Document peGwRR3B15VE8KXOmZ6LKaZMB
Intcroffice Alcm oramluin
ro (N*m* and Location) Dr. R. W. Godwin and Mr. R. E. Cromer
FROM (Nam# #nd Location)
J. C. Pullen - Charlotte
t! \)
GENSSaev 2(5. 71
DATE
May 21, 1979
reference no
JCP-79-108
CONFIDENTIAL
SUBJECT: Dissemination of Test Information
We are receiving more and more "aTerts" on various chemicals, and at the present time have no policy for dissemination of such chemical/health test information to employees. Each situation has been handled on a case-by-case basis, and generally we have chosen not to make "formal" announcements to hourly personnel with the recent exceptions for benzene and methylene chloride.
The Chemical Company is taking a more open position, and is communicating to
employees all such information, whether the test conclusions are from extensive
epidemiological and/or animal tests, or from simple screening tests. A recent
example was mutagenic -screening for-methanoU the Ames test was negative, while
the mouse lymphoma test was'positive. Here, the Chemical Company conveyed these
results to all its employees (attached). '
/
in discussions with the Celriver and Amcelle industrial hygiene coordinators (Benjodk and McLain), we have concluded that CFC should not routinely communicate "suspect" information based on screening tests. If such an alert is received, we recommend that the following actions be taken:
1) Conduct area and dosimeter testing to assure no employees are being
exposed in excess of OSHA limits,
'
2) Determine if engineering- controls can be devised to significantly reduce -
exposures,
"
3) Determine if a substitute chemical can be substituted^. -
If an alert is received based on good "hard" human and/or animal testing (as judged by Dr. Clary), then formal communications should be made to affected employees. These conmunications should be coordinated through Jim Allen, and involve theplants, the CFC Industrial Hygienist and Dr. Clary. The three actions above should
also be completed as soon as possible.
-.In the case where an employee requests information on a "suspect" material, a back up statement should be prepared for use by the plant supervisors. This statement should emphasize that data is inconclusive and will be verified or refuted by further, more refined, testing. _It should also be emphasized that exposures are
- being monitored, and controlled below appropriate limits. __ _
Could we discuss this problem with the obTective^af developing^ r CFC policy?
cc: Mr. J. P. Allen*. Charlotte Mr. L. H. Knox -
HNA 24843