Document Z4Vj3EyXNERRx5Qg3Y5MM6xNY

i/c, ^ TTtZ: BIRTH DEFECTS AND VINYL CHLORIDE Mr. Larry Edmonds Health Services Officer Birth Defects Branch Center for Disease Control I would like to address the question of vinyl chloride monomer exposure and its possible relationships to birth defects. If there is a relationship between vinyl chloride and birth defectSi it could be either a iwtagcnic effect, prior to conception^ a teratogenic effect after conception. One of the first reports that vinyl chloride may be related to birth defects in humans was presented in March, 1975, by Dr. Infante at the New York Academy of Science. The study conducted by Or. Infante, then with the Ohio Department of Health, noted increased rates from 1970 to 1973 in three Ohio communities where polyvinyl chloride plants were located. Anomalies of the central nervous system were of greatest concern and most of the excess was attri buted to the city of Painesville, Ohio. The concern was that resi dential and occupational exposure might be associated with increased rates of CHS defects. At the Center for Disease Control, data are collected through the Birth Defects Monitoring Program (BDMP). Briefly, the BDMP is a national, hospital-based system for monitoring the incidence of birth defects and other newborn conditions from hospital discharge diagnoses; it consists of approximately 1,200 hospitals monitoring a million births per year from 1970. The BDMP provided data with which we could further examine the suggested increase in CHS rates in Ohio. We Identified two cities which had a polyvinyl chloride plant, and one BDMP hospital believed to serve each conwunity. One hospital was in Pottstown, Pennsyl vania,and the other was in Painesville, Ohio. Selected malformation rates for these two hospitals -- 1970 to 1974 -- were compared with rates for their respective states. The rates seen in Pottstown, Pennsylvania, were 21.6 per 10,000, approximately what was expected from the national BDMP rates, the expected number of defects in Painesville was approximately .11. The observed number of 22 cases was twice the expected. On the basis of this increase, an investigation was undertaken in Painesville. Painesville, Ohio,is an industrial city on Lake Erie, near Cleveland, with a population of approximately 16,000. There are two polyvinyl chloride plants located in Painesville. They are across the street from each other and about two and a half miles from the center of the city. One of them has been in opera tion since 1949 and the other since 1967. . 114 The in to cases of pared to bi of Health, total of 15 The he and obtain were select birth befor The ph and permiss ~ past occupa did confirm pared to ex The hb' and for spii : times the e: I -the 14 case ) vinyl chlor not be loca work at the Among polyvinyl ci parent in e' either, plan* Statist to 10 miles was no d i fft LocaT 1 as seen in I * no assoeiatj CNS defects. A secor County, West teratogenic , viewed for c j least one BI ' In the only one ho: fiod 17 cour and at least Four of significant! UCC 006309 lorlde monomer cts. If rth defects, ption.or a be rented to , by Or, Infante td by Dr. ed Increased re polyvinyl al nervous s was attriwas that resiI with increased acted through r, the B011P is incidence of tal discharge ils mopitoring *r examine the ed two cities ispital believed iwn, Pennsyl- lals -- 1970 live states, per 10,000, iP rates. The mately 11. id. was undertaken :1ty on Lake :e1y 16,000. inesville. two and a half >een in opcra- The investigation was a hospital-based study arid was limited to case? of anenccphaly and spina bifida. The tlQMP data were com pared to birth certificate data obtained from the Ohio Department of Health. One additional case of anenccphaly was found, making a total of 15 cases. The hospital records were reviewed to confirm the diagnosis and obtain other demographic data. For each case, two controls were selected from the hospital records; the first normal, white birth before and after the case, since all the cases were white. The physician of each mother in the case group was contacted and permission obtained to interview the parents concerning their past occupational and residential histories. The investigation did confirm increased rates for anencephaly and spina bifida com pared to expected statewide rates. The hospital rates for anencephaly (14.1 per 10,000 births) , and for spina bifida (21.2 per 10,000 births) were greater than two times the expected rates, based on the UDMP state data. None of the 14 cases interviewed had ever worked at either of the two poly vinyl chloride plants in Painesville. One set of parents could not be located, but hospital records Indicated that they did not work at the plant at the time of their Infant's birth. Among the 30 control parents, two fathers had worked at a polyvinyl chloride plant at the time of their Infant's birth. No parent Ip either case or control group lived within two miles of cither plant. Statistical comparisons on distances varying from one mile to 10 miles of parental residence to the plant indicated that there was no difference between the cases and control. Local Increases in CN5 and other malformation rates, such as seen in Painesville, are not uncommon. In this particular study, no association could be found between VC and the higher rates of CNS defects. A second and simitar study was just completed in Kanawha County, West Virginia. Because of the continued concern about the teratogenic potential of vinyl chloride, 80MP data were again re viewed for all counties having a polyvinyl chloride plant and at least one BDMP hospital. In the earlier study, the selection was limited to cities with only one hospital-serving the entire coimunlty. At COC, we identi fied 17 counties In the U.S. which have a polyvinyl chloride plant and at least one BOMP hospital. Four of these 17 counties had rates for CNS defects that were significantly higher than rates for the U.S. for the time period, 115 ucc 006310 * 1970 to 1974. Two of the counties so identified had less than 50 percent of total births in the BOHP and were excluded from this study. The two remaining counties with increased rates were Lake County, Ohio, (Painesvi 11 e) the site of the previous'study -- and Kanawha County, West Virginia, where 95 percent of county births were monitored. In Kanawha County there were 59 infants born be tween 1970 and 1974 with CNS defects. The expected number, based on U.S. rates,was 37. The principal centers of population in Kanawha County include Charleston and South Charles ton,which are located along the Kanawha River which meanders through the valley's hilly terrain. The Kanawha River Valley is known for its chemical industry. There are seven major chemical plants and several smaller ones within 10 miles of Charleston. There is one polyvinyl chloride plant, lo cated in South Charleston, bordering Charleston, which began pro duction of polyvinyl chloride in 1935. Two sources of data were reviewed to identify all cases of cen tral nervous system defects occurring in Kanawha County, between January 1, 1970,and December 31, 1974. One source was a case list ing obtained from the Birth Defects Monitoring Program.which would list the cases occurring In the BDMP hospitals in the county. The second source was vital records. The West Virginia Department of Vital Statistics provided a.ll cases of CNS birth defects occur ring between January 1, 1970,and December 31, 1974. The two lists were combined and the hospital records reviewed to confirm the diagnosis and the place of residence. For each con firmed case, two controls whose parents resided in Kanawha County were selected from vital records. These controls were the first normal, live-born infants whose certificates preceded and followed a case. The cases and controls were matched according to month of birth, race, paternal education, and maternal age. With the per mission of the local physicians, all cases and one randomly chosen control were Interviewed. The parents were told that this was a birth defect study and vinyl chloride was not mentioned. The following information was obtained: history of previous pregnancies! five year residential history, prior to and including the time of birth of the affected infant; and five year occupational history of both parents, including the location of work and any possible chemical exposures. 116 If) BOHP U.S. Rate 1968 N.A. ! 1969 N.A. 1970 21.8 1971 22.1 1972 21,6 . 1973 19.9 1974 "18.4 1975 18.2 19701974 20.6 ! The Br ! The high Kc ; prompted tr ' the confin 1972 were i in 1973 am Fortyinterviewee the time oi ' in calculai i ing was act ! lion, matei i tor of soc j total numbt j- controls; I live birth j The fetal < stillbirth' Occup. trol fa the of concept worked at had possib in either ucc 006311 ad less than 50 'tded from this ^aes were Lake '"'US' study -- and ^ county births ,, (nfants born bc- ' .d number, based -a County include . -along the Kanawha rrain. The "listry. There are es within 10 ide plant, lo tiich began pro- - -** all cases of cen-ounty between ___ uj was a case listgram which would .the county, ginia Department --h defects occur- records reviewed e. For each conKanawha County ___ vere the first "'"Med and followed to month of " With the per- randomly chosen lat this was a ioned. The ;vious pregnancies; ing the time of tional history of ly possible TABLE 1 INCIDENCE OF CNS MALFORMATIONS IN KAIIAWIIA COUNTY, W. VIRGINIA AND THE UNHID STATES. 19GS-1975 (RATES PER 10,000 TOTAL BIRTHS) BDIP Hospital Data uTT Kanawha Co. Rate Case Ra to 1968 N.A. 1969 N.A, 1970 21.8 1971 22.1 1972 21.6 1973 19.9 1974 18.4 1975 18.2 N.,A. N, A. (12) 35.9 (19) 51.7 (ID 30.5 (11) 28.9 ( 6) 14.4 (10) 22.9 19701974 20.6 (59) 31.7 Vital Statistics Kanawha Co. Case Rate 03) 35.4 ( 8) 20.3 (16) 42.8 (13) 34.4 (13) 37.9 ( 5) 15.0 ( 1) 3.0 (48) 27.2 Confirmed Cases Kanawha Co Caso Rate (14) 37.5 (15) 39.7 (12) 34.9 ( 5) 15.0 ( 1) 3.0 (47) 26.7 The BDMP rates arc given in the first column of the table. The high Kanawha County rates compared to the U.S. rates are what prompted the Investigation. The last column gives the rates for the confirmed cases from 1970 to 1974. As you can see, 1970, 1971, 1972 were the highest years, with the rates starting to decline in 1973 and only one case observed in 1974. Forty-six cases and their matched controls were located and interviewed. Five cases were not residents of Kanawha County at the time of conception and were eliminated from the study, except in calculation of rates, which are based on residency. Close match ing was achieved between the cases and controls for paternal educa tion, maternal age, and the llollingshead index, whicn is an indica tor of socioeconomic status. Reproductive history revealed that the total number of pregnancies were similar between the cases and controls; 49 for the case group and 48 for the control group. The live birth percentages were also very similar between the two groups. The fetal death rates, which include spontaneous abortions and stillbirths, were 222 for cases and 232 for controls. Occupational histories revealed that two cases and two con trol fathers were employed at the vinyl chloride plant at the time of conception. Fathers of three additional controls also had worked at the vinyl chloride plant on a contract basis and may have had possible vinyl chloride monomer exposure. None of the mothers In either the case or control group had worked at the polyvinyl 117 ucc 006312 chloride plant, but few women work in the vinyl chloride industry. The residences of case and control parents, at conception, were plotted on county maps and the distances from the plant were cal culated. Using a chi square test, at one mile intervals, no statistical difference was observed between the cases and controls. Matched pairs of cases and controls were also tested, using a matched-pair T test of significance, and no difference ws observed. While no difference was observed in the distance of residence from the plant, inspection of the map suggests that, within the five mile area, cases were concentrated to the northeast of the river, and the controls were concentrated to the southwest. From the polyvinyl chloride plant, X and Y co-ordinates were determined for the parents' residence, at the time of conception, for each case and control. Cases and controls were then compared for a statistically significant difference in their respective centers of gravity, which is the mean position of the group. The only statistically significant difference (p.OZ) noted was within the three mile area. There were 10 controls and 9 cases within this area. Both cases and controls within the three mile area had a higher socioeconomic index than those outside the area. Ho dif ference was noted between the cases and controls in regard to occupation or length of residence within the three mile area. Cases did have an interesting family history of birth defects. One case mother gave birth to two of the cases within the three mile area. Another case mother had had a sister with spina bifida. A third mother in this case group had reported a cousin with a heart defect. While familial components do not exclude environmental cause, they suggest a possibility of a genetic causa tion. Atmospheric and environmental data related to vinyl chloride monomer and other chemical emissions in Kanawha County arc limited. Some data were provided by the vinyl chloride plant. These data have been collected over the past several years. On October the 1st, 1974, the largest single emission was noted and the VC levels were measured in the community. The highest atmospheric levels were .1 and .Z parts per million. At that time the wind was from the soutnwest, and these levels were found to the northeast of the plant. Additional data were available from the West Virginia Air Pollution Commission. These data, gathered over the past several years, dealt with suspended and scttleable particulate matter. They indicate just the opposite of the VC measurements. They in dicate that the highest concentrations of the settlcablc and sus pended particulate matter were to the southwest, suggesting a pre- 118 ; j i ! ! domlnan In wind an Kanawha for any chemica alone 01 pattern unwarrar In expectoc differen historic and the monomer, case and vinyl ch How pattern miles. ! available Further birth defrom Kan, for thest UCC 006313 toride industry. conception, were ')iant were cal- :rva1s, no "!es and controls, wd. using a snce wdS observed. . residence from .hin the five s of the river. ordinates were of conception, . then compared 1 respective centers . <. The only as within the s within this jarea had a rea, Nodif- rcgard to ni)e area. f birth defects, in the three ih -bins i a cousin i exclude i genetic causa- '.finyl chloride >ty are limited. rr. These data ilssion was ty. The million. At levels were rginia Air past several to matter, ts. They inable and susgesting a pre dominant wind direction from the northeast. In addition to these conflicting data, other data available on wind and temperature data, coupled with the terrain, suggest that Kanawha County in the Kanawha Valley is a veritable mixing bowl for any emissions. There have been identified over a hundred chemicals emitted into the valley. The effect of these chemicals, alone or in combination, is not known, and to attribute this case pattern within three miles to the effect of one chemical plant is unwarranted. In conclusion, both studies did confirm higher CHS rates than expected during the early 1970's. CNS rates are not significantly different from the U. S. rates at the present time. Occupational histories In both studies revealed no difference between the case and the controls in possible work exposure to vinyl chloride monomer. Residential histories showed no difference between the case and controls when compared at varying distances from the poly/vinyl chloride plants. However, in Kanawha County, we did see a difference in the pattern of residents for cases and controls living within three miles. Ho explanation of this difference could be found, but the available data suggested no association with vinyl chloride monomer. Further plans are to monitor the counties identified earlier in the birth defect monitoring program. We also are gathering back data from Kanawha County to 1953 in order to determine the CNS rates for these years. 119 ucc 006314 those people with the structural deformity, those fetuses, died. So, you'll have to look at the structural deformities in relation to numbers of abortions in the community, which I did not hear in the study. I think that when we do these studies, they have to be done with extraordinary care because the stakes are extraordinarily high, Again, I'm not faulting the study. I think that it represents a very serious and important effort. I'm only suggesting that we do need a lot more environmental measurements in the plants and out of the plants. i I { j j [ j I I ages, in ordt aborters una: The com[ which was rei available fot DR. PETER INI CDC study of west side of nantly from i We do have to define all of the populations at high risk. ! We do have to carry out studies which will then look at the level at | ' which these populations are affected. As I said.before, there is no threshold for most of these things. At every level of environ- ' j mental contaminants -- in the plant or out of the plant -- someone may be affected. So what we're really talking about when we do j careful studies -- and this, I think, is one of the approaches we j can take to this problem -- is that we have to look for what are I socially acceptable risks. We have to look at dose response re- | lationships and try to come up with some level in the workplace [ and in the community which will protect virtually all of the j population. j If we do this, then we can look at the question of the pregnant woman as a very special case, and make every attempt to protect her without sacrificing her economic status and so on. I think we'll have more to say about that kind of thing in discussion, but I feel that this really is what we're trying to grapple with today and tomorrow. j j QUESTIONS, ANSWERS AND COWENTS DR. CLARK COOPER: Along with Dr. Carnow, I think we need epidemio logical studies concurrent with the actions that we are going to have to take. We have found it very difficult to develop designs for studies that we feel are satisfactory, and I am particularly interested In Dr. Wagoner's report of fetal deaths associated with male exposures to VCM, because this really has been one of the most startling reports that we have had. It was given to us in a very abbreviated form and 1 am very interested in just how tnc study was handled, and how data was obtained. In fact in which the; tural purposi tccted in Cii the predonin that is why the plant, w plant. . Also, I study -- loo' of the worki; in the plant Should a bir would show u, hours a day < Again, In addition, nation. The;, merization ; central nerv Now, at would expect and yet they of central n because in t tained less able to ider. anomalies. OR. WAGONER: This was a survey in which both male employees exposed to vinyl chloride ami unexposed rubber workers in the same facility were questioned concerning the reproductive histories of their spouses. The data were analyzed for potential interviewer bias, and none was found. The data were analyzed, as l indicated in the presentation, witii regard to those individuals having two or more miscarriages, three or more miscarriages, or four or more miscarri- 136 1 have ity that was ccived from incidence of is a large i for the ren:: 1974, there births. Th_ ucc 006315 lose fetuses, died, irmities in relation ii I did not hear in jey have to be done extraordinarily high. Jat it represents a suggesting that we ,fn the plants and out 1 ns at high risk, n look at the level at Id before, there is 'y level of environIhe plant -- someone about when we do : the approaches we Slook for what are dose response re in the workplace illy all of tne ;stion of the pregnant tempt to protect her on. I think we'11 scussion, but I rapple with today t v/e need epidemioi we are going to to develop designs 1 am particularly :hs associated with teen one of the most in to us in a very it how the study was ages, in order to eliminate potential bias resulting from chronic i aborters unassociated with the place of employment. The complete methodology of the study is included in the paper which was recently published in The Lancet Magazine, where it is available for peer review. OR. PETER INFANTE: I am also concerned about the results of the CDC study of vinyl chloride, and about the clustering on the north west side of the plant. I believe the wind direction was predomi nantly from the southwest in this part of the country. In fact, recent studies by the Environmental Protection Agency, I in which they tagged chlordane isotopes and spread them for agricul i tural purposes in Oallas, resulted in this chlordane being de i tected in Cincinnati's water supply. For this reason, I think j tne predominant direction of the wind is to the southwest, and i that is why I'm a little concerned when I see the clustering near i the plant, within the three-mile limit on the north side of the 1 plant. Also, I am concerned about the case control method for the study -- looking at distances from the plant -- given the mobility of the working population. For example, a worker who doesn't work in the plant can work next to the plant but live ten miles away. Should a birth defect or some other anomaly be related to this, it would show up ten miles away when, in fact, the worker spends eight hours a day closer to the plant. Again, I think those are questions that need to be resolved. In addition, the method of selection in this study requires exami nation. They looked at 17 conronities, with vinyl chloride poly merization facilities, and four of them had a significant excess of central nervous system anomalies. Now, at the statistically acceptable five percent level, you would expect five out of 100 conrounities to show significant excess, and yet they found four out of seventeen with a significant excess' of central nervous system anomalies. This is of further concern because in two of the communities, the monitoring system ascer tained less than SO percent of the births. Yet they were still able to identify a significant excess of central nervous system anomalies. _te employees exposed n the same facility orics of their iterviewer bias, I indicated in the iving two or more * or more miscarri- I have some information concerning birth defects in a commun ity that was not in the COC monitoring program. The data was re ceived from the Michigan Department of Health, and it shows the incidence of birth defects in Midland County, Michigan, where there is a large industrial chemical complex, in relation to the rate for the remainder of the state. During the five-year period, 1970- 1974, there was an incidence of 21.3 birth defects per thousand live births. That's compared to 9.5 for the state as a whole. So, 137 ucc 006316 * again, we see a repeated pattern of birth defects In areas with vinyl chloride polymerization facilities. As I said a year ago, this certainly does not mean that these observations are causally related to vinyl chloride. But as data continues to come in, I am becoming more concerned about It. OR. FINKLEA: Thank you very much. 1 think maybe Or. Cdmonds might want to make a reply. I might add one thing that would be helpful to you. The Environmental Protection Agency did publish a monograph on the air pollution in the Kanawha Valley. And I think if you will look at that, maybe elevation might be just as important here as a location for a plant. That valley acts as a trough and you have frequent inversions, and you have a lot of almost slushing back and forth in that trough. And your air pollution there should follow a little bit different pattern than you would see if your topography were quite level. HR, EDMONDS: I would just like to make a few comments. First of all, somebody made a comment earlier to the effect that these studies found no association with vinyl chloride. In fact, these studies cannot rule out such an association. The first thing we compiled was wind data. Dr. Infante said that the predominant winds were out of the southwest. Kanawha Valley is a deep valley. The very top of the valley is an airport, and wind direction at that airport is out of the southwest. Down in the valley there is a different situation. The wind direction is different during the time of day,,and time'of year. In addition, you cannot ascribe any one wind direction to any one part of the city. We did try to ascertain wind direction at the time of con ception for both cases and controls. The wind blew a little more out of the southwest than out of the northeast -- about A2 percent of the time versus 37 percent of the time. So the difference is very minimal. And difficult to assess. There is very little information on environmental pollu tants in the vafley. There are a lot of chemicals. I mentioned the VC levels on one day they measured. That one day's measure ments were the only levels we could find in Kanawha Valley. The levels were a little bit higher to the northeast, with the winds out of the southwest. The particulate and settleable matter I told you about has been measured over several years. These measurements are higher to the southwest, and could be reflecting emissions from other industries in the general vicinity. The environmental and atmospheric data were very confusing. You cannot pinpoint wind direction to any one part of the county. As for selection of the counties, four counties with the highest rates were identified out of the seventeen. Two of them were eliminated, monitorod. 30 percent < I but where tt community w, Paincsvillc The ne> \ in Midland, i they are. ! DR. INFANTE: : defects. Wi tal defects 1 twelve heart pected; and i whereas five ficant stati HR. EDMONDS: Valley, we a 1958. We st DR. INFANTE: j population s : chloride pol; ' excess of bv I b.i rth defect: j your study di DR. GORDON: OR. INFANTE: j four out of : me that is. a ! MS.. CLARA SO J are nccessar. ! 1 would like i scavenger in i ly, I know Or * what Dow doe: ask him what Some of these DR. CORBETT: j approximately j room anesthc*. I the equipment ; other words, i gases dircctl air is rccir' 138 ucc 006317 In areas with mean that those "ic. Out as data i about It. -Or. Edmonds might would be helpful to . lish a monograph I think if you is important here trough and you most slushing ition there should ild see if your "nts. First of that these In fact, these 'r. Infante said -----st. Kanawha ey is an airport, outhwest. Down wind direction ear. In addition, ne part of the j^Je time Of con- ' est than out ___ersus 37 percent And difficult to onmental pollu. I mentioned day's measure; Valley. The _____I'ith the winds * you about has .r(g>ts are higher s from other ery confusing, of the county, th the highest f them were eliminated. In one of them, only three percent of the births were oonltored. The other county that was eliminated was a county where 38 percent of the births were monitored between 1970 and 1974, but where the VC plant was not in operation until late 1972. So that conrounity was eliminated, which leaves the two counties of Painesville and Kanawha. The next comment I would like to make is about the high rates in Midland. I would be interested in knowing what types of defects they are. OR. INFANTE: The data from Midland County, Michigan, show total defects. With regard to congenital anomalies, thirty-four urogeni tal defects were observed, whereas only seven were expected; twelve heart anomalies were observed, whereas only four were ex pected; and fifteen cleft lip and palate defects were observed, whereas five were expected. These observations are highly signi ficant statistically. ' MR. EDMONDS: We need to monitor these counties. In Kanawha Valley, we are going to evaluate all birth certificates back to 1958. We still have a concern. DR. INFANTE: Well, the point I was trying to make is that the population study conducted in the Ohio communities with vinyl chloride polymerization facilities demonstrated a significant excess of birth defects. This study did not conclude that the birth defects were related to vinyl chloride. On the other hand, your study does not rule out the possibility. DR. GORDON: You cannot rule It out. DR. INFANTE: In fact, I am more concerned now in that you identify four out of seventeen counties showing a significant excess. To me that Is a significant observation. MS-CLARA SCHIFFER: I am Interested in the technologies that are necessary to reduce hazards, and I have two questions. First, I would like to ask Dr. Corbett how much it costs to install a scavenger In an operating room and properly vent It? And, second ly, I know Dr. Gordon was asked to speak on placement and not on what Dow does. But I want to take advantage of his being here to ask him what technological changes Dow is putting in to reduce some of these hazards? DR. CORBETT; The answer to the first question is that it costs approximately $100 to install the scavenger device on an operating room anesthesia machine. That is, if the existing remainder of the equipment is suitable for removing the gases from the room. In other words, docs the operating room ventilation system carry the gases directly outside, as opposed to recirculating the air? If air is recirculated, an alternate form of exhausting is necessary. 139 ucc 006318 Actin' Director Office of ikcr.raiatrnl Coord!nation and Special Projects Deputy Director, dlOSU October 7, lS7b /'v`- Vinyl Chloride Mmiry Joiinwon of Z, F. Goodrich called today to see what our interpretation Of Uniconi'g latest finding!) on VC Were. lie relayed tiiu followiur;: 4 tt* ju*.yc Ho. of Rats with Kauntnry Carcinoma 1*10 I VO / J.0 1 % o tjx O.-- y.s 10 5 1 0 (control) -- ----------5----------- --., u 13 7 4 (P 0 I don't know ctia number of rats involved. Wo. of Rats vita Antiosnrco.va 3 0 0 0 0 Maury said a number of copies of the report were distributed (:.*CI nnd others) bat, if wj can't locate a copy, to call him (^la-3 7d-31jj) and ha'll fiend a copy to us* lie also naked to be hope appraised of our decisions ou this. I assured hie we could do this. /s/ Edward J. 3a icr cc: Mr. Vcrn Rose Ur. itoscoc Moore Ur. JJobby Craft + * i .i" *P1 II i.nm , q I lyjcwr, .iTir* ucc 006319