Document RJdYavdMwZGmXwLO4QK5G06yV
Memorandum
PRO
To: T. J. Marriott* Jr.
Dept.:
Corporate Safety
From: A. J. Olgllo
Dept./Ext.: Corporate Environmental
Date:
7 December 1987
Subject: Chemical Industry Institute of Technology (CUT)
Tom
CUT was established as an Independent* non-profit toxicology research Institute. CUT Is respected by the Government and environmentalists and "keeps there honest" on matters of toxicology. For some time. Lloyd Tapper serves as a Board member of CIIT. Bob Sander and I concur with Lloyd's memo that CIIT provides a valuable cost-effective service for Air Products and the chemical Industry. However* Bob thinks we could get more value from CIIT and other outside associations by dedicating more personnel time.
Air Products operates with a lean staff In all areas and particularly in environmental* health and safety. CIIT works on generic Issues of major importance to the Industry such as Improving extrapolations from rodents to man, chemical-induced Imunotoxlclty and risk assessment models. We are dependent on outside services In these matters. Air Products has one toxicologist and no toxicology lab.
The Board of CUT establishes a direction In which Its generic research Is oriented. We are represented on the Board by Lloyd Tapper* but ha sarvas mora as an Industry representative. Because of the nature of CIIT* it would only marginally help Air Products to add more dedicated time unless we wish to specifically fund a project that Is solely beneficial to Air Products.
Concerning our increased participation In other associations, it is a matter of balancing priorities and value. Those Individuals who have functional Involvement In our ongoing business best serve our Interest and that of the trade associations.
I concur with Bob Sander that In order to provide more Air Products' * participation In outside associations would require an Increase In our personnel. In some associations, more dedicated Air Products1 time would be marginally beneficial. In those outside situations where more participation would Increase value to Air Products, the additional person planned for Corporate Environmental could help on a selected basis. There are times when Air Products does not directly benefit. For the most part, we have benefited more than we have contributed.
Please let me know If you wish anyth
A. J. Dlgllo
AJDspbr
S!?!chment: Your note of 23 November 1987 and other attachments
AP00036900
Tom Marriott Corporate Safety and Environmental (215)481-6197
PRODU&&&;
23 November 1987
TO: A. 0. Dlgllo Corporate Environmental
Attached Is some correspondence on CUT. This was passed on to me by P. L. T. Brian. P. L. T. Brian asked me to give him feedback on our continued Involvement with CIIT. To do so, I need your Input. Please look over the attached Information and then let's discuss by 4 December 1987. Thanks.
TJM/ses Attachment
T. 0. Harriott, *fr"
AP00036901
Frank J. ftysft
Chsmicals Administration (215)481-6669
PRODUCT^ tz:
19 October 1987 TO i P. L. T. Brian
Thibaut,
Are wa doing what Bob auggeats? I know wa did in tha past before a number of people retired.
Frank
RECtuVED . OCT 19 1987
P.L.T. BRIAN
AP00036902
Memorandum
To: From: Date: Subject:
P. J. Ryan * C. Sander 14 October 1987 CIIT/DNT, etc.
PRODUC7&
Dept.: Dept./Ext.:
Chemicals Administration Manufacturing Admin / 8510
rtAi^Al V*SJ 1 1IOCC07/
' X RYAN
Frank, this is in response to your question about CUT* This group can and does provide valuable information for us -- particularly in the nitrations area. I receive the periodic summaries of information and research results. Z find them interesting and informative. However, like a lot of data and information that crosses one's desk/ you tend to react to that which has a current impact.
I would support continued involvement in this group if we are prepared to commit the APCI personnel to make use of the information and have a continuous involvement in the programs, etc. that the CUT develops and executes, wie do nnt mat* fho involvement in these outside groups an integral part of any ona pggsbh's position. Ratner, it tends to be an informal add-on that Is pursued with varying degrees of intensity. As a result, we do not always consistently get full value from the money that we spend in these areas. If we want to really get value from these efforts, we should make them a part dt " 1 someone's position requirements, recognize the tmeand expense that involvement entails and, most importantly, matte it part of the position performance and recognition requirements.
AP00036903
Memorandum
To: DEXTER BAKER
RttCElViiO
OCT 7 13fl7
F. X RYAN
D"':
BttUTIVE
PRODuM&
From: BRIAN RU5HT0N
Dept./Ext.; VICE PRESIDENT - RAD / A400
0t: 2 OCTOBER 19117
Subject: REPORT OF MEETING AT C.I.I.T. - 1 OCTOBER 1987
cc; Lloyd Tepper b
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Attached please find a list of attendees at the above-mentioned meeting.
I believe the meeting was satisfactory in as much as It helped to convnunlcate O't
to most of those present the general worth of C.I.I.T. Some of the more ./we./-*/ Important points to emerge from the meeting are as follows:
e C.I.I.T. Is generating basic science that Is helping to form the basis
for possibly toxic tort law reform.
^
7 {;
e There Is evidence that chemical corporations can be helped In the : * '
avoidance of law suits (see attached paper by Dr. Jack H. Dean).
ZW
e Bob Kennedy of Union Carbide stated that, on listening to the various
messages of the day, he was persuaded that putting money Into C.I.I.T, / *
might have a more significant payback than capital programs of some universities.
e C.I.I.T. should put Its message on film and aggressively promote Itself lobbying with the CMA would be the best recruitment vehicle for this.
The member companies and non-member companies would do well to put more "sweat equity" Into C.I.I.T. In order to promote It, gain more out of It, and help formulate the future direction. The size of an Individual company donation does not determine It's Impact In this respect.
Some of the value that member companies can derive are as follows:
- consultation with C.I.I.T. toxicity experts, - effective execution of social responsibility,
- possible avoidance of expensive legislation brought by Irrational Individuals or groups via use of data generation,
- an understanding of the relationship between animal and human
toxicology via mechanistic studies of major chemical moieties, an easier time In defending themselves against critical toxic Issues or broadly dealing with these problems because of the precedents now created by the excellent C.I.I.T. work on teraphthallc acid,
formaldehyde, dichlorobenzene, gasoline, dlnltrotoluene, etc.
AP00036904
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2 OCTOBER 1987
supportive of C.I.I.T. However, most mount a renewed effort to get non-member sign up as dues-paying members. I to CMA members at large and try to tat Dr. Lloyd Tapper had written roducts* positive experience by the attendees. It s of membership.
s
/
AP00036905
Keeping Up With CUT Summer, 1987
A periodic report on toxicological laauaa of Importance lo tha Chemical Induatry InatHuta of Toxicology. Per more Information
about CUT and Ita roaaarch program*, contact Wlllanna Orfffln, CIIT Information Service*, P.O. Box 12137, Raaaarch Trfanoia
Parte, N.C. 27709 (919/541-2070).
y
Immune System Damage and the Courts
7
Jack H. Dean, Ph.D. Department of Cellular and Molecular Toxicology
A recant rash of litiQatlon against chemical
interaction, transmembrane
companies has charged damage to the immune system jnalling. gene expression, and production of activation
following environmental exposure to chemicals. In the products (9.g,, cytokines) In lymphoid cells are available.
past two years, several companies have either lost or These powerful new probes from molecular and cell
settled cases out-of-court in which the totaljudgment biology can now be used to examine and understand
approached 40 million dollars. These cases (Elam ef a/, toxic phenomena. Toxicologists should embrace this
n. Av. Alcolae Inc.; Sterling ef a/, v. Velslcol Chemical new methodology to characterize and understand
Corp.; Andersot etal. v. W. Grace Co.) have mechanisms of injury to ceil or organ systems.
alleged that the immune system was a target of the
CUT la tacklino tha dilummn nf Mlxctlno appropriate
purported toxicity of these chemicals (Marshall 1986a, methodology and improving flak axtrapoierinCTSm,
1986b). A new trend in toxic tort law has become rodents to humana in the tom nf r-harnlrl-inHnoH
established In which cases are developed around data immundtflklCiTv ov usino human lymphocytes exposed to
from extensive clinical evaluation of the immune system. cnemicailn tiaatui culture tor ceil actTvatTon and
Often subtle changes in lymphoid cell subpopulation oiTTerentiation models praviouak/validated in rodents, it is
distribution or functional alterations of immuns recognized that certain assumptions will have to be made
fjarameters have been alleged to represent "serious about the pharmacokinetics and disposition of the
mmune dysfunction or dysregulation.* Some expert chemicals under study. However, in vitro human
witnesses suggest these alterations In the immune lymphocyte exposure systems will provide e correlative system are of grievous consequences and may ultimately data base allowing industry to move from a defensive
result in an increased frequency of disease or tumor posture to an enlightened understanding about the
development. In most instances, the individuals with tha effects of
a on the immune system.
speculated immune abnormality have no evidence of spent: to undersdiayd mechanisms of chemical injury to
disease that might be linked to immune dysfunction, lymlocnicio cens and to develop more relevant Dioroarkers
although some report general complaints (Marshall, of irtiurv will ao m6re to prevent litigation than money
1986b). Uttte attempt has been made to link the type of spent to settle caaea oui-dr-coun wnen no real inlurv is
magnitude of chemical exposure with e particular evtoem.
immune deficit end in some cases the offending agent
r--Earlier this year, in response to these concerns, ths
was not even identified or proposed (Toxica Law Center for Environmental Health within the Centers lor
Heporter. 1966).
Disease Control, in cooperation with the Agency for Toxic
The clinical studies which form the basis for these Substances and Disease Registry, established a
claims suffer from several flaws. First, some of the Committee on Biomarkers of Organ Damage and
methods utilized have not been standardized for clinical Dysfunction to address the selection of appropriate
epidemiology studies. Second, the lack of baseline data biomarkers to detect chemical injury to the kidney, liver,
Irom the study population or data from a well-matched and immune system. The author is a member of this
control cohort precludes interpretation of often subtle committee and believes that the committee can be helpful
changes in immune function in the study population. in recommending appropriate guidelines on the use of
Third, it has not yet been determined whether the immune dinicai assays and me development of more predictive or
changes reported are biologically significant or beyond etandarized methodology where needed.
the physiological reserve and lie outside the normal rang*
for that individual or population.
References
Therefore, there is an urgent need for industry and
Sublic health authorities to begin to address the issue of
Dean, J. H.. Murray, M. J.f and Ward, E. C. (1986).
ioiogical significance, starting with the development of a Toxic responses of the immune system. In: Casarett and
panel of rational, sensitive, standardized biomarkers to Douirs Toxicology* The Basle Science of Poisons, 3rd
detect system immune alterations. The establishment of ed. C. D. Klaassen, M. O. Amdur, and J. Doull, ads-,
this group of tests in humans for immune system damage MacMillan Publishing Co., New York. 245-285.
may require the development of new methodology for
Marshall, E. (1986a). Woburn case may spark
evaluating lymphocyte activation, proliferation, and explosion of lawsuits. Science 234,418-420.
differentiation, since these endpoints are often altered in
Marshall. E. (1966b). immune system theories on
rodents exposed to immunotoxicants end are more trial. Science 234,1490-1492.
predictive indicatora than are static or basal
Science and Toxic Tort Law: Novel strategies In the
measurements (reviewed by Dean ef/., 1986). Assays Woburn litigation. Toxics Lew Reporter 1986,374-381.
AP00036906
Chemical Industry Institute of Toxicology
TNllHli'l, ftobm A.NatL, PhO.
Via
DlNir ol RmikIi. JamM t Clbaon. PhX>.
Vk* PnkdML AOrtnlatmton aitd Sammy. Donald A. Han, 4.0.
ICIIT1
P. O. Box 12137 4 Daata DrN
fUoaareli Manila Piik North CaraUna 17709
(919) 941-1070
VISIT TO CUT BY THE KENNEDY GROUP October 1, 1987
List of Attendees
Mr. C. J. Caldwell Chairman of the Executive Committee National Starch it Chemical Corporation
Dr. Ernest H. Drew President and Chief Operating Officer Hoechst Celanase Corporation
Mr. Arden B. Engebretsen Vice Chairman and Chief Financial Officer Hercules, Incorporated
Mr. Clyde R. Greenert Director of Publle Policy Union Carbide Corporation
Mr. Vincent L Gregory, Jr. Chairman and Chief Executive Officer Rohm it Haas Company
Mr. E. D. (Ned) Griffith Manager of Public Affaire ARCO Chemical Company
Mr. Robert Kennedy Chairman and Chief Executive Officer Union Carbide Corporation
Mr. Philip Krug Executive Vice President The Lubrizol Corporation
Mr. H. Eugene McBrayer
President Exxon Chemical Company
/
Mr. Bill Parker Director
Safety and Environmental Affairs Phillips Petroleum Company
Dr. J. Fred Pendleton
Environmental Officer
Borg-Wamer. Incorporated
Dr. Brian Rushton Vice President, Research and Development
Air Products it Chemicals, Incorporated
Mr. Ron Van Mynen Vice President Safety and Environmental Affairs,
Chemicals and Plastics Group Union Carbide Corporation
Mr. Irwin S. Zonls
President Essex Industrial Chemicals, Incorporated
AP00036907
Brian Rushton and I have briefly discussed the worth of CUT to APCI and the chamical industry. Our annual dues assessment is $123,857, which sum is determined by the overall
CUT budget and our net annual sales for chemicals. The budget la set by the member companies.
There is no question o the quality of work done at CXIT. The issue is whether the work meets the needs of the chemical industry. Relevant points:
1. Research is not primarily the "testing" of chemicals
but is, rather, mechanism-oriented with long-term
goals relevant to responsible company practices and
rational governmental regulations. It is no longer appropriate for epa or PDA to simply cry "carcinogen*
when CIXT can show that rodent studies may be valid
for man only under certain circumstances. -gisk_^
assessment is becoming more sophisticated, and CXIT
is leading one way.
~
--
2. At a time when the anti-industry bigots are complaining about deregulation" and lax agency surveillance, CIIT is a prime example of social responsibility in the business community. Even the Environmental Defense Fund would agree.
3. Air Products has gotten its fair share of CIIT attention* The CIXT studies of the carcinogenicity of DMT and the metabolic studies in man were done with our material and our Pasadena people. Accordingly, we are leaders in plant hygiene and work `practices. Some day we may need this record.
AP00036908
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4, in contrast to du Pont, Exxon, Dow, Monsanto, and others, APCI does not have its own toxicology laboratory and sponsors relatively little toxieologlcal research. CXIT is our vehicle for studies which, over the long haul, promote corporate responsibility and public health*
5. A decrement in commitment to CXX? would be especially disadvantageous from the socio-political point of view when we are perceived to be in a "deregulatory* period. Industry's claim to responsible behavior, self-regulation, and sensitivity to environmental concerns would be materially weakened if CXIT were to be neglected or abandoned when the governmental "heat* is off.
The budget is about right, but there are too few members. Pat McCurdy, Editor of Chemical week, puts it strongly (see attachment).
If you visit (with our without Mr, Kennedy), you will be impressed. But the importance of CXIT is not demonstrable through a tour of laboratories. We need to see beyond that from a higher helicopter.
LBT:bmw
AP00036909
Anthony J. Diflio Director Corporate Environmental Activities (215) 481-6339
2 March 1987
D. F. Baker Dex: This Is In reply to your request concerning the CMA Executive Corralttee March meeting's action Items. CM requests the Executive Committee member's approval of their proposed legislative positions on:
Nonattalnment - Clean Air Act - Acid Rain - Clean Air Act Worker Notification - Gaydos/Metzenbaum Bills The CM proposed positions are attached. Your approval Is reconmended.
AJD:pbr Attachment: CM Proposed Positions
AP00036910