Document kaQ9rJzKV31Q1Qj6ELXxB5LMO

If C l C . MANUFACTURING CHEMISTS ASSOCIATION ' <|e(K>4y 1825 CONNECTICUT AVENUE, N.W. WASHINGTON, 0. C. 20009 (202)U83-6126?:- SEP 3 0,1974 ,.;c cjui'j HL'Arcc; " x' lwbr'vSi:reptember1 27, 1974 To: Management Group and Technical Task Group on Vinyl Chloride Research Subject: MCA Comments to OSHA re Jellinek Letter Gentlemen: The Final Environmental Impact' 'Statement of OSHA on its proposed vinyl chloride standards included, as one exhibit, a letter from Mr. Steven D. Jellinek of the Council on Environ mental Quality referring to the epidemiological and toxicologi cal data from the MCA-administered studies. The misleading implications and errors of fact in this letter are sufficiently significant that, at the suggestion of industry representatives, MCA has attempted to correct the record. A copy of Mr. Drivef'-s letter of September 24 to Mr. Stender is enclosed. Sincerely, KDJ/mb Enclosure Technical Task Group on Vinyl Chloride Research *sv 0002173 ! i i WILLIAM J. DRIVER PRESIDENT NFORMATION COPY MANUFACTURING CHEMISTS ASSOCIATION 1825 CONNECTICUT AVENUE, N.W. WASHINGTON. D.C. 20009 (202) 403-6126 September 24, 1974 Honorable John H. Stender Assistant Secretary of Labor "U. S. Department of Labor Occupational Safety and Health Administration Washington, D. C. 20210 Dear Mr. Stender: The Manufacturing Chemists Association (MCA) is extremely concerned over certain statements appearing in the Final Environmental Impact Statement (EIS) on the Proposed Regulations on Vinyl Chloride. As OSHA did not see fit to make a copy of this document available to MCA, we have only recently learned of the misleading implications in these statements. The statements in question occur in the letter of Steven D. Jellinek, of the Council on Environmental Quality, to Dr. Daniel Boyd, dated August 5, 1974. Mr. Jellinek erroneously states that MCA "has not seen fit to supply this important data" from the epidemiology study conducted by Tabershaw/Cooper Associates for MCA, and incorrectly identi fies the Industrial BIO-TEST Laboratories (IBT) vinyl chlnri^g study as a "feeding study." Mr. Jellinek proceeds to criticize the IBT data, made available to OSHA concurrently with MCA's receipt of that data, on the grounds that the final statistics will be differ ent from the interim figures. We were aware, at the time a decision was made to keep the Government agencies fully and currently informed, of the hazards of uninformed use and im proper interpretation of incomplete and fragmentary data, but. judged that the needs of OSHA outweighed the risks to the industry. Mr. Jellinek's comments tend to reaffirm our concern. _-- RSV 00l74 Honorable John H. Stender September 24, 1974 Page Two We are particularly concerned over the implications of bad faith imputed to us by the remarks in the first para graph of page two of Mr. Jellinek's letter. The request of CEQ for retabulation of certain sets of data in the TCA re port was conveyed to us by letter of Dr. Warren Muir. MCA requested TCA to determine whether, and to what extent, the desired recomputations could be performed within the time limits set by Dr. Muir. The correspondence involved in this matter is enclosed. At no time did Dr. Muir or CEQ indicate dissatisfaction with the material supplied, nor have they asked us for any additional information. The implication that MCA is withholding adverse data is unwarranted and simply untrue. Mr. Jellinek is entitled to differ with the experts of TCA as to the optimum design of an epidemiological study, but his comment that "it by design vastly underestimates the rate" remains an unbased comparison. Certainly, as the TCA study pointed out, there appears to be an increase in the incidence of malignancies with increasing lengths and intensi ties of exposures to vinyl chloride. Thus rates calculated for more recently recruited employees are not expected to be the same as those for men employed since the early days of the industry. It would be equally improper to assume that the health experience of those now working in vinyl chloride or PVC plants will parallel, a couple of decades from now, the ^ present experience of those who worked under the vastly dif ferent conditions that prevailed in the forties and fifties. In follow-on studies now being discussed with TCA, we hope to improve substantially the percentage of the past work forces that can be traced, and their health status ascer tained. In this supplementary study, the entire body of data will be subject to retabulation and analysis, and MCA welcomes the suggestions of OSHA and of CEQ as to data treatment that will best enable them to meet their responsibilities for the protection of the public. RSV 0002175 Honorable John H. Stender September 24, 1974 Page Three The Manufacturing Chemists Association has tried to be open and frank with the results of its study projects on vinyl chloride. For the OSHA record to indicate otherwise would be entirely inappropriate. Therefore we request the record on vinyl chloride be corrected with regard to the errors in Mr. Jellinek's letter. Sincerely, ccj Dr. Mr. Mr. Mr. Daniel Boyd Steven D. Jellinek Glenn Schweitzer Edward J. Baier RSV 0002176