Document jyX38eYrbvwR085Z0zkLDpQ3y

* I The BFGooancn ComDary 3925 EmDQiry Parttway AJuor. Oho 44313-1799 4// > ' J /f// ;; V. ) I* 4 A I lit. I t L December 12, 1989 Carlo H. Tamburro, M.I). , M.P.H. University of Louisvii.le School of Medicine Health Sciences Center Louisville, KY 40202 Dear Dr. Tamburro: At your request I am enclosing comments on the the "Case Studies In Environmental Medicine Vinyl Chloride Toxicity". Please call me at (216) 374-4534 if you have any questions. Sincerely, THE BFGOODRICH COMPANY D. Manager, Toxicology Health and Environment al Services 91212-3/jp cc: H. W. Dietz, M.D. SPI-01196 COMMENTS ON: CASE STUDIES ] N ENVIRONMENTAL MEDICINE ON VCM 1. Page 1, Paragraph 2 The scenario that the subject has noticed an odor due to VCM in his backya rd is not realistic. The odor threshold for VCM is 300 pf m which is for above any level experienced on an occasional basis. Community exposure levels are at mos t in the low ppb to nondetectable range, Only a catastroph ic loss could result in community levels in the hundreds o f ppm range and this would be a very rare event. 2 . Page 2. Paragraph 3 The 1-10 ppm leve Ls of VCM in cars was demonstrated under worst case and/or artificial conditions. Because of the finite levels of fCM in the polymer, such levels are not expected to occur This statement also inaccurately suggests that sue l levels are expected to occur frequently. 3. Page 2, Paragraph 3 The combustion of PVC does not release VCM. 4. Page 2, Paragraph 4 Residual VCM in p. pe is available for leading into drinking water. owever, numerous studies under static and dynamic conditions have shown that VCM is not detectable. Page 4 The data as a wholHe indicates that VCM is not a teratogenic hazard (Attachment 1). However, rodent studies indicate t|hat the fetus may be at increased risk to cancer. 6. Page 5, Chronic Exposure No non-malignant liver tumors have been associated with VCM exposure. Furjthermore, while some studies have suggested that VCM may cause other tumors. The epidemiology studi|s*s on VCM as a whole do not support an association at oth r sites (Doll, 1988; Attachment 2). Page 15, Food This highlighted s sction should note that the FDA limits are now only propo sed, not mandatory limits. 91211-5/jp SPI-01197