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AR226-2023 MEMO RA N D U M Date: From: Dept: Tel No: 12-Dec-1886 02:30pm EPT ANTHONY J. [TONY] PLAYTS PLAYTIS POLYMERS SHE&EA 304-863-^228 TO: ROBERT R. MATTSON TO: YOUNGER L. POWER, M.D. ( MATTSORR ) ( POWEBYL ) CC: Gregory A Chapman CC: BARRY L HUDSON CC: William J Vogler ( CHAPMAGA ) ( HUDSONBL ) ( VOGLERWJ AT Al AT HSKVAX Subject: RE: O.H. Review - Qrganofluorine Compounds Ramirez and Reinhardt make a number of recommendations concerning medical surveillance for several biopersistent fluorochemicals, specifically C- at Washington Works and TAF and HFPO trimer at Fayetteville Works, In this letter, I-list each recommendation- (CAPITAL LETTERS) along with what 1 believe is the appropriate action for this site. I tried to take into account the considerations that were raised in our earlier discussion and also what I learned from talking to Gerry Kennedy. 1) CONTINUE, BUT ENHANCE PRIMARY PREVENTION THROUGH USE OF ENGINEERING CONTROLS AND UTILIZATION Of PERSONAL PROTECTIVE EQUIPMENT. The site is already committed- to this course of action. One of the action points from my May 1996 summary of the 1995 blood study results was to do job reviews and employee interviews in order to-identify routes of C-8 exposur^ that may be better controlled. This analysis has recently been completed, and the results will be Used by the BTQ- in- its ongoing, efforts to improve C-8 handling. In fact, the job reviews showed a number of instances where the BTO proactively installed engineering controls that should reduce the potential for c-8 exposure. 2} EXPOSURE POTENTIAL AND. PROGRAM- EFFECTIVENESS..SHOULD- BE MONITORED. BY ROTH AIR SAMPLING AND BIOMONITORING. Ws already do this, with- routine- industrial hygiene air monitoring, and with our 5-year blood testing. , 3) SKIM.EXPOSURE POTENTIAL SHOULD BE.ADDRESSED. BY APPROPRIATE WIPE SAMPLING AND BIOMONITORING. Me already do the biomeaitoring, but wipe- sampling has been limited to special studies, such as the one to determine the C-8 exposure from FEP dust. Additional wipe sampling would be a reasonable thing for us to do. If any problem areas are identified, we should make it a part of our routine monitoring. ' ....RECOMMEND PRE-ASSIGNMENT AND POST-ASSIGNMENT EXAMINATIONS BE CONDUCTED. WE ALSO RECOMMEND THAT BASELINE EXAMINATIONS BE CONDUCTED ON ALL CURRENT EMPLOYEES WHO HAVE NOT PARTICIPATED IN PREVIOUS- SURVEILLANCE CAMPAIGNS. T^IESE EXAMINATIONS ARE TO INCLUDE: 1) MEDICAL HISTORY QUESTIONNAIRE INCLUDING SMOKING HISTORY. 2) BLOOD TESTS - COMPLETE BLOOD COUNT - SMA-12 FLUORINE-IN-BLOOD-TEST. . AJP000596 SID924123 There are two separate issues here. First, should we force employees to be tested. Second, are the- recommended tests- appropriate. Voluntary participation in the 1995 blood study was about 50% of the employees who were contacted. The only way t o get 100% participation from, the C-8-exposed cohort would be to force these people to submit to invasive medical testing. This will create- employee relatione issues, and we have to ask ourselves if it is worthwhile to do so. Considering the lack of evidence of a C~8 health problem, and tha amount of- additional information to be gained,, and the low level of employee concern, 1 think the answer is no. This brings us to the question ef the- usefulness- of the proposed tesjts, which seem more appropriate for the chemicals of concern at Fayetteville. In the case of C-8, the target organs- are not really, known. The data from rodent studies are not applicable to humans, and all epidemiologic work thus far, including-liver function studies, has not shown-any eennsotion between chronic C-8 exposure and human disease. I would recommend that we postpone any additional medical surveillance until the- completion- of the planned rhesus monkey toxicology study. This study, using a more appropriate primate test species, should give us a mush better idea- of what, if anything, to monitof in humans. WE ALSO RECOMMEND THAT PERMANENT ROSTERS..BE ESTABLISHED. FOR ORGANOFLUORINE COHORTS. THE FOLLOWING INFORMATION SHOULD BE MAINTAINED FOR EACH COHORT MEMBER: 1) DEMOGRAPHIC INFORMATION - SOCIAL SECURITY NUMBER, &IRTHDATE, SEX, ASD. 2) WORK HISTORY INFORMATION - JOB TITLE, WORK AREA, ENTRANCE AND EXIT DATES, S). EXPOSURE HISTORY-INDIVIDUAL/JOB/GROUP - AIR MONITORING D^TA, BIOMONITORING DATA, WIPE SAMPLING DATA. Ms already do this at Washington Works with the- help ef two computer programs, FLAIR and HYGIENE. WE RECOMMEND THAT EACH INCIDENT OR EXPOSURE TO. ORGANOFLUORINE.COMPOUND? BE ADDRESSED ON A CASE BY CASE BASIS BY A QUALIFIED MEDICAL PROFESSIONAL. Dr. Power, the Plant Medical Superintendent, routinely reviews each serious safety incident that involves an overexposure to a chemical agent. WE RECOMMEND THAT MONITORING-CONTINUE-TO-ENSURE-EXPOSURES ARE KEPT BELOW THE AEL. PERIODIC APPRAISALS OF THE DATA SHOULD BE DONE TO GUIDE FUTURE OCCUPATIONAL HEALTH EFFORTS CONCERNING ORGANOFLUORINE WORKERS. This is done as part of our routine industrial hygiene monitoring. PARTNERSHIP AND EXCHANGE OF INFORMATION-WITH 3M- OR- OTHER MANUFACTURERS SHQULD BE CONTINUED. ' In the case of C-8, this is-dene at- the-SBU-level and by Haskell Laboratory. CONSIDERATION SHOULD BE GIVEN- TO UNDERTAKE. A STUDY. TO DETERMINE THE BLOpD ELIMINATION RATE OF ORGANOFLUORINE COMPOUNDS....REVIEW OF WASHINGTON WORKS EMPLOYEES-BLOOD RESULTS SUGGESTS THAT A LARGE ENOUGH-POOL OP RETIRED OR TRANSFERRED ORGANOFLUORINE WORKERS IS NOW AVAILABLE FOB TESTING. This was already done as. pact of our 1995- blood-study. The pool of test subjects is not large enough to be useful for two reasons. First, an initial C-& bleed test must be run- very elose to the-time-that exposure stops. This was the case for very few retirees. Second,..the limited data we do have AJP000597 EID924124 V* % indicates there is a wide variablility in the rate of C-8 elimination, necessitating a large group of teat subjects, to gat. a good average result.. It is unknown whether this variability is associated with individual metabolism, initial C-8 blood level, or test error. EID924125 AJP000598