "decided lo post pone compilation of the delinilive review The report of the AAAS Committee on lo llie next iitcctuii; ol llic committee" (7). Scientific Freedom anti Responsibility, ab After a period >n which epidemiological breviated as an article by John T. Edsall and animal studies were being established, (16 May, p. 687), requires comment. The MCA, on 17 Apnl 1973, asked the Euro section entitled "The ease ofdata suppres peans-to jointly make presentations to sion concerning the carcinogenicity of vi U.S. and. European government author nyl chloride" (p. 690) contains omissions ities. The Europeans readily agreed, and and errors that are inconsistent with the on 15 June 1973, MCA called the National committee's concern for scientific freedom Institute for Occupational Safety and and responsibility. Since so much pertinent Health (NIOSH) and requested an oppor information has been omitted concerning tunity to bring new information to that this matter, readers may be misled into agency's attention. The appointment was believing the report. set by NIOSH for 17 July. Five European Edsall states that, until May 1970, and American industry representatives "there had apparently been no research in presented to NIOSH the information that the plastics industry concerning the pos tumors had been found in animals exposed sible hazards of vinyl chloride___ '' This is to vinyl chloride concentrations below untrue. In fact, the basic published data on those that Viola had reported caused can vinyl chloride toxicity came from Ameri cer in rats. At that time, no human cancer can industry (/, 2). The information in (2) cases had been reported; therefore, no spe had been publicly disclosed and presented cial significance could be attached to the before their publication dates. Further types of tumors observed by Maltoni. more, the investigations of Viola and of The precautionary label suggested by Maltoni have been supported by European MCA and referred lo by Edsall was illus industries. trated in MCA's Chemical Safety Data Edsall correctly states that Manufac Sheet (SD56) on vinyl chloride, revised in turing Chemists Association (MCA) mem April 1972. Section 10.1 on "Health haz ber companies entered into an agreement ards" refers to Viola's published studies. with the European sponsors of Maltoni's The Data Sheet states, "Recent research work not to reveal preliminary Italian studies reported from Italy indicate that data. The agreement was not dissimilar to repeated, long-term high level exposures of those commonly made between American rats to vinyl chloride monomer vapor can sponsors (government, industry, and aca result in the development of malignant tu demic) and research institutions that new mors. However, many years of industrial data remain the property of the institution experience with human exposures to con and that final results be disclosed through centrations frequently far above current proper scientific channels when a study is standards have not demonstrated any car completed and evaluated. There was no in cinogenicity to humans." Thus the state tention of withholding adverse data. Under ment by Edsall that MCA "... appears to MCA rules, all data developed under its have deliberately deceived NIOSH regard auspices must be promptly reported pub ing the true facts" is inaccurate and mis licly. Without exception, this has been leading. done with all data on vinyl chloride. Albert C. Clark U.S. government scientists knew of Manufacturing Chemists Association, Maltoni's preliminary results early in 1973 1825 Connecticut Avenue, NW, but considered them to be as preliminary Washington. D.C. 20009 as did U.S. industry. At the Second Inter national Symposium on Cancer Detection titmrni and Prevention in Bologna, Italy, 9 to 12 April 1973, Maltoni showed a table of pre liminary results linking vinyl chloride with cancer formation (which was not published until 1974) (3), Umberto Saffiotti. asso ciate director of carcinogenesis at the Na tional Cancer Institute, was present at the meeting and Subsequently discussed the re sults with Maltoni at his Italian laboratory (4). Salfiotti felt that the work should be included in "a well documented report" to be assessed by a review panel of the World Health Organization's International 174 I. T. R. Tvrkctwn. F. Oye, V. K. Rowe. Am ind lift. Auoe. J. 11154(1961); R. H. Wilioa, W. E. McCormick, C. F. Tjuim, J. L. Cretch. J, Ant Med Auot. 261, 577 (1967); E- D. Bantu. R. D. Stewart. 1. E. Mutdtlar. Am. Ind. //. Allot. J, 36,537(1769). 2. B. 0. DintnaA. W A. Cook. W. M. WkiichouM. H. i. Magjtuaoo, T Oitchock. Arck Environ. Htahb 2161 (1971); W. A. Cook. P. M. Gioer. B. D. Oinman, H. j. Maimnoii. ibid., p 74; V. N. Dot), son. B. D. Dinmait, W. M. Whuchouic, A. N. M. Naif. H. J. Magnuson, ibid., p. SI; C. G. Knitter, and J. E. Mutchlr, Am. Ind. Hyp. Auot. J. 33. 19 (1972). 3. C. Maltoni. Exctrpio Med. Ini. Congr. Sir. No. 271 (1974). p. 4. 4. G Saffiotu, in US. Senate. Committee on Comniercc. Subcommittee on Environment, Vinyi Chloride (93rd Concrete. 2nd teuton, 1974), pp. 54-56. John T. Edsall errs in crediting DDT with halting a cholera epidemic in Naples during World War U. A National Acad emy of Sciences committee staled in 1970 (/) that "DDT has prevented 500 million deaths due to malaria that would otherwise have been inevitable." However, the Naples miracle involved typhus rather than cholera or malaria. It is unfortunate that Edsall selected an undergraduate student's term paper (2) as "a useful short history of the use of DDT," for several well-informed scientists have written articles and books on DDT which would be more appropriate sources lor AAAS articles. He also refers to 'The long persistence of DDT in soil," perhaps being unaware that Stringer et al. (3) found the half-life of DDT to be only 3 years in orchard soil after 17 successive years of heavy spraying. Edsall cites DDT's "pro gressive concentration in food chains" as having "led to the killing of great numbers of certain birds and fish"; however, the lack of food chain magnification, espe cially in marine environments, has been pointed out by Moriarty (4), Hamelink et ai. (5). Harvey (6), and in two committee draft reports of the National Academy of Sciences (7). While Edsall did not recommend halting DDT use for malaria control, some "envi ronmentalists" are again seeking to halt all DDT exports from the United States. It is encouraging to see no such proposals in the AAAS committee report. J. Cordon Edwards Department ofBiological Sciences, San Jose State University. SanJosi, California 95192 RcftNMW l. Commute* on Socaot ami Public Policy. The Lift Sciences (National Academy of Science*. Wigjtmgion, D.C., 1970V p. 431 1 G. Mclntira, Envitonmtni (St- Louis) 14 (No. 6). 14(19721 3. A. Stringer. I. A. Picktid* C H. Lyons, Festk- Set 5.5*7 (1974). 4. V, Moriarty. N*wSd. S3.394 (1972). 5. J. L. Hamdink. R. C, Waybrant. R, C. Ball tw. Am. FiskSoe. 109,207(1971). 6. G. R. Harvey. Oceanus 11,19 (1974). 7. J. W. Kanwisher. "DDT m the marine environ* (ir (chairman's draft of an ad hoc committee report. National Academy of Sciences, Washing* ion, DC.. 1971); G. R. Harvey, "DDT in the marine environment** A review of present under* 11401)109" (draft of an ad hoc committee report. National Academy of Science*, Washington, D.C, 1973). 1 am glad to note that, as Clark's letter points out, there was research by Ameri can industry on the toxicity of vinyl chlo ride, beginning several years before 1970. In this work, however, what have proved to be the major hazards were not discovered; if they had been, the later story would have been very different. I am obliged also for Clark's correction regarding the pre cautionary label, which did in fact make reference to malignant tumors in rats pro- SCIENCE, VOL. 189 ucc 001210 duced h> "repeated long-term high level exposures." 1 be a III Hide expressed in Clark's letter. however, illustrates die ma jor point that caused concent to die C'utii[imiee on Scienlilie Trccdont and Kcsponsihility. The extremely ominous findings in the animal studies did not trigger any ma jor alarm until cases of cancer in factory workers exposed to vinyl chloride began to be reported. This has been in the past the general attitude regarding such problems; I believe that it is now out of date. New re agents introduced into industry on a large scale should be regarded as dangerous un til proved safe. Precautions to protect workers from inhaling or absorbing them should be built in from the very start, rath er than being superimposed later, after damage has become apparent. Carcino genic substances usually take years to pro duce cancers; we should not wait for the cancers to appear in human subjects before taking action. Fortunately the. work of Ames et at. (/) and others has shown that carcinogens are generally mutagens. Screening of chemicals for mutageni city can be carried out fairly rapidly. With the techniques available today we can thus often obtain an early warning of danger, but negative results on mutagenicity tests should not be cause for complacency. Highly toxic substances miy be nonmutagenic. 1 thank Edwards and others for correct ing the erroneous statement that DOT brought a halt to a cholera epidemic. It was of course a typhus epidemic that was halted by DDT. How this error slipped through I do not know; the error is in any case mine, not that of the committee. This point wilt be corrected in all reprints. One can add to the references cited by Edwards a recent review on insecticides by Jukes (2) which contains a vigorous de fense of the value and safety of DDT. Some of the environmental damage that has been charged to DDT was probably unreal or greatly exaggerated; some was probably due to other substances, such as the polychlorinated biphenyls (PCB's), which most analysts long failed to distin guish from DDT and its breakdown pro ducts. Nevertheless the official decision to ban DDT for nearly all uses in iht United States was not arbitrary or capricious; it was taken after prolonged hearings, with presentation of a profusion of evidence by both sides. The ease for using DDT in countries where malaria is a serious prob lem is far stronger. To my knowledge there is no adequate substitute for the spraying of interior walls of houses with DDT solu tions as an essential element in a malaria cuntrol program. I would oppose any poli cy of denying such countries the ability to purchase and use DDT for these purposes. IS JULY 1975 I lie need ol tile luiioc, however, is to de velop less persistent oul more speedic pes ticides ih.it eon lie directed against n nar row range of targ> i species, while doing hide ur no damage to others. John T. Udsai.i. Uiologteal Laboratories, Harvard University. Cambridge. Massachusetts 02US Rtfemcts 1. B, Am*!, F. D. Lee. W fc. Dursion. Proe. Nail. So US A 70, 7X2(1973). 2. T. J ukci, Naturwureruchaften SI, 0 (1974). r V V' Copied by MCA for Milton Freifeld 7/15/75 ucc 001211