Document nkoGV7rgZ2Dpp2qw7Y8LDdpDR

mmtfiN rARBIPE CORPORATION Chemicals b Plastics 270 Park Avenue, New York, New York10017 recd, J To: (See Attached Distribution List) Date: PLANT MGRS. Fll 'S_J recd. JUL 16 1974 WML RECtll^j^ct;; connnents on Proposed Standard .... a r? ,f\-^A For Occupational Exposure to VCM jUL 1 6 1974 reS.'JUL 1? 1974 dm------------ W. P. N. RECD. JUL 12 1974 DLE The testimony to date clearly established that an assessment of the risk of VCM exposure at any level was made impossible by the absence of medical knowledge. Under such circumstance, all uncertainties must not be resolved in favor of health safety as proposed by OSHA in setting non-detectable limits on VCM. Since the appropriate threshhold level for safe toleration of VCM is unknown, OSHA proposes to protect against the unknown by simply assuming that exposure to any VCM presents a health hazard. In doing so, OSHA disregards the documented human experience - SPI, Dow and Carbide testimony - which provides direct evidence to the contrary; namely, that exposure of workmen to moderate amounts of VCM over extended periods does not pre sent a health hazard. We must emphasize that our proposal rests not on the view that VCM exposure of workmen represents no risk but rather on the view that given the evidence, no substantial danger of angiosarcoma of the liver has been proven to exist with ex posures of workmen to any moderate VCM concentrations (50 - 250 ppm, OTA - 8hr.) We hold that OSHA must base its limits of exposure on proof of a demonstrable hazard to emphasize health rather than a conjecture as to the possible relation ship of incidence of disease vs. VCM exposure levels. ABS:ml Attachment CL h.dc. U A. B. Steele UCC 090699