Document nkGZbvMgzyvGjxqvaa9LwM11G

. r1 pprP'VE0 1 Q HII.L and KNOWLTON. Inc October 7, 1974 MEMORANDUM TO: VCM and VC Producers Group VCM Publilc Relations Committee SPI Vinyl (fhloride Group Hill and Kdowlton Vinyl Chloride Task Force SUBJECT: OSHA VCM Standards -- Press Activities OSHA's decision last Tuesdiy to release its long awaited permanent standard on vinyl chloride two days earlier han previously announced caught the industry and organized labor somewhat by surprise. Nonetheless, by a rapid mobilization of available manpower and resourres, a plan decided upon by the VCM Public Relations Committee at a meeting in Washington on September 24 was put into effect. Repre sentatives from SPI and Hill anl Knowlton attended the Stender press conference in Chicago and reported back promptly on events at the conference. At the same time, personnel from Hill and Knowltsn's Washington office and from Keller & Heckman were at the Department of Labe r to pick up copies of the OSHA press release and the standards themselves. The repease was telecopied to Hill and Knowlton in New York for immediate delivery to SPI Within a half hour of the ainouncement of the standards, an SPI press release, which had been prepared earlier in the day in anticipation of a promulgated standard stricter than that recommended by SPI was issued simultaneously in Washington, New York, Chicago and Los Angeles, and to selected members of the plastics trade press (a copy of this release was sent to members of the VCM-PVC Producers Committee that evening by Keller & Heckman). SPI-01714 In order to assure that papers received the release in time for inclusion in the next morning's editions, a summary of the standards was not added to the release as 1 2- - prepared earlier in the day Information that SPI had filed for judicial review was, however, telephoned that afte noon to various influential newspapers and wire services in Washington and New York. The following morning (V ednesday, October 2), the original SPI press release was updated to include information on the contents of the standards package and on the law suit, and was sent to the fePI plastics trade press mailing list of some 300 publi cations. A copy of that revise 1 press release is attached. Later that afternoon, a c jmpletely new SPI press release dealing in some detail with the law suit was prepare! and distributed throughout the country. A copy of that press release is also attached. Press coverage of the OEHA standards was extensive. Attached for your information are copies of articles that apieared in The New York Times. Wall Street Journal, Journal of Commerce, The Washington Post, The Los Angeles Times, and wire stories from UPI and Reuters. Also attached is the two part series from The Wall Street Journal on VCM, an editorial from The New York Times of October 4, and an excellent article from the Oc ober issue of Fortune. On Friday, October 4, a third SPI press release on the OSHA standards was issued, again nationwide. A copy of hat release is also attached. As a result of the numerms press releases issued by SPI during the course of last week, well over a hundred press queries were received by SPI in New York and by Hill and Knowlton in Washington. Once again, SPI has established itself as the prime source for industry comments on thd new standard. On Friday evening, Octo ser 4, CBS-TV evening news ran a segment on the new standards, in which feasibili y was the prime topic. The SPI press release from last SPI-01715 -3- June with regard to the results of the Arthur D. Little study was quoted extensively, A transcript of the show will b forwarded as soon as it is available, It is to be anticipated that, as a result of the press queries received, numerous articles on VCM quoting the SP|l position will be appearing in various publications over the next few weeks. Copit s of these will be distributed when available. /sr attachment IlialLuu Ji J/rt'/z);. c Matthew M. Swetonic SPI-01716 THE S O C ETY OF THE PLASTICS INDUSTRY. INC. 250 PARK AV ENUE NEW YORK. NEW YORK 10017 212 687-2675 Contact: E.S. Nuspliger (212) 573-9400 M. Swe tonic (212) 697-5600 FOR IMMEDIATE RELEASE. (Tuesday, Oct. 1, 1974) PtASTICS INDUSTRY LABELS OSHA VINYL CHLORIDE STANDARDS UNREALISTIC NEW YORK, O ct. 1 -- The Occupational Safety and Health Administration (OSHA) permanent occupat ional health standard on vinyl chloride monomer announced today is unrealistic, probafyly will be impossible for most, if not all, of the industry to meet and appears to hav ; been developed on some basis inconsistent with recorded facts, according to The Sor iety of the Plastics Industry, Inc. (SPI). The standard a mounced by OSHA calls for a limit of one part per million of vinyl chloride monomer as measured over an eight-hour working day, with a ceiling of 5 parts per milli )n as measured over any 15 minute time period. The standard applies to fabrica ors of finished polyvinyl chloride products as well as to producers of vinyl chlor de monomer and polyvinyl chloride resins, and is scheduled to go into effect January 1, 1975. SPI President Ralph L. Harding said that "OSHA may believe that it has adopted a compromise position between organized labor on the one hand and industry on the other, but the result is a standard that does not take into account in a practical wav the known medica and technological facts. " SPI-01717 2- - Shortly after lie OSHA announcement, SPI filed a petition for judicial review of the standard in the United States Court of Appeals for the Second District of New York. A similar suit was filed by Hooker Chemical Company of Stamford, Connecticut. Vinyl chloride monomer (VCM), an industrial chemical used in the production of polyvinyl chloric! e (PVC), a widely used plastic resin, has been linked in recent months with a hi gher than normal incidence of angiosarcoma of the liver, a rare form of cancer, an i<ong previously highly exposed workers. According to Hr. Harding, "the evidence presented at the OSHA public hearings in late June on V 2M clearly showed that the employee deaths from angio- sarcoma were a result of :onditions existing decades ago, when exposure levels were many times greater han they are today. Furthermore, data developed by the Dow chemical Company stowed no excess mortality from any cause among long term workmen exposed to evels below 200 parts per million (ppm), "OSHA apparerrtly relied heavily on animal studies in setting its standard, This is quite incomprehen ible, especially when more relevant human mortality data is available, " Mr. Harding said. At the OSHA public hearings the VCM-PVC Producers Committee of SPI recommended the estallishment of a ceiling standard of 40 ppm and an eight hour time weighted average (T\Vk'4) exposure of 25 ppm for the PVC resin industry, and a ceiling of 25 ppm and a TW,'4 of 10 ppm for the VCM producing industry, with additional phased reductionl; over the next few years. SPI also recommended that fabricators of finished PVC products be excluded from coverage under the standard altogether or that a separate, more relevant standard be considered for that part of the industry. (morei SPI-01718 -3 "Our recommend tions, " Mr. Harding said, "were based on an honest evaluation of what the industr , believed it could accomplish with knowm technology or with technology that could lopefully be developed within the" next few years. Not one shred of evidence was pr{ sented at the public hearings or since which could have lead OSHA to the conclu ion that a lower level was necessary or achievable throughout the industry at thi time. " As to the net effecjt of the standards on the industry, he stated, 'It would be inappropriate for us to comment on the overall impact until we have had time to study carefully the entU re set of standards. " - 30 - SPI-01719 THE SOCIETY OF THE PLASTICS INDUSTRY. INC. 250 PARK AVENUE NEW YORK. NEW YORK 10017 212 687-2675 Contact: E. S. Nuspliger (212) 573-9400 M. Swetonic (212) 697-5600 FOR IMMEDIATE RELEASE ( Wednesday, Oct. 2, 1974i SI I FILES VINYL CHLORIDE I-AW SUIT CHALLENGING NEW OSHA STANDARD NEW YORK, Oct. 2 -- A lawsuit filed by The Society of the Plastics Industry, Inc., on October 1, following the announcement of the Occupational Safety and Health Administration (OSHA) permanent standard on vinyl chloride is intended to seek "prompt ahd complete judicial review of the standard in an appropriate legal forum, " a spokesman for SPI said today. The SPI suit was iled in the United States Court of Appeals for the Second Circuit in New York. A companion suit was also filed by Hooker Chemical Company and. it was announced today, Firestone Plastics Company joined the apellate court suit in New Yoi|k and also filed individual action in the Sixth Circuit Court. According to Ralp i L. Harding, Jr. , President of SPI, the action filed in the appeals court is simply a petition for the court to review the OSHA standard and to examine the important question of its feasibility. SPI-01720 2- - "We believe now , as we did when we presented our testimony to OSHA only two months ago, that ai excessively strict standard cannot be met by the industry, " Mr. Harding sai^i "We also believe that the standard announced by OSHA is so restrictive that it merits immediate appeal. "In effect," Mr. Harding said, "OSHA has called for establishing operating standards for.the vinyl chloride and polyvinyl chloride industries which are impossible to achieve tqchnologically. " OSHA promulgate d a standard of one part per million of vinyl chloride monomer as measured over an eight-hour working day, with a ceiling of 5 parts per million as measured o>VI! r any 15 minute time period, SPI said this st dndard is in effect the engineering equivalent of the "no detectable level" origin : illy proposed by OSHA and therefore could have the effect of shutting down the i ndustry with a resultant loss of 1. 7-2. 2 million jobs in consuming and related intiustries and a loss of domestic production value of $65-90 billion annuallv. - 30 - SPI-01721 * y i !> h l t K Vinyl Choride Rules Seek To Guard Workers' Health to T> y?;i> T ff.fj / C f 2. I ^ *4 Washington*, Oct. I--The'" The final ru'es, to become ef- Department of Labor announced fective Friday, will continue today final industrial health the 50 parts per million level rules designed to reduce werk- through Dec. 31 and require a er exposure to vinyl chloride reduction, thereafter, to only a canecr-during chemical wide- one part per million averaged lv used as a basic material in over any eight*hour period and the manufacture cf plastics. -'ve parts per million averaged John H. Slender. head c# over any IVminute period, the department's Occupational These limits on the permis- Safety and Health' Administra* sible concentrations cf the tion, said the rules y.oufd pro-. chemical in the air of industrial tret workers by significantly work places would be tightened ?educing the amount of vinyl further on Jan. 1, 197(3. in that chloride to which they we.*e ex- - jhird phase of the new rules, posed. ; workers would be required to The chemical lias born shown wear respirators \f they were to induce incurable cancecs cf exposed to air containing nmre , the liver in seme workers cx- vinyl chloride than the one posed to it over substantial pjrt per million and five parts periods of lime. per million 1 mils. | The dangerous effects of the During 1975. respirator use chemical became a -public is- would be discretionary nt ain sue last January when the B. levels below 25 parts per! r. Goodrich Cniaatv. reportro million. thru se\cra; o; us employes The industry ob-erted ;mmehad died of relatively rare can-.diaielv after the new rules cers of the liver called ancio-.were announced here and at a sarcomas: The employes had National Safety Congress Mr. been exposed to the chemical Tender is attending in Chicago, over long periods of lime dur*. Firestone Pisstics Company ing their work. ;said it was planning c. leyri* Because of these and other challenge and declared thr. the deafhers reported later, the new rrl.nc "puts the vinyl plas- Labor Department safetv end tics industry on a collision health unit issued'an emergen- course with economic disaster."1 cy rule on Apn! 5 lowering the Thc_Soc.etv of the PI:>*=:;csT permissible exposure levels Industry" said ;hg oocupa-. from 500 par:< per million to lior.ai neuan standard v,as un- 50 parts per rv'lion. The emer* realistic and that it would' gency standard would have ex- probably be impossible for most. pired this Saturday. of the industry to meet it. ; sri-01722 The Wall Street >'ournal Monday, October 7, 1974 Health Hazards Vinyl-Chloride Scare Points Up Dangers Of Other Chemicals Substances Long Believed Safe Now Are Regarded With Greater Skepticism A Hospital's Hidden Perils By Barry Kramer stair Reporter of The Wall Street Journal It's a simple molecule: two atoms of car bon, three atoms of hydrogen and a single atom of chlorine. At room temperature It is a gas The molecule is called chloroethylene by chemists, but It Is more commonly known as vtnyl chloride. The chemical structure of vinyl chloride' has been known since the 1830s. Since a dec ade after the Civil War, scientists have \ known how to link, or polymerize, the vinyl- chloride molecules like beads on a chain to form a plastic called polyvinyl chloride, or' PVC. Smce the late 1930s, when B. F. Good-; rich perfected a commercial process for po lymerizing vinyl chloride, the plastic hast come to be a staple In thousands of house* hold products ranging from kitchen food wraps to construction materials. | Last January, the world learned soma-t thing else about vinyl chloride: It can causaj [ Thu is the second of two stories coir j renting implications of the discovery I that vtnyl chloride can cause cancer. cancer in humans. Twenty-six cases of a ' rare liver cancer have been discovered among workers in polyvinyl-chloride plants. All of the workers were exposed over many years to large quantltlee of vinyl-chloride gas. In recent months, furthe' evidence has coine to light indicating that the gas is also responsible for an Increase of other cancers among the workers in the PVC plants. As a result, there now are standards regulating vinyl-chloride emissions tn factories. Vinylchloride gas has also been banned for use as an aerosol propellant, and toe Food and Drug AdmUustration Is toughening restric tion of the amount of vinyl-chloride In PVC food wraps. Potential Dangers Vinyl chloride, of course, is far from the only man-made chemical known to cause cancer or, for that matter, other human ail ments Industry regularly works with toxic substances of all types known to cause 111 ef fects ranging from skin disorders to dam aged lungs, kidneys and livers. In fact, the findings about vinyl chloride point up the potcntia' dangers ol an entire group of simi lar chemicals, which, like vinyl chloride.^ contain hydrogen, carbon and chlorine. The chlorinated hydrocarbons, as the chemicals are collectively called, are used In a broad range o! products to which every human being has multiple exposures. ft would tfr difficult to find a person snywheit who uasn't come Into contact with products such as plastics, anesthetics, msec- < ticidea and herbicides, solvents and phar-| maceutloals, all of which can be made from ` chlorinated hydrocarbons. As a result of j their widespread manufacture and use, mol-! ecules from these products can be found ev- j erywbere on earth and In the upper a/tmo-| sphere. Such molecules are also commonly | found In human tissues. What Is particularly concerning some scientists Is the fact that tbe compounds are rarely found tn natural systems unless those systems have been exposed to man-made pollution. "Although all living things contain considerable amounts of chloride Ion very lew chlorinated organic compounds ac-1 ttmlly occur In living things," says Dr. Barry Commoner, director of the Center tor the Biology of Natural Bystems at Washing ton University In St. Louis. ! Trial and Error j Dr. Commoner further notes that bio-t logic evolution is a process of trial and error over millions of years; therefore, he says, the assumption can be made that since the chlorinated hydrocarbons are virtually ab-| sent from all living things, the compounds; are likely to be "evolutionary rejects," And: that means, he says, that If such compounds j Invade a natural system like that of man.j they are likely to be toxic. | "This means that Industrial operations that synthesize or make use of such sub stances, and agricultural and other opera-1 Hons that disseminate them Into the envl-1 ronment, ought to be governed by the level: of prudence that Is demaraud by the Inher ently dangerous situ - .ion," Dr. Commoner says. "That we now are discovering, with; increasing frequency, health hazards due to! dissemination of synthetic organic sub-1 stances, both In the workplace and the gen eral environment, Is evidence that we have! thus far failed to appreciate the need for! auch care." [ It to Interesting to consider that vinyl! chloride, In the early days following Its dls-i covery, was actively considered as an anes thetic for surgery But animal texts showed, that the gas caused heart Irritation, and It! was abandoned for that use In favor of other, substances. However, many anesthetics In! use today are chemically related to vinyl chloride-and there Is growing evidence that they aren't without harmful side ef fects. For the past several year*, for example, there have been scattered reports of 1U ef fects suffered by those who administer anes thesia and among others continually ex posed to anesthetic gases while working In hospital operating rooms. It has also been known lor some time that there Is gre&ter- than-expected Incidence of spontaneous abortion among female anesthesiologists and nurse-anesthetists and. more tellingly, a greater than expected rate of certain types of fatal cancer among anesthesiologists of both sexes. (There Is no evidence that such anesthetics pose long-term dangers to surgi cal patients.) One recent survey of nurse-anesthetists in Michigan showed that of those who worked In the operating room during preg- Please Turn to page tt, Column 1 ' Spl-01723 9 `22 THE WALL STREET JOURNAL, Monday, October 7, 1974 Health Hazards Scientists Take [workplace cau*e cancer only in combination iviili other chemicals. And the exposure of -moat workers to many chem.rala a: the iiame time would make It diffuult to plni point the offending chemical. Another Look at `Safe' Chemicals The cancer danger of vinyl chloride was spotted only because It caused an exceedngiy rare tumor, liver angiosarcoma of which there are only slightly more than 100 Continued From Pint Pope I researchers found that of 17} worker* who case* in medical literature. If vinyl chloride nancy, more than 169c delivered Infan j `died between 1940 and with birth defect*, compared with a blrt i ;cer. Both studies show 1973, 57 died of can higher-than-expected were such to as cause a more common malignancy, lung cancer, it wouldn't have been defect rate of under S% among nuree-anei . rates of cancer death. so readily detected as a carcinogen. thelists who stopped working during the r Based on previous, less-conclusive evi But testing Is only one part of the prob pregnancy. Other survey* have found hlg i dence Unking arsenic with cancer, the Na lem, the outer pari being what to do about er-than-expected rates of miscarriage aid tional Institute for Occupational Safety and toxic substance! once their dangers are ex stillbirths among the wives of anestheslol >- Health last January recommended reducing posed. There's some risk In almost every gists, even though these wives presumab maximum levels of arsenic In the air of tac activity, meaning that "acceptable" risks didn't enter an operating room until tkje torlet from the preeent 0.5 milligrams per have to be determined for various sub time of their deliveries. One explanation cubic meter of air to 0.05 milligrams. Indus stances. For example, even sugar. V In vanced by observers Is that the anestheslol h try has opposed that reduction, but there is jected tn sufficiently large does, will oause gists somehow carried home sufflde t growing pressure on the Occupations! cancer In laboratory animals; yet no one Is amounts of anesthetic gas In their breath <Jr Safety and Health Administration to Impose suggesting that sugar use be drastically cur on their clothes to affect their spouses. a "no detectable" limit on arsenic. tailed among humans tor that reason. Studies are currently under way to dete Obviously. It Isn't enough to learn that To arrive at a balance between risks and mine whether or not the wives M vtny workers exposed decades before to vinyl benefits, the risks must be fully understood. chloride worker* have been affected by ml: i chloride, arsenic and aabeatoa-to name a But very little Is known about the dangers uie amounts of the gas unwittingly carrlt 3 few carcinogens-are dying today of cancer posed to workers by the thousands of sub home by their husbands from the plants. C f or at other toxic effects of those substances. stances they work with, and there la little particular Interest Is the rate of stillblrtl But the question at bow to go about deter optimism that such substance* will be fully and miscarriage* among these women. Tt t mining whether chemicals are indeed lethal tested In the near future. Government agen studies are by no means simple, since tt s is the long term la the subject of some dis cies are understaffed and working with lim true rate at fetal wastage throughout the a pute. ited funds. A Toxic Substances Qoirtrol Act, tioci Isn't exactly known end therefore Suggested Solution which the Labor Department says It needs basis of compartoon Is difficult. Furthe One euggested solution la to teat all to strengthen its hand in controlling Indus more, the women's husbands are also ord chemicals already In the workplace and to trial chemicals, is stuck in s House-Senate narlly exposed to a wide variety at chem test other chemicals before they are used. conference committee. cals other than vinyl chloride*, hampering However, Dr. Irving J. Seilkoff, an expert Of course, even if euch an act were to be direct correlations. on environmental carcinogens at Mount paseed, even the moet tangulne an i't sug There are, of courae, other carcinogen: Sinai School of Medicine in New Tork, gesting that the workplace* of Amen. in or cancer-causing agents, and toxic diem claims that this would be "unrealistic and dustry will be cleared of danger. Neverthe cals in widespread Industry use that scientifically Impossible. less, It is becoming more and more evident even more dangerous than vinyl chloridi "Resources are limited," he says, "ao we that there is less willingness to accept Before the Labor Department began eetthi: can't go charging off In all directions at chemical dangers as simply as Inescapable standards for vlnyl-chlorlde emissions 1: once." Instead. Dr. 8ellkoff says that he and part of working life. factories-by an emergency decree In U& ' Dr. E. Cuyler Hammond, the chief health and then by a "permanent" standard effec [Statistician of the American Cancer Society, "Whatever happens," editoriallie* Lan Uve next Jan. 1 -- tt had Issued standard i last January for 14 other carcinogens. The Implications of all these studies an I standards are clear: Industry will no lange have worked out some tentative testing guidelines. First, he says, chemicals to be tested should be those to which large num ber* of workers are exposed. If many con cet, the British medical journal, "the vlnylchlorlde episode will have provided a salu tary lesson. It will not be quite so easy In the future as It has been in the past for any be able to assume blithely that unteste 1 chemicals In the work environment are sat simply because they've never demonstrate i any overt harm. Like vinyl chloride, which sumers are exposed to the chemical as well, he adds, the substance Is an even likelier target for study. An example of one such chemical Is car- chemical manufacturer to asaume. until proved otherwise, that a chemical to which workers are exposed is carclnogenically safe. There must surely be more systematic took yean to take its toll on worker health many chemicals thought to be harmli ! bon black, an Ingredient In rubber tires and, consequently, a widespread air pollutant. evaluation of Industrially used chemicals carcinogenic risk to workers." for may be equally Insidious. This may wel "We ought to be taking a look at what's hap mean that there will have to be eztenslv pening to carbon-black workers," the doctor animal testing of new chemicals before the; ays. (Scientists currently know that mas are Introduced and that workers' health wll sive doses of carbon black painted on the; have to be continually monitored to detec skin of mice has caused turnon.) Other! clusters of disease. prime study targets, he says, are sub-| The task of such testing and monltorlni ! stances whose chemical structure Is "*uspl-| would be mammoth indeed. There are cur cioui" (or not unlike the structures of rently 25,000 Industrial chemicals. Uori I known carcinogens). I than 500 new ones are Introduced even A Complication I year. With an array like this. It'* lljtely tha The tejung envisioned by Dr. Selikoff other vinyl chloride* are lurking In thi would be a combination of animal trials. In1 background. iwhlch hundreds of animals would be ex-j Allied Chemical Oorp. and Dow Chemlca posed for long periods to the chemicals Co., for example, recently reported to th< being studied, and statistical survey* of Labor Department'* Occupational Safety 'working populations that have handled thej and Health Administration that they had -chemicals. "There are agents to which mil-] found excess cancer mortality among work lions of people have been exposed which! era at two plant* that made pesticides witl now can be evaluated m terms of long-term i Inorganic arsenic. One study, conducted b> human experience," he says. "The human: Johns Hopkins University's School of Hy [data Is there waiting for us to evaluate It.", giene and Public Health, found that of the 22 (Because animal studies don't always pre-1 retired male workers from Allied * Bald diet what will happen in humans exposed to more pesticide plant who died between 19*2 the same substances, he says the human and 1972. 17 had died of cancer. At Dow1 monitoring is essential.) Midland. Mich., arsenical pesticide plant Ail thi* tesang would be complicated by which was dosed down 20 yean ago. Dow the possibility that some chemical* In the SPI-01724 -X THE JOURNAL OF l COMMERCE , Wednesday, October 2, 1974 <jSro-Ri BES-AK cn PAee ome) Vinyl Chloride Regulations Set By ROBERT M. LEWIN Journal of Commcroe Staff Tcugh new standards regu lating the amount of vinyl chloride gas to which workers may be exposed were an nounced by the Labor Depart ment in Washington and dhicage yesterday. The plan provides that on Jan. 1. 1975. the level of ex posure may not be more than one par: per million in factory air averaged over eight hours, or five parts per million in , any penod no longer than 15 minutes. John H. Stender assistant secretary of laoor m charge of administering the Occupation al Safety and Health Act. signed the new rules at a Ch,cago press conference yesteiday and said that he expected lawsuits attacking the stan dards from both labor and empiovers. T c.ti not take leng for Sienner s prediction to mate rialise. A few hours later, the _SMiled a petition for a Judi cial review of the Libor De partment'* atandard in the U. S Court of Appeals for the Second District of New York. N o injunctive relief was sought. A similar auit was filed by the Hooker Chemical Jr Plastic Co. in Stamford, Conn. Ralph L. Harding, Jr., (resi dent of the Society of the Pias tres Induatrv in New- York, issued a bi.sienng statement, saying that the proposed stan dard is unrealistic and prob ably wil be rupeesable to meet for most, if not ail, of the plastics industry. "There will be no excep tions," Mr. Stender said, an nouncing that the rule would apply to ail employers, even if they had only one employe. Mr. S.ttien let: said that the ex; isUng pr*visional standard which pent liits 50 parts per million level will continue until Dec, 31, 19 4 to give employers reasonable time to make changes in their plants^ r After the new standards will have been in effect lor one year -- or by January 1, 1976 -- it will be mandatory for , workers hiio are exposed to either one or up to five parts per mdllioi of vinyl chloride gas to wea r respirators. Until Jan. 1, 19 6 the use of respirators w LI be optional, provided the exposure is to not more than I parts per million, The rule: apply to chemical plants mal ing vinyl chloride monomer io resin manuiac- hirers malI ing polyvinyl chilo- ride (PVC) and to fabricators making pro hi cts from vinyl -- anything ft tm an automobile top to a r >ck music record, Mr. Stendei said that the rules apply to 7 500 manulacturing plants emp oymg 350.000 workert, and t< chemical production plants wrploying more than 6,500 workers, Mr Han In-ig said that the Labor Dep udinleent "mry be heve that lt has adopted a ccmpromja i position between . organized abor on the one band and t iduatry on the other. but the esuk is a standard (hat doe* n take taco account In a praouftal way the known medical od technological facts.'' Sone labor leaders had demaia led a- zero part per millioni stai da rd. During tie Jtase hearings in Waahingtot Mr. Harding aaid. "the evidence cat vinyl chloride nonomer clearly showed that the employe deaths Ire m angmoaarcoma were a suit of crttdmons existing de idea ago when ex po a u re eves were many time* grea|t:er than they are today. Funhei are. data devei- oped by the Dow Chemical Co. Mvnvd no excess mortality from any ause among iorgterm worlla mb exposed to leveis beiow DO parts per mil- hon OSH A apparently relied heavily on anrna. studies in setting its standard This is quite incur ipreh-enattoie. eqpedaily wr more relevar* hu man marr Jrity data 1* avail able Labor Sets Tough Standards On Vinyl Chloride Exposure (_'Tomp HEAD -- PAGE 2) SPI-01725 THE JOURNAL OF COMMERCE, Thursday, October 3,1974 Economic Disaster Seen OSHA Vinyl Standards Blasted Firestone Plastics Chief Sees Vinyl Regulations Courting a Major Disaster By WILLIAM H. LANDER Journal of Commerce Staff The stringent new govern ment standards covering vinyl manufacturing put the vinyl industry or a collision course witr. economic disaster which could throw two million men and women out of work. Todd C Walker, president of the F.restone Plastics Co., Potts- lown. Pa., said yesterday. The Office of Safety and Health Administration 'OSHA' of the Department of Labor has decreed that effec tive Jan. 1. 1975, only one part per million of vinyl chloride gas may be permitted in areas wnere operators work eight hours a day. The temporary standard of 50 parts per million, adopted ir April, 1974. will prevail un til the end of the year. Legal Steps Mr. Walker added that his company is initiating the nec essary legal steps to challenge the OSHA order, thus joining the Society- of the Plastics In dustry and Hooker Chemical & Plastics Co., which had al ready- filed suits. Hooker filed its petition in Stamford, Conn., and the SPI asked the U. S Court of Appeals for the Sec ond District of New York for a . judicial review of the order. Several SPI member com panies are expected to join in suit, as they did w-hen the SPI successfully challenged me New York City tax on piastics containers in New York Supreme Court two years ago. Dow Chemical also said it will seek judicial relief. Or. the other hand, Robtntech Incorporated in Fort Worth. Texas, announced that on the basts of its understand ing oi the announcement by the Labor Department, all of t s PVC pipe fabricating plants will meet the one part per million vinyl chlonde standard It also said that its new Shinrech plant at West- pert Texas w.il have little, if ary p: ob.em ;r. complying but the PainesvLe. Ohio piant wtti. require some mod_fccacioa at the reactor, slurry scupp er - and slurry drying areas Ruo:n'.ch said it believes these changes can be made within the time frame indi cated The Dow Chemical Co.. Mid- land M-ch . wh.cr. is a marrj- Jacas-o- at vinyl chloride monomer. In a stats m-ent said that the OSHA stand an-ds were "unnecessarily stnn g;ient" and not supported by thje data on Dow Chemical Co workers which was presenter at public hearings in Wash ngton in June. Mr. Walker, who Heads a di- vision of the Firestohe Tire t Rubber Co. which i a major PVC producer with capacity of some 400.000.000 founds per year did not mince words in his reactitm to the bSHA or- der. OSHA Standard "The permanent O ilHA start dard for vinyl chloqidle exposure." Mr. Walker- s. id puts the vinyl plastics in- lastly oo a collision course vith ecocomic disaster. `More impo>i rt antly. tt throws 2D,000 jobs down the drain, according to an economic impact study i lade iearlier this year by -the , u-thur D. Little Co. `TTiis study, other medical, scientific and en fi ineenng data submitted by the industry and indivii'dial comparties in re^ronse t< CJSHA s request, appear to h tve been completely ignored n establishug-this standard "The result is that ,t is economically un-realisti technicaUy unfeasible, dohtieaJly motivated, and med:< ally rfchculous, comparable a law aimed at slopping aJtomtAile deaths by lowering tie speed limit to one mile per hour." In Midland. C. B Branch, president at Dow (temicai. aid that "our data I iBsed on nearly X years of experience without any cases of ver eancer in&cates that he new standard is more n strictive than necessary to pr< tect the health of our workers. "We had as early as 1951 dropped from the : ten accepted exposure star dard of 500, to 50 parts per m: 1 100 voiun-ar-Jy as our Dow standard, and Dow- Chemical -S A. is currently opera ring ui net ai rm- ditions which genera lumt worker exposure to 4ss than 10 parts per million on an eight-nour time we -g tec average Tnese low lev i is o! 10 p.p.m. or less, which are being experienced, can only be achieved through advanced engineering methods and good jsork practices on the part of our employes. "We question the ability at the industry to develop the technology to meet the level of one part per million (time weighted average) and five parts per million ceiling la the time specified and we will seek remedies through the Ju<haal process." Rohtntech also took advan tage of the commotion of tne standards to announce that the Sbcntech plant at Freeport will have 150 miiiinr pounds more capacity than originally planned. This plant "is to ac commodate the continued de mand for PVC resin and should be completed by fall 1975," the company said. The plant belongs to Shistech Inc . a joint venture of Rofeiatech and Shin-Etsu Chemical In dustry Co., Ltd., Tokyo, which is e leader in the PVC field in the Far East. It's just bees learned that the original plan for the OSHA announcement was for it to be issued today, however the is suance was speeded up so a) to provide John H. Stander, assistent secretary of labor in charge of OSHA. wfih a ready made forum at the Qnd Nataoeal Safety Congress and Ebgxxition in Chicago spon sored by the National Safety Council. The shift In goveromedl plans, however, dud not catch the plastics mb us ay sleeping, so that within minutes at the signing of the new OSHA stan dard. the SPI was at the cour thouse asking for judicial re view At the meeting of the Coo grata in Chicago yesterday. R Heath Larry, vice chalnnaa of United States Steel Corpora tion. said that there had bees great potential values is the Occupational Safety d Health Acs. "tout they- have beer, more potential than real " A' one point he said: "We have seen more than wre ought to have f standards directed at 'ccnditiena' -- wtnen either require the irtv poss.h>. -- or require the po srble r tx impossible time fra-T." -- or requ-re the un- reasooable because there has not been an opportunity for an adequate research of the re-atioosn-p between -dosage and response' --and the relat.ve coast of reducing to different ievels of dosage. . . ." SPI-01726 THE JOURNAL 5F COMMERCE, Friday, October 4,1974 Reservations Voiced On Vinyl Health Rules By ROBERT LEWIX Journal of Commerce Staff CHICAGO -- Leaders of unions representing workers in plants producing and using vinyl chloride said yesterday that they have "cautious re servations" about the new health standards over the can cer-causing chemical. They agreed that the new three-phase job rules applying to the gaseous chemical are "a step toward, toward a good standard." But they emphasized that the new standard is not one that "protects every worker, which is our goal. Jour, H. Stender. assistant secretary of labor, in charge of administration of the Oc cupational Safety and Health Act. made public last Tuesday the "Trial job health rules" that are designed to reduce worker exposure to vinyl chlo ride. In discussing the govern ment's three-phase program, Jacob Cayman, secretarytreasurer. AFL-CIO Industrial Union Department, stressed that labor's goal is worker ex posure to no panicles of vinyl chloride a', all. "It could be that one part permillion in air exposure to vinyl chloride means no detec table limit," said Mr. day man. But we have not changed our view -- there shouki be no worker exposure to vinyl chlo ride or any gaseous chemical that causes cancer." Sheidon W. Samuels, the In dustrial Union Department's direct, of health and environ ment. said that the depart ment would consult with the doctors who have worked with the unions on the vinyl chlo ride problem. Mr. Samuels also said that meetings would be held with health and safety specialists of the 13 5-million member A F L-C 10 and affiliated unions and with doctors who have worked on the vinyl chlo ride problem. The issue las alarmed union officials side Jan. 22. this year, when the National Iristi- tute for Oc riipational Health and Safety told the Ocoupatonal Safety and Health Ad- minlstratioi (OSHA) that B. F. Goodrich Chemical Co. had reported the death of several employes rom a rare liver cancer (an giosarcoma) may have been iccupatonally relaled." Asst. LaJi or Sec. Stender said that inder the threephase progfiam, which is to apply to all snployers, includ- ing .those s ith only one work- er: -- The 1 vel of 50 parts per million in exposure to vin- yl chloride cow permitted, is to be cooti sued through Dec. 3L 1974. Mr. Sten.,< er isaid that would, givei emplo retirs "a reasonable amount of jme to accomplish changes a their plants that will permit them to reduce ex- posures or provide employes protective < quipmeot " -- Jan. 1975. employers must redact levels to one part per million in air exposure to vinyl ide -- averaged over any 8 hour period, and 5 parts per million averaged over any period longer than 15 minutes. -- Jan. ., 1976 -- the .third phase -- Workers will be re QUired to 1 year respirators if they are exposed to levels higher that the "1 and 5 parts per million ' allowable tains, However until Jan. 1. 1976. the wearing at respirators is optional lo exposure no gree- ter than 25 parts per million. Mr. Sta deir said that the new rule would cover the manufactub packaging, repackaging, transportation, storage, handling or use of vinyl ehl< ri ide or polyvinyl chloride They will not Apply to the handling or use of products made of polyvinyl. M r. dayman said that "something less than 50 parts per million has caused cancer. "We don't know what levels are tolerable. We don't know whether engineering is so price that zero can be at tained," be added. "We believe that it will be very difficult to monitor air exposure to one part per mil lion over eight hours, and five parts per million over a period up to 15 minutes. "Five particles for 15 min utes -- the monitoring can be so easily circumvented." Mr. dayman said that In dustrial Union Department of ficials would consult their spe cialists and doctors to deter mine whether lawsuits are to be filed to strengthen the job health rules. SPI-01727 THE JOURNAL OT COMMERCE, Friday, October 4, 1974 Plastics Corner Instrument Makers Offer Chromatographs as Judicial Opposition Takes Spurt By WILLIAM H. LANDES Journal of Commerce Staff The legal battle against the OSHA standard* (or vinyls which are scheduled to go Into effect sc Jan. 1,1375 has gath ered momentum. Started by the Society of the Plastics In dustry It has been joined By* Hboker, Dow, Firestone, and now B. F. Goodrich announce* that it pians to take legal 'step*. The level of one part per million ol vinyl chloride gas which w.,1 be permitted for an e ght-rour exposure to the opera cr contrasts with the present level of 50 parti per million. The new standards, Good rich said In a statement Is sued In Akron, Ohio, were es tablished arbitrarily and are not supported by the record of OSHA hearings conducted in February and this summer. Technology to attain these le vels does not aalat today. Therefore, the full-time uae ot respirators by all employes would be required by 1976 A spokesman for Goodrich said that it plans to seek a lag- a! review of the stsndard*. "It ia an intention, but we don't know exactly how or when we'll seek a legal review. We would like to point out that we are a member of The Society of the Plastics Industry, and that organization has already filed suit." Goodrich said that It Intends to do whatever is required to sustam operations at its plant. It said that the vinyl chloride exposure ia them had been re duced to an average of 13 to u pans per million, from the previous 35 to 60 p.p.m. In New York, the 3PI pro vided additional details about the Impending legal battle. It said that iu suit is intended to seek "prompt and complete judicial review of the standard in an appropriate legal fo rum. "An SFI spokesman as id that Fireside had joined in theSPI suit in the Seoond Cir- cu::. and had also filed an in dividual satloo la die Sixth Circuit. Hooker filed its suit in Stamford, Cana. Ralph LJHtrdlnt, Jr., prsai- dent of SFI, said that its sa lon is a petition for the churt to review jhe OSHA standard and to examine the important question of Its feasibility, "We believe now as we did whssi we presented our tes timony to I OSHA only two months sgcl that as excessive ly atrict studard cannot be met by thel industry. We also believe that tbe standard an nounced t>j| OSHA is so re strictive th^t it merits imme diate appea "In effect) OSHA has called for establishing operating standards tor the vinyl chlo ride and guyviftyl chloride in dustries which are impossible to achieve technalefiaaUy." The API laid that the new standard ts b affect the eng ineering equivalent of "no de tectable" [level originally, proposed by) OSHA and could therefore hive tbe effect of shutting down the industry with a loss lof L700,000 to 2,- 200,000 jobs In consuming and related Industries sod a loss of domestic production value of 995 to 9S0 billIon annually. Meantime the instrument makers appear to be the ones who might |profit from the need to accurately measure the minuscule amount of vinyl chloride gaa Which will be per mitted, One of the at to com* for- ward with announcement regarding a vay to measure the air to st the standards which go in i| effect on Jan. 1, 1976 ia Automation, Inc. of Ofcla. It baa a proceaslehrornstagrapriy system that It says can con- txiuously ptor anti record vinyl chicrh levels lower than one per miihon m air Robert Z. 'Ighsnan. mar kertng i ic hardware said the bea red tor this application an optlehrtm 199 pre< ess |gms chromato- graph with id stats pro- grammar an sample con- ditiomng syste n The system, employs two air pumps with automatic switch-over in the event of pump (allure. This switch-over mechanism U linked to an alarm for instant notification at a remote location. The analyzer is designed to monitor the normal ambient air tor vinyl ohloride. High concentrations of other com ponents suspected of inter, tonng with this measurement bevs been tested by applied automation and have been found not to interfere with the vinyl chlonde in analysis, Mr. Wightmao added. Honeywell Inc. is also ready with a chromatograph, as re ported in a UPI dispatch from Houston. Gene Manno, general manager of the Honeywell Process Analyser Center there said that his company has de veloped a ehromotogrsph that can measure loss than one part per million maximum and can automatically set off an alarm when the con centration exceeds or nears that danger mark. Mr. Manno said that the Honeywell chromatograph was first developed by NASA and the 'Jet Propulsion Labo ratory in the 19905 tor use in the Mariner program. He said at that time the unit had a very high speed, but did not measure is small amoixits as it does now. "It Was to have been in the herd module for crash landing on Mars. It had t deliver 50 measurements in 50 seconds before It crashed " The Honeywell expert said that hia group has already shipped etit of tbe units ts pkstlci manufacturers. He said they cost from M.000 to 115,000, depending on their versatility. TUt wa>himiVj* nr>t * New Rules Set to Reduce Vinyl Gdoride Risk / Tb tjaw | Administration fOSHA) came after loontlu at srrrr- (mTiboob!!'^ that worker, ex of <Wfri to Uk vtdciy Bkd pttt- rkVr to trhfcfc fortocyi ties industry faa wrr* ^rrrlo^- vorketi *>' be exprt^d, ***c j ine a rare bat fata' fcnn of sLTjsTM **" ***** * tiort tufstfo? lo tnnrw z su*, ,, bon workers out or war jobs. ,""rid traeed to workpiece **- TV new rule* liws Ut Oc- pororr ecw number w tlui piperioral Safety and Uealth'S). The Society of the PTastiee ladnxtry, ioc^ hied * i; in Cinwt Court of Appeals In Sew Took nsklrcj Vinyl Choride R ides Seek | to Guard Worke rsf Healthi l **1**1 ** T*t Tm% Tip* ^WASHINGTON. Ok-: 1--Thr The 4*1 itoe*,' to Income ef- j Department of Laboran.viu.wd ffctire Friday, win continue i today fatal Lrefuunal hreiihthe 50 ^arts per million levrij nfits designed to Rdti.** uork- threwih Dec. SI and require * j tf exposure to vinyl eMofide.'redJciloK, tlmeaftg, to only s rtinT-fMm'^ clvcinteol wk!e- oae part par million xve-iixi; It, tsoi as a basic material in over any ei*Jit.hour penod and: tho manufacture of piasocs. ;fiv* pai^s txr million averaged , ^obs H StcadiT. head of ow anJr IS-nuoule period, (he departronl's OccuittUonaJ Thm* limits on the permit-; Safely and Health Ari'nhis'.ra-.s,b)e cpnfmimin?.".; of the; tacts, "said the iert orker> reduce* the arbumyleo*usnwiptouuoiU>fScaw.pvn'i>o!y)-icufcWaoijciuJJi.nrteosfarhn-r.puM1.d'r at industrial 0e ti*hteevdj: I376 In the. chtonde to which they were tx third pHu* i*f H*e new rules. I posed. workers would be rrouifrd to! Ihe dseeccal tas been shown wear reipuatora if they werey. to .induct irvorabt* nneen of exposed to ao containing mere the bver tn seme workers ex- vinyl Jilonde than Ure one pcdrd to h cvw subsijtoiiai part c Clill>Ori tfVd f*v pm? peftfkht of limr p*r mill1 iit?i 1*--i*i* The dincerous e/Iorts r*f the During 1976, iterator dsanslexl became a public is- would sue Iasi January Then the B..levels aw 25 .pai|.v. per F. Gocdnch Ctrpany. rrpmted millKm I 1 that Several cf its emniayrs The nduitcy nhyected isuT>e- had dwd of trUi-vrly rare cas, diatety|_a_it_er_.the c--^---w- ru lea t nrt of the iiver railed aniO- were anpivuniesj here and at a t-a...n...o...r..ui --The employes had National bsletr Lonjtresj Mr ! been exposed to the Tender if a!trndm{ ia Cbinco 1 ov er lortt twriods of time dur- Firrvidne Flatties Company ta* thetr work aid il r pas pUnoir.e a leyal! Because of these and nchcr rhalleni^ and declared mat lhe I drat her repotted later, the new rui ? "puts the \ myt Dili-; Labor Department sat.'iv and ttcs tndl cm * coIIIsiits: health unit issued an f.-nerperv course | lh Ksumr d'sister.' ey rule on April 5 tower:.-!* tne rciy r,* I-- Plasrirti pi-rmisSilU* rvp'.'rujT levels tndj'-in o<-cupa-. from iOO parti per nv.iinm to ttemjl he||aith standard uat ujv- 50 parts per million. The emer- rrau;- a :3 that it would.' jenry nanrtaid mould have ex prohablv She tcntVritihie t,-,v ny.ti pired this Satutday at lb .riic'Stm' to meet it. j ""J- tor the judicial rrvie* of the OSH.V standard ft Bid tbe stanrUrd *snooneed Tcsterdar i* unrcslts, Ut aad It wfH be inppsfihi* far most 51 hot all of the iadnstry to meet it- Last April 5. OSHA aa onuct'd that wortcei* could be exposed (0 n more than M Parts pef min:hn of rlnyi chlo ride c*j in tha air and pro posed ereolaally reducing toe mriiotii.at lercl to zttv DurlBft tenzlbv bkH-p an the matter the isdostrf eiatmed it arou'td be Impr-cflb^t |to meet a detectsbl* level of }tJ fM lftdde the fitinejet I Under the new trial Miopa. jelfeclir* Friday, the prrwct iSdpart-per-anllllon expoaare Terri Win he allowed otsiil Dec- 51. After next Jan. > workers maty be rxpvwd ro n more than l part per PuTTice wnac< ever eixht boo re of cxpsisuie and DO eoneestratioa bteber than 5 parts per csf bam srrer sty LS-mlpsts oenod. Alter Jaa- t ar unt, eb EEtse expcwjr* levels will bo mpmed except that worker* exposed to auj-Jun" atrtrr.fw wiJ! hare to wear rerpirctora. FI tortawe FUitics Ca said the aew roles put the industry "oa a eolUsos cvurxe wifi oeoatomiemsaxter* AnofGcrat Of the firm saJd the rfstrieboors would "throw 2 suibno jotodow. the hraln." 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S3|i:SB|J Ul SjK);Ui3l]3<}| 3J uo 49$ sjiuin V6I jaqo^PQ `XBpsaupsM S3KI1 SHIEST SOT p.Hoa *r -xaaad KO'di 311HM NOQ : 01 UP' 'ii. CVIHVL CHLORIDE) wSEHIHGTGI-i (DPI) -- THE LABOR DEPARTMENT TUESDAY ANNOUNCED NEK RULES TO DRASTICALLY CUT T.L E AMOUNT OF CANCER-CAUSING VINYL CHLORIDE GnS TO WHICH FRCTORV HQRKEF 3 MAY BE EXPOSED. ONE FL.RSTICS COMPANY oFilD THE RlllUri THREriTiio j 0 THROW 2 BILLION WORKERS OUT OF THEIR v u 'z. the m RULES FROM THE OfcCUPnTIONfiL SfiFETV BHD HEBLTH ADMINISTRATION (GSHfi) CSHE AFTER SEVERAL MONTHS OF>GROWING EVIDENCE THfiT WORKERS EXPOSED TO THc WIDELY USED PLASTICS INDUSTRY GRS HERE DEVELOPING A RRRE BUT FATAL FOR?! OF LIYER CANCER. DEATHS AROUHD THE HORLD TRACED TO WORK PLACE EXPOSURE NOW NUMBER MORE THAN 20. LAST APRIL E w;; DSHA RNNOU ICED THAT WORKERS COULD BE EXPOSED TO NQ HORE THRU 50 PBRTS PER HILL ION OF VINYL CHLORIDE GAS IN THE AIR AND PROPOSED EVENTUALLY REDUCIN THE EXPOSURE LEVEL TO ZERO. DURING LENGTHY HERRINGS IN THE NATTER THE INDUSTRY CLAIMED IT WOULD BE IMPOSSIBLE TO MEET A DETECTABLE LEVEL OF THE GAS INSIDE THE FACTORIES. UNDER THE'NEW REGULATION p, EFFECTIVE OCT. 4, THE PRESENT 58 PARTS PER MILLION EXPOSURE LEVEL JILL BE RLLDKED UNTIL DEC. 21. AFTER NEXT TAN. 1 WORKERS NAY SE EXPOS ID TO NO'MORE THAN 1 PART PER MILLION RvL.'.'jL ^ rt.R EiGHT hUUl;b Ur EXPOSURE AND NO CONCENTRATION HIGHER THAN 5 FARTS PER MILLION OVER AN' 15-nI MUTE PERIOD. AFTER JAN. 1 OF 1?7S, TH SANE EXPOSURE LEVELS HILL BE REQUIRED EXCEPT *X Kusf.ERi EXPOSED TO ANYTHING STRONGER HILL HAVE TO HEAR RESPIRATORS. FIRESTONE PLASTICS CO. SI D THE RULES PUT THE INDUSTRY "ON A COLLISION COURSE WITH ECONOM C DISASTER. ' AN OFFICIAL OF THE FIRM RAID THE RESTRICTIONS WOULD THRQD! 2 MILLION JOBS DDWH THE DRAIN. 8 THE 2 MILLION FIGURE REFF E5EN7S THE TOTAL NUMBER OF PERSONS EMPLOYED IN THE PLASTIC? INI USTRY. ONLY SEVERRL THOUSAND WORK IN FnCTCr.t:; Nr.ERi THE Eh; ITSELF IS MADE BEFORE IT IS TURNED INTO POL: i i NYu CAlURIDc -- ; He S'. FORM WHICH LATER BECOMES EVERYTHING PROP CERT COVERS TO SUITCASE THE GAS NAS FIRST LINKED TO FATALITIES AT PLANT IN LOUISVILLE, AY., AND STUDIES AT SIMILAR FACILITIES LATER SHOWED OTHER CASES. OTHER GOVERNMENT AGENCIES HAVE SINCE MOVED TO ELIMINATE THE GAS rr^M -EROS . ; r r ~ r : r.i.r. Er- 1 i TURNED OUT IN A VARIETY OF CONSUMER r* r- ..'-s V " V ' " Y: r..; J i ; U r r l; i : r r\ n * iINTS TO PESTICIDES TO HAIR SPRAYS. Ur I .U'L * Uw . SPI-01731 FIRST ICS GP3UP CALLS GOVT VC RULING 111NPG55ISLE1 NEW VGR GCT 2 - THE SGCIETV OF PLASTIC? INDUSTRY Cfiil LED YESTERDAY'5 PULING BV THE LABOR DEPARTMENT, OH THE AMOUNT GF VINYL CHLORIDE IN THE FIR HO Pi ER5 ARE ALLOWED TO BRERTHE, "UNREALISTIC" AND "IMPOSSIBLE" TO MEET. . THE GOVERNMENTAL''AGENCY SHARPLY REDUCED THE AMOUNT OF THE.GRSEOUS VINYL CHLORIDE PERMITTED IN THE AIR T) BN AVERAGE OF ONE PBPT PER MLN fiS COMRPRED NIT \ THE PRESENT INTERIM STANDARD OF 50 PARTS PER ML i. 'THE RULIilG BECOMES EFFECTIVE JANUARY FIRST. IN fi PREPARED STATEMENT, THE INDUSTRY ASSOCIATION 5 AID THE RULING "PROBABLY HILL EE IMPOSSIBLE FCjR MOST, IF NOT ALL, OF THE INDUSTRY TO MEET. .. VINYL CHLORIDE MONOMER IS ft KEY INDUSTRIAL CHEMICAL USED IN THE PRODUCTION OF POLYVINYL CHLORIDE (PVC), A WIDELY USED PLASTIC RESIN THAT HRS RECENTLY SEEN LINKED TO A RARE CANCER OF THE LIVER AMONG [GHLV EXPOSED HORNERS. REUTER SSB8 SPI-01732 Sharp Drop in Vinyl Chloride Exposure j Is Ordered by Labor gency for Workers By a Wall Street Journal Staff Reporter WASHINGTON-The Labor Department ordered a aharp reduction In workers' expo- aure to vinyl chloride, a widely uaed Indus- trial gas that has been linked to liver can cer. The ruling, which comes alter nine months oi controversy, brought a lawsuit from the plastic industry, which contends the standard can't be met, and criticism rule contains loopholes. Vinyl chloride Is a basic ingredient In making many everyday plastic products. Hie new standard, Issued by the Labor Department's Occupational 8afety and Health Administration, requires that, start ing Jan. l, vinyl chloride levels In the air that workers breathe be held to one part vinyl chloride per million parts of air, aver aged over an eight-hour period. Actual levels may exceed one part per million for abort periods, but they must average out to no more than five parts per million for any 16-mlnute period within the eight-hour time span. The standard also calls for regular moni toring of plant air. regular medical exama for workers and establishment of "regulated areas'' where vinyl chloride exposure la high. It prohibits direct worker contact with liquefied vinyl chloride and requires posting of signs warning the chemical Is a "cancersuspect agent." Since last April, companies handling vinyl chloride have been under an emer gency restriction of SO parts per million, without any time period. The emergency standard was Issued after the discovery, beginning last January, of cases of a rare and fatal liver cancer, an giosarcoma, among workers exposed to vinyl chloride. Nineteen deaths among such workers in the U.S. and other countries have been attributed to liver cancer caused by long exposure to the chemical. Vinyl chloride Is a gas that ts processed to form a powdery substance known as polyvtnv! chloride. Polyvinyl chloride. In realn or pellet form, ts then fabricated Into a wtde variety of finished plastic products. Though only about 6.600 workers are em ployed In plants that make vinyl chloride and polyvinyl chloride, about 660.000 others, who work In facilities that create finished products from the polyvinyl chloride, will also be covered by the new ruling Workers who handle only finished products, and don't have any chance of contact with "raw" vinyl chloride or polyvinyl chloride, are the only ones exempted. The Labor Department initially proposed that exposure be limited to "no detectable level," without any averaging over time. This proposal pleased organised labor and some key researchers in the field of occupa tional health. But the Society of the Plastics Industry, a trade group, and many compa nies using the chemicals, denounced 11 as technologically Impossible and warned It would drive the Industry out of business. In selecting as Its final standard one part per million over eight hours and five parts per million over 16 minutes, the department apparently was trying to reach a compro mise between its original Idea and tbe toughest proposal offered by the Industry, which would have left exposures as high as 10 parts per million In some plants and 36 parts per million in others Tbe department sought to smooth further until next January the drop from the pres ent 60 parts per million. Also, it gave Its en forcement staff discretion to determine bow tbs companies must meet the standard. While the goal Is to reach the new levels | through "engineering and work practice" I controls," suah. controls must be deemed "feasible," and companies can deal with I any exposures produced by Inadequate con[trola by giving workers respirators. A date wasn't set tn the ruling for ImIprovtng plant engineering and practices to Ithe point where respirators won't be needed. jjWhat's more, until January 1*78 workers nay refuse to wear the respirators when exres don't exceed 29 parts per million, leven if they exceed the one part per million pver eight hours specified In the regulation. Deaplte this attempt at compromise, vever, the 8oclety of the Plastics Indus_and some producers sued the Labor D~ nent to overturn the ruling only moafter it was Issued yesterday. And Plastic Co., a unit of Firestone i Rubber Co., said It will ask a court to ay enforcement of the standard while the llta are being tried. Ralph Harding, president of the Industry up. said the standard is 'unrealistic, will be Impossible for most. If not 11. of tbe Industry to meet and appears to ^ve been developed on some basis inconsls- with recorded facts." The job-safety kency "may believe that It has adopted a ampromise position," but the result Is un| acceptable to the Industry, be added. Industry sources also Indicated dlspleare at the Inclusion of plants making fabri- 1 products from polyvinyl chloride The pustry had proposed excluding these nts, contending they didn't present any But the department said it decided to In clude them because polyvinyl choride resin pellets can give off vinyl chloride gas In snjall amounts during processing. It said, ever, if the plants weren't exposing ' ers to more than half a part per million, of Ivinyl chloride gas. they needn't under take any control measures. Midland. Mich . Dow Chemical Co. sain the standards were "unnecessarily 'ent" and unsupported by the data an workers that was presented at public Organised labor expressed some Immediate reservations o! Its own 1 In Akron. Ohio. Peter Bommar,.o prc? Ident of the United Rubber Workers utron which represents many vinyl chloride work ers. said "It would appear this thing has a number of loopholes In it." Mr. Bommantt reserved final Judgment until he has seen a full text of the regulations, but he was quick to take iasue with the decision to let workers , decline the use of a respirator until 1976 "We can't make a guy put on a respirator, and while he's not wearing one, he may be endangering himself." What is more, he- added, "The respirator situation is going to be even worse In nonunion plants." ! The department defended its reliance on the use of respirators, saying definite dates, couldn't be set for dealing with the problem! solely through engineering and work rules because "we are presently unable to deter-; mine when it will be feasible." It added. "We would agree that respirators have many drawbacks" but said, in the absence ot complete engineering control, they are needed. The official explanation ol the regula tions also said that although a deadline wasn't set for completing engineering and work-rule changes, a continuing plan, avail able for government Inspection, must be pursued by each company at a pace agreed on by safety Inspectors, until respirators are needed only occasionally It admitted, how ever. that at different plants this could lake as long as "several years." THE UJALL STREET TOURNfij_ CdED. , OCT. 5?, tf'T'f SPI-01733 Health Hazards Vinyl-Chloride Risks Were Known by Marjy Before First Deaths Hindsight Shows Weakness In Firms' Systems Aim ;d At Protecting Workers The Tip of a Large Icebe `g By Barry Kramer Staff Reporter of Thi Wall STitirr JournaL A few weeks before Christmas In II 48, Earl Parks, then 26 yean old, signed on a helper-trainee at the large B. F. Qoodr ,ch Co. plastics factory In Louisville, Ky. ' he plant had been making polyvlnyl-chlor de plastic from vlnyl-chlorlde gas since bef ire the war, using a process developed by Go xl rich In 1937. It was a growing Industry that Mr. Pa Joined. Polyvinyl chloride-dubbed PVC ahort--had found special, but limited, ap ill cations in the war yean, especially at fireproof coating for electric wiring fighter planes and ships. But In the lkte 1940s, so-called vinyl consumer produi ts, made from PVC, began coming into vog le and by the time the 1930s were under a ay polyvinyl-chloride products such as conti Inen. phonograph records and curtains w ire staples In American households. The basic Goodrich process, still In ^se today, pipes vlnyl-chlorlde gas Into large This ie the first of two stories eon ceming implications of the discover) that vinyl chloride can cause cancer. actor vessels; there, the gas Is agltatedltogether with a liquid and catalysts. 1 be process causes polymerization, a linking Io gether of the molecules of the gas (a m n omer) Into the long chains that give PVC ia polymer) Its strength and other di characteristics. In bis first years with Goodrich, It Earl Park's Job to crawl Inside the reactira after each batch of PVC was drained off I ad to chip away that portion of the polys that had congealed. During the hour-k og task, repeated several times m the course an elght-bour shift, Mr. Parks and otl er worker* who performed the same fund on would unavoidably Inhale the heavy, swe Kamelllng fumes of vlnyl-chlorlde gas tint had escaped polymerization. As the 1960s went by and the 1960s begi, n, Earl Parks was working his way up to 'he Job of foreman, a post that he had attalzled by the time that 111 health forced his ea ly retirement In the late 1960s. Is the yet rs that he had worked with Goodrich, the P 'C Industry nourished as thousands of new u^ee were discovered for the polymer. On March 3, 1973, St the age of 30. E^rl Parks died of angiosarcoma of the liver type of cancer that Is invariably fatal, Ills death attracted ecant public attention at ' he time, but today the significance of 1 !r. Park a Illness la unquestionable and shatt ir lng In Its Implications. For Earl Parks ca. ne to be one more statistic In turning a hypep epu into a reality: Vinyl chloride can U'-fiLL STREET JOUR M3.J- UBD. CCTt 2, JT74- L Deadly Statistics The link between angiosarcoma and vinyl chloride is further buttressed by other deadly statistics. Seven of Mr. Park's fellow workers at the Goodrich plant also con tracted the disease, and five have died. In all, there have been 16 documented angio sarcoma cases In the U.S. In recent years, all of them linked to vinyl chloride. In addl-| tion, 10 other cases have been reported In, Europe. While the total number of cases Is small, the Industry has been shaken to Its roots. The disease now Is known to work Insidi ously, slowly, during decades of exposure, the Implications being that the cases thus far are quite likely only the tip of an Ice berg. Nine companies, with 14 plants and 940 employes, currently produce vinyl chlor-1 tde monomer from ethylene, a petrochemi cal. The monomer, In turn, la used by 2l| compenlei operating 36 major plants and employing 8.000 workers, to make more than five billion pounds of PVC annually. (World-wide production la some 18 billion pounds annually.) Even the five billion pounds of PVC an nually produced In this country Isn't enough to meet the domestic demand for the plastic Into which PVC Is formed. From 3,000 to 4,000 processors, employing an estimated 700,000 workers, fabricate the plastic Into a wide variety of products ranging from vinyl floor tiles to shower curtains. According to a study done for the Society of the Plastics In dustry by Arthur D. Little Inc . as many ss ' 2.2 million Jobs depend on polyvinyl-chloride plastic. If PVC were banned, the study says, the annual loss to Industry In sales and pro duction would be some 163 billion to 390 bil lion. (The Manufacturing Chemists Associa tion estimates the wholesale annual value of all PVC products Is $3 billion.) Emergency Decree At the moment, no one believes the In dustry will suddenly come to a acreeching bait. However, after the first human cases of vinyl chloride-induced angiosarcoma were disclosed, the Labor Department's Oc cupational Safety and Health Administra tion Imposed a temporary emergency stan dard for PVC-factories; thenceforth. OSHA decreed, the permissible level of vinyl chlor ide In the air of such factories would be 30 pert* per million. This level was far below the Industry standard in effect for years, of 300 parts per million. OSHA's emergency decree was made last May. Since then, animal research found that tumors develop at 30 parts per million. Yesterday OSHA Issued a new permanent standard requiring employers after Jan. 1. 1973, to reduce exposure to one part per mil lion tn factory air, averaged over eight hours, and five parts per million averaged over any period no longer than 15 minutes (Sae story on page 22.) While considerably more stringent than the emergency decree, the new permanent standard--particularly with its flve-parts-per-mllllon provision and Its allowance of averaging--nevertheless falls ahort of the "no detectable" limit advo- Please Turn to Page tt, Column 1 SPl-01734 2 09 THE WALL STREET JOURNAL, Weanesday, October 2, 1974 Health Hazards: Vinyl-Chloride Risk Was Known By a Lot of Peopie Even Before the First Deaths Continued From First Page 4.000 in workman's compensation from Dow published its results in 1961. But the c&ted by unions, many medical experts and Goodrich before die died, but only after test of the Industry chose to rely or a Yale such groups as the National Institute (or Oc Goodrich protested that his Illness couldn't University study that recommended 500 cupational Saiety and Health, and the lave resulted from exposure to the chemi- parts per million as a safe level. This ,-ame American Chemical Society. This no-detect able limit would have constant, not average, adherance to one-part-per-mlllion levels. Therefore, it seems certain that the argu ment won't abate. .) level had been recommended by the Manu It was an alert Louisville doctor who first facturing Chemists Association since 1954 nade the connection between angiosarcoma was affirmed In 1942 by the American Con tnd vinyl chloride. Dr. John L. Creech, who ference of Governmental Industrial Hygien or years has treated workers sent to him ists and was given the force of law by OSH A As the controversy continues, it Is reveal >y Goodrich on a fee-per-patlent basis, bad In 1971. However, evidence at the OSHA ing to examine how the link between vinyl ollowed Earl Parka's case for some time, hearings Indicates that this level was regu chloride and cancer was established. If ven though he wasn't treating Mr. Parks. larly exceeded until this year in many nothing else, such an examination points out Jr. Creech says he bad been concerned plants. (The hygienists' group didn't recom the grave weaknesses of the present system ibout an abnormally high number of Good mend lowering the level to 200 parts per -or lack thereof--of protecting workers and Ich workers who had liver disease. When mlIllon lt72 four years after Dow con- others from Industrial hazards. le heard that Mr. Parks had died, he re-j^y^^j from further tests that repeated ex The judgment Is made In hindsight, but tails, he asked to Me the autopsy report. posure by workers to vinyl-chloride mon the history of vinyl chloride shows that evl It was In August 1973 that Dr. Creech omer at an average of 300 parts per million dence of Its toxicity was often Ignored earned that Mr. Parks had died the pre- or above for a working lifetime could cause What's more, the chemical companies loue March of angiosarcoma of the liver. changes in the liver.) knew, but kept secret for at least six months, the fact that Italian researchers had shown that rats develop tumors. Includ ing angiosarcoma, when exposed to low levels of vinyl chloride monomer. European companies, which paid for the animal re search. knew of these research findings for more than a year before the first human cases were reported but didn't reduce the exposure of their workers to vinyl chloride. But Dr. Irving J. Selikoff, an expert cm Die doctor aays he then realized that somehlng was seriously wrong, since another Joodrich PVC worker, a private patient of Jr. Creech, had succumbed to the same ype of cancer In 1971. Dr. Creech saya he tnew that liver angiosarcoma Is exceedingly are end that two cases among such a small ilant population was abnormal. (In fact, nedical men estimate that fewer than 30 axes occur each year in the U.S., striking inly one In 900.000 persons.) During the 1980s, there were reports of a dlMase called acroosteolysis among vinylchloride workers. The disease consists of skin lesions and changes in the blood ves sels, leading to degeneration of the bones ai the tips of the fingers and toes in those ex posed to high levels of the monomer (Emis sions of vinyl chloride are generally lower at plants where the monomer, or gas, is made, since the process Is less complex, and there Is less chance for leaks than at environmental carcinogens, or cancer-caus Dr. Creech met with Goodrich's occupa- ^ planta; none 0, the re ing agents, claims that blame shouldn't be lonai health director. Dr. Maurice N. John- ported angiosarcoma cases In this country placed at Industry's door alone. "We're all a on, who subsequently decided to ask Taber- has occurred among workers making vinyl- bit responsible," he says. "None of us did our homework." Culpability, he says, should be shared by scientists, government agen cies and labor unions. The Case of Earl Parks The case of Earl Parks Is Illustrative. Mr Parks first came to the attention of thaw-Oooper Associates Inc., a Berkeley, lallf , epldemlologlcal-studles concern, to lo a survey of Goodrich death records. But he study was hardly needed; on Dec. 19, a hird PVC worker at the Louisville plant lied at the age of 58; he had been at the >lant for 28 years. chloride monomer, and only one of the 10 deaths In Europe was in a monomer plant.t, In early 1967. the Manufacturing Chem ists Association arranged with the Univer sity of Michigan to study acroosteolysis among vinyl-chloride workers, particularly those who cleaned the reactor vessels and Goodrich medical people In 1984. when the Public Announcement others who were exposed to large concentra- company, concerned about the known liver On Jan 22 of this year, Goodrich officials I tions of vinyl chloride In the air. 77ie Michl- toxicity of ethylene dlchloride <a chemical met in Washington with officials of the Naelgan scientists reported In 1970 that although from which vinyl chloride Is made) tested tonal Institute for Occupational Safety and they couldn't pinpoint vinyl chloride as the the liver function of workers in the Louis Health and informed them at the three an- cause of the disease, worker exposure to the ville plant. floaarcoma deaths The following day. Ken- j monomer should be cut to 50 parts per mil-. Mr. Parks's readings were abnormal. ucky occupational-health officials also were lion or below. Nevertheless, he continued to work at the nformed and Goodrich made Its first public Other than Dow. which had already instl-1 name job. In October IMS. however, be was announcement tuted reductions In air level of the mon hospitalized with what was initially diag Almost since its first commercial lntro- omer. the rest of the Industry In the U S ig nosed as a bleeding ulcer. Doctors treated! luction, there have been reports that vinyl nored the recommendation Nor was there the "ulcer" without surgery, and Mr. Parks ihloride Is toxic above certain levels. In- any significant reaction to findings by Euro was released. leed. during World War n. vinyl chloride pean industry that animals developed ad He was readmitted to the hospital the fol vaa rejected as a surgical anesthetic be verse effects from vinyl chloride. This wasj lowing May. and the decision was made to cause animals developed heart Irritation at least partly because the Europeans down operate. But when the operation was begun, vhen exposed to It. In 1949. Russian acien- graded the importance of some of their find surgeons, Instead of finding an ulcer, found lets reported "hepatitis-like changes" In ings. For example. Prof. Pier Luigi Viola, a Instead that Mr Parks's problem resulted the livers of 2591 of the workers In s small medical director employed in Italy by Sol- from severe liver damage, which had PVC plant. vay k Cle., the Belgian chemicals company, caused blood to back up in the portal vein Then. In the late 1960s. research toxocolo- found bone changes in rats exposed to air leading Into the liver. The surgeons cor fists at Dow Chemical Co ahowed that art- levels of 30.000 parts per million ol vinyl rected the vein problem with a shunt and nais exposed to as few as 100 parts per mll- chloride; even more important, he found took a sample of liver tissue for analysis. lon of vinyl chloride (or 100 molecules of that vinyl chloride at that level caused The analysis showed that the liver had been dnyl chloride In every one million mod malignant tumors In the ear canals, lungs damaged by exposure to "chemicals " Can ules of air i developed alight liver damage. and bones of rats. cer wasn't mentioned. Baaed on its research, Dow began a pro (According to testimony at OSHA's hear gram in the 1980s to reduce the level of ings on vinyl chloride, held last June and rtny! chloride monomer in the air of its July. Mr Parks received a total of almost slants to beiow 50 parts per million. SPI-01735 3 j Prof. Viola reported his findings bef ire I an international cancer congress in Hous on: in 1970. It was the first reported link >e-j tween cancer and vinyl chloride. But hei professor expressed doubt about the pur ty of the vinyl-chloride gas he had used a id stated that the rat cancer findings, becat se they occurred at auch high levels of t le monomer, had no human implications. (Prof. Viola subsequently found tum( rs I in rats exposed to 500 parts per million; t ut this fact wasn't revealed until well after t le first human angiosarcoma cases were i evealed.) The Research Goes On Baaed on Prof. Viola's early cancer fin Iings in rats, Montedison S.p.A., the hut e Italian chemicals company, in 1870 aaki d iCeaare Maltoni, a respected researcher i t the Institute of Oncology in Bologna. Ital; . to do more extensive animal studies By O' tober 1877, Prof. Maltoni says, he had foun 1 that 250 parts per million of vinyl chlorid i produced tumors In rats in three parts o' the body; the ear canals, kidneys and th liver. The liver tumors included angloaai coma. The professor immediately lnlorme (his sponsors. The Europeans offered their informatioi to the Manufacturing Chemists Associatloi |in the U.S., but only ii the Americans guar lanteed confidentiality. With great reluc tance, the association says. It finally agreec I to the secrerv condition "because of the (vital importance of learning of any indica. Lions from th European research . . . with(out the dels : which could have resulted Ifrom duplication of effort." On Jan 30 1873, a year before the ttrgt human angiosarcoma cases were reperfel by B. F. Goodrich, the MCA finally got Maltoni data For five months, the secrecy restrictions were such that government agencies, PVC workers exposed to vinyl chloride and even company doctors were! kept in the dark. Then, In the late spring. 1 the Europeans agreed that the Chemists As sociation could pasa the Information on to the U.8. National Institute for Occupational! Safety and Health, the Labor Department agency that monitors worker cafety On! July 17. 1873, representatives of the asaocis-j tion and the agency met. One Certainty i There is some dispute as to what tran-j spired at the meeting. The Labor Depart ment agency claims It wasn't given the full story; the chemists' association claims that the agency misunderstood the findings. But. one thing Is certain: The agency, and: OSHA. made no move to change the itan-j dard of 500 parts per million and didn't doj to until after the human angiosarcoma! cases were announced. In Europe, by con- j trait. Great Britain had lowered the maxi-' mum level to 200 parts per million following the cases of acroosteolysls in the '60s; and West Germany had set t level of 100 parts, per million In 1870. based on Dow's 1861 re sults with animals. According to New Scien-! Hat, the Britiah science Journal, *No other: section of the U.S. or European industry fol- lowed Dow'e lead. The reasons for this In-! tarnations! oonfuslon are obscure.'' : This all changed quickly, of course, once j the first human cases of angiosarcoma were reported by Goodrich. Indeed, the swiftness, with which new research has been carried j out since Jan. 23 is perhaps without prece-; dent In the world of medicine and science. Much of this recent research Is con cerned with studies of the incidence of dls-! esse of all types among vinyl-chloride work- j era. Thus tar, some studies show that work ers exposed to high levels of vinyl chloride | show greater than expected Incidences not! only of angiosarcoma but certain other can-1 cer* as well. The ramifications of these find- j togs for the future of the industry and tta workers remain to be seen However, for the veteran PVC workers, whatever changes the findings produce will be useless to counteracting the Insidious effects of working day after day. year after year, to (what now is generally viewed as a contaml- | nated atmosphere. ' SPI-01736 Slje JJork Sitnejs FR DAY, OCTOBER 4, 1974 Try It--It May Be Safe On three fromts, Government agencies are moving to reject the strajjge principle that an industrial process must be prove* beyond doubt to cause cancer before any curb or atjntrol is warranted. That has been the contention of le Shell Chemical Company, makers of two pesticides Suspected as carcinogens; of the Reserve Mining Compan; accused of dumping possibly cancerous materials into Lake Superior; and of the Society of the Plastics In#ustry. whose member-companies have been using vinyl chloride, an industrial gas linked to liver cancer. After prolongledi testing of mice and some tentative findings involvii;g rats, Russell E. Train, administrator of the Environ:,ne:ntal Protection Agency, has ordered a ban, with minor exceptions, on the two pesticides, aldrin and dieldrin. Be rause the agency has yet to prove that they produce cancer in man--a process that could take twenty years' ;he manufacturers are appealing the action, despite ihe existence of adequate and safe sub stitutes for botf products. The states of Michigan, Minnesota and Wisconsin are united in appeal ng to the Supreme Court for an imme diate end to th< Reserve Mining Company's continued dumping of dan ;erous asbestos fibers into the greatest and last of the nation's still pure lakes. The company wants to go on with its daily deposits of 67,000 tons of tailings duripg the indefinite stay granted by a lower court. In a more mods st effort to cope with the ugliest threat of all, the Labo: Department has issued regulations to reduce the expos ure of workers to vinyl chloride. Six deaths from an;i osarcoma of the liver, a rare form of cancer, have occ irred in a single plastics plant, and this is believed only a gnm forerunner of fatalities still to. come. Recognizu g the large number of people employed in the plastics in 1ustry, the department is not suggesting a ban on the g`> but only rules to reduce the hazard --time limits on exposure, use of respirators, and the like. Yet even these are attacked by the Industry as too stringent. Industries wh< re such health risks have been uncovered would do well to consider a legislative risk to themselves. Sena|tiors Gaylord Nelson of Wisconsin and Philip A. Hart Michigan have already introduced a bill that, under : pecified circumstances, would prohibit "potentially dan; erous" activity of this sort until it is proved to be saf or it Is shown that "the benefit aubstantially outwe ghs the risk." The burden of proof would be placed where it belongs--on the shoulders of those who stand to gain from a risk otherwise confined solely to those i fho work for them. SPI-01737 6CZKHdS If governrrxi nt allows workers to be exposed to the gas, son e of them may die. If it eliminates all exposure, a valuable industry may disappear. ON THE HORNS OF THE VINYL CHLORIDE DILEMMA by Paul H. Weaver N'ot lon>: ago, cancel- and plastic were associated with each other only in the writings of Norman Jlailer, where they serve as symbols of decadence and self-destructiveness in the high-technology society. Since January of this year a series of medical reports has showi this associat inn to be a real scientific fact as well. It is i ow clear that vinyl chloride, a jras from which the second most widely used U.S. plastic is made, causes a fatal ca icer of blood vessel cells in the liver: the gas is also implicated in a host of additional diseases, ranging from gastrointestinal bleeding to chromosome damage. These discoveries have touched off a flu ry of repudi lory activity. The Food and Drug Adniinisti ation, the Environmental Protection Agency, and the Co lsumer Prodnet Safety Commission have all banned ae rosol sprays using vinyl chloride as a propellant. Flut the measure that cuts deepest was taken by the Occupation U Safety and Health Administration. OSHA has moved to reduce the permissible level of worker exposure to vi Hvl chloride in the plants where it is made or converted into plastic. Preparing for the iceberg 1 n the course of these developments, it ha; become clear lhat our regulators have a hard time thinking sensibly about problems like vinyl chloride. The businessmen be ing regulated and the workers affected seen to find it no easier. The fact is that our society seemt to have no airrecd-upon standards for dealing with situations in which medical and economic consideration;, collide headon. Since collisions of this sort wilh plainly be numerous in the years ahead--the vinyl chloride case i < widely iden tified as the tip of an enormous regulatorv iceberg---it seems useful to get clear on the issues involv ?d. If vinyl chloride were an unimportant substance, or if it were known to be dangerous only in very high concer.- Rcscrrrh associate: Sudneu Li ilcnsolni Stern trations, or if it were easy to keep human beings out of contact with it, there would be no particular problem. In that case the health danger could be completely elimi nated at little or no cost, and the question of what to do would answer itself. Unfortunately, the vinyl chloride issue isn't so simple. It seems to be very difficult and costly--and it may be im possible--to guarantee that no vinyl chloride worker will be exposed to the gas. Though no one knows for sure, it is possible that even very small exposures may cause sick ness or death. Yet it is also true that the plastics made from vinyl chloride are extremely important to the Amer ican economy. The market value of the gas being pro duced this year, and of the resin made from it. is perhaps $1.5 billion ; the gas and resin industries together employ about G.000 workers. But what most people think of as the "plastics industry"--the transformation of resins in to products--is a far larger operation. The total number of jobs involved in polyvinyl chloride (PYC) alone is about 320,000; the sales volume runs to many billions. And there are no entirely satisfactory substitutes for PVC at hand. Banning it would be certain to cause grave economic dislocations. Thus the regulators at OSHA are caught between the proverbial rock and a hard place. It is clear that their task should be to find the right "trade-offs"--to devise regulations in which the benefit of increased health for The most hazardous job in polyvinyl chloride plants ucpc :c ce ciea^ng o' the vats 'n wh-ch vinyl chloride poiyrne"zes into PvC --tna: w*ii!!sh resi^ a* the wor*er s tee' 0` the six-ee" Know'' u S cases c` vinyi.chionae-reiatefl i.ver cance- fourteen occu'rea in va' cease's Tne jod is presumedly a :pt less hazardous s-nce the introd-c?.:'' o' the resonators pretect-ve ccn.ng anc a>r evacuate tprov-aed cv *Ke can- C'-ng r;se' 'hat Shown here The Starless s'ee1-lined va' S ^ 0 w ~ .s 'h B F Gccdr-cn s.Ded'ickiown New<^efsey cant pe'hacs th-e res' mop. e-o ,o u c t*p .c ehtered a^d c'??"ec ~3~ja . > o-ce a rron'h Uhtii recency vats m mos' oider carts w-ere en'ered once cr twxe a day 150 *: = SPI-01738 G'Oski'' j, The View from NIOSH: Make It Safe On January 22, 1974, Dr. Maurice Johnson, environmental health direc tor for B, F. Goodrich, called on Marcus Key, director of the National Institute of Occupational Safety and Health. Johnson had a discovery to report. Three workers in Goodrich's Louisville polyvinyl chloride plant had died from angiosarcoma of the liver since 1971. Key summoned Ms top aides, who agreed that they had aii emergency on their hands. Two days later a small army led by NIOSH Standards Development chief Vernon Rose, invaded the Louisville plant to conduct the first of many "walk through" inspections. Within a week, Rose's task force had a list of recommendations for re ducing worker exposure to vinyl chloride: protective coveralls, shoes, and g oves for workers exposed to P\ C. airtight suits and respirators for rdactor cleaners. --[daily showers for exposed workers. a 50 parts per million suggested ediling on vinyl chloride monomer ei posure. Normally, writing a criteria doc ument--NIOSHese for a recommendec standard--is an eighteen-month process involving exhaustive study. Ir this instance, however, Rose relied oi guesswork and precedent. Assumirg that vinyl chloride causes cancer tl rough inhalation and skin contact, hr modeled his standards on those ujed earlier by NIOSH for industrial rcinogens. Aiming for a mid-March deadline, N'llOSH organized a hectic series of etings and studies. By the end of February, its toxicology group had bi en unable to determine the carcinog< nicity of VCM below 50 ppm. The :dical group had suggested a bat tery of liver tests for PVC workers, but industry and labor had split over the exposure ceiling. Industry urged 50 ppm, which it knew it could achieve; labor advocated "no detect able level," refusing to treat workers as guinea pigs. In this situation, Rose simply toughened and expanded on his ear lier recommendations. Most impor tant. he decided that the ceiling for vinyl chloride be set at "no detectable level"--the only exposure he knew to be safe. "It is doubtful," he conceded in a memo to Key, "that n>n/ plant can show workroom levels of nondetected." To meet it, respirators would have to be worn at all times He wasn't sure this was practical, but he was certain it was safe. On March 11, Dr. Key submitted NIOSH's recommendation to Assist ant Labor Secretary John Stender. When OSHA proposed its permanent standard two months later, it incor porated most of the NIOSH text ver batim, including the ."no detectable level" provision. The View from Firestone: Make It Practical To Todd C. Walker, the towering, outspoken president of Firestone Plastics, OSHA's proposed standard was as much a crisis as the Goodrich bombshell had been to NIOSH. He was determined to resist the stand ard with "the maximum information" at the OSH A hearings in Washington, D.C., this summer. Walker assembled four task forces --legal, engineering, financial, and medical--to develop a Firestone-rec ommended standard on a crash basis. Four alternatives were to be studied: the interim 50-ppm standard, "noildetectable." and two intermediate levels chosen arbitrarily--40 ppm maximum with a time-weighted aver age i TWA 1 of 25 ppm. and a 15-ppm ceiling with a TWA of 10 ppm. For each level the questions were: is it safe and is it feasible' Weeks later, the medical group was ui able to say positively that any of tl e levels was unsafe. An epidemiolo rica! study of Firestone's rubber a id PVC workers showed no signifia nt differences, suggesting that 50 PI1 m was not relatively unsafe. The engineering group reported tl at the nondetectable level was un- at|tainable. It also forwarded a criti [ue of OSHA's proposed work peac ti es. Protective clothing for all w irkers was unnecessary, it said, beCl use PVC dust is not a carcinogen. V CM gas, which is, could be kept ay from the skin only by air-tight SI its, which would be "hot, cumI)( rsome. expensive, and dangerous." O 5HA's provision for air-supplied re spirators for all exposed workers w is also ill advised. These would be u ncomfortable ("an instrument of tdrture"j, fatiguing, probably haza i d ous, and would interfere with )rh. One portable type weighs t\ enty-eight pounds and would have tc be changed three times an ho.ur. Nbnportabie respirators could be used, but workers would be attached to air hoses (themselves a workplace hazard) and confined to a radius of less than fifty feet. The financial group reported that capital investment would have to double to attempt reaching a nonde tectable level. The legal staff conclud ed that OSHA's proposed standard was unfeasible and therefore illegal. When it came to deciding what level he truiihl recommend, Walker had a problem. His medical evidence showed the three levels above nondetectable to be equally safe. His en gineers said that the feasibility of the lowest of these (15-ppm ceiling with a 10-ppm TWA) was uncertain, and Walker ruled it out. Left with a choice between the two higher lex-el?, he opted for the 40-ppm ceiling with a 25-ppm TWA to show that Firestone was willing to do more than the mini mum. Thus, with a practicality rem iniscent of NIOSH's decision to rec ommend . level it Inmr was safe. Firestone ended up recommending a level it knew it could achieve. 152 r c a 7 c N O'c'cr?' SPI-01740 workers is balanced against the increased cost to the plas tics industry and society as a whole. Unfortunately, this task has remained largely unacknowledged. OSHA probably will end up compromising on the de gree of exposure to the gas it will allow; its decision is apt to be announced this month. But the agent y has been under terrific pressure to view the issue befo e it in absolutist terms, as if its only legitimate concer n wi'ere the preservation of absolute security for the vir 1 plastics industry, or the achievement of perfect safety for vinyl chloride workers. For a while, it seemed a foregone concl jsion that OSHA itself would opt for perfect safety. On May 10, it formally proposed that the new standard for \|inyl chloride be set at "no detectable level," i.e., that no p lant'would be allowed to operate so long as env of the St: R could be found in the air or in contact with workers, The industry replied, in effect, that any such standard woulc be technicallv impossible and economically disastrous, nd that if OSHA went through with it, the polvviny chloride industrv would be put out of business. OSHA's final decision will affect more than this single industry and its customers. The vinyl chloride issue may be viewed as the first major test case for a new movement in government regulation. The leaders of the movement are three of the newest federal regulatory aifjencies, all created since 1970 : EPA, CPSC, and OSHA. Onie general idea behind all of these agencies is that busin ?ss can no longer promiscuously pass on to society all tl indirect costs nf running a modern economy. As Sheldo i W. Samuels. health director of the Industrial Union D ipartment of the A.F.L.-C.I.O.. put it, "The free ride on s Dcial costs is at an end. In the plastics industry you'r seeing a manifestation of social costs With jurisdiction over virtually every produc t and sub stance, these agencies, together with the FD V, are be ginning to use their sweeping powers to reduce the pub lic's risk of chronic disease, especially from industrial products. Some of the agencies are subjecting new sub stances to rigorous pretesting before they are a lowed on to the market. And with the vinyl chloride case, they have tackled the first of a long list of basic substance? on which our industrial economy is already built. It could put you to sleep During the first decades of its commercial existence, vinyl chloride seemed a most unlikely candi dat e for the role of heavy in a historic regulatory drama Put into full-scale U S. production in 1939, polyvinyl c hb ride was b.'i'li'd :i' a "miracle'' material: cheap, stable, re-resistant, and able to assume an extraordinary range cf s< oft and hard forms. Its major applications now inc u ie coated fabrics (like those used in automobile seat cov ars), wire insulation, floor tiling, pipe and conduit, ph onograph record^, and medical supplies, e.g., blood-stor tee bags, In the beginning the vinyl chloride gas se ened to be virtually harmless. The only apparent dangers were of explosion (at concentrations beginning around 3G.00O parts per million) and narcosis. In fact, during the 1940's the gas was tried out as a medical anesthetic, but doctors abandoned it when it was found to cause heart arrhythmia. With low prices providing little incentive for conservation, producers paid no particular attention to workplace exposure levels so long, as they were safely below the point of fire and explosion. And yet exposure levels in plants producing the gas itself were probably not very high even in the early years. Vinyl chloride is synthesized from chlorine and petrochemical feedstocks (usually ethylene) in a con tinuous closed process. The plants, which resemble oil refineries (and in some cases are attached to them), are open to the air. Historically, the heavy exposures have occurred in the plants where vinyl chloride is polymer ized into PVC, the whitish powdery resin from which actual plastics are made. It could make you "high" Polymerization is a batch process : vinyl chloride mon omer (VCM) and other substances are put into a pres surized vat, heat is applied, and hours later, when polymerization is completed, the vat is emptied, opened, and cleaned for the next batch. The process is full of leaks. In most of the early plants the gas could be smelled almost constantly (VCM has a faintly sweet odor that seems to be detectable at concentrations above 2,000 parts per million), and workers occasionally got "high" from the fumes. It is widely agreed that in this early period, lasting into the 1950's, exposures of several thousand ppm were common. During the 1950's, as the vinyl industry grew, a trickle of little-noted and often inconclusive medical reports be gan to raise doubts about the monomer's presumed harmlessness. In 1949 a Russian group found a hepatitis like condition in more than one-fourth of seventy-three PVC workers .examined, and over the next ten years European researchers encountered other symptoms: skin lesions, a circulatory disorder, gastritis, and derma titis. to name a few. By the mid-19G0's these had been confirmed and were described collectively as "vinyl chloride disease." Later in the 19G0's, acroosleolysis. a disease involving a degeneration of the finger bones, was identified among workers who clean polymerization vats. As these findings accumulated, producers began to reduce exposure levels. In 19G1 the American Conference of Governmental Industrial Hygienists, a voluntary standards-setting organization, had put the maximum safe exposure at 500 ppm. During the 19G0's industry began working to get much lower than that, and by the early 1970's exposure levels were generally in the 100-to200-pprr. range, with short-term "excursions" to levels man;.' times higher. In this general downward movement, Dow Chemical continued page 200 SPI-01741 FORTUNE OclcOf' t97< 153 Vinyl Chloride continued from page 153 was far and away the leader. In 19G1 it hac conducted an animal experiment showing: liver effects a levels as low as 100 ppm and had decided to get its own p ants below 50 ppm. By the early 1970's, Dow had aehievi fl average exposures in the neighborhood of 25 ppm in ts copolymer plants (one of which produces resins for 1 aranWrap). In 1970. Dr. Pierluigi Viola, an Italian ph sician studying acroosteolysis for Solvay, a major E lropean PVC producer, reported an unexpected discover} After twelve months' exposure at 30,0f)0 ppm, many < f his experimental rats had developed cancers. Doubts about Viola's procedures led .Montedison and other Europ an producers to commission Dr. Cesare Maltoni to unde take a largescale animal experiment to see if this cam logenic effect could be replicated at lower exposure levels. Bv the end of 1973 Maltoni's well-executed study had sho vn that levels of VCM as low as 250 ppm induced a varietj of cancers in rats, including angiosarcomaof the liver. ! n June, 1974, he reported angiosarcomas at 50 ppm. American producers began to join the inqi iry into vinyl chloride and cancer in 1973. Early that year the Manufacturing Chemists Association decided to coi nmission two massive studies. One was an animal study s omewhat like Maltoni's (it has since confirmed his findings). The other was an epidemiological analysis of the morbidity and mortality history of American vinyl workers, In December, Dr. John L. Creech, a Louisville. Kentucky, surgeon who is plant physician for B.F. Goodrich's massive PVC installation there, received a report that one of the workers had died of angiosarcoma of the liver. F.emembering that another worker had died of the same cause two years earlier, he notified a superior. In midJanuary, 1974, while a systematic mortality study of Goodrich workers was being organized, Creech received a report of a third angiosarcoma death. On January 22, B.F. Goodrich announced the three Heaths and their cause. To date, a total of eight persons employed at the Louisville plant have been found to have contracted this disease, They blew the whistle themselves As of January, 1974, literally all the information link- ing vinyl chloride to cancer had been developed by the industry on its own initiative. As Ralph L. Harding Jr., president of the Society of the Plastics Industry, observed, "This is a unique situation. Industry financed the studies, and industry blew the whistle on itself.'' But this was quickly forgotten in the furor that arose during the weeks following B.F. Goodrich's continued page 202 200 FORTUNE October 1974 f' .___ . ` ' ' ' ' - ' -. - - ' s * *** *. ' ' ' i SPl-01742 announcement. Within days, regulator; public-health doctors, and union officials had begun to dominate public discussion of the vinyl problem. Within w ;eks,- the Louis- viHe Times initiated a series of stories a leging that in dustry had engineered a Watergate-style cover-up of the angiosarcoma discovery, which it abandor ed only when it saw that the information was about to anyway. This charge was symbolic of the manner in whi :h the initiative passed out of thehands of industry. It was seized, rapidly, by a loose but; not uncoordinated network of regulatory agencies, governmfnt research in stitutes, academic medical teams, labor ui ions, and other groups united by a common commitment o eradicate en- vironmental causes of disease. This "reg latory-medical complex" is largely the creation of a decad< s federal legis- lation in the medical and environmental flelds. Its unoffi- cial leader is Dr. Irving J. Selikoff, prbfess<}r of community medicine at the Mount Sinai School of Mledicine in New York City. The one-man power elite White haired, gracious, and preternatu|r;ally energetic, Selikoff is best known as the man who explored the haz- ards of asbestos and who fought for m a ly years to get thorn reduced. Dut a glance at his crcden ials shows him to hold so many oilier distinctions and p sitions that he constitutes a virtual power elite all by him elf: a recipient of the Albert Lasker Award of the Afnerican Public Health Association, he is also director o Mount Sinai's Environmental Sciences Laboratory, gov ernor and past president of the New York Academy of' Scie nces, editor in chief of Ev ru tnnu, ntal h'lsrin rh. pres ent of the So- cicty for Occupational and Environmen al Health, and consultant to the A.F.L.-C.l.O. as well as an almost end- le-s list of medical organizations and go ernment insti- lutes. He seems personally as well as ssionally close to nearly everyone who matters in gove nment occupa- tional medicine, and has excellent c in the press, which he uses skillfully. Though he insist that he is only a scientist, Seliku/T is also a crusader an I reformer, ami the weapons he takes into battle, aside from his many personal talents, are research and public y. Within a month of C.F. Goodrich's announcement, half of Selikoff's staff was working on a s eries of medical and epidemiological studies of workers at three older PYC plants. Researchers from the Ha ard School of Public Health began an analysis of mor dity and mm-- tality in Goodrich's Louisville plant. The Xational In=titute of Occupational Safety and Health vvhich does re- search and standards development for OSII,A. began a major epidemiological study of worker at four older plant.-, and together with OSHA sent out umerous teams to conduct "walk-through" inspections PYC produc- lion facilities across the nation. In Mi SelikofT con- veiled in New York City a large intern lonal working group on vinyl chloride, held under the auspices of the New York Academy of Sciences. As Dr. Joseph K. Wag oner of NIOSH described the position of the many re searchers who entered the field. " `Seek and ye shall hnd' is where we're sitting right now." What they found was a great deal of information that linked vinyl chloride ever more closely to a variety of diseases, and this information in turn generated news paper copy. To an attentive reader, the cumulative im pression conveyed was of a hidden crisis slowly uncov ered. With each passing week, the discovery of yet another angiosarcoma case or the release of a new report seemed to show the crisis to be graver and'more wide spread than it had been the week before. The tacit message was that industry had failed, and that govern ment would have to step in and do something fast. Federal regulators were quick to respond. By early February NIOSH and OSHA were actively at work on the problem of workplace exposure. (See the report on page 152.) By the beginning of April OSHA had issued an emergency temporary standard of 50 ppm and in May it proposed "no detectable level" as a permanent standard. But during the summer, the plastics industry, which had maintained a low profile during the preceding months, reassumed the initiative under the leadership of S.P.I.'s Ralph Harding and Jerome H. Heckman. The burden of the industry position was that OSHA's pro posal was not required on medical grounds and was tech nically and economically unfeasible. In its place S.P.I. advocated a phased reduction to 10 ppm as an average and 25 ppm as a ceiling by 1976. The industry case was set forth in considerable detail and with much documentation during the OSHA hearings that began on June 25. Making policy in a desert It was clear at the hearings that, in the end. the vinyl chloride decision was going to be made in an informa tional desert relieved by only the most occasional oasis of knowledge. It was established that vinyl chloride causes cancer and other diseases. It was also established that, over the course of two decades, industry had re duced exposure levels in its plants by a factor of some thing like 50 without experiencing notable hardship or burdensome expense. But beyond that almost everything was uncertain. One large area of uncertainty concerns the shape of the so-called "close response" curve for vinyl chloride between 0 and 50 ppm--the range within which, presum ably, OSHA will set the permanent standard. To date, no animal experiments have been completed at exposure levels below 50 ppm, and since historic exposure levels in most existing plants have been above that level, it is ex tremely unlikely that epi<3e"miologi''ai studies can reveal anything about human response below the level. The data for Dow Chemical's Midland, Michigan, copolymer plant. 'nntuvtrd ]>aie 20J 202 SPI-01743 where exposures have been monitored fo upwards of a decade, are difficult to interpret. Dow's own studies sug gest no adverse health or mortality effects for workers at exposures below 200 ppm ; however, Dr. Selikoff's group reports a significant incidence of abnorjnal symptoms even among Dow workers. Where data are unsatisfactory, one mu|st fall back on inference and theory--but these have pr 3v ed even less satisfactory, and much more subject to cjispute. At the theoretical level, there is disagreement o\ er how cancer is caused. Advocates of the "no detectabh level" argued for the so-called "one-hit" theory of car cer causation, which holds that there can be no such thing as a risk-free exposure to a carcinogen. The theory impl ies that any identifiable exposure to vinyl chloride is ci xtain to cause angiosarcoma, at however lo\v a rate. But there is another theory of cancer ca jsation, which emphasizes the role of the body's immune i ystem in combating cancer. According to this theory, dancers appear when the immune system breaks down. If what a carci nogen does is to weaken the immune system, and if the weakening process requires a certain leve of dose, then it is possible that there is a risk-free level of exposure. At the present time, there is no definitive way to evalu ate the truth of these competing model . Thus when OSHA chooses a standard, it will do so i 1 almost total ignorance of the different rates of cancer md other dis eases to be expected at different exposure pevels. The cost of approaching zero The agency will be just as uncertain a pout the other major point in dispute--the level below w h ich it is not economically feasible for industry to redh ce exposure, "No detectable level" advocates point to the huge exposure decreases that industry has alread ' achieved, to the fact that many producers got below 50 ppm soon enough after the emergency standards w me issued on April 5, and that not a few were far below hat. To many regulators, it seemed obvious that industry could get to a near-zero level if it really wanted to. Industry representatives argued vehen entlv that a nondetectable level simply could not be atta ned. "Even a system that doesn't leak, leaks," thujnd( ned Todd C. Walker, president of Firestone Plastics, at the OSHA hearings. The companies also argued that efforts to approach zero would be extremely expensive, irestone, for instance, detailed every capital expenditure that would be necessary if it tried to reach "nondetectaliil e" exposure levels and concluded that the total cost w on Id equal the entire value of its existing plant. Even th ?n. Firestone insisted, it would not ultimately achieve a "n mdetectable" exposure and would be forced to go out c the plastics business. By the end of the summer, it appeared hat even the OSHA staff felt the standard might be u justified. An August, 1074. report by the agency's Division of Program Evaluation and Research observed: "First, i( is not clear that it is technically feasible to comply with the proposed standard without a shutdown of the entire vinyl chloride industry. Second, it is not clear from existing experimental and other historical data that a `no detectable level' stand ard is justified. And third, it is quite clear that compliance with the proposed standard will require substantial cap ital investments and lead times." They'd call it a sellout If these findings should lead OSHA to compromise-- to set an exposure standard of, say, 25 ppm--the agency should not expect to be praised for its moderation. It may even be assailed for violating its charter. The Occupa tional Safety and Health Act of 1970 states that OSHA, in regulating toxic materials, "shall set the standard which most adequately assures, to the extent feasible, on the basis of the best available evidence, that no employee will suffer material impairment of health or functional capacity even if such employee has regular exposure . . . for the period of his working life." Members of the regulatory-medical complex would surely insist that a compromise was incompatible with these words--and would see it as an unprincipled sellout, sacrificing lives for dollars. Industry, meanwhile, is apt to view whatever level is allowed as an arbitrary interven tion, reflecting political emotionalism rather than reason. And whatever the level, it is hard to believe that the new vinyl chloride standard will do much to end the confusion and uncertainty that currently prevail in many different industries subject to regulatory power. The vinyl chloride hearings have made it clear that practically nobody in government, industry, or labor is willing to discuss these regulatory issues in trade-off terms. "We don't equate lives with dollars and cents--not at the Department of Labor," John Stender, Assistant Secretary of Labor in charge of OSHA, declares. Even spokesmen for industry seem unwilling to chal lenge Stender's formulation head-on. "If we know we're exposing our workers to a known health hazard, we get out of the business," says Dr. Ben Holder of Dow. In the course of the long argument about vinyl chloride stand ards, businessmen have shied away from asserting that some level of mortality might actually be "worth it." In stead, they have tried to smuggle some practical consid erations into the discussion by pointing to problems of "engineering and economic feasibility"--as if feasibility were an absolute. One reason for the general reluctance to think in costbenefit terms is to be found in the language of the Occu pational Safety and Health Act itself. But another nel son lies in the ethos of the regulatory-medical complex, which has something more oh its mind than the rate at which people get sick or die. It is committed as well to a larger conception of the good society. In this society the idea of health is central. Ever more continued pane loi. SPI-01744 PCPT'JSE C:' 203 remote causes of disease would be eliminated. The role of medicine in this society would be differ ;nt; it would no longer merely cure, but would actively redesign the environment and ways of living to prevent disease. In evitably, it would be a society in which doct ors, by virtue of their expertise, possessed considerable pcwer. The role of markets would be sharply curtailed, inasmuch as they often lead people to make decisions contrar; to their best medical interests. In this sense the regul itory-medical complex is a political movement. As such it perceives in issues such as the vinyl chloride standard s symbolic im portance that transcends the particular merits involved. They don't like business And, of course, it is an antibusiness mdvement in its underlying commitment. American -regulatory agencies seem to reflect the times in which they wen founded ; the new regulation was established in an era cf intense con flict and hostility to business, and there is ittle prospect of the movement's suddenly acquiring another personali ty. For all its unattractive implications for regulatory equity and consistency, this fact is not entir :ly without its redeeming aspects. By pressing industry ha -d, these agen cies will hasten economic modernization. It is clear that they have long since achieved immense sue :ess in raising health consciousness in industry and labor alike. As Dr. Ralph Langner, an industrial hygienist at Dow Chemical, says, "Vinyl chloride is to industrial hygiene what Rachel Carson was to the environmentalists." In any case, if Americans are now going to assume the responsibility of deciding what is a "socially acceptable risk," and thus of implicitly putting a price on human life, surely it is desirable that the critical decisions not be left entirely to business--or to any one group or center of authority. A process of indeterminate struggle between business and antibusiness forces, yielding decisions more political than rational, seems preferable to a system in which a single cooperative establishment coolly announces the exact going rate at the close of every business day. Even so, it seems clear that the process of conscious ness-raising could usefully flow in the other direction as well. The regulatory-medical complex would not be any the worse if it had a clearer sense of the novelty of the concept of health it is promulgating and of the uneasiness of its relationship to the existing economic system. And it could take more fully to heart the potential conse quences of its regulatory interventions for ordinary liv ing standards. As G.J. Williams, vice president of Dow Chemical, remarked recently, "You could probably not find a single thing in the world that's essential, but they all go towards making life pleasurable. You can do with out almost anything, but not without everything." END The Bounded Main continued from page 131 cooperation. Ironically, there's a good chance that the U.S. will be leading the trend to unilateral action. interpretations of innocence Because of the diversity of its inter ests in the sea, the U.S. had been expect ed to play a keystone role in locking to gether a compromise among all the di vergent points of view represented at Caracas. In fact, however, the confer ence was one of the first manifestations of a remarkable reversion in the inter national posture of the U.S. From a pre occupation with the politics of peace, we have moved to a preoccupation with re sources and revenues. The clash between this new U.S. stance and the ideological preoccupations of the less-developed nations brought the sea-law negotiations to a standstill at Caracas. To be sure. American economic con cerns originally began the erosion of thfe freedom-of-the-seas principle. In 19 45, President Truman unilaterally de ck red the U.S. to be sole owner of the m neral resources on its underwater co itinental shelf, where oil and gas had ently been discovered. This move was qi icklv followed by a rash of unilateral cl. ,ims by other nations, not merely to of shore resources but also to territorial w iters wider than the traditional three m les. In most cases, the new limits re set at twelve miles, but some coun tries, beginning with several in Latin A nerica, claimed absolute sovereignty 01 er areas extending as much as 200 m|iles to sea. At that point, the U.S. woke up to what it had set in motion, in particular tie implications for shipping and aviatipn. Traditional maritime law recog- zes the right of "innocent passage" tl rough any nation's territorial waters it ha? always been vague as to what tl e term meant. With the advent of new k nds of traffic, including airplanes, mis- iie submarines, nuclear-powered ships, and supertankers, various states have adopted their own interpretations of innocent passage--such as prohibiting aircraft overflights, requiring advance notification of warship passage, making submarines travel on the surface, or forbidding passage to tankers in order to avoid the danger of oil spills. Plannera in aore straits When combined with the almost worldwide adoption of territorial limits greater than three miles, these con straints on innocent passage had serious implications forall maritime nations, but they especially worried the U.S. Navy and its Soviet counterpart. The heart of the problem was the "straits issue": with even twelve-mile limits, more than 100 important international straits fall entirely within national jurisdiction. Cold-war military planners were ap palled b'j the prospects of emergency ship and aircraft deployments being held up by a straits nation or of ballisticmissile submarines being obliged to 204 = c-.-.zte' IS"? SPI-01745 THE SOCIETY OF THE PLASTICS INDUSTRY. INC 250 PARK AVI HUE NEW YORK NEW YORK 10017 212/687-2675 Contact: E.S. Nuspliger (212) 573-9400 M. Swetonic (212) G97-5G00 FOR IMMEDIATE RELEAS E (Friday , October 4, 1974) SPI SAYS OSHA WORKPLACE SAFETY STANDARD PLACES BURDEN ON PLANT WORKMEN WASHINGTON, Oct. 4 -- Workplace safety regulations announced today by the Occupational Safety ind Health Administration (OSHA) for the vinyl chloride and polyvinyl chloride indu^try place a tremendous burden on Industry workers to protect their health, The Sf>ciety of the Plastics Industry, Inc. (SPI) charged, Ralph L. Hardi ag, Jr., president of SPI, said the standard formally published in today's Federall Register runs contrary to the spirit of the 1970 Williams-Steiger Act which created OSHA, in two ways: 1. It seeks impose operating standards which are technologically impossible to achieve indusltry-wide. 2. It require 3 workers to wear uncomfortable respirators for extended periods of time while at the same time giving them discretion to take off the masks under certain conditions pri|or to Jan. 1, 197G. SPI-01746 Harding said the OSHA regulation states that beginning Jan. 1, 197G wearing of respirators shall be ihandatory for workers exposed to levels greater than 1 part per million of vinyl ciloride monomer (VCM) averaged over an eight-hour period and five ppm over any 15 minute period. ,TUntil that date,' Harding said, "the same regulation says wearing of respirators is 'discretionary for exposures no greater than 25 ppm. Since OSHA's own expert witnesses have te ntified that respirators are 'instruments of torture', it appears workers are first being told that there is a level of vinyl chloride exposure which doesn't require donning a respirator but that ultimately those respirators will be mandatory whenever VCM evels reach 25 parts per million. " Harding said that n effect, the OSHA regulation sentences the worker to imprisonment in a cumbersome and uncomfortable respirator, since industry contends that it is an engineer ng impossibility to reduce VCM levels in plants to the point required by OSHA. "As we read the OiHA act and the legislative intent expressed prior to passage, the law was never intended to eliminate the worker's job in order to make it safe nor was it intended to irake the worker's eight-hour day the equivalent of a shift on the rack, " Harding adeed. The SPI president f aid this is why the trade association, whose members account for more than 95 perce it of the viny l chloride and polyvinyl chloride produc tion in the U.S., have asked the U.S. Court of Appeals for judicial review of the standard. Meanwhile, he said the regulatory agencies of the Federal Government also have a responsibility to assure the general public that products made from PYC are completely safe. (more) SPI-01747 -3 - "Even the OSHji regulation does not apply to the handling or use of end products made from polyvinyl chloride, " Harding said. "Further, officials of agencies like the Food and Drug Administration and U.S. Senators have publicly stated there is no hazard in these end products because the vinyl chloride content of such products is either non existent or so infinites imally small as to be unmeasurable. "But they need to tell the public that. In today's shaky economy the nation cannot afford a public loss of confidence in plastic products which arc among the most omni-present in society'. Unfortunately, the cumulative effect of federal pronouncements could have y1 is effect. "What needs to hie stressed is that the hazards related to vinyl chloride and the manufacture of polyvinyl chloride involve the direct inhalation of unreacted vinyl chloride monomer gas jy workers. Many, many articles in common usage involve hazardous materials it the early fabrication stages, 'We don't stop d linking water because it is purified with chlorine, " Harding said. "Chlorine is, of course, an ingredient of vinyl chloride. In any case, The Society of the Plastics In lust ry believes appropriate federal agencies should make these distinctions clear to the consuming public. " - 30 - SPI-01748