Document pdDKLn8KBEQ0MenbKr1XRLD7
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MANUFACTURERS AIBSQSOn/C'IItATTI/IMONJ "
1001 Conn*otlout Avnu, N.W. WiiMngten, D.C. 20030
202/872-8110
FEDERAL REGULATION
RA No. 009-74 August 26, 1974
VINYL CHLORIDE MONOMER IN AEROSOLS CONSUMER PRODUCT SAFETY COMMISSION
The CPSC proposal (39 Fed, Reg. 18115, 5/23/74) to ban and to require repurchase of all aerosols containing vinyl chloride monomer which are subject to the Federal Hazardous Substances Act was finalized by publica tion in the Federal Register of Wednesday, August 21, 1974, pages 3011230114. Persons adversely affected by the order may file written objections on or before September 20, 1974 and may request a hearing. A hearing will be granted if objections are supported by grounds legally sufficient to justify the relief. Except for those provisions stayed by filing proper objections, the regulation will become effective October 7, 1974.
The preamble of the order summarizes the information relied upon by the Commission for imposing the ban and discusses the submissions filed during the original comment period.
In setting forth its reasons for promulgation of the order, the Commission among other things concluded:
1. That the Congressional intent of Section 15 of the Federal Hazardous Substances Act requiring repurchase of banned hazardous substances was not only to provide retailers and distributors a mealis to recover economic losses which may result when a product is declared to be a banned hazardous substance, but also contemplated that the provisions of 15 would facilitate the removal of such products from households.
2. That the degree and nature of the hazard presented by the use of self-pressurized household products containing vinyl chloride monomer is such that the public health can only be served by keeping those products out of the channels of interstate commerce. The action to classify such products as banned hazardous substances applies to such products irrespective
2- -
of the date on which the products were introduced into interstate commerce.
3. On October 7 all self-pressurized household products con taining vinyl chloride monomer will be subject to all provisions of the FHSA applicable to banned hazardous substances including repurchase under 15.
Please advise us by September 10th of your views as to any CSMA action.
Department of Legislative lfb and Regulatory Affairs
jm itZ M i
ea
CHEMICAL Vr SPECIALTIES ~ MANUFACTURERS ASSOCIATION
1001 ConnMtlaut
Avnu, N-W.
on
Washington, D.C. m
20030
202/072-8110
FEDERAL REGULATION
RA No. 010-74 August 26, 1974
CONSUMER PRODUCT SAFETY COMMISSION PROCEDURE FOR DISCLOSURE OF INFORMATION UNDER THE FREEDOM OF INFORMATION ACT
The Federal Register of August 21, 1974 (39 Fed. Reg. 30297) contains proposed procedures of the Consumer Product Safety Commission for disclosure or production of information under the Freedom of Information Act. Pending issuance of final regulations, the Commission intends to use these proposed rules as guidelines in making its records (including those from all acts transferred to the Commission) available to the public.
The preamble of the proposal contains a broad statement to the effect that information exempted from disclosure under the Freedom of Information Act may, where not prohibited by law, nevertheless be made available when the Commission determines that disclosure is in the public interest. This statement is toned down somewhat by a following paragraph which cites 25(c) of the Consumer Product Safety Act wherein accident or investigation reports may be made available to the public so long as it does not identify any injured person or person treating the injured person without their consent.
The proposal is divided into 3 subparts applicable to the following areas:
(1) Production or Disclosure under the Freedom of Information Act (5 U.S.C. 552(a))',
(2) Exemptions from Production and Disclosure under the Freedom of Information Act (5 U.S.C. 552(b)) and
(3) Disclosure of Commission Accident or Investigation Reports under the Consumer Product Safety Commission Act (15 U.S.C. 2074(c)).
Interested persons may submit comments on or before October 21, 1974. Please advise us by October 1st of your views as to any CSMA submission.
Department of Legislative lfb and Regulatory Affairs
CHEMICAL /
SPECIALTIES *' MANUFACTURERS ASSOCIATION --
1001 Connecticut
Avenue, N.W.
Washington. D.C. 20038
r"O1'*0h
202/872-8110
FEDERAL REGULATION
RA NO. 011-74 August 26, 1974
FDA - VINYL CHLORIDE AS INGREDIENT OF DRUG AND COSMETIC PRODUCTS
The Federal Register of August 26, 1974 contains a final order issued by the Food and Drug Administration declaring vinyl chloride as a deleterious substance which may render any cosmetic aerosol product which contains it as an ingredient injurious to users. Any cosmetic aerosol product containing vinyl chloride as an ingredient will be deemed to be adulterated under Section 601(a) of the Federal Food, Drug, and Cosmetic Act and will be subject to regulatory action.
With regard to the use of aerosol drug preparations containing vinyl chloride as an ingredient or propellant, the Commissioner has found that there is a lack of general recognition by qualified experts of the safety or effective ness of such preparations. Accordingly, any such product will be considered to be a new drug requiring an approved new drug application under Section 505 of the Act.
The order becomes effective on September 25, 1974.
The preamble of the order contains a request for data on the extent of the usage of polyvinyl chloride containers, the rates of extraction chloride monomer from these containers and other matters pertaining to the safety of these containers. Any pertinent information should be sent to the Hearing Clerk, Food and Drug Administration, Room 4-65, 5600 Fishers Lane, Rockville, Maryland 20852, as soon as possible.
cwo
Department of Legislative and Regulatory Affairs
THE WALL STREET JOURNAL Wednesday, August 21, 1974
Copy for: WRS (K)
Goodyear, Borden Sued for $284 Million Over Polyvinyl Chloride Meat Wraps
By a wall Street Journal Staff RepoHtr
CLEVELAND -- A class-action suit against Goodyear Tire k Rubber Co. and Borden Inc. asking (284 million in damages resulting from supermarket use of polyvinyl chloride meat wrap was filed In Cuyahoga County common pleas court here.
Mrs. Schultz and at least 283 other meat
wrappers employed at 71 Cleveland-area . Pick-n-Pay stores since the chain began using polyvinyl-chloride wrap In 1967.
The suit charges that the meat wrappers "endured chronic exposure to dangerous air contamination from thermal decomposition
The attorney said that others exposed to PVC or vinyl-chloride fumes In uss or man ufacture of other PVC products, may later be added as plaintiffs in the suit. He also said other manufacturers of PVC products
might be added as defendants, but indicated Mrs. Schultz hasn't any interest in siting the Pfck-n-Pay chain, a subsidiary of Cook
The complaint was brought by Florine Schultz, a former meat wrapper for Piek-nPay supermarkets, a Cleveland-based chain. It asks 21 million In damages for
of polyvinyl-chloride films as It passed over
an electric heat wire being used to cut said wrap for packaging," and that the exposure has caused respiratory, skeletal and cardiac
Injuries. The markets, the suit states, have
United Inc. until 1972,. and currently pri
vately owned. '* In Chicago, a spokesman for the Amal
gamated Meatcuttera and Butcher Work men of North America said the union has
used Prime wrap, a packaging film made been concerned for some time about possi
by Goodyear, and Resinite, a Borden pro
duct.
' ...........
In Akron, a Goodyear spokesman said,
"Although we haven't been presented with a
copy of the complaint, we are prepared to
vigorously defend suits of this type." A Bor
den official also Indicated the company
hadn't received a copy of the complaint, and
said public statements by Mrs. Schultz's at
ble dangers connected with wrappers and has discussed PVC products with several manufacturers.
Robert Vandervort, an administrator for the National Institute for Occupational Safety and Health, said institute studies
have linked use of the film to minor upper
respiratory ailments, but that a connection hasn't yet been established between the
torney that there is a medically proved link between use of the wraps and physical in jury are "without'foundation."
The federal government this spring im: posed strict regulations on exposure to vi nyl-chloride fumes In plants making PVC, a solid plastic with many industrial and con sumer applications, after exposure to the gas was linked to liver cancer among work
ers at certain plants. The supermarket meat wraps are made from a PVC resin.
wrap and more serious respiratory Injury or other major illnesses.
Mr. Vandervort also Indicated that PVC represents only a small proportion of fumes
given off when the wrap is cut, and that much of the gas is a plasticizer, DI-2-ethyl hexyl adipate. He said that studies haven't
pinpointed what chemical causes injuries, but that "probably both" are deleterious.
The institute is preparing recommenda
tion on use of the wrap, he said.
The suit alleges that "as a direct result
of Inhalation of the highly toxic films" from
cutting the meat wrap, "plaintiffs have in
curred extremely irritating damage to the
akin, eye, nose, and throat along with short
ness of breath, coughing and general respi
ratory distress, which eventually leads to
serious skeletal deterioration with perma
nent cardiac and bralnal injury."
Mrs. Schultz's attorney cited a Univer
sity of California at Los Angeles study re
ported Inst November linking fumes from
PVC wrap to respiratory ailments.
VihyrChltmae
Seen for Food Packaging
WASHINGTON--The Food and Drug
Administration plans to propose regula
tions to keep the hazardous chemical
vinyl chloride out of foods, drugs and
cosmetics. ;
The FDA rules would establish lim
its on the amount of the substance that
could be contained in plastic packaging
material or that would be permitted to
migrate into the contents of the pack
age. Vinyl chloride la *;gaa used to
make the plfoMd^ pblyvthyl chloride,
wtdc{ is urtdely used- for' packaging
toed and other consumer products.
FDA regulations, which will be
for comment in a few weeks,
establish r a' maximum "toler-
for leakage of. vinyl chloride Into
drugs or cosmetics of 50 parts
Agency .officials say this is
of'' present'' detection tech-
t e r Jo-.',
lerance of 10 parts per million of ide'would be permitted in tfik'
plastic' pojjrvinyi ch&ride. Wh'en tfi# plastic ls'maniifactiifed/vinyl chloride can be trapped as a'contaminate.1
OT^" vphIorlde is1 ` suspected as th4'
killed
35 < 3 O'
Top of the news
Building safer PVC unfe
(Trillion BTU'i)
Synthetic resins and other plastic materials
Synthetic rubber Cellulosic man-made
fibers Synthetic organic fibers Tires and inner tubes Rubber footwear Reclaimed rubber
Other fabricated rubber products
. Miscellaneous plastic products
Totals:
Fuel oils
33.4 0.9
7.5 50.6 13:8
1.1 0.1
15.0
7.0 129.4
Natural Purchased Coal 9>i electricity Total
29.0 5.5
46.3 59.5 13.8
0.1 0.4
55.8 61.5
8.8 52.8 35.0
0.7 0.6
7.1 29.9
1.7 163.4
46.7 291.8
102.8 21.1
5.4 57.1 43.4
2.1 0.9
36.0
117.6 386.4
221 89
68 220 106
4 2
88
173 971
Fuelsand lactrlc energy used in U.S. production of synthetic materials (SIC 282} and
rubber and plastic products (SIC 30) during 1973. Sourea: Fostar D. Snail, Inc., subsidiary of Boot, Allan & Hamilton.
uct separations and other techniques. Up to now, the Saxton group observes,
cost-benefit studies have tended to favoT the slightly higher operating costs of inefficient energy management over the increased capital investment necessary for the additional heat exchangers, longer distillation columns and other equipment associated with energy conservation. But now, the authors say, the ground rules have changed in two fundamental ways:
(1) Petroleum and other fuel prices have risen rapidly; hence, cost-benefit studies will shift toward favoring energy conservation.
(2) Allocation of fuels during a period of shortages will mean that an energy-ef ficient plant will be able to maintain out put at a higher level than a plant with low efficiency in energy utilization; "and the margin for economic operations at re duced output is usually rather thin." Sax ton says this aspect of conservation "makes it essential that those companies that have aggressively pursued energy re ductions in the past not be penalized by allocations based on future conservation steps."
Ping for Coal: In the plastics and rub ber industries, there could be appreciable substitution of coal for fuel oils and natu ral gas by 1980, according to the Foster D. Snell study.
Conservation of fuels and electricity by near-term measures to improve plant ef ficiency could reduce the rubber and plastics industries' total energy require
ments by only about 5%, the Snell team estimates. This would be in line with
trends already observed in these indus tries. For example, in plants producing polyethylene and other synthetic resins, consumption of Btus. per unit of produc tion is expected to drop by 50% from 1962 to 1980.
The Btus. in Benzene: Industry people do not take issue with the general find ings in these reports, but they do contend that the methods used in quantifying the various industries' energy consumption patterns have led to distortions.
In the report on industrial chemicals, for instance, feedstocks as well as fuels are measured in terms of each material's heat of combustion. The Petrochemical Energy Group, representing 18 producers of organic intermediates and derivatives, maintain that this method is inaccurate for some products and should not be used for determining any future regulations on allocation or pricing of petrochemical feedstocks. PEG says the energy actually consumed in producing -benzene and shipping it to a customer is about twice that product's heat of combustion.
As of now, FEA is merely stockpiling these reports, along with the written com ments that have been sent in by PEG and other industry groups. If new regulations are needed, the reports will undoubtedly provide useful background, but the in dustry comments make it clear that de tailed and up-to-date testimony from in dustry experts will be indispensable.
B.F. Goodrich demonstrated last that it apparently doesn't expect the feqbor Dept's. Occupational Safety qpfl Health Administration to promulgate-its proposed "no detectable level" stand^l for worker exposure to vinyl chloride monomer {CW, June 26, p. 14).
While testifying at OSHA's VCM hear ings in Washington last week, Goodrich
Vice-President of Manufacturing John L. Nelson said the company has begun con struction of a polyvinyl chloride plant in Louisville, Ky. The plant, to go into pro duction in mid-1975, will significantly re duce VCM exposure, Nelson stated, but still will not be capable of reaching the proposed no-detectable-level standard {see alsop. 30).
The new plant will incorporate Good rich's latest PVC technology and will have several features that will result in a reduction in VCM exposure, according to Nelson.
Polymer reactors to be installed in the plant will be larger than those in the com pany's five other PVC installations. Goodrich contends that the larger reac tors will have about 87% fewer VCM leak sources than those now in use. Other safety factors, according to Goodrich: greater use of computer controls and the fact that the plant will be an "outdoor" operation.
The Louisville plant will be located on the property where the company now op erates a PVC plant, which was built in 1937, a Goodrich spokesman relates. He adds, however, that the new installation is meant to supplement, not replace, die old plant.
It was at the existing Louisville plant that the link between worker exposure to VCM and the rare liver cancer, angiosar coma, was first reported in January. A search of employee medical records had revealed two deaths attributed to angio sarcoma. Investigations at PVC and VCM plants of other companies turned up sev eral more cases of the disease. Angiosar coma deaths of former employees of the Lonisville PVC plant now number five, Goodrich says, and two other cases have been reported.
Temporary Standards: Concern about incidents of angiosarcoma at installa tions of Goodrich and other companies prompted OSHA to impose a temporary 50-parts-per-million emergency standard in April for VCM exposure. The agency's next step was to order the proposed nodetectable-level standard.
VCM and PVC producers have con-
20 CHEMICAL WEEK July 17, 1974
.> l
Top of the ngfrs
vs
Disputed data: How much can CPI cut energy use?i
FEA gets a tally on industrial consumption of fuels but still may not know the score. Petrochemical group urges the agency not to make rules based on contested figures
Executives in the chemical process in*
dustries are uneasy about the dossiers that the Federal Energy Administration has been compiling on their operations.
Their worry: when the energy crisis heats up again, inaccurate or oversimplified data in those new FEA tally sheets may
mislead the agency into drawing up un workable regulations on the use and con
servation of industrial fuels and feed stocks.
"In some cases," declares the energy resources manager for one large chemical company, "the figures are off not by just 20%, as stated in the report itself, but by as much as 300%."
At this moment, of course, petroleum products have become relatively plenti ful, prices have eased in international markets if not in the U.S., and there is no Congressional clamor for FEA to propound tough new rules for curbing fuel consumption. Accordingly, FEA of ficials now regard these energy use re ports as a data bank to be accumulated for reference.
Keeping Options Open: The reports, which include recommendations for re ducing wasteful or inefficient use of fuel and feedstock materials, were commis sioned last winter when the Arab petro leum embargo prompted the U.S. gov ernment to adopt an emergency allo cation plan and to consider more dras tic measures, such as gasoline ratio ning.
And while the Nixon Adminis tration continues to back its proposal for virtual self-suf ficiency in energy by 1980, it can be expected to keep all its options open. But Eric Zausner,
FEA's assistant ad ministrator in charge of Project Independence, says the 16 industry studies are not now counted as a vital element in that project.
The studies were requested by Trea
sury Secretary William Simon when he was head man in the energy office, but they were sponsored by the U.S. Com
merce Dept By last week, FEA had received the re
ports, in final or draft form, on 10 indus tries: industrial chemicals, polymer and rubber products, petroleum refining, pa
per and lumber, hydraulic cement, iron and steel, food processing, coal mining, motor vehicles, and ground freight trans portation.
Still to come are reports on phar maceuticals, nonferrous metals, glass, plaster and concrete products, and con tract construction.
Commended on Perspective: By and large, according to industry people who have read them, the reports do give a rea sonably sound over-all account of energy consumption in these industries.
In the report on industrial chemicals, for instance, James C. Saxton and his as sociates at International Research and Technology Corp. (Arlington, Va.) point out that while this industry turns out more than 1,000 products of economic significance, it uses more than 75% of its total energy budget to produce just 37 of those products (chart, below).
And the report authored by Joseph Ne-
mec, Jr., Herbert Terry and StepheiF'F.
Nagy of Foster D. Snell, Inc. (Florbam Park, NJ.), shows that 22.7% of all
energy consumed in the synthetic mate rials and rubber industries is in the form of electric power purchased for use in the
plastics industry's polymerization and molding plants (table, p. 20).
Where Cuts Can Come: In plants that produce industrial chemicals, Saxton says, the greatest opportunity for energy
conservation lies in the area of turbine and boiler fuel use. Observing that lead ing-producers such as Dow, Du Pont and Union Carbide have already reported achieving increased efficiency in these op
erations, Saxton estimates that similar improvements throughout the industry could save 67-79 trillion Btus./year on turbine fuels and 382 trillion Btus./year on boiler fuels.
`Taken together, the improved turbine and boiler fuel uses represent a potential 25.7% reduction in 1974 fuel require ments," the authors continue. "If there' were no reduction in the 1974 feedstock energy requirements (estimated at 1,950 trillion Btus.X the savings in fuel use would mean a 12% over-all reduction in total energy requirements." They add that feedstock use- can be reduced by im provements in reaction efficiencies, prod-
July 17, 1974 CHEMICAL WEEK 19
tended throughout the OSHA headrings I Less urge to merge
that the proposed level is unrealistic. |
Most have recommended a compromise
The number of mergers proposed and
standard, such as that suggested by the completed by chemical, paint and coat
Society of the Plastics Industry--25 ppm. ings firms dropped 21%, to 23, in second-
by October 1975, with a time-weighted quarter 1974 from 29 in the same period
average of 10 ppm. for PVC plants and last year, W. T. Grimm & Co. (Chicago)
10 ppm. plus a time-weighted average of management consultant firm reported
5 ppm. for VCM plants.
last week. There were 41 mergers in the
Goodrich declares that its VCM expo first half, down 24% from the 54 recorded
sure levels have dropped from 35-40 in first-half 1973, Grimm added.
ppm. at the beginning of the year to 12-
Eight of the chemical, paint and coat
14 ppm. now. The company says it is try ings mergers in the second quarter were
ing to limit exposure to a ceiling level of cash transactions, compared with nine in
25 ppm. and a time-weighted average of the same period a year ago. Stock was ex
10 ppm.
changed in one case, compared with four
Nelson told OSHA that while Good a year ago, and a combination of pay
rich expects vinyl chloride exposure lev ment methods was reported in three
els at the new Louisville unit to be lower cases, the same number as in last year's
than those currently existing in the com quarter, according to Grimm.
pany's other PVC plants, the actual levels
The number of drug, cosmetic and
will not be known until the new plant is medical equipment mergers also dropped
in operation.
in second-quarter and first-half 1974
. The process to be employed at the fa from the year before--to 14 from 19, in
cility will be suspension polymerization. the second quarter, and to 27 from 37 in
Both suspension and emulsion polymer the first half.
ization are used in the old plant, Good
rich says.
Solid second quarter
VCM will be shipped to the company's
new operation by tank car from Good
Several early-reporting chemical com
rich's Calvert City, Ky., VCM production panies have chalked up record second-
unit.
quarter profits. They attribute the gains
The company stresses that the prelimi mostly to higher prices.
nary engineering work on the new plant
PPG's sales and earnings in the period
began in 1972--before the angiosarcoma were the highest in company history, ac
controversy emerged--and that actual cording to Board Chairman Robinson F.
field construction was started early this Barker. Earnings were $25.4 million, 5%
year.
ahead of the previous high set in same-
Expected capacity at the new installa period 1973. Sales were $448 million, 16%
tion and cost of the project were not re higher than the $385 million recorded in
ported by the company.
second-quarter 1973. Barker attributes
. the gains to higher prices and growing de
mand for energy-saving glass.
Allied Chemical's second-quarter earn
ings amounted to $50.5 million (up 80%
from same-period 1973) on sales of
$567.7 million (up 31%). Board Chairman
John T. Connor says the company's
energy, chemicals, fibers and fabricated
products and export sales and earnings all
contributed to the company's best quar
terly performance ever.
FMC predicts second-quarter results
will match the trend of the first quarter,
when sales were $477.2 million, up 20%
from same-period 1973, and earnings to
taled $23.1 million, up 21%. Chairman
and President Robot H. Malott says that
full-year sales will rise 18% over 1973 lev
els, topping the $2 billion mark for the
first time.
Reynolds Metals boosted sales 48%, to
GOODRICH'S NELSON: Even for new PVC $530.6 million, in the second quarter,
plant, `no detectable level' Is unfeasible.
thanks to a market recovery for alumi-
Top of the newg.
4o *
num. Earnings skyrocketed to $33.3 mil lion, almost six times higher than^i
same-period 1973.
***
Pluses in Paper; International Pagr
credits record production at its pulp md
paper mills and price rises in many areas
for its solid second-quarter results. Sdfts
were up 25%, to $763.4 million, wlufe
earnings jumped 61%, to a record $75.1
million. Crown Zellezbach reports a 10% in
crease in earnings and a 20% sales gain
for the second quarter. President C. R. Dahl predicts 1974 will be a record year
for the company, adding that sales "should break the $1.6-billion barrier."
A "particularly outstanding" perform
ance by Dart Industries'chemical group helped the company boost per-share
earnings 30%, to a record of about 87C, in the second quarter, according to Presi
dent Justin Dart
Akzona reports record sales of $208 million, up 88% from same-period 1973,
and record earnings of $1! million, up
37%, in the second quarter. Claude Ram
sey, chairman and president, says sales were limited only by plant capacity or
raw-material shortages. He believes raw-
material supplies will improve in the sec
ond half, but adds that "gains over the
strong performance of the second fcalf of
1973 will be increasingly difficult to
achieve."
IP scraps merger
International Paper still wants to tap the potential 300 million bbls. of oil be neath about 2.9 million acres it owns, but General Crude Oil (Houston) won't be part of the deal.
IP made an offer early last month to buy General Crude for about $437 mil lion--a payment of$45/share for General Crude common stock and $180/share for preferred stock (CIV, June 19, p, 23).
Initial response to the proposed merger seemed favorable. Pew Memorial Trust, which holds about 63% of General Crude's common, approved the deal. General Crude's directors would not commit themselves, however, promising only to take the matter under advisement
Meanwhile, General Crude began dis cussions with other possible suitors. Then, IP reported it had withdrawn its purchase offer and "terminated the nego tiations with respect to the transaction."
An IP spokesman declined to give de tails on why the proposed merger fell through but did say that development of potential oil lands "is still a priority in
tention here."
July 17. 1974 CHEMICAL WEEK 21
Top of the news
so
SENATOR McCLELLAN: 'Confused' law would lead to a weakened patent system.
Patent reform hits snag
The road to patent reform legislation continues rocky. As soon as the latest Senate bill on the subject cleared one hurdle, it ran smack up against several others.
Studies and 'proposals for patent re form have been in the works for eight years. Last fall. Senator Hugh Scott (R., Pa.) introduced S.2504, the Nixon Ad ministration's bill (CW Oct. 10. p. 20). That was turned over to the Senate Judiciary Committee's Subcommittee on Patents, Trademarks and Copyrights, which "marked up" (revised) the bill and turned it over to the full committee for a vote.
However, Senator John L. McClellan (D., Ark.), chairman of the subcom mittee, made it amply clear that he did not like the Committee Print (mark-up) of S.2504. Instead of writing a minority report, he issued a scathing personal statement in which he said, among other things, ". . . our patent system will be weakened by enactment of legislation which is confused in purpose and deficient in execution." 'He was partic ularly pained that C. Marshall Dann, Commissioner of Patents, had been de nied the opportunity of expressing his personal views on the matter.
Then, to confuse matters, Dann broke his silence with a 21-page letter to McClellan, acknowledging some of die new procedures would complicate the process "to some unavoidable degree." In general, Dann supports the Adminis tration's proposals, although he, too, ob jects to parts of the mark-up.
22 CHEMICAL WEEK July 17, 1974
Detailed Objections: Most knowledge able patent people lean toward McClellan's view. Their objections are many. But basically the consensus ap pears to be that the proposal is too de tailed, attempting to legislate in areas that are better left to Patent Office regu lations. Many feel that the bill would throw enormous roadblocks in the way of obtaining a patent, that it would raise the cost of obtaining and maintaining a pat ent significantly. The net effect, they fear, would be to encourage secrecy rather than patents.
Objections to the S.2504 mark-up can be expected to become vocal. What im pact this will have on the deliberations by the Senate Judiciary Committee and full Senate is difficult to assess. But chances of a patent bill passing through Congress this session are slim. Reason: The House Judiciary Committee, which would have to approve a House version, is too in volved with impeachment considerations to take on patent reform. Opponents fear, however, that the bill might sail through the Senate, generating momentum that would make for early passage next ses sion.
No goodbye Columbus
Production resumed last week at Bor den's Columbus Coated Fabrics plant (Columbus, O.) following settlement of a strike that had idled the wall-covering operations since February.
With the settlement, Borden rescinded a decision, announced last month, to move the entire operation to Andover, Mass. However, about half of the oper ation has been transferred to Andover, resulting in the loss of about 250 jobs at Columbus.
The strike began when negotiations be tween the company and Local 487 of the Textile Workers of America broke down over the issue of wages. Shortly after the strike began, Borden stated that it would have to dose the Columbus unit com pletely unless a settlement could be reached quickly.
The impasse continued- for several months, with the company refusing to yield to strikers' demands and union offi cials charging that the company was un fairly trying to pressure a settlement.
Then, on June 29, an agreement on wages was reached with most workers, and on July 1 there was agreement with the others. The settlement calls for a $ 1.30/hour increase during,the next three years.
"I'm not happy with the terms of the
new contract," says Corwin Smith, preac?
dent of Local 487. "But, under the cg|
cuinstances, I think we have something
we can live with for three years and ke|
the company from moving jobs awy
from the plant here."
^
Closing Shop: As the ColumbM
Coated Fabrics plant swings back into
operation, another chemical process plant
is shutting down for good. Litton Indus
tries reported last week that it will liquid
ate assets of its Hewitt-Robins subsidi
ary's unit in Buffalo, N.Y.
The plant, which produces industrial
rubber products, has been closed since
March by a strike involving about 475
members of the United Rubber Workers.
Litton tried unsuccessfully to sell the
plant to at least a dozen companies, ac
cording to a spokesman.
Alcoa set for expansion
Because of increasing demand, Alumi num Co. of America said last week, the smelting capacity of the company's Badin, N.C., plant will be expanded by 50%, to 180,000 tons/year of primary alumi num. Cost was not disclosed.
Alcoa says the project, expected on stream by mid-1976, will include a third potline and supporting facilities. The work force at the plant, now 680, will rise to around 830.
A spokesman says the expanded plant will not use the company's new electro lytic process for converting aluminum chloride into aluminum, but will use the conventional Hall process. Its aluminum chloride method, he explains, is still being developed by the company at a Texas pilot plant.
Power for the enlarged facility will be provided by local utilities, and the baux ite will come from Alcoa's world re sources, the spokesman says. No reason was given for choosing the Badin site for expansion, but relatively cheap power in the area might be a factor. Alcoa says its domestic smelters are now operating at 100% of their 1.57-miltion-tons/year ca pacity.
In another aluminum-related develop ment, Continental Oil (Conoco) said last week that it would construct a $ 10-mil lion, 40-million-tons/year high-purity-
alumina plant at its Lake Charles, La., complex. When, completed in 1976, the
unit will produce CATAPAL SB, a highly active form of high-purity alumina used as a catalyst support in all major refining
and petrochemical catalytic applications. Conoco now makes the product in a 20million-lbs./year plant in West Germany.
People: Italy's Cesare Maltoni
Cancer sleuth longs for simple life
For the man who launched a chemical industry cause cilfcbre by demonstrating the link between cancer and exposure to vinyl chloride (also see p. SO), Cesare Maltoni is singularly unchanged by sud den fame. The wiry, 5-ft, 9-in., dark haired, dark-complexioned Italian is a 44-year-old bachelor who remains mar ried to his work in preventive cancer re search and seems to enjoy a certain loneliness.
As one observer notes, he runs his lab oratory at the Institute ofOncology of the Hospital of Bologna "with the strictness of a bank." His voluminous records of doses, times of exposure, conditions, re actions of rats, etc., are immaculate and precise.
Yet, the large old summer house in
C5
<s
wr
which he lives just outside Bologna is set bill includes such a provision.) ^
in shaded grounds that are noticeably un
Maltoni is suspicious of all compounds
kempt. The long grass is filled with vari with a carbon-chloride linkage, aijfell as
eties of wild flowers, predominantly pop asbestos and chromium compounds. He
pies. Two large dogs guard the grounds.. bases this suspicion on a "bioloffial in
"I like the naturalness of it," Maltoni ference that, for the time being, I am
says.
keeping to myself."
Research First: He claims that his
Small-Town Roots: Maltoni was bom
work with exposure of rats to vinyl chlo in Faenza, then a small town near Ro
ride marks the first time a form of cancer, magna, nestled at the foot of the Appe-
and its cause, has been predicted before it v nine Mountains. The town is famous for
was recognized in man. Maltoni's work, colored tiles and pottery. And he has an
sponsored by four European chemical excellent collection of the pottery in his
companies (ICI, Montedison, Solvay and home.
Rhone-Progil), had uncovered the cancer
After schooling in Faenza* Maltoni
link more than a year before the first of went to the University of Bologna, where 19 cases of angiosarcoma, a rare liver he studied medicine and specialized in
cancer, was tied to plant workers' expo basic oncology, the study of tumors.
sure to vinyl chloride. And he is critical of Upon graduation in 1954, he spent a few
the U.S. government and the Manufac years in Paris, studying experimental canturing Chemists Assn, as being "need cerology at the Institut du Radium, Sec
lessly slow" in reacting to what he calls tion Fondation Curie. Between 1959 and
"conclusive laboratory proof." Three 1961, he did cancer research at Chicago^ MCA representatives had visited Mal Michael Reese Hospital.
toni's lab in January 1973; angiosarcoma
He returned to Italy in 1961 and begar
in PVC workers was not reported until- his present job in -Bologna. But his hear,
January 1974.
is in the provincial towns of Italy. 'To t
He actively promotes the concept of young person, the provinces can seen,
more predictive cancer research as op like a prison," he says. "But, as I gc
posed to treatment studies. "Most cancer older, the more I realize that the values oi
research is in therapy," he says. "Preven provincial life are on a human scale
tion is new and more difficult because it's Faenza taught me all I know about hu
always in conflict with something. But we man values. There,- and in proviricra
have to fight. No longer do we have to cities like it, the death of a person be
wait for carcinogenic evidence in man. comes the death of a friend for everyone
When the damage starts, it's too late."
All feelings are shared. Someday I woulc
Maltoni hopes his findings will give like to return there."
laboratory testing of animals new popu
But before he returns to that simple lift
larity. `Too often laboratory tests are Maltoni will obviously be kept busy pro
done merely to prove the carcinogenic ef moting the concept of preventive cance
fects in animals of agents that have al research. In the future, if Maltoni has hi
ready proved to be carcinogenic for man. way, all manufacturers of new chemica
This merely amounts to saying that compounds may have to put product:
people die of cancer," he says.
through the kind of rigorous testing h<
One of Maltoni's prime concerns is the thinks could have prevented the angiosar
number of potentially harmful products coma tragedies.
that are made available for human use
"without adequate testing. The human
progeny could suffer irreparable damage
within 100 years if we go on like this."
He concedes that every new product
can't be tested immediately, but suggests
starting with the most widely distributed
products. "I would like a rule that new
materials be tested for carcinogenicity be
fore being released into the human envi
ronment," he says. (In the U.S., the Sen
ate version of the toxic substances control
56 CHEMICAL WEEK' July 17. 1974
CHEMICALS FOR SALE/WANTED
CHEMICALS WANTED
u H i u m (la*
WE BUY, SELL ARID TRADE
KETONES ESTERS GLYCOL ETHERESTERS GLYCOLS GLYCOL ETHERS
alcohols
AROMATICS
ssc
'.'1 1. .if/ I.I'! . .
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T.H.F. AMINES MONOMERS RESINS TITANIUM DIOXIDE RESORCINOL
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BUYING AND SELLING.
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Buying Spent Catalyst Metal Residues and sludges. Submit details to New Jersey Metals Co., 141 South Harrison Street East Orange, New Jersey 07018. Tel: 201-678-7411.
Solvents--Sell us your by-product solvents for recycle. Legal disposal of non-recydables. Ten years dependable service. Marisol, Inc, 125 Fac tory Lane, Middlesex, NJ 08846. Tel. 201/4695100.
Cash for Surplus Plastics, Chemicals, dyes,
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NEW, LOWER, FRACTIONAL DISPLAY
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Recruitment advertising for CPI sales, management, and technical personnel will now be accepted in this Tracers Section in fractional display units, subject to agency commission, at the new lower rate per inch:
We sail, we buy, wa trade; glycols--ketones-- esters-- styrene--inorganics--organics--THF-- intermediates--amines--phenol--alcohols-- plastics--aromatics--methykene chloride--etc. Ben Sager Chemicals International, Inc, 540 Frontage Road, Northfield. Illinois 60093 (312) 446-9280.
CHEMICALS FOR SALE-------------------------
Surplus Bought: Chemicals, Drugs, OKs, Dyes, Resins, Pigments. Waxes, Plasticizers. Chemical Service Corporation, POB 270, 93 Ongley St., Rockville Centre, NY 11571. Tel: 516 536-5533.
Wanted: Phenol (carbolic add) up to 12,000 lbs. Description & price to T. J. Murphy, 405-2364431. P.O. Box 17446, Okla. City, 73117.
Truckload quantities of the following available: Methanol. Isobutanol. N-Butanol, Isobutyl Ace tate, N-Butyl Acetate. Ethyl Acetate. Isopropyl Acetate. Acetone. MEK, MIBK, Adipic Acid. Acetic Acid, Ethylene Glycol. Diethylene Glycol, Triethytene Glycol, Butyl Cellosolve, Cellosolve Solvent. Butyl Carbltol, Cellosolve Acetate. Phthalic Anhydride. Maleic Anhydride, Styrene, Cyclohexanol, Methylene Chloride. Write to FS-4562. Chemical Week.
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Buying slimes, sludges, minimum 30% metallic. ISC, 14 Library Place, Edison, NJ. 08817, (201) 494-9379.
Glycols of Ethylene and Propytene Chemistry. Adulterated, contaminated, spent, still bottoms. Add Chemical Company; 911 River Oaks Bank and Trust Tower; Houston, Texas 77019; 713/ 524-5858.
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Buying Spent Catalysts, Sludges, Slimes, Fines, Complete Assay Service All Metal. Parkans In ternational Inc.. 5521 Armour Drive. Houston, Texas 77020. Call: 1713) 675-9141.
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July 17,1974 CHEMICAL WEEK 55
CONCENTRATES
--S, <****'^4
/=/c-
*^frr
....-
rev.
Science:;
Technology
Evidence of direct production of leptons was re
A disposable, artificial kidney using hollow cupram-
vealed in London last week at the 17th Interna
monium rayon fibers for blood dialysis is being
tional Conference on High Energy Physics. Three groups working independently, at the Fermi Na
commercialized, by Japan's Asahl Chemical In ./TJ dustries. :The firm claims dialysis efficiency two to
tional Accelerator Laboratory, Batavia, III., have
three^tlmes that of existing devices (which typi
observed electrons and muons (heavy electrons)
cally ^use: hiembranes of cuprammonlum film or
emerging from collisions of 300-b.e.v. protons
triacetate hollow fibers). The unit's low blood-side
with atomic nuclei. The detected leptons occur
^-pressure drop enables use without a pump.
only once in about a million collisions. But this is
still many times larger than predicted by the theo
Vinyl chloride can be removed successfully from
ry that protons are made of quarks. The ultimate
plant exhaust air streams using granular activated
implication is that the three subatomic forces--
carbon, according to laboratory tests by activated
strong force, electromagnetic force, and weak
carbon producer Calgon Corp. ln the studies,
force--may not be as different as they had
V using 33% vinyl chloride in air at 75 F., a 12 X
seemed.
r 30 mesh activated carbon removed vinyl chloride
to nondetectable amounts, Calgon says, and had
Plans for the world's largest transit radiotelescope
adsorbed 30% of its own weight of the monomer
have been scrapped. The unit, which was to be
when breakthrough occurred. Steam stripping re
sited in Wales, would have had a 375-foot-diame-
moves the vinyl chloride from the carbon,
ter dish remotely controlled from the University of
Manchester's" radioastronomy department at.
g any possible impact of dyes bn man-and
Jodrell Bank 70 miles away. Soaring costs would
environment will be the focus of the newly formed
put construction at about $40 million, in contrast
Ecological and Toxicological Association of the
to the $15 million or so that was estimated 18 -
Dyestuffs Manufacturing Industry. Formed by a
months ago.;J;\; '
. number of dye producers, mostly European, the
4.'*..' - vis }-r- > ' - .vi
Association wlll be -headquartered In Basel,-~Swit-
Immobilized enzyme synthesis of keto acids Is the ^ ;^"' zerland. lt wiir.ma.ke scientific information and
goal of a new two-year study at Battelle-Colum-.^ '^eTechnical know-how available , to officials and
bus. Research has shown that adding keto add i.^ ^agencies involved-In. drawing up laws and regula
analogs of essential amino acids to the diet of 74s tions relating Ip^ enyironrnental and. toxicological
uremic patients helps maintain properyhVtrogen
^^toffects of.
;
balance and reduces the need for dialysls. How^
ever, conventional chemical approaches are too4 \~New solar cell technologyph^_generated a new complex and expensive to provide the 60 to 100 --i-rs P 14 company to deve1op ^jL4The . compa'ny, ' to be
grams needed per patient per day. Battelle hopes [v formed under an agreemenilbetween Tyco Labo
. to produce keto acids in larger quantities at lower
ratories, Waltham, Mass.,1 and MobilOil, will de-
cost by converting amino acids to keto acids with
velop Tyco's "edge-defined, filmfed growth" pro-
stabilized oxidative enzymes.
: .v
1 cess for producing silicon ribbon used in making
i cells to convert sunlight directly into electricity,
Dr. Veniamin Levlch may be allowed to leave the ' i
Mobil Oil will provide up to $30 million for the sev-
U.S.S.R., after applying to emigrate since March
' eral-year development program.
?-
1972. According to the Committee of Concerned
Scientists, the noted electrochemlst's two,;Sons ^ A hew plastic that Can withstand temperatures up to
have been told that they can leave for IsraelJthls^g Wv- v00 F. end Is 'stable at 700VF. has been devel-
year and that .he may be permitted to follow
:^- 4oped by scientfsts atj^Hughes Aircraft Co. under
the end of next year." Harassment and denial of
>; X^auspices of the^.S.4Aijr,*Force. Describing the
employment toT3r. Levich have aroused wide pro-r*^
^material, HR-6O0, as-a iiew'class ofaddition-cur-
tests by U.S. and foreign scientists. ~ *
v^ able polyimides, Hughes says It can be used eith-
- . JH *:er as a laminatingresin'Orhrvadhesive, or it can
y
VEd. ucation - 1
mixed with, other materials end molded to form '^r estructures. Keyttd the polylmide's performance is
A doctoral engineering program oriented toward ac^^jjjl jpSfos curing beha^orj^itdoesn't[give Off. gases that
tual practice instead of research wili be -offergdi^ |||~|Wouldform voidi*brAveakspbts,Hughes says.
. this fall at Texas A&M . Unlversitv. The, program
will combine courses in engineering with business!^
equipmentwill be built
management and other courses designed to help ^ Kt|4;/rand sold by Fuller Co. under a nonexclusive li-
engineers perform in industrial, political, and so- ) '4 -cense from Ishika-Wajima-Harima Heavy Indus-
cial arenas, according to the school's engineering %
tries, which developed the design jointly with Chi-
dean Fred J. Benson. The program will emphasize ' 1
chibu Cement Co. (C&EN, Aug. 21, 1972, page
complex engineering problems and will include a
:-:T4). A proprietary furnace between a conventional
one-year engineering internship in government or '* .preheater and kiln, says IHI, cuts total fuel de
industry instead of a dissertation.
^ mand by 5 to 10% and doubles the kiln's capacity.
?? CAPW .Intv R 1P74
CHEMICAL MARKETING REPORTER July 15, 1974
Copies to: KLS LNV DVP RSM WRBe WRS (F#
K)
N0O5
<=55
Goodrich Discusses New Unit: PVC Makers Begin Changes
At last week's Occupational Health
and Safety Administration hearings in
Washington on vinyl chloride, Goo
drich revealed publicly for the first
time that it was constructing a "new
facility" for the production of PVC in
Louisville, Ky. (see news story P.4).
The news was met with surprise in
some quarters for, despite the great
number of new plants coming on
stream in the next several months,
Goodrich, the largest PVC producer in
the world, has steadfastly maintained
that it was not contemplating any ex
pansions (other than a proposed plant
in Alberta, see CMR 7-1-74, P.7).
Approximately 1 billion pounds of new annual 'capacity for the U.S. PVC industry is scheduled to be completed within the next year. There will not be enough mono mer available to feed this new capacity, even if, as has seemed Indicated in recent weeks, monomer producers are able to again operate at full potential. There is not enough monomer capacity, even an nounced. to support such broad PVC expan sion. industry people have been saying. In addition, since the beginning of the year. VCM toxicity problems have suddenly cast far more troubling clouds over future PVC production capabilities.
The feeling has been that no monomer producer was going to invest any "megabucks". as one industry source said, in new plants until the OSHA problems were re solved, and that no PVC producer, unless already committed, was going to invest in new units until not only something happed at OSHA but until there was some signifi cant change in the monomer supply pic ture. So it was strange, it seemed, for Goo drich, who was not committed - some thought luckily - to risky expansions for the time being, to announce that it was going to have a new facility on-stream in a year. It not only announced the new unit but announced it at the OSHA hearings themselves, saying at the same time that if OSHA's proposed non-detectable exposure rule were adopted it, Goodrich, would have to get out of the business.
NEW REACTORS
Contacted for more details about the new
Louisville unit, a Goodrich spokesman said
that the "new facility" would be housed in
current plant buildings. The Louisville
plant-is one of the oldest In the country and
also the site of discovery of the first Ameri
can angiosarcoma deaths linked to vinyl
chloride. The spokesman said that the new
production potential being added consisted
in the replacement of some older reactors,
by new, larger reactors. He added that the
project amounted to "making more effi
cient use of (existing) buildings." Goodrich
declined to call the project either an "ex
pansion" or a "one to one replacement" of
current potential. The company would say
only that the project would result in "no
significant increase" of total company ca-
[ pacity.
1 So the truth seems to be that Goodrich
| is not expanding, and they never claimed to
. be, but are instituting engineering changes
which may not only be mandated by the
mere age of existing units but also by the
, desire to get a head start on practical
measures to reduce VCM levels. The larger
reactors, as the Goodrich spokesman ex
plained, contain less potential for leaking,
having fewer valves, pumps, reducing vent
ing operations, etc.
Producers who are scheduled to expand
during the next few months are also known
to be taking similar measures to build-in
some safeguards in anticipation of OSHA
regulations, which most feel will be less
strict than that proposed. Robintech, who
with Shin-Etsu is constructing a 220 million
pound plant in Freeport, Tex., says that it
is also going to use larger computer con
trolled reactors to reduce emission poten
tial. A spokesman for Certain-TEED, which
is completing Us first plant (300 million
pounds) in Lake Charles, La., says that en
gineers are going through the facility and
making changes In anticipation of stiffer
rules.
t
This spokesman points out that new 7
plants may have to be particularly careful i
about air levels, for, in his view, while oper- $
ating plants may be given deferrments in^
achieving whatever reduced air levels are 4
finally put into law, new plants may not be'' able to operate at all until full compliance ,,
is achieved. In this view the engineering
advantages owned by companies with new *
plants making it easier for them to adjust
to regulations may also make them more i
liable than companies with older plants for
failure to achieve early compliance with
those regulations: Georgia Pacific, another ;
company entering the PVC market for the *i
first time^ with a 220 million pound plant in
Plaquemine, La., declined to be specific \
about engineering safeguards being built-in
to their first plant, but a spokesman said ;
that the facility "will be safe in every de
tail."
Another engineering change, besides'
larger reactors, which may become popu- -
lar in the future in response to VCM regula
tions is the bulk process of production
which is now only' used exclusively by ~
Hooker. Bulk process involves no water and
consequently no VCM effluents. It is also <
said to leave up to one-third less residual
monomer after polymerization than sus
pension and dispersion processes. These
could be Important advantages.
Goodrich's announcement last week,
then, points up the action- industry is anx-.
ious to take in reducing VCM levels in an
ticipation of regulation, while calling for
easier "technically feasible" regulations,
and rather than being what seemed a re
sponse to former (ancient) market condi- 1
tions - expansion, it is an early response to
the new market era - reprocessing:
CHEMICAL MARKETING REPORTER July 15, 1974 Copies to: WRS DVP RSM (REL EAS)
<?>
OSHA Proposed VCM Rule Too Stringent
Chemical industry witnesses last
week warned that the proposed Occu
pational Safety & Health Administra
tion standard covering the exposure of
workers to vinyl chloride monomer is
too stringent and will cause great eco
nomic consequences for the industry
and its workers if adopted. The state
ments came from a long list of indus
try witnesses as the OSHA hearing in
Washington continued into its second
week.
John L. Nelson, vice-president of manu facturing for B.F. Goodrich Chemical Com
pany, the industry's largest PVC maker with 930 million pounds of capacity at five plants, as well as a billion pounds of mono mer capacity at Calvert City, Ky., told the hearing a no-detectable level of VCM in its operations is not technically feasible'nor is full-time use of respiratory protection by workers.
He says the company will be forced to shut down its PVC and monomer operations if the standard is adopted. Goodrich, he says, has embarked on a multi-million-dollar program to generate new technology which might make possible further reduc tions in levels of vinyl chloride exposure.
The American Chemical Society, howev er, took issue with industry spokesmen and
endorsed the "no detectable" standard. In a statement given by Dr. Stephen T. Qui gley, ACS pointed out the lack of available data establishing a safe level of exposure to vinyl chloride and concluded that "even the potential threat of exposure to vinyl chlo ride justifies the adoption of the proposed standard."
Dr. Walter Harres of Uniroyal, Inc., rep resenting the Rubber Manufacturers Asso ciation, said that "no prudent manufactur er, knowing that VCM is capable of causing cancer, will expose men at concentrations likely to cause harm."
However, he asked OSHA not to overlook our competitive system. A new criterion, he
explained, has entered the marketplace
and the energies of the large companies will be turned loose to solve the problem. He asked what is available to take the place
of VCM and urged OSHA to keep the stan dard as simple as possible.
Richard P. Carter, director of govern
ment relations, environmental affairs, for Johns Manville, Inc., expressed concern about two distinct goals of the standard.
On the one hand, he said, there is the recognized necessity to protect workers ex posed to potential hazardous amounts of
VCM and on the other hand that PVC resin has become "a critical component in an enormous variety of products upon which a
substantial portion of our economy'Is.de pendent."
He urged OSHA achieve a balance be tween the two factors in its final standard.
He also expressed concern that the stan dard could well result in stopping or reduc ing the available resin available for the firm's PVC pipe and pipefitting plants, re sulting in closing those operations and with
the elimination of 860 jobs. Johns Manville would lose about $91 million in sales and in vestments of about $41 million in its PVC pipe and pipefitting units, he said.
From data submitted at this hearing, he
said, there is reason to believe that it would be both economically and technologically unfeasible for both the VCM and PVC resin
industry to comply with the proposed stan dard by Oct. 5, 1974, or reasonably soon thereafter.
Robert I. Martin, president of Rimar Manufacturing Co., a processor and fabri cator, expressed deep concern about the re sult that the standard would haye on the small fabricator and that it could result in pricing them out of the world market.
Lauis J. Bibri, vice-president of Arm strong Cork Co., a larger user of PVC resin, said that the proposed standard was not written with compounder and fabricator in
mind. He pointed out that there is a vast difference between VCM and PVC resin
and suggested that performance standards
would be more meaningful. He suggested that OSHA recognize the
difference between the types of manufac turing operations and employer exposure.
Government
'O
*m u
Conflicting views on vinyl chlorido coalosco
Industry decries OSHA's
no-detectable level rule
as unnecessarily harsh;
both labor and ACS
support proposed standard
Mere mentioning of the words vinyl chloride to Occupational Safety and Health Administration officials who presided over public hearings on the agency's proposed permanent work place standard for the chemical may well lead to mutterings that enough is enough. In nine days, the officials lis tened to 35 hours of direct testimony by 44 panels of witnesses--and many additional hours in question and an swer sessions--and received 89 written submissions for the hearing record. Much of the data presented OSHA is conflicting. All this is of little comfort to the officials as OSHA has until Oct. 5 to come up with its final version of a permanent standard.
It's likely that OSHA may well pick some middle ground standard--tougher than that proposed by industry, softer than that initially proposed by the Government--which, if either labor or industry is unhappy about it, may well be challenged in the courts anyway.
Data presented at the hearings tend ed to coalesce, in effect, into two posi tions: that of industry and that of Govemment-labor-ACS. For instance, a spokesman for the Society of the Plas tics Industry maintained that OSHA's proposed work-place standard--which, among other things, calls for a no-detectable level of vinyl chloride--"is not technologically feasible and, if adopt ed, would shut down the industry.'' In contrast, Peter Bommarito, president of the United Rubber Workers, said that the "OSHA proposal comes closer to the ideal standard than any yet pro posed or promulgated for any work place hazard."
However, Dr. Daniel P. Boyd, direc tor of the office of standards develop ment for OSHA, although emphasizing that the proposed standard is just that--a proposal--said that "it repre sents our best judgment based on the information available on May 10 ... our present judgment is that vinyl chloride is a carcinogenic agent." Dr. Boyd pointed out that in protecting employees from a carcinogenic material, "We are operating in the area of many unknowns.
For example, we do not know the mecha
nism by which a chemical carcinogen operates or whether a safe level of ex
posure can be set." Much of the testi mony presented at the hearing dealt with industry's, labor's, and research
workers' effort to resolve the latter question.
The initial impetus for the vinyl
chloride industry came during World War II when it was used as a substitute for natural rubber. According to Dr. Irving J. Selikoff, professor of medicine at City University of New York's
Mount Sinai School of Medicine, "This immediately points to a problem of current vinyl chloride-polyvinyl chlo
ride investigations; the industry is a relatively young one, and the late ef fects of toxic exposure have only begun
to appear; most of our experience is still ahead of us." He told the hearings that clinical field studies are being
conducted that include examinations of more than 1200 vinyl chloride-PVC polymerization workers. Although all
the results are not yet in, he reported that studies of 354 current and former workers at Goodyear's plant in Niagara
Falls, N.Y., "demonstrated a signifi cant prevalence of liver abnormalities,
peripheral vascular changes, and lung abnormalities."
Information on deaths from two plants, one which produces monomer and the other polymer, was presented by Dr. John M. Peters of the Harvard School of Public Health. He said that
studies on 161 deceased white males showed "a 50% excess of deaths due to cancer." There was a "60% excess of
lung cancer (13 cases with 7.9 expect ed) and a 320% excess of brain cancer
(five cases with 1.2 expected) with the
number of liver cancer cases being 10 times those expected in a similar unex posed population. He stressed that
these studies, though preliminary, show that multiple cancer sites are in
volved and cancer is increasing over
time in the population. Dr. Peters agreed with Dr. Selikoff in that he said, "I do not believe we will know the
full cancer-causing potential of vinyl chloride for several years. At this point
the only way to assure an end to this serious hazard is to eliminate the expo sure."
The vinyl chloride-PVC industry, in general, took the opposite view. Harry
E. Conners, vice president of Diamond Shamrock Chemical, told the hearings, "In our judgment the cases of worker illness recently discovered in industry
are the delayed result of conditions that were common many years ago but are no longer present in today's
plants." Dr. Richard W. McBumey, corporate medical director of Diamond
Shamrock Chemical, pointed out that
"during the early years of PVC produc tion attention was given to vinyl chlo
ride vapors only because of the anes thetic qualities and the explosion haz ard. Since the explosion hazard occurs at upward of 30,000 p.p.m. and the an esthetic effect at 1000 to 5000 p.p.m. the vinyl chloride levels in work areas were undoubtedly quite high."
Dr. Carl U. Demehl, associate medi cal director of Union Carbide, told the hearing of a health survey conducted by SPI covering 16 plants employing
2372 persons whose current work per mits exposure to vinyl chloride, plus 471 who had worked with it in the past. He said that the study identified
1402 men who were exposed to vinyl
SPPs vinyl chloride rules would differ sharply from OSHA's
OSHA
SPI
July 22, 1974 C&EN 9
chloride at least 10 years ago, of which 416 had a latent period of more than 20 years. Also identified were 787 men ex
posed continuously to vinyl chloride for more than 10 years, with 104 being ex posed for more than 20 years. Dr. Der-
nehl said, "Examinations of these men have failed to show the existence of ab normal liver function tests in greater
proportion than would be found in a control population. There is no case of angiosarcoma of the liver among these
men even though their exposure time is sufficient for the disease to have oc curred and exposures are believed to have been in excess of 60 p.p.m." He concluded that "these data fail to sup port the need for an exposure level as
drastic as that proposed in the stan dard."
The SPI survey's findings were sup
ported by Diamond Shamrock, Dow Chemical, B. F. Goodrich, Tenneco
Chemicals, and Firestone. All reported
that despite extensive surveys of their current and former vinyl chloride-PVC
workers, no further cases of or deaths due to liver cancer have been found, other than the 13 previously reported to
OSHA.
Industry also felt that the proposed standard was too far-reaching. Accord
ing to Anton Vittone, president of B. F. Goodrich Chemical, "The produc tion of vinyl chloride, its polymeriza
tion into PVC resin, and the processing of PVC resin into semifinished or fin ished products is treated in the pro
posed standard as one industrial health problem." However, he contended, "Each is an entirely different operation
posing its own problems, permitting and requiring different solutions."
Of particular concern to many indus try witnesses was the inclusion of PVC processors and fabricators, such as phonograph record makers, under the
proposed standard. Monitoring data on vinyl chloride exposure in processing plants were presented by several wit nesses, including Philip J. Weaver, di rector of industrial affairs for B. F.
Goodrich. In a conclusion that agreed with those of other witnesses, he said, "Our data does not support this con
cept of inclusion of processor opera tions" under the proposed standard since "we find no detectable levels of vinyl chloride in most of the processing
work places." In addition to urging that fabricators
and processors not be included under the permanent standard, the Society of the Plastics Industry proposed that in vinyl chloride and PVC plants there be a stepped reduction in worker expo
sure.
This is in sharp contrast to the American Chemical Society position presented at the hearings by Dr. Ste
phen T. Quigley, head of the Society's department of chemistry and public af fairs, and Howard H. Fawcett, chair man of the ACS Committee on Chemi cal Safety. ACS, in essence, supports the OSHA proposed standard, asking
only that the standard be defined as a minimum practical level capable of de tection by a recommended method
rather than as a no-detectable level. SPI's proposed standard drew sharp
criticism from Anthony Mazzocchi,
citizenship-legislative director of the Oil, Chemical and Atomic Workers In ternational Union. He said, "It will be
a tragedy if OSHA adopts the so-called `common denominator' kind of stan dard that SPI sponsored. Under this
approach a standard is adopted that everybody can meet. But those plants that can go further are under no incen
tive, at that time, to do anything more."
Most companies at the hearing said
that although it would be difficult, they could live with SPI's proposed
standard. Two companies, however, re
ported that they are already operating at much lower levels. Dr. V. K, Rowe, Dow director of toxicological research in health and environmental affairs, said that the company, "is generally
operating within an eight-hour timeweighted average (TWA) concentration of 10 p.p.m.; however, brief malfunc tions and other temporary situations occasionally result in short-term excur sions in excess of 10 p.p.m." And Air
Products and Chemicals' John T. Barr reported that his company has an
eight-hour TWA in the 20- to 25-p.p.m. range for workers in its polymerization building and even lower levels for those
in other job locations. Tenneco Chemi cals, however, estimated that it would have to spend in excess of $10 million to reach the exposure levels recom mended by SPI.
Vinyl chloride-PVC industry wit
nesses contended throughout the hear ings that meeting the proposed stan dard was just not technologically
feasible, unless workers wore air-sup plied respiratory equipment all the
time. However, Calgon Corp., which
was moved from 20th to last on the witness list, declared that technology was available to remove vinyl chloride from the air. William Lovett of the company's activated carbon division said that the monomer can readily be adsorbed on activated carbon in con-
*s
centrationB ranging from 1 p.p.m. B
more than 30% by volume in air. He
said laboratory results show that 100%
removal of vinyl chloride from air ffi
nitrogen streams is technically possibS
using dual beds.
>
Earlier in the hearing Tennetjtt
Chemicals testified that it has includ^
carbon adsorption to recover the mono*
mer from two small process streanfsQ
neither of which contains air, in plans
for its new PVC plant in Pasadena,
Tex. However, it pointed out that it
considers this activated carbon method
to be "wholly impractical" where large
volumes of air and small concentra
tions of vinyl chloride are involved.
Mr. Bommarito expressed the belief
that the standard can be met, saying
that where "engineering controls may
not be applicable, personal protective
equipment can be used." He added
that especially in newer plants the
problem is "characterized by the will,
not the ability, to do the job." He con
cluded that "the medical facts are in
and the problem is now in the social and political arena."
International
U.S. reactor design
loses out in U.K.
U.S. reactor design has lost out in its bid for the next generation of nuclear power stations in the U.K. The British government has opted instead for the steam-generating heavy-water reactor (SGHWR) system. The immediate plan is to build three twin-reactor sta tions with an overall capacity of about 4000 Mw. of electricity. The first of these stations should be operating by
1982. The decision, taken by Eric Varley,
U.K. Secretary of State for Energy, bucks the trend in other countries, where planned nuclear power programs center on U.S. designs for light-water reactor (LWR) systems, either General Electric's boiling-water reactor (BWR) or Westinghouse's pressurized-water reactor (PWR). Indeed, at public hear ings before the Energy Resources Sub committee of the House of Commons Select Committee on Science and Technology last December, both Ar thur Hawkins, chairman of the Central Electricity Generating Board, which supplies power to England and Wales, and Sir Arnold Weinstock, managing director of British General Electric, which has a 50% stake in U.K. Nation al Nuclear Corp., came out strongly in favor of LWR's, primarily because the technology is already proven and can be fairly quickly brought into operation without major design and development effort (C&EN, Feb. 18, page 11).
Mr. Varley cites a number of reasons for deciding on the SGHWR route. "In the government's judgment, it will pro vide power reliably and we can proceed
10 C&EN July 22. 1974
VRD 0002014476
To JDB LNV KLS RDW From D. V. Porchey
Date 7-26-74
Washington Post, July 20, 1974.
CHEMICALS RESEARCH
JUL291974
Joiui iic/lui
..JVcp
Protecting
"7/
Workers
vo
hy
L ~--f Arid Their Jobs
V^
Like God's augfy mao. Peter Bom
j|Jr. Herling writes frequently (MS
marito. president eft tbs Rubber Work labor topics for these pages.
ers Union, stormed at leaders in the
chemical and plastics industries for re
sisting , stronger safeguards against management's tactics of delay and
cancer-producing vinyl chloride, a sub poor-mouthing of its financial ability '
stance used In the manufacture of a to cover the costs of protection.
wide variety of products., 1
What it amounts to, he said, is that
"There are millions of workers-- the "nation is being blackmailed" by
frightened men and women -- who managements resisting the application -
don't want to 'die for their jobs," said , of new effective health standards. They';,
Bommarlto, who is chairman of the oc- raise the specter of "an end to 1.6 mil--!' cupationaVsafety and health commit lion jobs and national disaster."
tee of the .AFL-CIO Industrial Union
Bommarito'g voice grew sharper:
Department ftrhich repesents 6,000,000
workers in 60'unions. "They want to be .
told that industry management and un- ,, ion and the government, federal and state, can assure them of a job and .
"He made it clear lie
their lives. They certainly want both," he continued. "But if this is not pos sible then they choose life."
had no intention of O bargaining with the health :
Bommarito spoke to an occupational
and safety of union.men !
safety conference on vinyl chloride. The hushed audience in the Labor De- J
and women'*1
V"
partment auditorium included repre
sentatives of management, government
and unions. He made it clear he had no intention of 'bargaining with the health and safety of union men and women--although this has sometimes^ happened in the past.
Often, when stricter standards are advanced for the protection of the
"This country survived for nearly 200
years without polyvinyl chloride (PVC) * and we can survive in the future with-', out it. If PVC cannot be made or used -
safely, then the proposed standard
1 must be replaced by an orderly procedure to phase'out vinyl"chloride pro-
health and safety of workers in plants. . duction and find Substitutes for its
and/or mines, two things take place. products, or to phase out the products;*-?
First, the prospect of greater.protec-/ themselves. -This is not an easy posi-As-
tion for workers scares the Industry tion to take. But there is no alterna
because of the expenses of implement tive."
ing safety standards. Second, manage
ment warns that the cost of such im-,
The battle over vinyl chloride is the
provements will be so prohibitive that' . latest confrontation betweeifTabor and I
plants will be closed and workers industry on the subject of protection ,
'thrown out of their jobs.
for workers against cancer-producing .
; i chemicals. Battles over asbestos and*
what it comes down to is that work- carcinogens continue to be fought, in j
1 ers are confronted with a dread Congress and in the courts. Labor, said '
-:3`
v choice: "Your wages or your life." 1'
Based on experience, employers are
confident that unions and their lead
ers, threatened with unemployment,
will make some face-saving compro
mises. These are often filtered'ihrough
a screen of confusing statistics, to reas
sure workers that at least for the time
being they have no medical cause for
alarm.1
'
But Bommarito was having none of
Bommarito, has listened to experts . from all over the world and "we have concluded that the proposed govern
ment standard of `no detectable level' for vinyl chloride is both necessary and feasible."
Bommarito concluded:"The issue be fore us is really not tbe control of vi
nyl chloride. The issue is whether life
has a higher value than dollars, whether we will permit corporate
structures to run the country without
that. Like the Oil, Chemcial and At- control. The language and the intent
, omic Workers, his union hai been one of the Occupational and Safety and ::
of the pioneers in insisting that man-. Health Act mean that workers' lives no
^ageraent must not duck responsibility ^longer can be sacrificed for financial:;#
''maintaining' safe ' work<p)aces.Bomn^gaiu'Th&*vital^grgenar.&pui^bodieB*&r 'raarito'says'be^has'bad`a~ bellyful of are not for sale".
&I
*' :3-
e=J
CD
r-- oa
. ~ `if"-
* ^VsV.tfcai : *-*.*
' 'v' * -' ~ ' r '
ill To
JOB LNV KLS RDW
From
Washington Post, July 23, 1974
(conoco)
O.U 7-26'74
L
CHEMICALS
research
i
Ll
''VtV'J'
CD
CD <s
r-o
t oman Won't Prod IIKW to Soften Slnmlnrri*
T/ty-if-'
By Bob Kuttner
ment regulations limiting mendations on worker health Both the Labor Department
Wuhtaston Post8UH Writer
Labor Secretary Peter J. Brennan, testifying at a Sen ate bearing, yesterday, prom
worker exposure to hazardous substances.
Recent published interviews with two Labor Department
with economic considerations,
or to keep its. findings confi
dential.
. >.
and the AFL-GIO oppose the amendment to the 1970 legisla tion.
Sen. Peter. Dominick (R-
ised that his department officials indicated that Labor's At yesterday^- hearing be Colo.) declared: ^This act was
would not nressnrf the De Occupational Safety and fore Sen. Harrison Williams' supposed to be ; a remedial
partment of Health,- Education Jtod Welfare to water down
scientific recommendations on tfork-place hazards.
Health Administration found the HEW reports politically embarrassing, since the HEW recommendations are often
labor subcommittee, however, Brenan said' economic factors were solely, the Labor Depart
statute, it is not; it.is a puni tive statute."
Dominick told of a Colorado ski boot manufacturer who
- Under federal job safety more stringent than the stand ments responsibility; "we're complained to the senator's of
legislation enacted In 1970, sci ards the Labor Department not going to cede Our responsi fice that OSHA was trying to
entific findings by HEW's Na wants to adopt.
bility to ' anybody," he testi put him out of business.
tional Institute of Occupa According to sources at fied. , According to Dominick, the i. *
tional Safety and Health HEW, Labor Department aides The Occupational' Safety ski. boot/ company was given
(NIOSH) are supposed to be tfae basis- for Labor Depart
have pressed NIOSH either to temper its scientific recom-
and Health Administration is also under tire as a result of a
less than a week to stop using a chemical which OSHA deter^
1972 election campaign memo mined could cause cancer.
randum made public last week Dominick, disclosed that he by the Senate Watergate com personally contacted Labor mittee, in which former OSHA Under Secretary Richard
l
L
jtA.t * -J ,*'v
Administrator George Guen Schubert to get a waiver for
O
ther suggested that worker the company. health and safety enforcement Schubert, asked about the
could be used as "a sales incident, said Dominick had 1
point" for corporate campaign misunderstood OSHA's regula
fund raising. Under question tion. According to Schubert,
ing from " Williams, Brennan OSHA merely required the
said yesterday, "I don't know company to fake certain pre
what went on in the,- past, but cautions when using the chem
I can assure you it won't hap ical, such as outfitting work
pen in the future." ,
men with protective garb.
However, Jacob- dayman,
representing the AFL-CIO,
said, "To this day, OSHA has
never published a standard
they have not been forced to
publish." * / i
Standards
regulating
Dr. Sidney Wolfe, director
of the Ralph Nader-affiliated
Health Research Group' which
has criticized OSHA as lax
and politically influenced, said
Dominick's . anecdote proved
his point.
"
worker exposure to asbestos, vinyl chloride and other can
/
ter-causing agents, dayman
said, were issued only as a re
sult of trade union petitions,
and 15-other standards recom
mended by HEW have not yet
been issued.
At the same time, OSHA
has received bitter criticism
' ti t* r.
from small businessmen who contend its standards are too tough.
Last month, the House ap
proved an amendment exempt
ing small businesses from
worker health and safety regu
v.
( if ' '
lations. The effect would be to
exclude about 90 per cent of businesses and 30 per cent of
the work force.
r- . CEJ
. wH
** ,, ' ..
fci v.rTi'V
vrd 0002014m
\-
cw- e ^
CAW
4, THE WALL STREETJOURNAL, .T Friday, July 12.1974
Tougher Vinyl Chloride Rules Are ,Goal-f By Fall as Labor Agency Ends Hearings1 ^
a Wai.I. STRKkT JoI.'IINai. Rtnff R- porlirr
WASHINGTON-Labor Department offii dais said they hope to Issue new, tougher
standards (or handling vinyl chloride by
Oct. 5. when the current temporary stan dard expires.
The department yesterday completed
nine days of hearing on the proposed stan dard barring exposing workers to any "de tectable" amount of the chemical. The hear
ings consisted mainly of plastics Industry
testimony asserting the proposed standard
would be Impossible to meet and would close down much of the industry.
But the hearings ended on a surprising note when an official of Merck & Co.'s Calgon Corp. described laboratory work show ing that vinyl chloride gas can be totally re moved from air by filtering It through acti
vated carbon, which Calgon makes. It can later be recovered and reused.
However, other Industry officials at the hearing insisted that the findings didn't nec
essarily show how the technique could be
used in an industrial plant,, or how expen
sive it would be to install. *
The Labor Department In April Issued a
temporary standard cutting vinyl chloride
exposure to SO parts per. million In the air,
responding to eytdence ,that exposure can
cause cancer.
-
Daniel P. Boyd, director of the Office of
Standards Development for the depart
ment's Occupational Safety and Health Ad
ministration, said the evidence at the hear
ings indicates a standard of 25 parts per
million can be met "across the industry."
He said the actual standard ' would be
"somewhere between zero and 25." A "no
detectable" level would be .about one part
per million.
*
"There Isn't any likelihood In my mind,"
he added, "that we're'going to put the In
dustry out of business."
'
Forty-four groups of witnesses from in
dustry and labor appeared at the hearings. '
VRD 0002014481
as does structuring the Federal Gov ernment into departments and agen cies, each with a reasonably coherent mission. Certainly, it makes manageri al sense. Unfortunately, this arrange ment for federal R&D exhibits ... seri ous weaknesses."
Further, Dr. Handler said, "It seems to me that the time has come for the Congress and the Executive either to accept the general philosophy by which we have operated--or reject it. But not snipe at it annually. If such acceptance
is politically unacceptable--although I do not see why--then let that be made clear so that we may proceed instead to erect NIRA.S, as once proposed by this Committee, or go further and transform NSF into a Department of Science and Technology which is deemed politically supportable."
And so it went. The House commit tee is yet to hear from a host of wit nesses, including all former Presiden tial science advisers. After drafting a bill to set up a council, the committee will hold a third round of hearings, with Administration science officials, including Dr. Stever, as the key wit nesses. At that time, Dr. Stever, who has been getting high praise for an ad mirable job from critics of the present arrangement, will get a chance to say how well thingB have been going and whether he feels-there ought to be a change, albeit within the constraints of being an Administration official.
ICI ends its silence
on vinyl chloride
The argument over the handling of re sults /rom animal toxicity studies that have helped to establish an apparent link between exposure to vinyl chloride and a rare form of liver cancer in hu mans isn't over yet. The studies are being conducted by Prof. Cesare Maitoni, director of the Istituto Di Oncologia, Bologna. Italy.
In an earlier story (May 20, page 16) C&EN reported that the Manufactur ing Chemists Association seemingly held in confidence from January 1973 until January 1974 scientific findings by Prof. Maltoni on vinyl chloride os an agent causing liver cancer in rats.
The story also raised the question of what an MCA group, which included an Imperial Chemical Industries phy sician, did, or did not, reveal about these rat studies during a July 1973 meeting with officials of the National Institute of Occupational Safety and Health (NIOSH). According to NIOSH director Marcus M. Key, the group made reference to neither Prof. Malto ni by name nor to angiosarcoma of the lioer in humans and animals (C&EN, June 10, page 3). In May of this year, MCA released a "vinyl chloride chro nology" that includes its version of the meeting (C&EN, June 10, page 12).
ICI, which had remained silent on
the issue, now has decided to come for ward with a letter to C&EN that it hopes will be a constructive contribu tion to help clarify the situation. The letter, and NIOSITs response, follow.
Dear Sir:
Dr. Marcus Key, in a letter in your issue of June 10, 1974, describes a meeting between NIOSH and MCA on
July 17, 1973. He refers to an ICI doc tor who flew specially to Washington
on this occasion to acquaint NIOSH fully with the results of a wide-ranging investigation on vinyl chloride mono
mer, currently being carried out by a group of European companies. Since certain of the phrases in Dr. Key's let ter might be capable of misinterpreta tions, which I am sure he would not have intended, some comment from
Europe may be helpful in clarifying these.
(1) Dr. Key reports that the ICI doc
tor "critically reviewed the work of Prof. P. L. Viola." This was an entirely proper review of the scientific criticism which had been made previously of Dr. Viola's paper and provided a possible explanation for the general lack of in
terest shown by the rest of the world in Dr. Viola's conclusion. The meeting provided a forum for the European group to outline the animal experimen tal work which it--alone--had spon sored in 1971 and to present its find ings to date. The protocol for the new work had been designed to avoid any criticism similar to that directed at Dr. Viola. Dr. Key, of course, confirms this in his brief reference to "more reason able levels of vinyl chloride," though this was by no means the only impor tant difference between the new and old work.
(2) Dr. Key then reports the Europe an representative as saying that "sev eral tumors interpreted as confirmation of Dr. Viola's work had been ob
served." For complete clarity, this sen tence needs a little expansion. Our
doctor, in fact, reported that primary tumors at several sites had been pro duced and that this confirmed Dr. Vio la's overall, and previously disregarded, conclusion that vinyl chloride was car cinogenic to rats. He did not say, as
some of your readers might miscon strue Dr. Key's sentence, that we con firmed Dr. Viola's results in that vinyl
chloride produced only Zymbal gland tumors metastatic to other sites. Such a statement would have been untrue.
(3) Dr. Key is correct in saying there was no discussion of angiosarcoma of the liver in rats at the meeting. Nor has anyone in Europe attempted to say that information was transferred in
this specific form. As of July 1973, the major new development in European work, which contrasted with Dr. Viola's, was that vinyl chloride had proved car cinogenic to rats at several sites and at levels down to and including 250 p.p.m. To those concerned with the work, this conclusion had far greater
impact than the observation that one
of the types was angiosarcoma of the liver, a form very rare in humans and unknown at that time in vinyl chloride
workers. In his initial presentation, therefore, the European delegate pre sented the animal results in the gener
alized form that would make maxi mum impact, within a wide ranging survey of past and future activities.
The major facts were made clear. NIOSH was told that vinyl chloride
caused multisited primary tumors in
rats at concentrations down to 250 p.p.m. It also was told of a wide range
of further actions already under way, in Europe and the U.S., as a result of this finding. The European doctor was
fully prepared to provide any further detailed information, within this main statement, that NIOSH might ask for. That NIOSH asked for little more be fore the meeting ended indicated to MCA and the European group that both information and proposed actions were thought adequate and proper.
At that time and in the absence of a known human hazard, that was a rea sonable conclusion for NIOSH to come to. When unexpected results first emerge in a long-term animal toxico logical program, the normal and proper course of action is (a) to scrutinize fur
ther results to ensure that the first in dications are significant, (b) to start
new experiments aimed at a more pre cise definition of the effect, (c) to start work with other animal species, and (d) to look urgently for any similar ef fects in human populations. All of these add to the time span of the study unless and until (d) produces positive results or even suspicions. In the case of vinyl chloride, all these actions had
been started by mid-1973 in a coordi nated program between European and
U.S. industry. Indeed, within ICI, an epidemiological study had been com
pleted to the end of 1971 and updated to the end of 1972. This study disclosed no increase in deaths attributable to
cancer among vinyl chloride workers when compared with a control group of chemical workers never exposed to vinyl chloride. The best view from all the information at that time was that there was no indication of a hazard to
man. The further work was being done to make quite sure that this assess ment was correct.
Finally, may I list a few facts about the role of the polyvinyl chloride in dustry in the whole problem of vinyl chloride and health. Before 1964, no health' problem with vinyl chloride had
been recognized. In that year, Solvay
first observed acro-osteolysis (AOL). Their finding of a link between AOL
and vinyl chloride was published in
1966 and was also communicated di rectly to U.S. manufacturers, and a great deal was done quickly to get this
under control. In 1967 Dr. Viola (who is a senior member of Solvay's medical group) began animal experiments to
Continued on page 37
July 8, 1974 C&EN 21
Z m iA Z ffJ B ANA
CONCENTRATES
vrd e e e m u n
foraia State University, Fresno ... Arnold J. Krubsack promoted to associate professor, department of chemistry. University of Southern Mississippi, Hattiesburg ... Don ald K. Kunimitau promoted to professor, department of chemistry, California State University, Fresno.
Ronald Neuman joins University of Min nesota, St. Paul, department of forest prod ucts, as assistant professor ... James W. Pinson promoted to professor, department of chemistry. University of Southern Missis sippi, Hattiesburg ... Henry Rakoff joins chemistry faculty of the University of Southern Mississippi, Hattiesburg, as asso ciate professor ... Stephen A. Rodemeyer promoted to professor, department of chem istry, California State University, Fresno ... Carl H. Snyder promoted to professor of chemistry, University of Miami, Coral Ga bles.
E. C. Taylor appointed chairman, de partment of chemistry, Princeton Universi ty, N.J. ... Sidney Toby becomes director, school of chemistry, Rutgers University, New Brunswick, N.J. ... William H. Wade appointed chairman, department of chemis try, University of Texas, Austin ... Glenn S. Weiland, professor of chemistry, Gettysburg College, Pa., retires after 25 years on the faculty ... Scott R. Wilson appointed assis tant instructor of chemistry, Gettysburg College, Pa.
Books
New quarterly
A new journal. Resource Recovery and Conservation, to be published quarterly with the first issue scheduled for mid1974, will be dedicated to detailed and comprehensive investigations of the interdisciplinary aspects of resource re covery and conservation. Editors of the journal are Dr. James G. Abert and Dr. Harvey Alter of the National Center for Resource Recovery, Washington, D.C. The yearly subscription price (one vol ume, four issues) is $34.50 from Elsevier Scientific Publishing Co., P.O. Box 211, Amsterdam, the Netherlands.
Functional Monomers: Their Prepara tion, Polymerization, and Application. Vol. 1. Ronald H. Yocum, Edwin B. Nyquist, editors, xii + 715 pages. Marcel Dekker, Inc., 305 East 46th St., New York, N.Y. 10017. 1973. $43.50. A practical reference work.
New Developments in Gas Chromatogra phy. Howard Purnell, editor, viii + 408 pages. John Wiley & Sons, Inc., 605 Third Ave., New York, N.Y. 10016.1973. $9.95.
Organicum: Practical Handbook of Or ganic Chemistry. Heinz Becker, et al. xx + 747 pages. Addison-Wesley Publishing Co., Inc., Reading, Mass. 01867.1974. $23.50.
Polymers: Chemistry and Physics of Mod ern Materials. J. M. G. Cowie. xii + 298 pages. Intext Educational Publishers, 257 Park Ave. South, New York, N.Y. 10010. 1974. $11.75.
Principles of Quantum Mechanics. W. V. Houston, G. C. Phillips, xi + 376 pages. American Elsevier Publishing Co., Inc., 52 Vanderbilt Ave., New York, N.Y. 10017. 1974. $39.50.
. Continued from page 21
get a better understanding of AOL. He
reported preliminary findings in Tokyo
in 1969 and his earliest observations of
a carcinogenic effect were delivered to
the 10th International Cancer Congress
in Houston in 1970. It must be as
sumed that his paper reached a large
and influential audience. Nevertheless,
the only action came first from Euro
pean industry, through the Maltoni an
imal studies, in 1971, and then from
U.S. industry with its Biotest [Labora
tories] program in mid-1973. 1CI ini
tiated epidemiological studies in 1971.
The results of these were given to MCA
in late 1972 with the recommendation
that similar work should be done by
MCA. It was this latter work that fi
nally led to the discovery of a human
cancer hazard.
The point is obvious. For the past 10
years the industry on both sides of the
Atlantic has been active in its work to
protect health, and, in Europe, animal
studies have been in continuous prog
ress for the past six and a half years.
The latest and most serious hazard of
angiosarcoma of the liver H only been
discovered through the coordinated
and unprompted effort of European
and U.S. industry.
This is the record of an industry that
has taken action and published, and
not, as you have "hinted" in other col
umns, of an industry that "withholds
information."
Barnti
A. W. Bamed
Director, Imperial Chemical Industries
plastics division
Here is NIOSITs response:
Dear Sir: It is still difficult for me to understand how a description of the preliminary findings of a rat study conducted by an unnamed Italian investigator can be retrospectively interpreted as providing to NIOSH full information on the sig nificance of Prof. Maltoni's findings in
July 1973. We still disagree on the details relat
ed to us. Our notes do not confirm a description of tumors other than Zymbal gland tumors or their metastases, nor do they confirm specific mention of 250 p.p.m. of vinyl chloride as being tumoragenic. It is reassuring, however, that the ICI letter corroborates our notes that there was no discussion of angiosarcoma of the liver at the July 1973 meeting.
In spite of the differences, I respect the ICI medical officer who attended the meeting and appreciate very much his coming to this country and briefing
us. Incidentally, I did not mean to use the word "critically" in the pejorative sense, but rather in the sense of exer cising careful judgment or judicious evaluation.
Marcus M. Key, M.D. Assistant Surgeon General, Director, National Institute of Occupational Safety and Health
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(609)829-5237 (215)743-4602
S'Chloro-S'phenylanthranH
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write for catalog
F=?
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eMCTHn-i-rniMUMwecAiMiYuc *m wusxrr.ou Micnichh ^
EQUIPMENT MART
HOLDING BASINS SETTLING TANKS PONDS RESERVOIRS
From alamentinr holding ponds to sophisticated reser voirs, Carlisle engineers have the knee-how and Via right membrane to do tha job. There i* a Carlisle Elastomeric membrane to solve the day-to-day prob lems and tha isoiatad "special Instanct" aa wall. Conatruciion Materials Department CARLISLE TIRE A RUBBER COMPANY. Oivlalon of Carlisle Corporation P.O. Box 99. Carlisle, Pa. 17013
prittJ it fir hu (Ken rtproJuetlen niff U..I ter climiclt, sMi, enMlic me, Kydrtvliu red Mnvids. HIGH MESSUSC TANKS. SOP fU C!.' thitadl <cl> err*
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Many sizes in stock up to 3000 psi--write. Send Purchase Order. Terms 2% 10 days, 30 days nei.
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July 8, 1974 C&EN 37
t m u ia a t aha
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THE WASHINGTON POST tT'&xwiay.Jtm* 12.19U A 13
Vinyl Plants;;
Found Clear,
Of-Pollution - , r.
I By Morton Mints
1 wunintUm Pent urf WrHr
Preliminary
monitoring
round industrial plants that roduce toxic vinyl chloride
as, or that convert the gas to
common plastic, found no
jientUlc evidence ' of cmls* ; ons in the atmosphere which
ose "an Imminent, hazard", to
eople living,in .the vicinity,
\e Environmental Protection
, gency said yesterday.
"However, prudence dictates
iat reasonable steps should
e promptly taken to reduce inyl chloride emissions to the
iwest practical level,'' EPA
.dmlnistratoT' /Russell ? . E/ rain said. --
He met. with senior execu--
RUSSELL TRAIN ; , ;
ves of the 2d companies that ' . .. ; . called meetinc < -
tanuiaclure the gas and the
lastlc, polyvinyl chloride,' ; to
rge- a step-up - in efforts- to Worldwide^ 19'cases of-an- '
tinimize discharge of the gas tta the environment-. He said
giosarcoma of the liver have been confirmed at facilities
fterward that they had se producing polyvinyl chloride
ared their cooperation-
for phonograph records, floor
Train called the meeting sf- tiles, electrical insulation and
er reviewing a summary of many other uses.
he preliminary-monitoring re In each case, the victim hid
mits in the- neighborhoods of been repeatedly exposed over
2 plants grouped in seven many years to high concentra-
hemical complexes.
itioos oLthe gnv The posslbU-
More than 93-per cent of the I tty that the gas figured in the
amples collected within a ra- I death from liver cancer of sev
lius ol a- balf-raile of,the eral non-workers Is being in
ilants' property Uaes--con- vestigated.- -
*' '
ained vinyl chloride at a level Train, at his meeting -with
if less than 1 part per million, the executives, emphasized the
he agency reported. In one preliminary nature of-the find
ase, 3.4 ppm-was recorded ings, saying that only a 11m-.
hree miles away although sev- Ited number of samples was :rsl readings, averaged only taken at each facility, and that
>.8 ppm. - `--------
meteorological and- tempera
At four of the complexes-- ture . conditions during .. the
I >t Louisville, Ky.. Long Beach, monitoring varied.
1 lalif., PainesviUe, Ohio, and He said that-the levels of vi
; `laquemine, La.--a number of nyl chloride In the air fluctu
amples showed more than 1 ate sharply with such events
ipm. At the B.F. - Goodrich as the periodic opening of re*
ilant at Louisville,- where the actor kettles, accidental plant, verage ranged- between '0.3 discharges and changes in pro ad 1 ppm, an apparent one- duction processes. Ime high of 33 ppm was rec- EPA monitoring teams
rded. The other sites moni- checked water discharges and ored were at Delaware City, {sludgefrom the plants in the
lei., Flemlngtoo, N.J., and Le- {survey, but found no basis at
minster, Mass.
this time for considering that
Because vinyl chloride has the vinyl chloride levels "if
i | teen strongly implicated asi handled properly are hazard ; he cause of a rare but fatal ous to human health or aquat* onn of cancer, angiosarcoma ic--life,** Train, said.
f the liver, the Occupational Train has cited the difficult iealth and Safety Adminiatra- 1 ties incurred in getting hard
lon has set an emergency data on vinyl chloride a3 an .
emporary standard for work-1 urgent argument for giving
laces of 50 ppm, but has pro I the EPA enlarged powers as |
posed to lower the standard proposed under" toxic sub-
tor job-sites to whatever level stances legislation, which ha*
at which the gas esn be de-1 been languishing in a House-
| tected.
Senate conference committee.
4. V
mp*. V/vV
Research ' Oftuloio
JUN 1 4 1974
COP:
CHEMICALS RESEARCH JUN 191974
J S n iflZ B ffl on A
PACKAGING OF FOOD'and other products is a major market tor polyvinyl chloride.
Second thoughts on using PVC
Packagers stick with PVC, but seek substitute materials for new products and as hedge against possible forced cutbacks
Continued discovery of liver cancer cases among workers in polyvinyl chlo ride plants is posing a threat to the mate rial's future in the packaging field. Sev eral food manufacturers are dropping plans for packaging new products in the controversial plastic and PVC users are searching for possible substitutes in case federal regulations covering worker expo sure force cutbacks in output
At 325-million-lbs./year consumption, packaging is a major outlet for the 4.6 bil lion lbs./year of PVC resin produced. And the reluctance of food packagers to use PVC could signal the beginning of harder times ahead for the material.
Reports earlier this month of two cases of angiosarcoma in Czechoslovakian PVC plants has raised the toll to 24. And as those numbers mount, public pressure is building on the Occupational Safety and Health Administration to promulgate its "no detectable level'' exposure limit for vinyl chloride monomer in work envi ronments. With the final standard due
Oct 5, OSHA is said to be seeking a com promise position that will avoid lawsuits from industry on the one side and labor and consumer groups on the other. One source tells Chemical Week that "trial balloons of 20-25 ppm. have been lofted by the agency."
Industry representatives have been
contending that imposition of a no detec table level limit--essentially 1 ppm.--for worker exposure is technically impos sible. Enforcement of such a standard,
they claim, would cause shutdown of all PVC plants in the U.S., eliminate 1.7-2,2 million jobs in consuming and related in dustries and result in a loss of domestic production value of $65-90 billion/year.
Manufacturers of substitute materials are not crowing over PVC's setbacks. Most, suffering feedstock shortages, are struggling to satisfy their own markets. Moreover, for many applications, there is no substitute for PVC.
And the vinyl industry's occupational health problems may be precursors of difficulties for other segments of the or ganic chemical industry, "It's only one tree in the forest," says Cesare Maltoni, of the Institute of Oncology (Bologna, Italy), whose research first predicted the link between VCM exposure and cancer (CW} July 17, p. 30).
The National Institute of Occupational Safety and Health has taken on the task of developing work exposure standards for some 400 chemicals by 1976. By No vember the agency hopes to publish ex posure standards it has developed for five ketones--2-butanone; cyclohexanone; 2pentanone; hexone; and acetone. It had hoped to have 40 chemicals completed.
but "underestimated the difficulty." NIOSH also will be getting approxi
mately 18 standards per month from
three consulting groups: Stanford Re
search Institute, Kaiser Foundation and,
Arthur D. Little.
Future Unclean Opposing what he
called "blackmail" over the alleged con
flict betweenjob losses and worker safety,
Peter Bommarito, president of the United^ $ Rubber Workers and chairman of AFL- P*
CIO's health and safety committee, says j L
"this country survived for nearly 200 *
years without PVC and we can survive imjF-
the future without it"
>'
But Arthur D. Little (Cambridge,
Mass.), in its examination of the possible
demise of the PVC industry for the
Society of the Plastics Industry says: "It
would not be possible to duplicate the
exact properties of vinyl plastic products
by using substitute raw materials." And
even if it were possible to find a product with the exact or equivalent properties,
says ADL, cost of production would
probably price the substitute out of the
market.
"Choice of a packaging material is a series of complex considerations," says;
industry observer. For many applications
it's difficult, if not impossible, to find a
material that fits the bill exactly. PVC has
clarify and excellent oxygen and carbon
dioxide barrier qualities. Polypropylene '
does not. On the other hand, polypropyl- iS .
ene is a tough construction material.
i ;.
According to Modem Plastics' 1973 ^,
survey on plastics production, some million lbs. of PVC were used for bottles,
compared with only 19.8 million lbs. of s,
polpropylene for the same purpose. And>^
while polypropylene is more available
than PVC, a Phillips Petroleum spokes
man says, "We don't have that-much.'
Search for Substitutes: There was an"
earlier spur to the search for PVC substi-
tutes when a problem arose with the test
marketing of half-gallon PVC bottles for
liquor in 1973. Alarmed by reports
VCM migration into the liquor, the Food ' and Drug Administration proposed to^^-
drop to zero the allowable VCM migra-
tion into food, drugs and cosmetics on V
May 9, 1973. Almost immediately, the
Bureau of Alcohol, Tobacco and Fire
arms cancelled its approval for the test
marketing of the half-gallon PVC liquor
bottles. (Final FDA decision on VCM
migration limits is still pending.)
.,
According to one packaging supplier, * ^
"We lost some business in PVC over the
liquor decision, and it was picked up by
our glass operation." Glass is probably the best qualified al-
July 31, 1974 CHEMICAL WEEK 19 *
m n a m fl
Environment
IS W fiZ M fl OHA
temative across the board, but it, too, is in tight supply.
For certain film applications, polyvinylidene chloride could benefit For ex
ample, Dow notes that for odd shapes and barrier packs, such as for cheeses, it is "ideal." But a spokesman notes, it is
more difficult to handle than PVC in ma chines, and it is more costly.
Other packagers report little if any in* crease in interest from marketers anxious to switch. But most agree that the PVC problem is influencing new-product in troduction. Case in point: Borden's ReaLemon Subsidiary, which was test marketing a line of cocktail mixes called On the Rocks in PVC containers. The PVC packaging idea has been dropped. "We're exploring a number of alterna
tives," a spokesman reports. Opinion seems unanimous that large
market shifts from PVC would be impos sible to soak up. Construction is the larg est consumer of PVC resins. Last year, for example, 1.34-billion lbs. of PVC were used to make pipe and fittings. That's more than 25% of total PVC consump tion, estimated by the SPI to be 4.6 bil lion lbs. in 1973. An additional 464 mil lion lbs. went into flooring. And siding use as well as miscellaneous construction applications pushed total construction markets for PVC well over 2 billion lbs. in 1973. Auto upholstery, seat covers, mats and decorative tops accounted for 256 million lbs.
PVC output has risen about 70% dur ing the past five years, for a compound growth rate of about 11%/year from 1968 to 1973, This year's growth, however, is likely to be much slower. Output during the first five months of 1974 was up only 1.7%, according to data compiled by the Tariff Commission. That's partly an indi cation of slackening growth in demand but also reflects shortages of capacity. ' Reactor Role: Of the 24 reported cases of angiosarcoma linked to VCM expo
rsure, only one, in Sweden, involved a worker at a monomer plant Of the rest 20 were in PVC plants, two among com pounders and fabricators (one wire extru sion plant one plastic fabric plant) and one West German worker engaged in fill ing aerosol pesticide containers with a \VCM propellant
Because vinyl chloride plants are gen erally automated they can be built with out enclosures. But PVC production is la
bor-intensive, and in the colder climates it's necessary to enclose the plants. "Less than half are open," estimated one com pany spokesman. Goodrich has an nounced that it plans to build an "out-
20 CHEMICAL WEEK July 31, 1974
door" PVC plant alongside its Louisville plant where the VCM-angiosarcoma link was first reported last January.
Four basic polymerization processes are used for PVC production--suspension (which accounts for more than 75% of the tonnage), emulsion, solution and bulk. The reactor or autoclave, where polymer ization takes place, is the key piece of
equipment in each. Conversion of 85% of the monomer is considered high. Unreacted monomer is removed from the unit by vacuum for recycle to the process before the polymer is fed into a drying tower or storage tank.
Moreover, some polymer sticks to the reactor sides, hardens and accumulates, lowering the heat transfer in the units. When the heat transfer becomes too low, or a different resin is produced, it be comes necessary to clean the reactors.
High-pressure water jets are used pri marily to do the bulk of the cleaning. But in some older plants, the ports in small kettles are positioned so that water jets can't be used. Some efforts are under way
It will be impossible
to duplicate exact
properties of vinyl
to develop new monomer-absorption, hardened resin removal methods. For ex ample, GAF has patented a solvent addi tion method.
One producer's engineer, who has worked around PVC plants and been ex posed to the monomer for over 20 years, thinks companies will have to "sharpen up polymerization techniques and meth ods of stripping free monomer."
He would like to see free-monomer concentrations in the dryer reduced to 500 ppm., claiming they are now up to 3,000-4,000 ppm. on resin leaving the plant "The plant of the future--if we have one--will be able to strip most of the free monomer," he says.
Meeting Standards: Acknowledging that the 1-ppm. standards are "going to be tough to achieve," Daniel Boyd, direc tor of OSHA's standards development of fice, says a combination of engineering controls, work practice methods and res pirators could be used.
A spokesman for one manufacturer says he fears "we'll be hung with hose-fed positive pressure masks." All sources agree that self-contained supply packs, similar to those used by astronauts, couldn't be used because the workers couldn't function. In fact labor sources
oppose use of respirators, too. "Have you ever tried working all day with a respira tor on?" asks Tony Mazzochi of the Oil, Chemical and Atomic Workers union.
One possible answer is to collect the es caping monomer and vent it to the atmo sphere. But the Environmental Protection
Agency, concerned about escaping mono mer, has been monitoring the air around
10 PVC plants. ''When OSHA gets through EPA will move in and won't want monomer going out the stack," says a Union Carbide spokesman. EPA con tends that there are 6% VCM losses from
PVC plants and concentrations of 1-2 ppm. in air outside plants.
Another possibility: absorbing 4he monomer in the vent gases on activated carbon. Calgon has reported successful
laboratory studies of the technique and is installing a system for the effluent from the vent condensers at a southwest PVC plant. The company says the monomer can be regenerated with steam.
But other companies are skeptical, say ing relatively concentrated streams of
inert gases with relatively small amounts of oxygen are needed for activated car bon absorption. One company reports its estimated cost for activated carbon scrubbing in its resin-drying operation at 5500,000 per stack.
Chemical Carcinogens: Maltoni is al ready looking for other chemical carcino gens, based on evidence supporting his predictive cancer techniques. He is sus picious of all carbon-chloride groups. Maltoni is also doing more work on VCM, studying inhalation doses of 25 ppm. down to 1 ppm. and doing tests on the effect ofingestion.
Tm sure 25 ppm. will show cancer, too," says Joseph Wagoner, chairman of NIOSH's occupational carcinogen com mittee.
"There's no way to demonstrate the safe level of a carcinogen," he warns. Wagoner is also concerned that other dis eases may be caused by. worker exposure
to VCM. While critical of the "serious limitations" of the Tabershaw-Cooper epidemiological studies sponsored by the Manufacturing Chemists Assn., he notes that they demonstrated brain and lung damage linked to VCM exposure.
Occupational health standards may be
one of the greatest problems the chemical industry has faced. But great optimism and faith in`the industry has been ex
pressed in some unexpected quarters. "The ingenuity of American industry never fails to surprise me," says NIOSH's Wagoner. "Somehow, surprising thing* can be done."
Copies tofRWG ODBuJJL^Kt^^V CLW WRS (REL-EAS)
CHEMICALS -
research i h ,
JUN1 11974^
MANUFACTURING CHEMISTS ASSOCIATION
1825 CONNECTICUT AVENUE, N. W.
FOR RELEASE-----------
WASHINGTON, D. C. CONTACT:
cn:<
A.JLu WRS LM
For Immediate Release
Richard F. Blewitt
(202) 483-6126, eitr '288-
WHITE SULPHUR SPRINGS, West Va., June 6 -- The Manufacturing Chemists Association (MCA) today announced that it will administer four new research projects to further probe the relationship of carcinogenicity in animals due to vinyl chloride as it may relate to humans. The studies will be funded by U. S. producers involved in the synthesis and polymerization of the chemical. This is in addition to substantial research being carried out by individual companies here and abroad.
The new projects were approved unanimously by the Association's Board of Directors in session during MCA's Annual Meeting here.
The program includes: 1. A study of animal metabolism; 2. A study of teratogenesis (animal fetus); 3. Animal chronic inhalation studies at concentrations
below 50 ppm, in' an effort to identify a "no-effects" level, and 4. An acute inhalation experiment in which animals will be subjected to a massive exposure simulating conditions which might be experienced by a community exposed to a tank car rupture in a transportation accident. The animals would be observed over their lifespan.
(more)
VRD 0002814489
Page 2 of 3
The funding companies, which are supporting current research, and MCA consider it essential that the program be expanded to determine the conditions necessary to assure the safety of workers involved in the manufacture and use of the products and of the plant neighborhoods in which they are made.
The scientific information developed from this program will be disclosed publicly without restrictic . Further, as appropriate to the advancement of the program, technical reports will be developed and made publicly available on work practices, industrial hygiene monitoring and analysis and the medical surveillance of exposed workers.
The first two projects will be conducted by The Dow Chemical Company. The other projects will be carried out by Industrial BIO-TEST Laboratories, Inc- Industrial BIO-TEST has been conducting vinyl chloride animal exposure studies, under contract to MCA for administration, since Feb. 1, 1973. Progressive results have been announced in this continuing study.
Results of another study, documenting the health experience of present and former employees who have worked with the chemical, were released May 7 of this year- Tabershaw-Cooper Associates, Inc., conducted this epidemiological study.
All findings also have been reported immediately to government bodies concerned with the problem. This practice will be followed in respect to the new studies.
(more)
0 6 W 0 1 0 0 0 1 <BA)
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Page 3 of 3
It is estimated that the four projects will cost a minimum of $400,000 to $500,000. Because of the fluid status of scientific knowledge and regulatory climate in respect to vinyl chloride, an upward revision of the cost estimate might be necessary to accomodate change of test protocols.
### MCA-3851