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A JOHN R. ENGLEHORN. PRESIDENT KENNETH W. GREEN. VICE PRESIDENT SIMON D. STRAUSS. VICE PRESIDENT WARREN I. TRASK. VICE PRESIDENT JOHN L. KIMBERLEY EXECUTIVE VICE PRESIDENT D A VID M. BO RC IN A SECRETARY AND TREASURER 2 9 2 MADISON AVENUE X E W Y O R K , X . Y. 10017 AREA CODE 212 OR 9 -6 0 2 0 So - ^ D E T R O IT L A B O R A T O R I!^? REFER TO REFER TO -HEH o : uj-SS- CAH JK BJ0_ _ccs_ J0 nwo VIVIS Cd -U <S) fiAT ASH CD DAH G, FOWLCJi "oi J f r 7 HEALTH ANO SAFFT^. LE July lA -------------C L 966I RI T U R N T O _ Pennsylvania State Air Pollution Control Commission c/o Department o f Health. . Division of Air Pollution Control Post Office Box 90 Harrisburg, Pa. 17101 Gentlemen: Ye have been xuvisod than your Commission is con sidering the drafting of air cualiuy criteria, including un-- e for lead. Ye would, therefore, line so inform you of research programs which the lead industry has under way ana which are concerned with lew level exposures of the kino, likely to occur in the ambient atmosphere and alien are unsigned to provide scientific answers to cuecmions likely no arise when criteria are being determined. About four years ago members of she lead industry and the U..S- Public Health service agreed than it would be wise to design a project, or projects, which would 'lead to answers to the question as to what effect lew level exposure no lead would have on the human system and to attempt to cuanuitaue such exposures in terms of concentration of lead in air. The Kettering Laboratory set up an experimental protocol -chat would use human volunteers in exposure chambers and expose these * volunteers to low level, and increasing amounts of lead in air. The levels of lead maintained in these inhalation chamber-' would be progressively increased in suitable increments of concentration and time. In order to test whether or not such an experiment would give significant results, the first phase attempted to measure the effect of continuous exposure at 150 micrograms per cubic meter of air. You will remember that 150 micrograms per cubic meter of air was the old industrial hygiene exposure limit for eight hours a day. This phase of the experiment was com pleted and shoved that when human beings are exposed continuously to 150 micrograms per cubic meter of lead in air, in somewhat lJ H E 006280 N7545 Page Two Pennsylvania State Air Pollution Control Commission. over two years blood lead levels would reach 80 micrograms per cent, which is the limit prescribed by Dr. Kehoe below which clinical manifestations are not found. The most important reason for performing this first phase was to test the method and to determine whether it could provide significant results wihout the necessity of confining a human subject in an exposure chamber for 2 k hours a day. Here is a brief outline of the experimental method that was used: First an exposure of two hours a day until equilibrium values of lead in blood were reached;, then four hours a day until equilibrium values of lead in blood 'Core reached, then eight hours a day and finally sixteen hours a day. Using those equilibrium , blood values as points on an exposure curve it was possible to'ox- o IT ip O C the curve to the po Oc_ \i`O -at/j/" J.otir x O c x satisfied.us thu'b the use of Ji-.*O''*_~I1 v g.vc ox ^ n i i it rGSU-LTS p results which coini <>'iOx w.ib/wO oo uiined X U o O i l e r i-wOOOiu exposure studies . n u e n O x o n e u e C -*_ y e ----- t * . e . . o S x O l e a S o O i_x _ / o a r to complete ana we are now in cur third year of operating this study, We now have two men being exposed in inhalation chambers cnd plan co conoin^e tno souay u*xu-ua sx-gnm.xcc.no and reproaucxde results have been obtained. U X X o / l x X x d X -J XM ' X/ X X x X m X; Li other inhalation chamber studies using rets as confi provided by the lead industry, Tne American Petroleu the United States Public Health Service. The State : ment in California has agreed with us that these are experiments and that the results will be of great in when they are ready to determine air quality criteri W u t>o Oilen 'or -LCcid. We, therefore, suggest to your Commission, that the results of these experiments will, be of equal value to you in the determination of rational and scientific air quality criteria. This study is being performed in the public interest and the results will be made known to all interested parties. . Thus far sufficient data has not been accumulated to provide a number, or numbers, that would be of scientific signifi cance. We have assumed that air quality criteria for toxic materials should be derived from data that is significant in terms of human health. Our studies are unique in the field of air pollution, are of course exceedingly expensive in terms of dollars, but, what is most important, give us results that directly relate to human physiology, results that do not have to be extrap olated from one animal species to another. ftg 0006281 Page Three Pennsylvania State Air Pollution Control Comission The lead industry has in the past; and will continue in the future; to act in a responsible manner and will cooperate with all interested Government and private agencies in evaluation of lead and the public health. Our industry and its members have spent many millions of dollars on the evaluation of the relationship of lead to problems of health: therefore; we believe we are in a position to ask your cooperation; and to cooperate with you in the establishment of scientific and reasonable air reality standards. In our opinion one of the most important activities of Government agencies in the field of air conservation and pollution control is the establishment of reasonable air Duality criteria. The report of the Research Management Advisory Panel to the Commitnee on Science and Astronautics of the u. S. House of Representatives, * which is entitled "The Adequacy of Technology for Pollution - Abatement"; makes the following statement which is pertinent to our discussion here: Once the goals of pollution abatement are _ agreed on, attention can be dirccteu to the equally important questions of how the goals can be attained most effectively; and who should pay the costs of ' measures to bring as out the desired conditions. The Panel believes tnat science and technology must play an important role in finning answers to all of these questions. Goals taut are not in harmony with the scientific ~orlnclol.es underlying the field may never be attained. Very truly yours; O', . Bon G. Fowler DGF:b cc: Mr. Allen D. Brandt Mr. Victor H. Sussman 2n e 000628