Document mqVVgQ92e83n3Q2Zn7RwYq04k

ONICH CARBIDE CORPORATION________________ P-2 HEALTH, SAFETY & ENVIROWCBNTAL AFFAIRS 39 OLD RIDGEBURY ROAD DANBURY, CT 06817-0001 TO: SUBSTANTIAL RISK EVALUATION BOARD B. Ballantyne R. G. Hanlon w. B. Chambers D. L. Heyvood J. N. Cleverdon E. K. Jensen M. N. Duvall W. C. Kuryla F. R. Frank H. G. Ott T. G. Fortney S. K. Phillips H. T. Prosser DATE: September 10, 1986 COPY: R. E. Bollinger H. L. Greenberg SUBJECT: Vinyl Chloride Epidemiology Study Attached for your file is a copy of the "FYI" letter concerning the QtA sponsored epidemiology study of vinyl chloride workers which was sent to EPA today. Very truly yours, WCX/bd Attachment 089 5H W. C. jRTryla Secretary, SREB occ UNION CARBIDE CORPORATION 390ujriogebubyroao.daiwi^itoi COMMUNITY AND EMPLOYEE HEALTH. SAFETY PHONE 1203) 794-8251 UA ENVIRONMENTAL PROTECTION CORNEUUS C. SMITH, M. VICV MIUDtMT Certified lull Return Receipt Requested SptEabr 9, 1986 Document Control Officer Information Management Division Office of Toxic Substances (WH-557) Environmental Protection Agency 401 H Street, 8.N. Washington, D.C. 20460 Dear Sir or Madam Enclosed is a draft report by Environmental Health Associates, Inc. entitled Epidemiologic study of Vinyl Chloride workers*, prepared for the Chemical Manufacturers Association. The draft report states at (i)> The study confirmed that the vinyl chloride workers experienced significant mortality excesses in angiosarcoma (15 deaths), cancer of the liver and biliary tract (SMB 641), and eanoer of the brain and other central nervous systam (SMl - 180). in addition, tbs study also found a significant mortality excess in emphysema (SNR - 179). while Onion Carbide Corporation does not agree, for the reasons stated belar, that Section 8(s) of the Toxic Substances Control Act applies to the information transmitted herein, this submission should be deemed to discharge any Section 8(e) responsibilities that might exist and should bs processed in accordance with UN's `substantial risk" procedures. Onion Carbide believes that the information herein on excess cancers (other than possibly biliary tract cancer) observed in vinyl chloride workers is corroborative of well-established adverse effects already documented in the public literature. The information on excess emphysema observed in vinyl chloride workers is not reliably ascribed in the report to exposure to vinyl chloride because oft (1) potential problems involved in the cause of death coding for emphysema) (2) the manner in which the diagnosis of emphysema was 08B9H ucc 004809 2 ud (clinically or pathologically); (3) tha possible contribution of other factors such as ssoting and geographical variation; and (4) the absence of precedents in experimental animals. You will also note that there was an apparent excess of biliary tract cancer in this cohort in addition to the excess of angiosarcoma of the liver. This apparent excess may be explained by failure to diagnose angiosarcoma properly. He recommend that further information on this study should be btained from Dr. a. C. Shaw of the Chemical Manufacturers Association (202-887-1100). CCStpnb Attachment cct Dr. H. E. Chambers Dr. H. C. Xuryla Vice President Community and taployee Health, Safety and Environmental Protection 0889H ucc 004810 Draft Epldaaiologie Study of Vinyl Chlerida Vorkuta Praparad for Chaaleal Manufacturara Aaaoeiation CbmH&re* Envlronaantal Moalth Ataorlataa, Ine. 520 Third Stroot, Suita 20S Oakland, CA 94607 Auguat 5, 1986 ucc 004811