Document mm6Xknw58v2w4D0Xe3ZL40O2J

tlNION CARBIDE CORPORATION Chemicals U Plastics 270 Park Avenue, New York, New York 10017 RECEIVED JUL 08 1974 To: (See Attached Distribution List) Date: From: Dr. A. B. Steele Subject: UCC Contribution to the SPI Presentation before the OSHA Hearing on Pro posed Standards for Occu pational Exposure to Vinyl Chloride Many of you have contributed ideas and data in support of the position -taken by the Society of the Plastics Industry; namely, that the actual human ex perience in the 36 plants operated in the United States in the manufacture of Polyvinyl chloride resins does not identify vinyl chloride as a material that impairs worker health when reasonable limits are imposed on its concentration in the workplace air. The industry's position was strengthened significantly by the testimony of our Dr. Carl U. Dernehl, who summarized the finding of no case of angiosarcoma of the liver among some 1,402 men working in 32 PVC plants even though their exposure time was sufficient for disease to have occurred and expo sures were believed to have been in excess of 50 ppm on a time weighted average. Appended for your reading and reference, please find a copy of the text submitted to SPI on the matter of industry experience as compiled and analyzed by us on behalf of SPI. ABS:ml Attachment A. B. Steele UCC 009601 I 15? .1 ft 'No. i f?:'- / 7/. (1) STATK.'H; Nr r\-c producers n: ti;e 'jniii;d STATUS KillAT1VE L'O I!SALTII e:< r,'.i;ir:Nr i: or v.'OKKT[y-. tm piants pm.v: I'-nuzTNr: vinyi. ciii.np.inr, st.'v::* `~<v The Department of Labor has imposed major restrictions on the exposure levels of workers in the VCM and PVC industry based on a possible connection Letvcvn vinyl chloride exposure and deaths of a limited number of workers from angio?arcoma--a rare form of liver cancer. The Department's regulation on vinyl chloride limits in the workplace air is based, in part, on the findings of sn'cial scientists who report that vinyl chloride exposure in mice and rats / causes cancer. because animal data are unreliable in measuring impact on man unless the test animal and man have been shown to have similar metabolic pathways and as such defa have indicated a hazard from vinyl chloride exposure far greater .Iian th,-t generally experienced by workers and technicians in individual vinyl chloride monccier and polymer plants, a study was initiated to determine the actual experience in all operating plants within the United States where workers have bean exposed to significant concentrations of vinyl chloride in the work place air over extended periods of time. Reconstructions of past frequencies '"d levels of vinyl chloride exposure have been correlated with recent and cur rent experience in 36 plants manufacturing PVC resins. The health status of individual workers has been determined by extensive medical examination and the cause of death of all FVC workers has been tabulated. Based on these evidences, we conclude: - that there is no significant impairment of health to workers exposed to restricted amounts of vinyl chloride monomer for extended time periods. - that exposures to high concentrations for short periods do not impair health; high concentrations being at or above Ihc odor level of 250 - 300 ppm. ucc 009602 that an eight-hour time-weighted average (TWA) of 50 ppm represents a realistic exposure limit; at higher levels respiratory protection is appropriate. ucc 009603 /. O) RELEVANCY QF ANIMAL TOXICITY DATA Extrapolation of animal toxicity data directly to man is fraught with gross uncertainty without prior knowledge of the manner in which man metabolizes the compound. Thus, in the case of vinyl chloride monomer, the finding of angiosarcomas in mice and rats should not be considered pertinent to man until it is demonstrated that rodents metabolize vinyl chloride in a manner and at a rate similar to man. While methods have been established for the determination (1) of metabolites in man and rodents , such experimental procedures have yet to / be applied to vinyl chloride, leaving in serious doubt the relevancy of the animal test data that are used to brand vinyl chloride a carcinogen in nan. Because vinyl chloride is a carcinogen for rats and presumably even a more potent one for mice does not mean that the same rapid induction can or will (2) occur in man. The evidence provided by the industry survey in itself is evidence that very few man have been involved to date.. Witness more than thirty years of manufacturing experience with only limited cases of angiosarcoma among more than 1500 workmen variously exposed for 15 years or more. Additionally, no case should be charged solely to vinyl chloride exposure if the victim has a his tory of exposure to other chemicals. (1) In vitro vs in vivo chromatographic profiles of Carbaryl anionic metabolites in man and lower animals. Sullivan, L. J., B. H. Chin and C. F, Carpenter. Tox. Appl. Phann. 22: 161-174 (1972). (2) Deringer, M. K. - Journal of National Cancer Institute; .12., p. 437 - 445, October 1951, (3) EPIDEMIOLOGICAL STUDY OF VINYL CHLORIDE WORKERS - FINAL REPORT - May 3, 1974: Tahcrshaw-Cooper Associates Berkeley, C3lif. for Manufacturing Chemists Association. 1 ucc 009604 (M / LEVELS OF YTN"L CHLORIDE EXPOSURE IN PVC GIT RATIONS Experience within the PVC industry generally has shown that workers ex posed to vinyl chloride have maintained health status comparing favorably to that of workers in other chemical and resin operations and to other industrial populations, yet the PVC workers have been exposed'to significant concentrations of vinyl chloride in the workplace air over extended periods of time and to con centrations well in excess of the limits now imposed on the industry by the pre sent temporary 0S1IA standard of 50 ppm celling level. Attempts to, quantify the levels of exposure to which workmen were subjected in past years on each job and in each plant had to be abandoned because reliable measurements of vinyl chloride levels in the workplace air over extended periods of time are generally not avail able, However careful examination of certain plants and of their operating data has provided insight into the vinyl chloride, exposure levels of workmen in speci fic assignments. Case studies have been documented end support the view that there is no discernible impairment to health of workers exposed either to restricted amounts of vinyl chloride for extended time periods or to high concentrations for short periods. ucc 009605 V- (5) The solvent process as operated by Union Carbide has remained essen tially unchanged as to process, recipe, equipment and operating procedures since about 1951. It is the testimony of those closely associated with the plant op eration that vinyl chloride emissions are presently of the same order of magni tude in the Solvent polymer plant as has been experienced regularly over the past twenty years. .'furthermore, measurements of vinyl chloride monomer in the workplace air and of exposure of operators to monomer made recently are reoresen- t tative of the continuing condition since 1953 in which significant and frequent excursions beyond the 50 ppm ceiling standard were experienced as determined by detection of vinyl chloride odor (250 - 300 ppm V'G-I assumed as the odor thresh old. Recent determinations (January and February, 1974) identified the fol- lowing VC-1 exposures to operators in the polymerization section of the plant: Ooerator Number 1. 2. 3. 4. 5. Time' Vejghted Average - PP.l - ? uour 16.9 9.8 23.6 3.5 4.8 21.3 One of the tasks assigned to these operators is the taking and testing of autoclave samples to determine degree of conversion. During sampling and testing, which occurs four times each shift and requires about eight minutes to complete the task, workplace environmental levels range as high as 400 ppm ucc 009606 in the sampling area. Exposure time has been gathered on all employees working this job at the lexas City plant from 1948 to the present. There were 53 such employees; 24 had more than 1 year work experience on this job; 2 employees had 12 years of exposure. Kor.e of these have liver abnormalities, based on recent medical evi dence. At South Charleston where a similar line is operated with'almost iden tical exposure levels, a similar breakdown on operators is not available due to differences in job dynamics. Nevertheless, health of PVC workers is statis tically similar to that of other workers in the same plant and no case of angio sarcoma has been identified among these operators. UCC 009607 (7) CASE STUDY -- IMPROVED CONVEUSION' OF VIEYE au/'E'. IK ivc susfeis 10:: ,\Ei) p/r .`.'COMER <*:,. a The economic realities of the VC.'M resin business .. ince 1965 have forced all resin producers to seek improved efficiencies in convec ion of VOU to PVC through mod ification of operating procedures and plant facilities. Increases in monomer efficiency (Polymer/Eunomer E'r .r ,>_*d x ICO) from 85 per cent in 1968 to 96 per cent in 1974 in suspension iv -'n. manufacture are documented, Improved machinery for recovering VCU from vjw-'v released in ven ting and stripping sections is estimated to have accounted more than half of the Improvement. Similar improvements In monomer efficiency within the PVC dispersion resin process have been recorded; i.e. 787. in 19. increasing to 91 per cent in 1973 is representative of the improvement. 'Chile s.ch increases in monomer efficiency were oriented toward economic ernsidera ; r. s, reductions in monomer lost to the air lessened the amount that emitted to tne workplace at mosphere . Graphs A and B record the annual improaments being achieved in monomar efficiency in polymer production of both suspension an' dispersion resins. Recent measurements within both FYC suspension and dispersion operations established that maximum VCi levels in the workplace sir eperox treated 30 ppm TWA (eight hour) at a ceiling of 45 ppm. Based on the known improvement in monomer efficiency, it is certain that the VCM levels in t! = workplace environment in 1974 are below those of prior years when recovery was less efficient; and tnat FVC workers in the prior years were exposed to significantly higher concentrations than is presently experienced. The employee health records of workmen operating in cko majority of the plants where the data show a significant and continuing reduction in VCM losses from the experience of 1967 show no measurable deterioration in the health of the workmen exposed during this period. UCC 009608 POLYVINYL CHLORIDE DISPERSION RESIN OPERATIONS VINYL CHLORIDE EFFICIENCY TOTAL P 0 LY E R / M 0 X 01! E R CHARGED X IOO EFFICENCY PER CENT %V O 19609 POLYVINYL CHLORIDE SUSPENSION RESIN OPERATIONS VINYL CHLORIDE EFFICIENCY TOTAL POLYMER/MONOMER CHARGED XIOO PER CENT o 9610 CASE STUDY pvc: sr;::;::r>TQ:; n.". __D_C_*_..' Testimony of V. K. !'ove at Public lienrins; on VC! (C" ['fcbnnrv 15.__1j tJh_________ co: nv "Our Polymer Plant -;1 was operated from 1946 to 1972. Hocwc-en 1950 and 1959, several industrial hygiene surveys were cc: b .ted. A number of job classifications (polymerizer operators, drier operator'', monomer still opera tors, and monomer transfer operators) had workplace environmental levels ranging from 50 to 385 ppm vinyl chloride. After ins fulls cion of a continuous analyzer for the workplace air in 1959, improvement:; were achieved, Vinyl chloride TWA values ranged from 25 to 85 ppm during the period 1960 - 1967." "Our present Polymerization Plant, Polymer Plant number Two, began operation in 1953. Historically the TWA values have been decreased over this period of time. In the early history, TWA values of i'o - 240 ppm were ob served. During 1973, wVA values for vinyl cr iorice rr -me air were in the 1 to 25 ppm range. * Hutchler. J. E. Kramer, C. ", - "Report on Relation of Exposure to State of Health of Dow Chemical Workers" - Gorden Conference, Tilton. N.H., August, 1968 - TLV Citation UCC 009611 (II INDUSTRY FROFTIJI PVC resin production in the United States approximated 4,600,000,000 pounds in 1973: Number of producers (domestic) 22 Number of Plant locations 36 , Number of producers by process: Suspension / - 22 Dispersion - 10 Bulk Non-solvent - 4 Solvent -1 Emulsion -3 Number of Production Workers: 5,045 Relative to the number of domestic plants manufacturing PVC resins, only four plants have been identified as having a possible connection between vinyl chloride exposure and the development of angiosarcoma in workmen; ten of the twelve cases being traced to two plant locations. ucc 009612 PI a n. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 mi WANT LOCATIONS u.s. product;us - 1974 Plant Startup Da tic 1957 1963 1961 1963 1946 1966 1968 1954 1953 1960 1970 1946 1956 1956 1956 1966 1963 1936 1947 1959 1955 1950 1971 1953 1965 1947 1965 1965 1942 1969 1955 1968 1965 1967 1957 1949 . No. of PVC Workers 64 46 80 155 75 158 120 130 300 40 55 300 60 27 76 140 187 272 140 74 150 74 30 241 200 350 70 180 . 266 90 98 150 95 160 70 322 Reported Cases Aneiosarcona *1 ' ' 0 0 0 0 0 0' 0 0 0 0 0 3 0 0 0 0 0 1 0 0 0 0 0 0 0 1 0 0 7 0 0 0 0 0 0 0 (12) ucc 009613 (13) UNITED STATES PVC PLANTS DURATION 0^ PJI51N MANUFACTURE Span of Operations 1 Co 5 Years 6 to 10 Years 11 to 15 Years 16 to 20 Years 21 to 25 Years More than 26 Years Number of Plants 3 9 6 8 A 6 ucc 009614 cent; ha l co;:s ide ii\ r i o;:s Various parties involved in considering the possibility that vinyl chloride monomer is a causative agent of angiosarcoma in humans recognize: - that as of this date no definite connection has been established between angiosarcoma among workers and any of the major chemical raw materials used in polymeriza tion of FVC. However, vinyl chloride monomer, being a volatile chlorinated hydrocarbon, is the primary tar get due to its being the abundant raw material to which workers might have had the most exposure. - that vinyl chloride is not the only raw material in volved in resin production in the two plants where mul tiple cases of angiosarcoma have been identified among workers; acrylates, vinylidene chloride among others have been listed as additional reactants. - that no rationalization has yet been published as to why the lack of angiosarcoma among workers in the vast majority of P/C plants employing the same basic processes for resin manufacture; none among workers in other plants of the sane producers reporting multiple cases of angio sarcoma in single plant locations. - that the development of angiosarcomas of the liver de veloped in animals exposed to vinyl chloride has been used to postulate that VCM is the etiolcgic agent in the excess of deaths due to angiosarcoma of the liver in IVC workers. Astudy of the possible impact of exposure in other work situations, of the eating and drinking habits of the afflicted workers, and of other complicating health problems has not been made. (l/.> ucc 009615 (15) The National Institute for Occupational Safety and health (NIOSH) has u'ed VCi as a potential health hazard to PVC workers primarily on the basis inductive reasoning. Vet the health experience of workers in the 36 PVC poly- ixntior. plants indicates that no serious health problems exists generally in plants -.-i ch but tv7Ci exceptions. " 25 19 A. B. Steele UCC 009616 THE SOCIETY OF THE PLASTICS INDUSTRY, INC. 250 PARK AVENUE NEW YORK, NEW YORK T0017 212/687-2675 QUESTIONNAIRE RESULTS OK VINYL CHLORIDE EXPOSURE EXPOSURE LEVELS < 1. Cdor of vinyl chloride noncper preseat throughout such of the day. MO - 21 plants, YES - 7 plants; Average number of years - 7-7 Before i960 - 6 plants, 1960-1970 - 3 plants. After 1970 - 1 plant 2. Odor of VCM present occasionally during the vork day. NO - 3 plants, YES - 25 plants; Average number of years - 11.3 Before i960 - 10 plants, 1960-1970 - 23 plants, After 1970 - 19 plants 3. Odor of VCM a rare event in any vork day. NO - 3 plants, YES - 25 plants; Average number of years - 2.9 Before i960 - 0 plants, 1960-1970 - 6 plants. After 1970 - 25 plants 4. Have there been process or processing changes Introduced which have resulted in an increased escape of VCM? NO - 23 plants, YES - 5 plants; Average number of yeers - 2.6 Before i960 - 2 plants, 1960-1970 - 3 plants. After 1970 - 1 plant 5. Have there been process or processing changes introduced vhich have resulted in a reduction in the escape of VCM? NO - 1 plant, YES - 27 plants Before i960 - A plants, i960-1970 - 12 plants. After 1970 - 24 plants 6. Do you have environmental measurements prior to 1970? NO - 24 plants, YES - 4 plants PERSONNEL EXPOSURE DATA 1. When did the plant start to vork with VCM? 1940-1950 - 4 plants, 1951-1960 - 12 plants, 1961-1970 - 10 plants 1971- 1974 - 2 plants UCC 009617 -2- 2. How many employees are working with VCM? Total - 3957 employees. Average per plant - 141 employees 3. How many employees are still working for you who once worked with VCM hut do not do so now? Total - 1503 employees. Average per plant - 54 employees 4. Of the persons identified la 2 and 3 above give the number who have been exposed for the following time intervals. Total employees Average per plant More than 1 and up to 10 years 10 and up to 15 years 15 and up to 20 years 20 and up to 25 years 25 years and more 3515 611 286 244 128 126 22 10 9 5 Of the persons identified in 2 and 3 above give the number falling within each latent period given below and considering only employees with more than one year of service. A latent period is the time lapse frco first exposure to the present date. Total employees Average per plant More than 1 and up to 10 years 10 and up to 15 years 15 and up to 20 years 20 and up to 25 years 25 years and more 2916 768 354 257 128 104 27 13 9 5 DATA FROM CURRENT EXAMINATION PROGRAMS 1. Give the number of persons who have been examined since January, 1974. Total - 7232 employees of which 2775 include retirees and 4457 exclude retirees 2. Vere liver profile studies made? NO - 3 plants (representing 132 employees), YES - 25 plants(representing 7100 employees) 3. Did the studies include at least bilirubin, SCOT, LDH and alkaline phosphatase ? NO - 3 plants (representing 132 employees), YES - 25 plants (representing 7100 employees) UCC 009618 / -3- 4. How many of those examined showed an abnormality in; Total employees Average per plant one test two tests three tests or more 957 162 78 56 (17 plants) 11 (15 plants) 8 (10 plants) % of total $ of those incl. retirees % of those excl. retirees one test two tests three tests or more 13.2 2.2 1.1 3^.5 5-8 2.8 21.5 3-6 1.8 5. Have you had any cases of angiosarcoma? HO - 22 plants, YES - 3 plants, Incomplete data - 2 plants 6. Was this determination made by your own survey? NO - 2 plants, YES - 22 plants, Partly - 1 plant, Incasplete data - 2 plants 7. What percent of the total exposed population was cowered in the survey? 95-5$ of total exposed 8. Were retired personnel included? NO - 14 plants, YES - 9 plants, Not applicable or no data - 2 plants 9. Were persons who had left your employ and gone to work elsewhere included? NO - 19 plants, YES - 8 plants 10. Did you review causes of death of those who died while still employed by you? NO - 3 plants, YES - 22 plants, Not applicable - 2 plants 11. Did your plant participate in the Tabershaw-Cooper epidemiologic survey? NO - 7 plants, YES - 20 plants UCC 009619 I am Carl U, Dernehl, M. D., Associate Medical Director of Union Carbide Corporation, testifying on behalf of the Society of the Plastics Industry. I am a board certified specialist in Occupational Medicine and have been practicing this specialty for more than 30 years. For 8 of these years I had medical supervision of a vinyl chloride monomer plant's employees and employees of a polyvinyl chloride plant. 1 have held teaching appointments at the Medical Branch of the University of Texas, the Baylor Medical School and, at present, at the Medical School of New York University. The Society of the Plastics Industry has conducted a health survey of the polyvinyl chloride producers. This survey was conducted to determine if there are factories in which vinyl chloride exposure occurs and in which there have been no cases of angiosarcoma of the liver even though adequate exposure had occurred. Adequacy of exposure must be judged both by time and concentration of the toxicant. In this survey, 36 plants of 20 producing companies were covered. Plants in which cases of angiosarcoma had occurred were discarded from the data, Becuase the most brief exposure period reported in existing cases was 12 years, all plants with 10 years operating experience or less were also discarded from the data as having exposure time insufficient to result in evidence of disease by current criteria. Accordingly, the data  / 2 covers 16 company plants which, employ 2, 372 persons currently in work permitting exposure to vinyl chloride, plus 1,471 persons who had worked with vinyl chloride in the past but do not do so now. Thus the survey is looking at 3, 843 persons some of whom have not worked long enough to expect the disease to become evident. However, 787 persons had worked more than 10 years with vinyl chloride and 1,402 persons had a time lapse since first exposure to vinyl chloride of more than 10 years. This last figure, called a latent period, does not require constant exposure but it covers those persons who may in the past have worked with vinyl chloride but do not do so now. The data shows 104 persons have been exposed to vinyl chloride for more than 20 years, but 416 persons have a time lapse from first exposure to the present time of 20 years or more. There are those who insist that any exposure to a carcinogen however remote in time initiates changes which ultimately result in cancer formation. If this be so, then we must accept the fact that we have here 1,402 persons who have the necessary time element for some of them to develop cancer. In addition, over one half of these 1,402 people have been continuously exposed for more than 10 years to vinyl chloride. Having established that sufficient exposure in terms of time has occurred, attention must be directed toward the concentration of vinyl chloride in the air of the work place. Only 2 out of 16 plants indicated UCC 009621 -3- existence of measurements of the environment prior to 1970. Because of the scarcity of data, the presence or absence of the characteristic odor of vinyl chloride was used as a measure of exposure. Vinyl chloride is believed to have an odor threshold in the vicinity of 250 ppm. Therefore, if the odor is detectable, vinyl chloride is present at least in a concentration of 250 ppm. The concentration may be much higher. Three guide lines of exposure were used. The heaviest was when the odor of vinyl chloride was present most of each work day. Intermediate exposure was when the odor of vinyl chloride was present occasionally during a work day. Light exposure was when the odor of vinyl chloride was a rare event on any work day. Four companies reported that the odor of vinyl chloride was detectable most of the work day prior to I960. Between I960 and 1970 this condition was present in only 2 cases and after 1970 it no longer occurred. All 16 of those reporting stated that the odor of vinyl chloride was present occasionally during the work day at some time in the plants history. Eleven said this occurred prior to 1960. During 1960 to 1970 the number increased to 15 cases and from 1970 to date the number is 10. It is interesting to note that in 3 cases there were process changes reported as occurring during 1960-1970 which resulted in increased escape of vinyl chloride thus largely accounting for the increased incidence of exposure. UCC 009622 The low exposure level reflects the general improvement which has been occurring in the industry. Before I960 the detection of vinyl chloride odor was never a rare event but was common as already indicated. During 1960-1970 the situation improved where 4 of those reporting stated that odor detection was a rare event. In the period since 1970 this number has increased to 15 of the 16 reporting. There is some conflict in reports between intermediate exposure and light exposure after 1970. Thus 10 plants reported occasional exposure during a work day and 15 plants reported that exposure was a rare event. This discrepancy cannot be explained but it really is not too important since it refers only to the last four years. In brief the data show that the 1,402 men not only had a significant time element in their work exposure but they also were exposed for much of the time to what must surely have been considerably more than a time weighted average of 50 ppm in recent years and most probably in excess of 250 ppm in years prior to I960. Since January 1, 1974, a total of 3, 285 examinations have been made on employees of which 872 were made on retirees. The examination of 3, 249 of these men included the liver profile tests found in the SMA-12, namely, bilirubin, SGOT, LDH and alkaline phosphatase. Fifteen per cent of those examined had an abnormal test result in one of the four tests in UCC 009623 #a 5 the liver profile. This falls within the levels of abnormality we in Union Carbide have observed in approximately 900 employees who have not been exposed to vinyl chloride and also in 400 office personnel not exposed to any chemicals in their work place. The frequency of abnormalities in 2 tests (2.7 per cent) and 3 tests (1.3 per cent) in the same person also are comparable with control groups. This evidence suggests that workers in this survey group are not significantly different from their fellow workers who are not exposed to vinyl chloride in regard to liver function tests. In summary, this survey has disclosed the existence of 1,402 men having a latent period of exposure to vinyl chloride of more than 10 years. Four hundred sixteen of them had a latent period of more than 20 years. Also, 787 men were exposed to vinyl chloride for more than 10 years with 104 of them being exposed for more than 20 years. Based upon odor recognition it is estimated that these men were exposed to a time weighted average of at least 50 ppm and in earlier years to much more than this. Examinations of these men have failed to show the existence of abnormal liver function tests in greater proportion than would be found in a control population. There is no case of angiosarcoma of the liver among these 1,402 men even though their exposure time is sufficient for disease to have occurred and exposures are believed to have been in excess of 50 ppm. UCC 009624 -6- This absence of cases of angiosarcoma is supported by the independent epidemiological study conducted by Tabershaw-Cooper Associates for the Manufacturing Chemists Association who also found no new cases of angiosarcoma of the liver. A copy of the Tabershaw-Cooper study is attached for the record. The plants in which cases of angiosarcoma have been found have an employment of 1, 188 persons. The finding of 13 cases results in a ratio of one angiosarcoma for each 91 employees. If these plants are the same as the plants in this survey the incidence of angiosarcoma should be in the same ratio and we should have found 21 cases. The fact that not one case was found cannot be ignored. There are people in the survey group who have the same latent period as those seen in cases of angiosarcoma. This suggests that the difference lies in the degree of exposure which in the survey group is estimated at more than 250 ppm in early years and about 50 ppm in recent years. We submit that these data fail to support the need for an exposure level as drastic as that proposed in the Standard, and in fact, these data suggest that the level of 50 parts per million proposed in the temporary emergency standard was not unrealistic. ucc 009625 DISTRIBUTION LIST Mr. E. Bell Mr. G. P. Bigelow Mr. P. E. Bouffard Mr. L. D. Burnert Mr. J. L. Carvajal Dr. C. P. Carpenter Mr. D. Engle Mr. E. F. Cox Mr. R. G. Davis Mr. M. E. Eisenhour Mr. C. R. Field Mr. R. L. Frantz Mr. J. E. Giffin Mr. R. J. Hanna Mr. J. M. Herbert Dr. M. H. Jellinek Dr. W. R. Manning Mr. S. A. Mortimer Mr. J. Nesmith Mr. G. J. Norberg Mr. G. T. Scott Mr. G. C. Shipston Dr. A. B, Steele Mr. G, F. Tacquard Mr. R. N. Wheeler/ ucc 009626 t I* f' I'^ION CARBIDE CORPORATION Oiemicals f, plastics 270 Park Avenue, New York, New York 100U re>Tfa,{ RECEIVtO . To: (See Attached Distribution List) Date: July 9, 1974 JOL i,: 1974 R. N. WHEELER. JR. Subject: Comments on Proposed Standard For Occupational Exposure to VCM The testimony to date clearly established that an assessment of the risk of VCM exposure at any level was made impossible by the absence of medical knowledge. Under such circumstance, all uncertainties must not be resolved in favor of health safety as proposed by OSHA in setting non-detectable limits on VCM. Since the appropriate threshhold level for safe toleration of VCM is unknown, OSHA proposes to protect against the unknown by simply assuming that exposure to any VCM presents a health hazard. In doing so, OSHA disregards the documented human experience - SPI, Dow and Carbide testimony - which provides direct evidence to the contrary; namely, that exposure of workmen to moderate amounts of VCM over extended periods does not pre sent a health hazard. We must emphasize that our proposal rests not on the view that VCM exposure of workmen represents no risk but rather on the view that given the evidence, no substantial danger of angiosarcoma of the liver has been proven to exist with ex posures of workmen to any moderate VCM concentrations (50 - 250 ppm, TWA - 8hr.) We hold that OSHA must base its limits of exposure on proof of a demonstrable hazard to emphasize health rather than a conjecture as to the possible relation ship of incidence of disease vs, VCM exposure levels. ABS:ml Attachment /j.iJC;. U. /'* A. B. Steele ucc 009627 - r--i DISTRIBUTION T.TST WEEKLY HASH REPORT vinyl operations TO: Mr. E. Be 11 Mr. o. P. Bi gelow Mr. P. E. Bouf fard Mr. L. D. Burnett Mr. J. L. Carvajal Mr. D. Engle Mr. E. F. Cox Mr. R. G. Davis Mr. M. E. Eisenhour Mr. C. R. Fie Id Mr. R. L. Frantz Mr. J. E. Giffin Mr. R. J. Hanna Mr. J. M. Herbert Dr. M. H. Jellinek Dr, W. R. Manning Mr, s. A. Mortimer Mr, J. Nesmith Mr. G. J. Norberg Dr. A. B. Steele Mr. VJ , Tacquard Mr. R. N. Wheeler Mr. Mr. jv 1: Scptt Shipston Mr. J.' w. Whittlesey 312 33 28 28 514 515 312 312 515 28 515 . 514 511 28 32 511 28 33 28 28 515 514 28 46 Bound Brook (Bldg, 72C) New York New York New York South Charleston (Plant) Texas City Bound Brook (Bldg. 200) Bound Brook (Bldg. 72) Texas City New York Texas City South Charleston (Plant) South Charleston (Technical Center) New York New York South Charleston (Technical Center) New York New York New York New York Texas City South Charleston (Plant)1^ New .York New iork New York ucc 009628 v- V. x Union Carbide has been producing polyvinyl chloride in South ' Charleston, West Virginia, since 1935, and in Texas City, Texas, since 1947, The company stopped producing vinyl chloride monomer several years - : s* f "\,ago ,and now purchases the monomer from other companies. . V Even before the discovery of a possible relationship between ' - exposure to vinyl chloride monomer and angiosarcoma (a rare type of cancer -. 'that', affects the blood vessels of the liver), the company's work practices - . ' 'i 's''- " j, ;.v,Vhave been directed toward minimizing workers' exposure to any chemicals . V. 7 - `.-Atf**'' **.i.. *n* cluding vinyl chloride. .. '..''s,',- J -* l Union Carbide's vinyl chloride plants are operating well below , - the limit set by the U. S. government for worker exposure to vinyl chloride noiner. The government standard is 50 parts per million of vinyl chloride . y 'j. XT*1- * monomer and the level of exposure aa It Union Carbide plants is 25 parts per ,* .% . - .V,)4.sa' J ?' .^.'million on a time-weighted average, with some personnel operating positions < " - ~Mr*- l*.,` ... - > * at time-weighted average levels as low as 5 parts per million. .VAT*`' : 4 r. ' , ` Personnel monitors are being used by the company to evaluate the \ - r ` "sdegree of exposure to vinyl chloride by individual workers. In addition, ili^the air at the workplace is being monitored and when these indicate con- ' "^centrations above 50 parts per million air masks are required to be worn by - > "'* 'v` *:i' '' ' ' -* ` / ^ ^workers- ' '.Cj '/________1. iin *t-ht e ^area. mT1_hJis_ jis d1 one a1bou.t 5* per cen.t omf t. h4 e t.i.m. e f--or two- v^ 1 .*-: * v, . * thirds' of the operating positions. 7- v':pW*'.- When B. F. Goodrich disclosed early this year that several of employees who worked in the polymerization of vinyl chloride had of angiosarcoma. Union Carbide began a review of the medical records employees and the medical and death, records of former em- ;;?T>7:i;-:^.7afi>lhyees. ' : . . ;} : , ' 'V- 7'' .^V"':: To date, this review has turned up one case of angiosarcoma aiid< annoottlher possible case of the liver disease. The first case resulted '\--yr-v.. ^ ucc 009629 , . " v? in the 1968 death of an employee who had worked in vinyl .chloride poly^ '*4 T&A -, ! : > ' ' "/ , r: ' * 'V,.'. '"&? ' ` merization at South Charleston from 1944 to-1962, This death was'.reported .; ~- ijL r * -i* `-v J<\ *>: +; to the National Institute of Occupational Safety and Health '.on.Februarylis.. In mid-March, Union Carbide learned of, a liver' ailment of an, TM " ' " . -'c ' employee who worked in vinyl chloride polymerization from 1942 to,l964.lv' j; v- ** i; This illness was reported to NIOSH as adenocarcinoma, as it was initially1/ "^-2- . ' . .,.4 diagnosed by several pathologists. Subsequently"1 the National- Cancer- ,-"*v Institute disclosed at a meeting of the New York-Academy of Sciences oi??W.- May 10 that this case had been diagnosed as angiosarcoma. ,, Union Carbide'V v> -L- has requested written confirmation of this diagnosis and other employees can be informed. Union Carbide provides periodic health checks for its employees:: "i and those who have been working with vinyl chloride for ten years`or^more^^-^^^P^ 'v ... ' *2, will receive medical examinations'every six months. ' All of the company?S'^ .v. .v ; y ' vinyl chloride workers have been reexamined since February, 1974. VliiV.i^V,; ,'C . <, . .''l i' .V. V addition, the company has joined with Local 598 of the InternetionalV'''^.^'1'!' Association df Machinists and Aerospace Workers in assisting a.medicViflTj-^'^'vft*'^'.' -, "" . ,-*v . J I1-- . , JI iL,'* research team from the Mt. Sinai School of Medicine, New York,' to' further^ examine the vinyl chloride workers, : : y ^ Union Carbide is stepping up efforts to lower emissions by improving equipment and developing new engineering^ .'V, \i- as well as to provide advanced instrumentation to monitonr uvlinnwyll chloride .-'?-- ''' N ;- -.T*y. e - ' ' ' emissions. . 'v;. , * . i 'V * i \ The company is also participating in several induussttrryy-wide ?-'.' '' , V-,Vi 'J* ' - . studies to learn more about the problem and how to dea 1.wlthit^ ' These :-i% ; . ' ' studies are being sponsored by the Manufacturing Chemists A r- -----.----i -> * 'V>- 4?" >1 ^^,Ir L-" '' - UCC 009630 \ ^* the Society of the Plastics Industry and the National Institute of Occu-?'>*f4-"- r- _ + . J.. ** \ ,. * ~yv. >* . t.V pational Safety and Health. On May 10, the Occupationa1l Safety and Health Administra *^ proposed that the level of vinyl chloride monomer exposure at plants K be . lowered from the present temporary standard of '50 parts per million 'v : ; jfey to a "no detectable"* level. However, there is no technology or" operating procedure at present to achieve this reduction. , One alterVn-atiivvee** ww' oou'ulln^bbee-Vv.^wA/jtj to insist that workers wear air masks in the vinyl chloride opera ting,varea3'.* .-i""'-';1vs Experience has shown this to be extremely impractical.. `Thus; `it tKfr proposed -' ' ;r * ^ standard becomes permanent, and a person in the work area can never, posed to more than 1% parts per million of vinyl chloride in Carbide will find it virtually impossible to operate its vinyl'.chloridef&it^St'^^*^ *OSHA has defined "no detectable" level as one minus 50 per cent. '^ . ( s^-e {X^S) . 1" ............. vt - ' V V*' .. . - .' '' v -v.-y- V v - ^ ` *. - v . , / ' - l'1'',/ * '-f ..; V, -'`. ' Vi + ;^-V ./ .-ft * & '"^r ! 1' I'.' ;/*',!='' *. -' 1 . /./$?% r\ V * . `.(.Hi,, tlv11 `*`Ci..v * UCC 009631 % Qdv I4.r Oct . 75 _ Ot^i.75- Oc|,7(. 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