Document pBBrk2EwrokEzn3jnGVw3ajwD

UNION CARBIDE CORPORATION old wogesury road, danburv. ct oeai 7 Corporate Health, Safety and Environmental Affaire Department March 25, 1985 James V. O'Gara III, Esq. Kelley, Orye ft Warren 101 Park Avenue New York, New York 10178 Re: Slrecl vs. Chemco, Inc., et al Rohm and Haas "Kydex" Dear Mr. O'Gara: Mr. Edwin H. Knauer's letter to you dated March 12, 1985, containing a general description of Rohm and Haas' manufacturing process. Is adequate to technically demonstrate to me that use of "Kydex" by Elm Coated Fabrics would not expose Its employees to enough vinyl chloride monomer to seriously affect their health. On consulting the plaintiff's complaint, however, the claim Is that polyvinyl chloride Is a carcinogen. "Kydex*1 admittedly contains polyvinyl chloride, thus Rohm and Haas Is not home free yet. One thing that disturbs me 1$ that probably all the other defendants, except Union Carbide, could be excused by the same general approach, l.e., they supplied no PVC containing vinyl chloride monomer. This would leave UCC liable for the whole claim. For your Information, I am attaching a portion of a study done by NIOSH, the whole of which was never published. This was provided by James Jones as a favor with the understanding that a final report would someday be published. The Plant M described could be similar to Elm Coated Fabrics. The most disturbing part is that this plant employed 325 people with a total worker role for 25 years of operation, possibly 1100 people (turnover 51 per year). One In four will get cancer from natural causes and If 10% of the cancer cases sue UCC, we are looking at 27 additional claims down the road. I worry a lot but I'd feel better If we knew who else sold PVC to Elm Coated Fabrics over the years. Very truly yours Attachment cc: Mr. L. A. Crlsorlo Mr. R. Horowitz, Esq 0292G R. N. Wheeler, Jr PRIVILEGED AND "CONFIDENTIAL MATERIAL SUBJECT TO PROTECTIVE ORDER" i L