Document qwqgrOJ419505NV0JZz5waDx

APPLIE EPIDEMIOLOGY INC. April 4,1994 Hasmukh C. Shah, Ph.D. Vinyl Chloride Panel Chemical Manufacturers Association 2501 M Street, NW Washington, D.C. 20037 Dear Dr. Shah: As you suggested in our brief telephone conversation about two weeks ago, I am writing to express my interest in preparing and submitting a proposal should the Chemical Manufacturers Association decide to update the vinyl chloride cohort study. This study has provided valuable information on a large sample of employees occupationally exposed to vinyl chloride, and should continue to elucidate a number of important issues. My colleague Dr. Harris Pastides and I have worked with CMA on a number of occasions, mainly with Ms. Sandra Tirey and the Epidemiology Task Group. We authored the CMA Occupational Epidemiology Resource Manual, a practical guidebook on establishing epidemiology programs and conducting epidemiological research. Related to this, we presented an Epidemiology Resource and Information Center (ERIC) Workshop on "Establishing and Maintaining an Effective Occupational Epidemiology Program." Most recently, we authored another CMA manual entitled, Establishing an Occupational Epidemiologic Surveillance Program: A Resource Guide. We have worked and continue to work with several member companies, and have established excellent relationships with many of their corporate epidemiologists. Perhaps the most recent and relevant of this work is a P.O. BOX 2424 AMHERST, MA 01004 W (413) 256-3556 FAX (413) 256-3503 Dr. Shah, April 4,1994, p.2 cohort mortality study of employees in the VCM and PVC division of the Vista Chemical Company, which will begin this month. I have enclosed a copy of my Curriculum Vitae, and will be happy to send additional information, including Dr. Pasfides's CV, if needed. We look forward to discussing with you the prospects of assisting with this research. Please do not hesitate to call me if you have any questions or need additional information. Sincerely yours, enclosure Kenneth A. Mundt, Ph.D. SL 107220 Curriculum Vitae KENNETH ARTHUR MUNDT, Ph.D. CURRENT POSITIONS Assistant Professor (1989-present) Department of Biostatistics and Epidemiology School of Public Health 403 Arnold House -- University of Massachusetts Amherst, MA 01003 Telephone Fax (413) 545-2861 (413) 545-1645 Visiting Associate Professor (1991-1996) Institut fur Epidemiologie und Sozialmedizin Universitat Munster Von-Esmarch StraJJe 56 D-48129 Munster GERMANY Telephone 49 (251) 83-5520 Fax 49(251)83-5300 Senior Epidemiologist (1991-present) Applied Epidemiology, Inc, P.O. Box 2424 Amherst, MA 01004 Telephone (413) 256-3556 Fax (413) 256-3503 EDUCATION Ph.D., Epidemiology University of North Carolina at Chapel Hill, Chapel Hill, North Carolina, 1990. M.S., Epidemiology University of Massachusetts at Amherst, Amherst, Massachusetts, 1986. M.A., English University of Virginia at Charlottesville, Charlottesville, Virginia, 1982. A.B., English Dartmouth College, Hanover, New Hampshire, 1981. SL 107221 Mundt C.V., p. 2 UNIVERSITY RESEARCH 1994 1993 1992 1991 1990 Principal Investigator Healy Endowment Award. Lead Prevalence Study (1993-4) $5,000 Co-Principal Investigator Occupational Upper Extremity Disorders Clinic University of Massachusetts Medical Center (1993-4) $57,000 " Principal Investigator. E.I. Du Pont de Nemours Company. Educational Aid Program. Occupational Epidemiology Unit (1992-4) $15,000/year Principal Investigator/Convenor. Second National Conference on Occupational Surveillance, University of Massachusetts, Amherst, MA (March 9-11, 1993) $26,000 Co-Investigator. Chemical Manufacturers of America. Definition and Strategies for Developing Occupational Surveillance. (1992-3) $38,000 Principal Investigator, Faculty Research Grant. Epidemiological Surveillance. (1992-3) $4,940 Principal Investigator. Faculty Research Grant for Conference/Performance Travel. Third Annual Symposium on Environmental and Occupational Health in Central & Eastern Europe in Poland. (1992)$600 Co-Investigator. Occidental Chemical Corporation. Development of a Corporate Epidemiological Surveillance System. (1991-2) $50,000/year Principal Investigator/Convenor. National conference, "Occupational Surveillance" University of Massachusetts, Amherst, MA (April 28-30,1991) $22,000 Co-Investigator. Chemical Manufacturers of America. Development of Resource Materials for Occupational Epidemiology. (1990) $75,000 SL 107222 Mundt C.V,, p. 3 UNIVERSITY RESEARCH (continued) 1990 (cont'd) Principal Investigator. National Institute of Occupational Safety and Health. Immuno-Epidemiology of Crab-Induced Occupational Asthma. (1989-1990) $43,500. 1989 Principal Investigator. United Way of North Carolina. Immuno-Epidemiology of Crab-Induced Occupational Asthma: Pilot and Preparatory Phases. (1989) $4,000. Principal Investigator. Biomedical Research Support Grant, School of Public Health, University of North Carolina. Production of Antigen Solutions for Skin Testing. (1988-1989) $5,886. RELEVANT EXPERIENCE 1994 1993 - present 1993 - present 1993 - present 1993 1992 - present 1992 - present 1992 - present 1991-1993 Guest Editor, Journal of Ambulatory Care Management "Epidemiological and Managerial Challenges in the Workplace" Volume 17(2), April, 1994. Director, Occupational Epidemiology Unit School of Public Health, University of Massachusetts. Consultant to the Medical Director, The World Bank, Washington, D.C. ATSDR Peer Reviewer in Epidemiology. Member, 1993 Internship Program Objective Review Committee, Association of Schools of Public Health/Centers for Disease Control/Agency for Toxic Substances Disease Registry. Founder and Director, Surveillance Resource Center, Occupational Epidemiology Unit Epidemiologist, Northeast Regional Environmental Public Health Center, School of Public Health, University of Massachusetts. Member, Human Subjects Committee, School of Public Health, University of Massachusetts. Assistant Director, Occupational Epidemiology Unit, University of Massachusetts SL 1-07223 Mundt C.V., p. 4 RELEVANT EXPERIENCE (continued) 1991 - present Member, Union Carbide Scientific Board of Advisors. 1990 - 1992 Member, International Chrome Development Association, Health, Safety and Environment Committee, Paris, France. 1990-1992 Epidemiologist, Chromium Environment, Health and Safety Committee, Industrial Health Foundation, Pittsburgh, PA. 1988 -1989 Research Assistant"to Carl M. Shy, M.D., Dr.P.H., on Oak Ridge Universities Occupational Studies of Department of Energy Employees, and on North Carolina Dusty Trades Occupational Health Studies, University of North Carolina. 1988 -1989 Visiting Researcher, Duke University Marine Biomedical Center, Duke Marine Laboratory, Pivers Island, Beaufort, North Carolina. 1983 -1984 Commissioned Officer Student Training Extern Program (COSTEP). United States Public Health Service, Health Resources and Services Administration, Silver Spring, Maryland. TEACHING EXPERIENCE 1989 - present 1987 -1988 Assistant Professor University of Massachusetts, School of Public Health: "Principles of Epidemiology" "Applied Epidemiology" "Occupational Epidemiology" "Special Topics in Occupational Epidemiology" "Departmental Doctoral Seminar" Numerous Independent Study Projects Teaching Assistant to David G. Kleinbaum, Ph.D. University of North Carolina, School of Public Health. "Special Topics in Epidemiological Methods" "Advanced Methods in Epidemiology" SHORT COURSES 1993, 1994 Applied Epidemiology, Inc. and Akademie fur offentliche Gesundbeit, Wermelsckirchen, Germany: "Intensive Course in Occupational Epidemiology" SL 107224 Mundt C.V., p. 5 SHORT COURSES (continued) 1991 Cancer Registry of Norway, Oslo, Norway. August 12-16: "Occupational and Environmental Epidemiology" 1989, 1990, 1991 International Summer School for Epidemiology, World Health Organization and the Akademie fur offentliche Gesundheit, Bochum, Germany "Occupational and Environmental Epidemiology" HONORARY AND PROFESSIONAL SOCIETIES American Conference of Governmental Industrial Hygienists (Full Member) American Public Health Association Delta Omega, Public Health National Honor Society International Society for Environmental Epidemiology Sigma Xi, Scientific Research National Honor Society Society for Epidemiologic Research PRESENTATIONS 1994 Birk T, Mundt KA, Schumann J, Person M, Weiland S, Keil U. "Cost-center Accounting Codes ("Kostenstellen") as Exposure Indicators in an Epidemiological Study of the German Rubber Industry." Conference on Retrospective Assessment of Occupational Exposures in Epidemiology, Lyon, France, April 13-15, 1994. Weiland S, Birk T, Mundt KA Person M, Schumann J, Keil U. "The Epidemiologic Study of Cancer in the Rubber Industry in Germany: An Update." International Conference on Occupational Health in the Rubber Industry, The Netherlands, May 31-June 1, 1994. 1993 Mundt KA "Occupational Epidemiology in a White-Collar Setting" Invited Speaker, The World Bank, May 11-12,1993. Mundt KA "Occupational Surveillance: Concepts and Goals." Second National Conference on Occupational Surveillance, University of Massachusetts, Amherst, MA March 9-11,1993. SL 107225 Mundt C.V., p, 6 PRESENTATIONS (continued) Mundt KA "Practical Stxetegy for Developing Epidemiological Surveillance." Design and Analysis Workshop, Second National Conference on Occupational Surveillance, University of Massachusetts, Amherst, MA, March 9-11,1993. 1992 Mundt KA and Weiland S. "The Association of Asthma Symptoms and Allergic Rhinitis with Traffic Density on Street of Residence." Annual meeting of the International Societies for Environmental Epidemiology and of Exposure Analysis, Cuernavaca, Morelos, Mexico, August 26-29,1992. Pastides H and Mundt KA. "Retrospective Estimation of Exposure to Hexavalent Chromium in an Occupational Cohort." Annual meeting of the International Societies for Environmental Epidemiology and of Exposure Analysis, Cuernavaca, Morelos, Mexico, August 26-29,1992. Pastides H and Mundt KA "Epidemiological Occupational Surveillance." Surveillance in Europe and the EEC, Devonshire Park Centre, Eastbourne, Sussex, United Kingdom, July 1-3, 1992. Mundt KA "Occupational Surveillance as a Strategy for Policy Development and Disease Prevention." Protecting Workers, the Environment and Health in a Market Economy: Translating Science into Policy and Action. Tlie United StatesCentral and Eastern Europe Exchange for Occupational and Environmental Health, third annual symposium, Pultusk, Poland, June 26 - July 1,1992. Pastides H, Austin R, Lemeshow S, Klar J, Noess R, and Mundt KA "A Retrospective Cohort Study of Health Risks Among Chromate Production Workers." Annual Meeting of the Society for Epidemiologic Research, Minneapolis, MN, June 10-12, 1992. Weissman L and Mundt KA "Prevalence of Immediate Hypersensitivity in Black Women: A Re-evaluation of Skin Prick Test Data from the Second National Health and Nutrition Examination Survey (NHANES II) and Comparison with an Occupational Study." Annual Meeting of the Society for Epidemiologic Research, Minneapolis, MN, June 10-12, 1992. Mundt KA, Leeser J, Adams R. "Establishing a Mercury Biological Exposure Index (BEI)." American Conference of Governmental Industrial Hygienists (ACGIH) BEI and Threshold limit value (TLV) Committees, Orlando, Fla., March 21-22,1992. 1991 Mundt KA "Epidemiological Approach to Occupational Health." Annual Scientific Meeting, Industrial Health Foundation, Pittsburgh, PA November 6-7,1991. Mundt KA "Role of Epidemiology in an Occupational Medical Department" Bayer Chemical, Leverkusen, Germany, June 19, 1991. SL 107226 Mundt C.V., p, 7 PRESENTATIONS (continued) Mundt KA "Occupational Epidemiological Studies and the Social Context" Department of Epidemiology, State University of New York at Albany, April 18, 1991. Mundt KA "Use of Skin Tests in Epidemiological Research." Clinical Epidemiology Department, University of Pennsylvania, Philadelphia, PA March 14, 1991. Pastides H and Mundt KA "Establishing"an Occupational Epidemiology Program." Chemical Manufacturers Association, Washington, D.C., March 12,1991. 1990 Mundt KA "Studies to Document the Healthy Worker Effect" Department of Work Environment, University of Lowell, Lowell, MA, December 11,1990. Mundt KA and Miller J. "Use of Industrial Hygiene Data in Epidemiology Research." Occidental Chemical Industrial Hygiene Annual Meetings, Houston TX and Atlantic City, NJ, November 12-14,1990. Mundt KA and Shy C "Occupational Allergies and the Healthy Worker Effect" Annual Meeting of the Society for Epidemiologic Research, Snowbird, Utah, June 12-15, 1990. Mundt KA "Health Effects of Vinyl Chloride Monomer (VCM)." Occidental Chemical Company, Plastics and Polymers Group, Berwyn, PA May 11,1990. 1989 and earlier Mundt KA "Skin Testing for Allergies in an Occupational Setting" Clinical Epidemiology Seminar Series, University of Massachusetts Medical Center, Worcester, MA, December 20,1989. Mundt KA "Immuno-Epidemiology of Crab-Induced Occupational Asthma: Methodological Issues." Visiting Researcher Program, Duke University Marine Biomedical Center, Beaufort, North Carolina, January, 12-13,1989. Mundt KA and Heiss G. "Measuring Ankle Systolic Blood Pressure: Interaction Between Ankle Geometry and Method of Applying Blood Pressure Cuff" National Heart, Lung and Blood Institute Seminar, Bethesda, Maryland, November 3, 1987. Mundt KA and Pastides H. "Microcomputer-Based Instruction: Applications in Epidemiology." Annual Meeting of the American Public Health Association, New Orleans, Louisiana, October 18-22,1987. Mundt KA "Distribution of Selected Mineral Concentrations in Urban Children's Hair." Annual Meeting of the American Public Health Association, Las Vegas, Nevada, September 28 - October 2,1986. SL 107227 Mundt C.V., p. 8 PUBLICATIONS AND REPORTS 1994 Mundt KA Dell LD. Neuropsychological effects of environmental dioxins and furans? (accepted for publication) Occupational and Environmental Medicine Report 1994. Pastides H, Austin R, Mundt KA, Ramsey F, Feger N. Transforming industrial hygiene data for use in epidemiology studies: A case study of hexavalent chromium (accepted for publication) Journal ofOccupational Medicine and Toxicology 1994. Mundt KA Epidemiological surveillance: A management tool for occupaitonal health. Journal of Ambulatory Care Management 1994;17(2):20-29. Wei land SK, Mundt KA, Ruckmann A and Keil U. Self-reported wheezing and allergic rhinitis in children and traffic density on street of residence. Annals of Epidemiology 1994;4:79-83. Pastides H, Austin R, Lemeshow S, Klar J, Noess R and Mundt, K, A retrospective cohort study of occupational exposure to hexavalent chromium (accepted for publication) American Journal of Industrial Medicine 1994. Gehlbach SG and Mundt KA Evaluating Worksite Health Programs. Journal of Ambulatory Care Management 1994;17(2):88-94. 1993 Pastides H and Mundt KA Establishing an Epidemiological Occupational Surveillance Program. Chemical Manufacturers of America, Washington, D.C., 1993. Mundt KA Occupational surveillance as a strategy for policy development and disease prevention. In: Proceedings of the Third Annual Symposium on Environmental and Occupational Health during Societal Transition in Central and Eastern Europe. Protecting Workers, the Environment and Health in a Market Economy: Translating Science into Policy and Action, June 26 - July 1,1992. Published by Management Sciences for Health, Boston, Massachusetts, 1993. 1992 Mundt KA The Workplace as Laboratory. Business Digest, June 1992;34. Mundt KA, Chambless LE, Burnham CB and Heiss G. Measuring ankle systolic blood pressure: Validation of the Dinamap 1846 SX. Angiology, 1992:43(7);555-566. Mundt KA Letter to the Editor: RE: "Exposure to residential electric and magnetic fields and risk of childhood leukemia" and "Case-control study of childhood cancer and exposure to 60-HZ magnetic fields." American Journal of Epidemiology 1992:135(9); 1070-1075. SL Mundt C.V., p. 9 PUBLICATIONS AND REPORTS (continued) Health, Safety and Environment Committee, International Chromium Development Association. Health, Safety and Environment Industry Guidelines. Paris, France, April, 1992. Pastides H, Miller JR, Mundt KA, Klar J, Adams RF, Olendorf T. A characterization of occupational static magnetic field exposures at a diaphragm-cell and a mercury-cell chlor-alkali facility. Applied Occupational and Environmental Hygiene 1992;7:42-48. 1991 and earlier Mundt KA. Epidemiological Review of the American Conference of Governmental Industrial Hygienists (ACGIH) Recommended Biological Exposure Index (BEI) for Urinary Mercury. The Chlorine Institute, September 30,1991. Pastides H and Mundt KA. Resource Manual for Occupational Epidemiology, Chemical Manufacturers of America, Washington, D.C., 1991. Walker A and Mundt KA. Feasibility of Conducting an Industry-wide Study of Respiratory Cancer Related to Ceramic Fiber Inhalation, Final Report to TTiermal Insulators Manufacturers Association (TIMA), Epidemiology Resources, Inc., Boston, MA, November, 1990. Mundt KA. Immuno-epidemiology of crab-induced occupational asthma, doctoral dissertation. University of North Carolina, 1990. Pastides H, Mundt KA, McKnight CJ and Tuthill RW. Formulating case definitions and identifying cases for analysis (computer-assisted instructional software). In "Applied Epidemiology," Centers for Disease Control, Atlanta, Georgia, 1986. Pastides H, Mundt KA, McKnight CJ and Tuthill RW. Descriptive analysis of the disease outbreak (computer-assisted instructional software). In "Applied Epidemiology," Centers for Disease Control, Atlanta, Georgia, 1986. Pastides H, Mundt KA, McKnight CJ and Tuthill RW. Formulating and testing hypotheses (computer-assisted instructional software). In "Applied Epidemiology," Centers for Disease Control, Atlanta, Georgia, 1986. Mundt KA. Distribution of selected mineral concentrations in urban children's hair. Masters thesis. University of Massachusetts, 1986. Tuthill RW and Mundt KA An evaluation of hazard abatement activities in selected state-funded lead screening programs, Final report to Massachusetts House of Representatives Post Audit and Oversight Committee, June 27,1985. Mundt KA and Polk BF. Identification of site urinary-tract infections by antibody-coated bacteria assay. Lancet 1979;2:1172-5. Mundt KA and Polk BF. Predictive value of a single diagnostic test: a belated correction. New England Journal of Medicine 1979;300(15):859. Revised 3/94 SL 107229 POTENTIAL CONTRACTORS Howard Rockette, Ph.D. Department of Biostatistics Graduate School of Public Health University of Pittsburgh 130 DeSoto Street Pittsburgh, PA 15261 (412) 604-3022 Harris Pastides, Ph.D. School of Public Health Occupational Epidemiology University of Massachusetts Room 407 Arnold House Amherst, MA 01003 (413) 545-6167 Sc&L f -JOLla Pl\h yUA oioos (S4t^ SU'S-XZU Dr. Roy E. Shore Professor Environmental Medicine New York University Medical Center 341 E. 25th Street, Room 204 New York, NY 10010-6500 (212) 340-6500 SL 107230 DRAFT Scope of Work Update of Mortality Among Vinyl Chloride Workers The Chemical Manufacturers Association (CMA) is interested in receiving proposals to update the mortality experience among an established cohort of workers employed in the vinyl chloride/polyvinyl chloride (VC/PVC) industry. This cohort was previously studied by Tabershaw and Gaffey (1974), Cooper (1981) and Wong, et al. (1991). The Scope of Work for this project is outlined below and includes some key elements which should be addressed in any proposals submitted. As you will note, the CMA is interested in receiving two major work products at the conclusion of the project: 1) A written technical report summarizing an epidemiologic evaluation of the mortality experience of the workers through 1992 and 2) A manuscript which is suitable for publication in the peer-reviewed scientific literature. Background The original records which formed the basis for prior reports of the mortality experience of this cohort are currently in the possession of ENSR Health Sciences located in Alameda, California. If a different study group is awarded the contract to conduct the update study, CMA will arrange the transfer of all pertinent records from ENSR to that contractor. However, ENSR did make confidentiality agreements with some states (see attached list) precluding a direct transfer of death certificates for some of the cohort members. Therefore, submitted proposals will need to indicate how other contractors would proceed to obtain such death certificates for persons dying prior to 1983, the end date for follow-up in the most recent update. Projected Scope of Work All proposals submitted in response to this request should address the following issues: 1. Verification of the completeness of the database in comparison with the results of the most recent update (see Wong, et al. 1991, attached.) SL 107231 2. How to obtain death certificates for employees dying before 1983 which could not be transferred directly from ENSR. 3. Ascertainment of vital status of cohort members who survived through the end of the previous update period (i.e., 12/31/92.) 4. Obtaining death certificates for employees determined to have died after 1982 and assigning a nosologically valid cause of death to each. 5. Conduct of a Standardized Mortality Ratio analysis comparing the cause-specific mortality experience of the cohort with age-, race-, gender-, and period-specific rates for the U.S. male population and individual state male populations. The analyses conducted should consider at least the following factors: Age at first exposure Year of first exposure Type of plant (VCM or PVC) Length of exposure Elapsed time since first exposure In addition to these points, any proposal should also include the investigators' thoughts on the feasibility and technical merit of the following: 1. Updating the exposure histories of surviving cohort members from 1982 through 1992. 2. Performing internally standardized mortality comparisons using such methods as Poison-regression for comparing SMR's. f .! ;- >. " - * / r <' ~ _ ' ^L SL 1-07232 Technical Criteria You may be interested in some of the criteria that the CMA Vinyl Chloride Research Coordinator's Group will use to evaluate the proposals received. These are listed below for your consideration when preparing your response. The criteria are not listed in any particular order and should not be viewed as having equal weight. 1. The curriculum vitae for each of the scientists who will comprise your project team. 2. Your proposed approach to each of the technical items listed in the Scope of Work. 3. Your proposed schedule for completion of the required deliverable work products listed below. 4. Your description of the technical and physical resources at your disposal for completion of this project. Required Deliverable Work Products The deliverables expected by CMA include the following: 1. A series of timely progress reports addressing the following: Verification of completeness of the existing database against the tables presented in the 1986 report to CMA prepared by Wong, et al. (see attachment.) Outcome of efforts to ascertain vital status of cohort members through 1992. Outcome of efforts to obtain death certificates for employees dying after 1982, and for employees dying before 1983 if necessary. 2. A detailed technical report summarizing the epidemiologic analysis submitted to CMA for review and commentary by participating member companies. SL 107233 3. A manuscript suitable for publication in the peer-reviewed scientific literature, submitted to CMA for review and commentary by participating member companies. Timing Investigators wishing to submit proposals should do so by June 15, 1994. CMA would like to receive proposals in two separate documents--one containing the technical proposal and one containing the cost and time-schedule proposals. This will allow us to evaluate the technical merits of the proposal independent of cost and timeschedule considerations. Please supply an original plus ten copies of the technical proposal, and an original plus two copies of the cost/time-schedule proposal. CMA proposes to evaluate all proposals received in late June 1994, and will select a contractor in July 1994. CMA proposes to award a fixed-price contract to the successful applicant. If your project team prefers a different form of contract, please indicate your preference in your cost proposal. Additional Information Please contact Dr. Has Shah at (202) 887-1192 if you have any questions about this request or about contract administrative details. Our lead scientist for this effort is Dr. Jonathan Ramlow of The Dow Chemical Company. You may contact him at (517) 636-1276 with questions about the scientific aspects of this Scope of Work. SL 107234 Status of ENSR Confidentiality Agreements with Individual States ENSR had to enter into agreements with different entities to obtain death certificates. In some states, there were no restrictions with whom who we could share, while with others there are variable restrictions. The following summarizes the options by the states that know: Group A: States will allow ENSR to give the death certificates to individual companies or CMA as long as we document what is being transmitted This group includes the following states: Alaska, California, Connecticut, Washington, D.C., Illinois, Iowa, Maryland, Massachusetts, Minnesota, Nevada, Ohio, and Washington. Group B: ENSR can provide state file numbers, dates of death, and names to companies or CMA. This group includes the following states: Colorado, Georgia, Idaho, Indiana, Kentucky, Louisiana, Maine, New Mexico, New York, Oregon, Rhode Island, South Carolina, West Virginia, Wisconsin, and Wyoming. Group C: These states require both ENSR and the companies or CMA to write and request the death certificates based on the studies. This involves completing application forms for each state (not all the same), entering the state file numbers, and communicating with each company or CMA. There is then the additional cost of the death certificates. This group includes the following locations: Alaska, Arizona, Arkansas, Delaware, Florida, Kansas, Michigan, Missouri, Mississippi, Montana, New Hampshire, New Jersey, New York City, North Carolina, North Dakota, Oklahoma, Pennsylvania, South Dakota, Tennessee, Texas, Utah, Virginia, and Puerto Rico. We are still investigating the process for three states: Hawaii, Nebraska, and Vermont. They have not responded to multiple inquiries. SL 107235