Document gaQkkZMekGB2q7Bwy6Np9XKgV

josccn K. XRIXER JEBOHF. |]. HECKMAN CURLKb' K .HEB11AX william n. oononesANt. jr RODCBT R.TTEBMAV WAYNE V. I11ACK david L. mu. MARTIN W. BSMCOVICt EDWIN n. SHIEVACK PETES K, NEHKOV JOSEPH 8. tlADLET CABOLE C. nAJiRJS WILLIAM W. POOH law orrtCES Keller and Heckman 1130 irts STBEET, N. W. SUITE IOOO WASKINOTON, D-C. 2003G February 20, 1974 TELEPHONE eoa eeo-sKoo CABLE ADDRESS "KCLXAJI' FES 0 5 1M TO: All members of; SPI Ad Hoc Liquor Bottle Committee? BATF Mailing List; Plastic Bottle Division (Voting Representatives); Food, Drug and Cosmetic Packaging Materials Committee Health Administration Hearings Gentlemen: You will recall that, on January 31,- 1974, Mr. Heckman wrote to you advising about a "Request for In formation and Notice of Fact-Finding Hearing" published in the January 30 Federal Register. In particular, the Notice advised of the intention of the Occupational Safety and Health Administration to hold public hearings on the possible hazards of vinyl chloride manufacture and use, said hearings to be held on February 15, 1974. Since Mr. Heckman was required to be away from Washington at a Society of the Plastics Industry Board of Directors meeting on February 15, I attended the session at his request; the purpose of this letter is to give you a summary report on the proceedings. I should also point out, as a prelude, that no testimony on behalf of SPI was given at the hearings since we received no indica tion of disagreement with our January 31 recommendation in this respect. Moreover, I am somewhat pleased to note that the hearings'did not highlight any PVC packaging materials problems although three Food and Drug Adminis tration representatives were in attendance as observers. Despite the fact that the Hearing was billed as an "informal fact-finding hearing," it was conducted by RSV 0002372 February 20, 1974 Page Three In these presentations, it was indicated that the tentative conclusion expressed at a NIOSH briefing in Cleveland, based upon post-mortem evidence from four former B. F. Goodrich employees, was that "angiosarcoma is a new industrial health problem." Likewise, it was stated that although NIOSH recognizes that all the workers were exposed to other chemicals, vinyl chloride remains the principal suspect as an etiological agent. The next speaker was Dr. I. J. Selikoff, Director of the Environmental Sciences Laboratory of the Mount Sinai School of Medicine, who is also a consultant to the Oil, Chemical, and Atomic Workers International Union (OCAWI). The major point that Dr. Selikoff made was that in literally thousands of general autopsies performed in various sections of the country no cases of angiosarcoma were reported. Consequently, the appearance of four cases in Louisville must be considered as extremely significant. Dr. Selikoff was followed by Mr. Mazzocchi of the OCAWI. He called for the immediate promulgation of emergency temporary standards for vinyl chloride monomer manufacturing and polymerization plants. One of the more impressive presentations was that of Professor Cesare Maltoni of the Institituto Di Oncologia. Professor Maltoni reported on preliminary results obtained in a major study of inhalation car cinogenicity of vinyl chloride monomer. He reported that at levels well below those previously used by the now renowned Dr. P. L. Viola, tumors appeared in the experimental animals including, among others, liver angiosarcomas. At the lowest levels tested, no tumors were noted; this work is being repeated with larger numbers of animals. Not directly related to vinyl monomer, but of significant interest to some in the plastics industry, vinyl acetate was found to cause no tumors in any of the test animals. Following Professor Maltoni's presentation, A. C. Clark appeared for the Manufacturing Chemists RSV 0002374 February 20, 1974 Page Four Association; Mr. Clark provided details on an ongoing study on VCM inhalation toxicity including carcinogenicity. He was followed in the course of the hearing by speakers for several chemical companies including Goodrich, Shell Chemical, Dow, and Firestone. All these presentations were, in my opinion, objective and based upon facts in j evidence as distinguished from the very emotional presenta tions by speakers representing the United Rubber, Cork, Linoleum and Plastic Workers Union of the AFL-CIO. In general, the industrial concerns called for standards promulgated through the regular rulemaking procedures, whereas the unions "`demanded" immediate emergency temporary standards. Dr. Jaeger, speaking extamporaneously since he had no advance statement pre pared, indulged in speculations, some of -which were scientifically ill-founded. The full transcript of the hearing can be obtained from Joanne Goodell, Office of Standards, Occupational Safety and Health Administration, United States Department of Labor, 1726 M Street, N.W., Washington, D. C. 20210, Room 240. The price is $38.80 for the full transcript, but individual pages or exhibits can be purchased separately. We hope this report will transmit some of the substance and flavor of the informal hearing. If you have any questions, however, please do not hesitate to contact us. Cordially yours, Enclosure Daniel S. Dixler, Ph.D RSV 0002375