Document XzLXzJkB5mLQQvmONprb73ZyR

I ... *H < ,rd Oroani2aiion Resources Counselors. Inc. 16C0 L Street. N. W. Suite 21? VVeshm.-ton, D. C (202) B72-W30 Cable Address: ORESCON September 26, 1974 OCT i 4 13% Honorable John H. Stender Assistant Secretory of Labor Occupational Safety & Health Administration U. S. Department of Leber Washington, D. C. 20210 Dear John: You may recall that on April 24 we wrote you concerning a mortrlity study seeking to determine the effect of exposure to low levels of vinyl chloride monomer. Being conducted under OJC management, the study is based on the examination anti analy sis of death certificates for employees who worked in the fabri cation of products that contain polyvinyl chloride resins, and who died in the years 1964-1973 inclusive. These employees have unquestionably been exposed to varying concentrations of polyvinyl cnlcride, estimated to be in the range of 10-15ppn or. less. In conducting the study, we contacted fabricators known to us, solicited the assistance of trade associations, and obtained the cooperation of resin producers to identify major customers. As a result we have been in contact with 35 companies, of whom 10 declined to participate because they had been fabricating polyvinyl chloride products substantially less than the time required for inclusion in the mortality study. There was evi dence of active interest and desire to participate on the peri of every company we contacted. The search for the facts seems fc generate a common desire to help. We have studied death certificates supplied by eight companies with 34 plants in 14 states (the combined total employment of these plants being approximately 16,000 as of December 31, 1973). OLI 390 Honorable John H. Stender September 26, 1974 Page 2 In order to verify that we had all of the death certificates, where possible, v/e have requested confirmation of the list on the part of the life insurance companies involved. Additional companies are now making their data also available to us. Upon receipt of death certificates, they are studied by a nosologist who classifies them in the broad categories of cancer, liver disease, or neither. Those in the cancer and liver disease category are then assigned to a field investigator who is a Registered Medical Records Administrator for further investiga tion. The field investigator checks the cause of death on the death certificate against the pathology records in the hospital (after overcoming the reluctance of many hospitals to make re cords available). If final illness was not in the hospital, the treating physician is contacted. At this point, field investiga tors have visited ten hospitals and one state tumor registry. About 350 abstracts have been completed with respect to such deaths. Our experience to this date leads us to conclude that the records maintained by insurance companies were never designed to support epidemiology studies (v:e have in fact formed a new task force designed to develop a uniform, system of maintaining health re cords in the hope that in the future epidemiology studies may be facilitated). Under present circumstances, gathering data is a slow, tedious, and laborious process. It is impossible to collect meaningful data and to provide meaningful analysis during the brief sixmonth statutory period of an emergency standard. The time span between the discovery of vinyl chloride problems in January and the time when the temporary emergency standard must be pro mulgated is so short that even accelerated research cannot be completed. However, our study will continue and progress will be reported to you periodically, even though it is impossible to make a definitive report in time for consideration with respect to the permanent standard. At this stage we can only say that, of the limited number of death certificates processed, no case of angiosarcoma has been found, in fact only two pathologists contacted by us have ever seen a case of angiosarcoma. OLI 391 vr Honorable John H. Stender September 26, 1974 I Page 3 Aside from the matter of angiosarcoma, the incidence of cancer and liver disease do not appear to be disproportionate to what might be expected. However, at this stage the data is so limited that these results must be considered as highly tentative. We are now making determined efforts to complete as much of the study as possible by the end of 1974. As new information becomes available, it will be shared with you. While we can understand the reason why the lav; provided a limited duration for an emergency temporary standard during the past three years, this experience makes it clear that so short a period imposes an almost impossible burden on OSH as well as those who are helping it to determine the facts. Certainly there is very little time in which to do essential research. Sincerely yours. Leo Teplov Special Consultant OLI 392