Document dY4531N7E8EyZjEmR9yvq63RR

R&S 105694 DOW CHEMICAL U.S.A March 22, 1977 MICHIGAN DIVISION MIDLAND. MICHIGAN 48640 Dr. John F. Finklea, Director Department of Health, Education & Welfare Public Health Service NIOSH 5600 Fisher Lane Rockville, MD 20852 Dear Dr. Finklea: Dr. John M. Lanham, of our Corporate Medical Department, has requested me to respond to some areas of your letter to Dr. Scharnweber. I have attempted to answer your first three questions in the chart attached (Attach. 1). Plants in which vinylidene chloride and vinyl chloride represent a mixed emission in the work place and are also currently regulated by the OSHA standard for vinyl chloride are indicated. Dr. Lanham has responded to your next four questions, but I would like to comment on his remarks. The work of Ott, Fishbeck, Townsend and Schneider covers a worker population where vinylidene chloride is the major chemical exposure and vinyl chloride was not used. This work is significant to our understanding of vinylidene chloride where it exists as the major component of the work place environment. The bulk of our product manufactured represents a combination of vinylidene chloride and vinyl chloride. This latter practice is covered in the work of Dr. C. G. Kramer and J. E. Mutchler. The authors have stated that "the concentrations of vinyl chloride were much higher than those of vinylidene chloride due to the much larger quantities of vinyl chloride used..........." The underlined portion is incorrect, as vinylidene chloride comprised approximately 80% of the monomer consumed by these plants. Vinyl chloride was the major air borne emission due to its volatility. (Attach. 2) A long term mortality study of these workers was made by Dr. B. B. Holder and presented in his Washington testimony on the OSHA vinyl chloride standard (June 25, 1974) and subsequently published in the Archives of Environmental Health AN OPERATING UNIT OF THE DOW CHEMICAL COMPANY Dr. John F. Finklea March 22, 1977 Page 2 (Volume 30, July 1975) under the title "Vinyl Chloride Exposure in a Controlled Industrial Environment." The title does not make clear that the study covered plants in which vinylidene chloride monomer was the major raw material consumed, but that vinyl chloride dominated the air borne emission due to its volatility. I have attached a copy of Dr. Holder's Washington testimony (Attach. 3)- An extensive review of toxicological literature covering vinylidene chloride has been recently published by the EPA. The Table of Conterts and Summary of this study "Health and Environmental Impacts, Task I, Vinylidene Chloride," is attached (Attach. 4). The protocol for the toxicological program being conducted by Dow under MCA sponsorship, all reports on completed studies released by MCA, and an interim report by Jessie M. Norris is attached (Attach. 5, 6, 7). The interim report was presented by Mrs. Norris at the Hamburg, Germany meeting during which Dr. Maltoni presented his most recent data. It is my under standing that all documents are forwarded to the regulatory agencies at the time they are approved by MCA. The applications of vinylidene chloride and its polymers are the subject of several surveys sponsored by the Environmental Protection Agency. "Vinylidene Chloride Monomer Emissions from the Monomer, Polymer and Polymer Processing Industries," by A. D. Little, Inc., is one such source. I have attached the Table of Contents and Summary of this report (Attach. 8). Marcus Sittenfield, Inc., the subcontractor to Auerbach Associates under contract to EPA, will finish and submit to EPA, around the end of this month, an input/output survey on vinylidene chloride which should be very descriptive of the vinylidene chloride industry, its applications, emissions, effluents, and disposal procedures. We do not know the exact title or how much data obtained from industry will appear in that final report. Finally, in regards to the residues trapped in vinylidene chloride copolymers, I have attached a table showing the total amount of vinylidene chloride shipped as residue in all our' polymeric products in 1975 (Attach, 9). We have estimated the residues in the products when they enter the consumer markets. .o tn o> <o R&S R&S 105696 Dr. John P. Finklea March 22, 1977 Page 3 I trust you will find this information a satisfactory response to your inquiry. Very truly yours. Phone: (517) 636-5575 Attach. js cc C. L. Baldwin, 1803 J. S. Beale/R. L. Dostal E. H. Blair, 2020 D\ T. Buzzelli, 433 J. G. Cobler, 574 P. J. Gehring, 18.03 F. D. Hoerger, 2030 B. G. Holder, 2030 C. C. Kazmierski, 2020 R. R. Langner, 1803 J. M. Lanham, 2030 R. McKellar, 2020 K. R. McKennon, 2040 J. M. Norris, 9008 D. C. Nuechterlein, 2020 R. D. Olson, 433 D. P. Sheetz, 47 E. R. Smith, 2020 J. M. Soper, 2020 L. M. Thomka, 2040 R. L. Wintermyer, 1603