Document r6x2oBQdb9MvnzGmj8XD4jdOv

HILL and KNOWLTON, Inc. MEMORANDUM TO: VCM-PVC Producers Committee FROM: Matthew M. Swetonic SUBJECT: Recent Developments April 11, 1975 Attached for your information are a number of recent articles, medical papers, etc, of importance on vinyl chloride. 1. Article from the April 14 issue of Business Week on industry efforts to meet the new OSHA standards. 2. Article from the April 7 issue of The New York Times on a letter from Dr. Herbert Stokinger of NIOSH to his former boss, Dr. Marcus Kay, attacking the vinyl chloride standard as "irrational. " Also attached is a copy of a 1971 paper by Stokinger on seven commandments for setting environmental standards. We are currently trying to interest selected segments of the media in doing more on this story. 3. Article from the February 22 issue of The Lancet on "Chromosome Aberrations in Workers Exposed to Vinyl Chloride. " 4. Notice from March 17 issue of Commerce Business Daily announcing a solicitation by NIOSH for research organizations capable of doing work on the pathogenicity of vinyl chloride. 5. Article from the April 7 edition of Chemical & Engineering News on industry efforts to meet the new OSHA standards. 6. Articles from the April 1 issues of The Wall Street Journal and The Journal of Commerce on the Supreme Court's refusal to stay the effective date of the OSHA standards. UPI, AP and Reuters also carried stories on the Court decision. The New York Times mentioned it briefly in its weekly wrap-up of Supreme Court decisions. 7. Editorial from the February 8 issue of the Canadian Medical Association Journal. 8. Consumer Product Safety Commission "Fact Sheet" on vinyl chloride. 9. Interview with Louis Beliczky of the Rubber Woikers Union from the latest issue of Job Safety & Health, an OSHA publication. 10. UPI story from the April 7 issue of The Financial Weekly on Robintech's efforts to control VCM levels in its plants. OO8955 INDUSTRIAL PRODUCTION 't The struggle to meet PVC safety standards Many producers claim that they cannot comply with dustry's battle to overturn the regu lations. So companies that work with the material are struggling to meet the tors in which the polymerization takes place are opened for cleaning. What is more, a pvc plant is a veritable spa OSHA's 1-ppm requirement standards in case spi loses. ghetti bowl of pipes and pumps, and vi The 22 polyvinyl chloride manufac nyl chloride "excursions" can occur at turers are facing the biggest challenge. any one of the hundreds of flanges and The vinyl plastics industry is not ready to show the white flag in its fight to get stringent worker-exposure standards They polymerize vinyl chloride, be lieved to cause cancer in humans, into pvc resin, which is then fabricated into valves. Many pvc producers say they cannot possibly comply with the Occu pational Safety & Health Adminis reduced. But the Supreme Court's re fusal this week to extend the Apr. 1 compliance deadline does not augur well for the Society of the Plastics in a wide variety of industrial and con sumer goods. Workers in pvc plants are exposed to high levels of vinyl chlo ride gas whenever the tank-like reac tration ruling that by April, 1976, workers may be exposed to an average of no more than one part per million of the gas during an eight-hour shift, and to no more than 15-minute peaks of 5 ppm. To meet these standards, workers may have to wear respirators, a fact that does not sit well with them. As Edwin W. Harrington, director of plas tics manufacturing at B. F. Goodrich Co., flatly states, "2 ppm or 3 ppm is the lowest we could ever hope to get." Goodrich (fort. Goodrich, the nation's largest PVC manufacturer, is already spending some $42-million on improved cleaning methods and the like. It has managed to lower exposure level at its five PVC plants from 50 ppm to an aver age of 6 ppm, but the mandated 1-ppm level remains out of reach. Other coin- panies-particularly those with old re actors like Goodrich's that must be manually cleaned every other day, and indoor plants where ventilation is poor-have had similar failures. "The flanges are under 35 lb, of pressure per sq. in., and vc molecules still get through," says one plant manager who says he has spent $25,000 on the devel opment of better gaskets and seals. Such frustrations are not unique. De spite the recession-caused slump in de mand, vc and pvc producers are al ready spending $200-million to comply with the OSHA standards, estimates John R. Lawrence, SPl's technical direc tor. Success remains elusive for most. Because the leaks are so difficult to eliminate, several companies are turn ing to better cleaning methods to re duce worker exposure. Japan, with only a 25-ppm voluntary standard for the vinyl industry, is ahead of the U. S. in this area. According to the Japanese Pvc Assn., at! Japanese plants use mechanized high-pressure water jets to clean facilities in order to minimize workers' contact with gases. U. S. producers are starting to follow suit. Most have installed powerful vac uum hoses to purge reactors of vc fumes before they are opened for cleaning. And many are using high- pressure spray cleaning devices to re duce the frequency of manual scraping Point ot danger-. Workers are most exposed to vinyl chloride when they clean reactors. and cleaning operations. After each 34 o BCS'NESS AEEK m IV75 BOR 008956 A brief remind rto busin ssm n who in 1962 thought the Polaroidcamera was just an expensive toy. Th large reactor is one a. .sw r "Large reactor technology" may prove the most feasible way out of the vinyl chloride emission morass. One large re actor for polymerizing vc resin into PVC requires hundreds fewer flanges and valves than do a dozen small ones. This drastically slashes the number of potential vc leak points. The concept is already working for Japan's Shinetsu Chemical Industry Co., which built Japan's only 35,000-gal. pvc reactor in 1970. And it is now working for Shintech, Inc., a joint ven ture of Shinetsu and Robintech, Inc., of Fort Worth, Tex. Shintcch's Freeport (Tex.) pvc plant is using four 35,000gal. reactors to produce the same amount of pvc that would be made in some 30 smaller reactors in traditional plants. The giant reactors require man ual cleaning no more than once a year. Shinteeh's experiences since the plant came on stream in October have been more than encouraging. "All our tests indicate we're well below the 1-ppm level without the use of respirators," claims James M. Danial, Shintech vicepresident. Treatment. The key to Shinteeh's sharply reduced cleaning schedule is a proprietary treatment applied to reac tor walls after each batch of PVC is made. The coating is sprayed on under high pressure after the reactor is purged with a hydraulic spray and a vacuum. "The whole plant is tighter than older pvc plants," claims Joseph L. Brawner, Shinteeh's plant manager. "We've used welded construction on lines holding vinyl chloride wherever we could, eliminating flanges." The plant is entirely computer-controlled and operates with only 25% of the 163man work force required at Robin- tcch's older Painesville (Ohio) plant, which has about the same capacity. Tenneco Chemicals, Inc., has licensed the technology for its new pvc plant in Pasadena, Tex. The plant has five 35,000-gal. reactors and a capacity of 250-million lb. According to Joseph P. Fath, a Tenneco Chemicals vice-presi dent, the plant incorporates some reac tor cleaning technology that Tenneco developed on its own which will "ob viate reactor opening and entry in the long run." But. Fath admits, there may still be maintenance situations where respirators are needed. It's not always wise to be negative. New developments have a way of changing old preconceptions lake Mississippi for example. Nothing but gators and mint juleps, nght? You really should get the facts In our book we tell yuu about our available labor and raw materials and abundant transportation and favorable tax laws Of '-ourse, you already know about our great climate You see tt on all those New Year's football yjmes If youie smart, youII wnte for the book If you re even smarter, you'll move yuur plant here And if you're a genius, you II fly down tun.onow a,id make some Polaroid shots of the place. Al.nij vsilii .-iy Kg Ihmlt Mississippi button pU.'A >t",tI trit *'if')U:,tili'>M "> !_ Initii".,mI `-.pp 'iiji.ituK m Mississippi 1 Aii.ilIi e.iUpon to yiur \ uyuv&s K'ft^rli.'.v? ) r_] Tt i.',`I i iff million inui , j, fr^vd Jwhj* ) *v pi while iookitig for j t, p!ini Nd-^ --- _ __ ..... iitir_____ B'JSinS > __ ___ __________ AJilu-v, ,, ( if. 'll i\* Zip _ A & t Uu^id P O Box 84^ .Jjsishfn Mii.Slw..^pl VCO'j 34 H _kj ,Vli ' batch of pvc is made, the tanks are hosed down to flush out unreacted vinyl chloride monomers andaccumulated pvc resin. "We are down to manual clean ing after only 2'r of batches," says Goodrich's Harrington. "With hydrau lic spraying, we are at 5 ppm for only five minutes instead of 30 minutes when we clean a reactor," adds Eli Zinn, plant manager at Diamond Shamrock Chemical Corp.'s Deer Park (Tex.) plant. Both Goodrich and Diamond Sham rock use water hydraulic sprays. Other pvc manufacturers, such as Union Carhide Corp. and Monsanto Co,, are try ing closed-reactor solvent cleaning sys tems, and Carbide officials claim that reactors at their Texas City plant nowneed manual cleaning only once every two months. Another problem. Even with perfected cleaning methods, however, the vinyl plastics industry will still have another hurdle to overcome: recovering unreacled vc monomer that may be trapped in finished f'VC resin. If the monomer is not removed before ship ping, it can escape when the resin is heated for fabrication. This then threatens fabrication workers with ex posure to unacceptable vc levels. Recovered vc can be recycled back into the pvc process, so pvc manufac turers are especially interested in de veloping technology for stripping un reacted monomers front the resins. But so far, they are facing a Catch-22 typo of problem. While the goal is to let fab ricators heat the resin without releas ing vestiges of VC, current stripping methods also require heating. The re sult can be overheating, which causes hydrochloric acid molecules to break away from the resin. The resin then turns brown and weakens. ''Once this degrading starts at the pvc manufac turing level, it continues throughout fabrication, so the goal is to get the vi nyl monomer out faster without excess heat." explains Goodrich's Harrington. One new process that looks promising involves use of a vacuum in the reactor to strip much of the unreacted mono mer before the resin is dried. A number of PVC manufacturers have programs under way to develop recovery meth ods. Goodrich, for one, hopes to market a system by yearend. But OSHA is leaving nothing to chance so far as claims l'or any system go. Us vinyl industry standard not only specifics exposure limits but mandates that all vinyl producers keep records of worker exposure and monitor vinyl chloride levels wherever they are ex pected to exceed 0.5 pptn. The fabrication plants may escape the monitoring problems, because most can establish that they have exposure levels below 0.5 ppm. "In most fabrica ting plants, there are already ducts and vents above the blenders to meet ear lier dust and fume regulations," notes BOR 008957 SPi's Lawrence. Fabricators may face exposure levels above 1 ppm in Pvc resin storage areas, but "the over-all concern for reducing exposure is with the PVC producers." Lawrence says. The monitoring requirements are a problem for pvc makers. The equip ment is not cheap-Diamond Shamrock, for one, has already spent $350,000 to monitor its Deer Park plant. And much of the monitoring technology is still embryonic. Only recently have vapor detectors and analyzers been able to work with levels as low as 0.5 ppm. Bandlx system. Most rvc producers are pursuing combination systems that in clude continuous area monitoring, por table monitoring, and personal moni tors. Bendix Corp. pioneered most of the vinyl chloride monitoring equip ment when the original pvc cancer scare broke a little more than a year ago, and the company's monitoring systems are still among the most widely used. At Goodrich's plants, the Bendix system includes funnel-like air samplers scattered throughout the work area. The samplers suck up air and feed it back into a gas chromato graph in a continuous stream. The chromatograph can detect vc monomer concentrations down to 1 ppm. In most plants, the chromatograph is hooked into an alarm system that is quickly .iggered when concentrations go above 25 ppm. If area sampling indicates an up surge in vc monomer, portable organic vapor analyzers are dispatched to the spot to pinpoint the valve causing the vc leak. These monitors are rarely ac curate below a 5-ppm concentration, but that is good enough for the pur pose. "They don't actually distinguish The vinyl plastics industry says $200-million still hasn't produced success vinyl chloride, but tell us if there is alien vapor in the air so we know which trouble spots to check further," says a Goodrich spokesman. Personal monitoring comes closest to detecting actual worker exposure. This is the method used by OSHA inspectors themselves. Workers wear a batterypowered device about the size of a transistor radio. It houses a charcoal tube, which absorbs vc vapors. The tube is inserted in a gas chromato graph, which can determine the amount of vc the worker was exposed to. Such personal monitoring may prove the crucial area for osha com pliance. Says Robert N. Rylands, man ager of Goodrich's Avon Lake (Ohio) plant, "As far as the osha standard is con ad, the real story is told with the personal monitoring.'' Even if the vinyl companies manage to meet osha's exposure and monitor ing rules, they may face additional problems from the Environmental Pro tection Agency. The EPA is in the pre liminary stages of developing an emis sion standard for vinyl chloride. Unlike the OSHA standard, the EPA rule is un likely to pinpoint parts-per-million lim its. Most industry sources expect that the agency will stress add-on pollution control devices, such as carbon adsorp tion and solvent absorption scrubbers, and incineration of eaptyred vc gas. But the spi's Lawrence and several EPA officials are optimistic that many of the measures that will satisfy osha will also satisfy the epa. Better seals and ventilation in plants, improved maintenance procedures for flanges and seals, and advanced stripping tech nology can all help. "If they can re move the monomer in the stripping process, they won't need so much con trol equipment downstream," admits Susan R. Wyatt, departmental engi neer at the epa's Office of Air Quality Planning & Standards. Lawrence agrees, saying: "Many things the in dustry is doing to meet the OSHA stan dards will go a long way in meeting epa requirements." 34 L eiJS'NEr-ii AprAU, 197S Bodine puts more into its fhp motor and drive system design to give you greater bottom line profit in the long run. We call it ADE (After Delivery Economics). You get fewer rejects from the start and less profit robbing service headaches when your product is in use. Motor to motor, lot to lot, Bodinc's con sistent quality pays big performance dividends. If you're concerned about costs, profit ability and tomorrow's repeat sales, take a close look at Bodine. You won't find a better fhp buy--1/2000 thru !4 Hp. Bodine Electric Company, 2500 W. Bradley Place, Chicago, 1L 60618. Phone: (312) 478-3515, Telex: 25-3646. ADE (After Delivery Economies) make Bodine a bottur Hip buy BODINE ELECTRIC COMPANY GUOEOAINRCMMOOTTOOfRlSS SPLCO CONTROLS BOR 008958 THE A'ElC iOhA T//V~i> frJA'SAy , *r/'T'`T ~ Scientist Calls Strong Curb on Exposure to Vinyl Chloride'Irrational' By DAVID BURNHAM , ttrirtiltirTin Witt TtnrTITrf Washington, April 6--a key Federal official has de nounced the scientists of the National Cancer Institute as "a lot of old fogies" and has de scribed as "an irrational deci sion" a Government require ment that workers be exposed to virtually no vinyl chloride. The criticism was voiced by Dr. Herbert E. Stockinger, who occupies prominent positions in both the Federal agency now responsible for establishing in dustrial exposure levels and the professional association that has recommended these stand ards for many years. The position of the cancer institute and other Federal agencies is that exposure to even the smallest amounts of vinyl chloride--the chemical base of a widely used plastic-- should be avoided by workers because it has been shown to cause cancer at very low levels of exposure and because its safety has not been demon strated at any level. Dr. Stockinger is chief of the toxiccology branch of the Na tional Institute for Occupational Safety and Health, the Federal agency established in 1970 to develop industrial exposure levels. He is also chairman of the committee on threshhold limits of the American Confer ence of Governmental Hygien ists, an organization whose recommended standards have dominated health practices in the United States and scores of other countries for many years* Criticized Institute The official criticized the cancer institute during a tele phone interview when asked about a letter in which he said the Government's vinyl chloride requirement was wrong. The letter, a copy of which has been obtained by The New York Times, was addressed to Dr. Marcus M. Key, the recently retired director of the Institute for Occupational Safety and Health and Dr. Stockinger's superior. "I was consternated, as were members of my threshhold lim. its committee, when we noted your name associated with the essentially zero tolerance for exposure to vinyl chloride," Dr. Stockinger's letter began. "In making the irrational de cision it is clear to us that you have fallen into the fallacious trap of believing that because the substance produces dire consequences at massive con centrations (and in this case probably aided by promoters), such consequences will result from exposure at all concentra tions. Wrong!" In the interview last week, Dr. Stockinger stood by his criticism of the Government's position on vinyl chloride, which he charged had been made for "political and other reasons." Dr. Stockinger then was asked about the statement ot Dr. Frank J. Rauscher. director qf the National Cancer program of the cancer institute, that re peated exposures to 250 parts per million of vinyl chloride should be regarded as a car cinogenic risk. "The safety of vinyl chloride has not been demonstrated at any level: there is no practical acientific method to prove ex perimentally the safety of any level of exposure to a carcino gen," Dr. Rauscher said. "Oh, there are a lot of old fogies over there at the Nation al Cancer Institute," Dr. Stock inger replied. Dr. Key, who received Dr. Stockinger's letter, now is a professor of occupational mediciae-at the University of Texas's Sdfcoi of Public Health in Houston. Aaked about the letter. Dr. Key said that though he had the "utmost respect for Dr. Stockinger. I think I just let it drop.T* .The threshhold limits com mittee that Dr. Stockinger beads has recommended ex posure levels for more than 500 individual 'chemicals or families of chemicals since it was formed in the late nineteen- thirties. These standards were accepted as a package by the Federal Government in 1971 under tiie law creating the National institute for Occupa tional Health and Safety, pendinf the slow proems of a complete review. U.S.S.R. an Exception The standards of Dr. Stock inger's committee also form the basis for the exposure levels permitted in almost all other countries of the world except the Soviet Union and the Eastern European socialist countries. In another Government health development the msttitute for occupational health hgs begun proceedings to dis charge one of its scientists af ter he accused the institute of needlessly exposing American workers to the risk of cancer. The allegation was made a little more than two months ago by Dr. Stanley C Mazaleaki, In an affidavit fried in Federal court. On March 19, the institution which has denied the charge, Informed Dr. Mazalestd that his services would "be terminated because of marginal or sub standard performance by you." The scientist, who is challeng ing his dismissal, said that the action was "an act of retalia tion because of my criticism." BOR 008959  r\ : ' Sanity in Research and Evaluation * of Environmental Health TK .ollowing roles, if followed, should go far in improving the criteria and standards for judging environmental pollution, as well as nuking them less worrisome to those who arc being protected and m,orc stableto ,hose who must comply. How to achieve a realistic evaluation (in seven commandments). Early in 1969, before the methyl^ mercury story broke into headlines, I presented a Cummings Memorial Lec ture titled, `The Spectre of Today's En vironmental Pollution--U.S.A. Brand --New Perspectives from on Old Scout" (/). I attempted a sane and real environmental sources, cither alone or in combination with respiratory irri tants, headed the list as pollutants of primary concern; yet pesticides of all types, as well as teratogens and muta gens, as found in the three environmen tal sources, were conspicuously absent istic. comprehensive toxicologic evalu from the list. Asthmagcns were not ation of the potential hazards to human absent. health from man-nude and natural en What-has the record shown since? vironmental pollutants (except radia The pesticide DDT [l,l,l-trichloro-2,2tion) in air, water, and food, based on bis(/-chlorophcnyl)cthanc] and the her their occurrence in the continental bicide 2,4,5-T (2,4,5-trichloropbcnoxy- United States then and in the foresee acctic acid) were, on first action, able future. The evaluation was made banned from further use, as were all on a "before and after" consideration uses of organic mercurials as pesticides. of all those substances about which Swordfish has been removed from sale, '.health-oriented groups had expressed although people may still eat fish, just concern. After a considered appraisal as they have since before the time of of the available facts, I judged the va Christ (2). Cyclamates have gone, and lidity of the concern for each individual monosodium glutamate is on its way pollutant. out. Nitrilotriacctic acid (NTA), the Of 18 major pollutants or groups of soap industry's dream substitute for the pollutants from all sources (air, water, polyphosphates that the industry itself and food) combined, only eight were banned from laundry detergents, was reevaluated as potentially hazardous, summarily prohibited on fragile and and nut all of these with the same de provocative evidence (i). Detergent en gree of certainty. There was no ques zymes appear to be on their way out. tion, for example, of the deleterious Potato chips may be next because of effects of environmental nitrates (and their increased solanin content, caused nitrites) on infants and on genetically by dehydration of hot fat. hypcrsusceptible Alaskan Eskimos and What next? If man is prohibited from Indians, but the hazards to public consuming foodstuffs because of their health of "hard" water constituents, content of natural toxins, where will it while suggestive, were far from proven. end? Honey contains the potent gray- Respiratory irritants (particularly oxi a notoxins (given intrapcritoneally, a dants) and carcinogens from all three dose lethal to 50 percent of the animals 1 lie author is chairman of the Threshold Limits Committee of the American Conference of Gov* ernn.ema] Industrial Hygienists, chairman Of the SuDCommitfce on Toxico'npy of the Public Hea'ch Service Drinking Water Standards, and chairman of the National Research Council's Committee on Toxicology. He is also chief of the Laboratory of Toxicology and Pathology in the National In stitute for Occupational Safety and Health, U.S, Department of Health, Education, and Welfare, Cincinnati, Ohio 45202. tested is approximately 1 milligram per kilogram) (4). German raisins have been found to be teratogenic (J), while caffeine (6) and tannin arc tumorigenic (7); nutmeg, parsley, and dill arc highly toxic because of their myristicin and apiolc contents (6). Vitamin C has pro duced tumors in mice (9). Commandment 1 Standards must be based an scientific facts, realistically derived, and not on . political feasibility, expedience, emotion of the moment, or unsupported infor mation. If necessary data arc not avail able, studies should be made to supply them. Meanwhile, provisional, tenta tive, or best judgment standards, clearly - marked and recognized as such, should be proposed, but only upon definite need. Jf the need is not there, it is bet ter to withhold until such time as the facts arc in. This commandment poses relatively few difficulties for drinking water stan dards. Based on the accepted average daily intake of 2 liters per person (in the United States), and primarily on human health or esthetic considerations, standards have been and can be deter mined reasonably well. For toxic food contaminants, the problems arc more numerous but not unrcsolvablc. In this case, because of widely varied eating habits, realistic evaluation of the facts (generally derived from animals) re quires more erring on the side of com mon sense than on the side of the overprotection complex that seems to have captivated the thinking of those com mitted to setting tolerances. In the case of air pollutants, scientific facts for each of the multiple criteria (for exam ple, human health, nuisance, crop and vegetation damage, surface erosion, and soiling) must be carefully developed and painstakingly assessed before air quality standards arc proposed and de cisions arc made about which of the multiple criteria the standards rest on. In selecting criteria on which to base standards for the prevention of diseases caused by more than one factor, the temptation to ascribe an effect of ques tionable significance and doubtful con nection to a pollutant, merely because that pollutant was selected for investi gation, must not be yielded to. Alt too often in the past this commandment has not been followed, particularly in those cases in which a disease entity was not sharply defined or when there was a paucity of data on >t 662 BOR 008960 T ' Further compounding the difficulties Com*i mandment 3 of arriving at scientifically based stan- i for example particulates dnd sulfur di oxide. Here, the result'of almost total dards is the modish procedure of "con Avoid the establishment of unneces elimination is either tremendous and sensus" standards, in which individuals sarily severe standards This admonish disproportionate costs to industry (costs from all walks of life have their say ment runs against thq current tide of that are ultimately passed on to the through public hearings, citizens' ad boiling popular cnthus|asm for cleaning public) or the shutting down of indus visory committees, and Senate investi- pollution up completely. But it is time tries, with the resulting loss of personal . gating committees. But when all the that popular enthusiasm cool down, to and state income. statements have been heard and judg recognize the consequences of establish Clearly, the establishment of unnec ments and opinions sifted, the tenets ing goals instead of standards. The fol essarily severe standards for all types of commandment I should prevail, lowing instances illustate and support of pollutants must be avoided--for a with the added proviso of command my stand. number of good and sufficient reasons; ment 2. -The townspeople of Fallon, Nevada, otherwise, their repercussions will be as well as residents on a nearby Navy felt in a variety of undesirable ways. base, were gravely concerned for their .Commandment 2 health when on 16 February 1969 the state's health officer informed the may Commandment 4 All standards, guides, limits, and so or that Fallon's water supply (which is on, as well as the criteria on which they exclusively well water) has consistently Determine realistic levels. What is are based, must be completely docu* contained levels of arsenic in excess of realistic may be defined for each pollu rnented. In such documentation it must 0.03 milligram per liter, which is con tant type (air, water, and food) as fol be made emphatically clear on what sidered the "mandatory" limit by the lows. For air, tested levels (dosages) basis a given standard rests. This must United States Public Health Service. should bracket the national average not only be done in a formal, written Analyses of the well waters in the area concentration of a particular pollutant document, but in the press and other for arsenic confirmed this statement. in urban air by at least one logarithmic forms of news media as well, thus pre Depending on the season, concentra decrement and two logarithmic incre venting the public from becoming un- tions of arsenic ranged from 0.05 to ments. Tested levels for water pol* *. necessarily or unduly alarmed. For ex 0.22 milligram per liter, from June lutants should similarly bracket the ample, in all the public announcements 1963 to June 1968. Despite a survey by national average for the particular pol of the banning of DDT, it was never the county medical society and the lutant found in surface waters. In like made clear that it was not for protect mayor's subsequent statement that the manner for food contaminants, the foc ing human health, but for protecting town's population had been drinking the al point for bracketing in this instance such endangered species as osprey, bald water for 28 years without any known being the intended level of addition; eagle, and other fowl. Similarly, in the cases of arsenic poisoning; despite the or, when naturally occurring or environ confiscation of canned tuna in 1970, fact that some of the people concerned mentally imposed, the span of tested no effort was made to evaluate for were over 70. years of age; and despite dosages should embrace three logarith the public the degree of hazard or the the Attorney General's ruling, after mic increments. margin of safety in eating the fish. Pos public hearings with expert testimony, Establishing dosage-response relation itive assurance should be given those that there is no evidence that the drink ships in this manner provides three de with the highest fish intake (those on ing water of Fallon is harmful (a find terminants critical to the setting of real ' prescribed tuna diets for reducing) ing in consonance with that of the Na istic permissible limits or standards: a that, for a given intake, there is a given tional Research Council's Committee on "no-cflcci," a borderline, and a "trank- margin of safety (10). Toxicology, which conducted a study at effect" level. From these determinants, Similar clear and properly phrased the request of the Navy's Bureau of a permissible limit can be selected at disclosures should be made for the Medicine and Surgery), the townspeople some point below the no-cffcct level. A bases of air quality criteria and stan are still worried, and the health officer known safety factor, the magnitude of dards. Most criteria and proposed is working elsewhere. All of this could which would be commensurate with the standards that have been developed thus have been avoided had the drinking seriousness of the response, can be in far tend to be misleading either (i) water standard been set more appropri corporated in this limit. through juxtaposing statements (first by ately at 0.2 milligram per liter (13). To what extent have efforts to date stating what exposure at unrealistically A similar unpleasant situation could - met these minimal requirements? Ex high levels can do to human health, di have been avoided in the Coho saim- amination of the criteria used for devel rectly followed by the proposed stand on-DDT episode had the tolerance lim oping guides and standards in all three ard at an unrelated, extremely low level it of DDT in fish been set at 20 parts areas reveals that they have rarely con (U), when in reality it is corrosion, per million instead of 5. There is evi formed. Haste to "put a number on it" plant damage, or something else on dence that human intakes of DDT in (15) has resulted in criteria developed which the standard rests], or (ii) far greater quantities than 20 parts per by heavy-handed, opportunistic toxicol BOR 0 0 8 9 6 1 through assessing the data that comprise million were entirely safe and that the ogists driven by a "look what I found" the criteria with unwarranted bias, a tolerance limit of 5 parts per million is attitude, and acceptance of weak, or practice which can lead to needlessly unnecessary severe (Id). even questionably related, information ovcrprolcctive levels (12). This is not To an even greater degree, unnec by harried standard-setters grasping at to infer that the levels arc incorrect on essarily severe standards for air pollu straws under legal pressure to comply a "consensus" basis, but that they have tants should be avoided, especially those with an unreasonable deadline. Current been erroneously depicted. standards not strictly related to health, instances abound in al three areas of * 'pollution. For air, criteria have bee *. ' accepted for some of the more commot. urban pollutants on evidence no strong er than a highly questionable statistical association--where adverse effects on health were "possibly related" to the in the use of the epidemiologic method is the complete lack of repeated sampling of the population under study, Far-rcaching conclusions on the health hazards of pollutants have invariably been based on the analysis of one sam* fi'1' ind lived and died without signs or s toms of mercury poisoning. This is not to say that local, aqueous mcrcury or other excess pollutants should not be spotted and, when possible, eontrolled, but that the thoughtless and ir- pollutant investigated. [For water, see plc taken at one time. Daily variations rational extension of a local finding to (J).) In the ease of food, low-protein in personal habits at eating, drinking, global dimensions is inconceivable in diets, or better, diets devoid of protein, and sleeping, as well as environmental persons of sound mind (24). resulted in the greatly increased lethal variations in temperature and humidity. Accordingly, investigators should de- ity of several pesticides for rats (IS). which influence not only the duration terminc trends before summoning the However, companion studies for effects and intensity of exposure but also the news media, in order that they may pre under realistic environmental conditions metabolism of the pollutant, can result sent the current picture fairly in rela were not performed; nor has anyone in great circadian variations in the tion to the past, considered the question of how human same individual from day to day. beings on such a diet would be exposed Obviously, only repeated samplings can to significant levels of pesticides. provide a reliable estimate of an in- Commandment 7 Clearly, nothing short of determining dividual's response to a particular complete dosage-response relationships pollutant. is acceptable, if solid, unassailable cri `s, Delimit banning. With the reexam ination of the list of foods generally teria are to be provided. No purposeful regarded as safe (2S) by the National evaluation can be made by determining Commandment 5 Research Council's Food Protection such relationships from a single point. Committee has come a succession of Along the lines of appropriate data- Interpret the "Delaney clause" with bannings of long-used food additives, gathcring, two ancillary command informed scientific judgment. This coumarin (vanilla flavor), safrolc (root- ments, applying chiefly to epidemiologic much-maligned clause has become an beer flavor), red and yellow food color studies, should be heeded: (i) study hy- excuse for oncologists to use inappro ings derived from coal tar products, and pcrsusccptiblc populations, and (ii) priate and unrealistically high levels in cyclamatcs. These compulsory actions make repeated samplings. ' testing for carcinogenic potential. Why on food additives arc now setting a pat It becomes obvious upon slight re this approach has been used so uniform tern for banning industrial chemicals, flection that, in assessing the effects that ly and without exception since the law's but for entirely different reasons. The extremely low levels of pollutants have enactment in. 1958 in difficult to under banned food additives were either un on human populations, a far greater stand, The Delaney clause (23) reads: necessary or could be readily substi chance of success is assured by studying "That no additive shall be deemed to tuted with less harmful substances. Not the most susceptible populations. Such be safe if it is found to induce cancer so the totally banned DDT and alkyl a procedure avoids the "diluting" effect when ingested by man or animal, or if mercury compounds. First, DDT does of a random sample. For example, a it is found, after tests which arc appro- not present an "imminent hazard'' to study of the effects of air pollutants that priate for the evaluation [italics addedj public health, despite misstatements to irritate the respiratory system should . ..." A review of the data purporting the contrary; second,, its use for con single out asthmatics, people with a to demonstrate carcinogenicity shows trolling the spread of malaria and Afri hereditary deficiency of antitrypsin scr complete disregard for the qualifying can trypanosomiasis is unexcelled, and um (candidates for hereditary pulmo-1 clause relating to appropriateness. Why? equivalent substitutes arc not available nary emphysema) (77), and people with at this time (26). Nevertheless, the ban a deficiency of leukocytic enzymes ning of DDT "for ail uses" was made (candidates for chronic granulomatous Commandment 6 official by court order (27), in spite of disease) (IS). Such groups arc now remonstrances and admonitions from readily identified by simple blood tests Determine trends, not pro tempore the World Health Organization. Sim --a deficiency of serum antitrypsin by monitoring. To lake official action to ilarly, evidence is being gathered to ban the procedure of James cl al. (19), and ban distribution and consumption of in organic mercurials, although in some a deficiency of leukocytic enzymes by dustrial commodities on the basis of uses (treating seeds for example) the Schlcgcl and Bcllanti (20). This is so newly discovered environmental levels mercurials arc agents par excellence. .. obvious a procedure for increasing the without the perspective afforded by Instead of wholesale banning in situ sensitivity of epidemiologic inyestiga- comparison with past levels in the en ations of this sort, limited use should tions that it is surprising that greater vironment, is to put unbridled enthusi be permitted by a procedure of "licens use has not been made of it (27). The asm for environmental control ahead of ing" and provisions for "restricted use." procedure is applicable to other types common sense. The most flagrant vio Such procedures have been used in the of pollutants as, well. For example, hy- lations of this commandment arc the U.S.S.R. for about a decade (28) and persusccptibility to waterborne nitrate, previously noted recommendations that are working well. Monsanto, the sole a condition caused by hereditary methe tuna and swordfish be confiscated or producer of the polychlorbiphenyls, moglobinemia (in Alaskan Eskimos denied access to the family dining table. highly persistent but relatively nontoxic and Indians), may be identified by a One moment's reflection would reveal chemicals for mammalian species, has test for mcthemoglobin: nicotinamide that the concentration of mercury in voluntarily adopted a form of this "re adenine dinucelotidc oxidoreductase the oceans has not changed perceptibly stricted use" by confining its sales and (22). since the white men reached these distribution only to those uses and proc One of the most serious deficiencies shores, and that men have eaten these esses known to be controllable. Such 664 BOR 008962 em * ^ procedures offer a saner approach to environmental control than do the pres* ent ventures of complete removal from ,, commerce. * Consequences of Dereliction When the pollution-oriented health administrators and the public alike be gin to focus clearly on the enormity of the bill that would be required to reduce pollution to meet unnecessarily severe standards (versus commandment 3) precipitously prepared from undigested, dubiously related facts (versus com mandments 1 and 4) on which the pub lic has been ill-advised or misled (ver sus commandment 2), then will come the day of reckoning and rude awaken ing to the folly of past antipollution^ actions. Already industry has felt the bite; shortly, the public will. Hardest hit arc the mineral and chemical indus tries. On top of multimillion-dollar out lays for air pollution control, and sums of similar magnitude for water, arc mullibillion-dollar legal suits that stag ger the imagination, cripple large indus try, and eliminate small industries. Two consequences of profound economic importance arc the increased price of basic chemicals and the loss of employ ment. Already a number of small man ufacturing plants have been forced to close, unable to bear the burden of meeting pollution standards. Heavy in dustry, unable to survive on repeated annual financial losses or to continue on less than a 4 to 6 percent profit margin, will ultimately pass the needless charge on to the consumer, It thus should be evident that such actions, with their unbearable conse quences, should only be taken when it is clear beyond a shadow of scientific doubt that human health is in imminent danger, as was the case in the localized pollution of water by mercury. In all other situations, the consequences of eliminating pollution must determine the character of antipollution actions. Docs the public really want to spend billions to reduce particulates in the vicinity of heavy industry to levels of an air-conditioned, air-filtered home? Or docs the public want to ban DDT, thereby eliminating the questionable * harm to the osprey and bald eagle tile certainly reducing food produc 6 jit, H. Sasaki. H. Nishimura, Jap,' J. t .nacol, 19. 134 (1969). tion and possibly 'allowing malaria to return to the United States? 7. Survey of Compountfs Which Ho\e Been Tested for Cawnoitemc Activity (Suppl. I, Public Health Service Publication No. 149, The ruinous concept of "zero toler ance" for pollutants must go! Man has Government Printing Office, Washington. D.C., 1957, W. von Otltingcn, Phenol and In Derivatives: never, before he was a man or ever after, survived in an unpolluted void. The Relation between Their Chemical Consti* tution and Their Effect on the Organism (Na tional Institutes of Health Bulletin No. 190, One has only, on a sultry day, to cast his eyes unto the lerpcnc-laden haze of Government Printing Office, Washington, D.C., 1949. 9. N. Dcbrovo?*fcaia-Zdvadskaia, C, R. Staneet the hills, or, on a humid day, to bring into view the fog born of condensation Sac. Diol. 119, 83 (19)5). 10. Data from the Food and Drug Administration indicate that, for man, levels of Jess chan nuclei of many chemicals from the oceans to realize that this is true. Phys 50 micrograms of meih>l mercury per 100 grams of blood are symptom-free. From the knowledge that the average content of iologically, man needs continual toxi cologic nudging to maintain the ho methyl mercury in ocean fish is somewhat below 1 part per million of body weight, it is possible to stipulate the safe daily intake meostatic mechanisms that keep him of ocean fish, making due allowance lor mercury intake from other sources, physically and mentally alert. On the 11. Air Pollution Control Mules Concerning Air practical side, zero tolerance can only Quality Standards (public hearing proposals. New York State Department of Environmental be attained by compete elimination of Conservation. New York, 1970). the source of pollutants, a situation 12. Air Quality Criteria for Sulfur Oxides (Na tional Air Pollution Control Administration, that may not be desirable, or, in fact, possible if the pollutant is ubiquitous. Washington. D.C.. 1969). 13. Consideration is now being given to this suggestion by the Drinking Water Standard Finally, it may be too much to hope that anlipollutionists will not direct a Committee on Toxicology of the Division of Water Hygiene. 14. Ihc finding of a concentration of 19 parts of blind eye and turn a deaf ear to the precepts I have put forth as necessary DDT per million of body weight (the highest concentration found) in the edible part of Coho salmon resulted in the ban on Coho for proceeding rationally against prob lems with which we arc all deeply con salmon fishing. Assuming (he highly unlikely daily consumption of 1 kilogram of fish con taining 20 parts per million of DDT, that 20 cerned and involved. No matter what the immediate reception may be, anti milligrams of DDT per day is still about one-half of the daily dose found entirely safe IScc W. Hayes, Jr.. W. Dale, C. PirUc, Arch, pollution efforts must ultimately take the direction indicated in these com Lmiron. Health 22, )I9 (}')71)). 15. A. Wolman, Chcm. Lug. Sewj (30 November 1970), p. 5, mandments, or wc will be faced with an economic upheaval approaching dis 16. E. lloyd. I. Dobos, C. Kronen, Arch. Environ. Health 21, 15 (1970). 17. S. Makmo, L. Chosy. E. Valdivia, C. Reed, aster. J, Allergy 45, 40 (1970). 18. T. Washburn. D. Mcdcans, 1). Childs, Pedi atries 35. 57 (1965). Reference* and Notes 19. K. James, M. Collins, 11, Fudcnbcrg, /. Lab* 1. If. Stckitiger, Artier, Ind, Hyg. Ait. A 30, 193 (1969), Clin, Med. 67, 52S (19G6) 20. J(, Schlerci and J. Ucitanfi. Lancer 826 (196V). 2. Matthew 14:17; Mark 6:38; Luke 9:13. John 21. The closest approaches have of 6:9, Measurements cf ocean waters in the records of hospital vjshs h 1 ,,j.. ,md 20th century indicated that they contain an a study of school children a, : iv<pi.Mtory average of 127 kilograms of mercury per cubic mile (4.1 cubic kilometers), or 2 parti per billion, probably only slightly more than at the time of Christ (Encyet, Ckem. Technol. `cripples-** 22. E. Scou and D. Hoskins. lilooc " 23. Federal Food, Drug, and Cosnieu. tion 409(c)(3)(A). fJ^P). 4-,s> ' *, 362 (1952)). 24. The tuna caught off Nova Scotia originate off 3. For the record, first, it should be noted that Africa's northwest voasi, swim io bim.m, and po'yphosphates were removed from laundry thence northward along the Adamic coast m detergents net for reasons of human health, pursuit of hernne. These tuna scarcely ever hut solely to reduce the growth of algae in enter the mcrcury-r:ch St. Clair estuary. stagnant surface waters. Second, 1 call the (Could control officials have overlooked evidence "fragile and provocative" because frowning upon kippered herring?) the questionably determined teratogenic effects 25. Reference to a lt picparcd in 1958 by the were not for NTA (mtrilotriaceiic acid), but Food and Drug Administration, which defines for eadmium-NTA chelate and an NTA* a GRAS substance as one "generally recog* methyl mercury combination at 6 milligrams ni/cd as safe," per kilogram of a rat's body weight. How* 26. The Place of DDT in Operations against ever, wc do not know when levels of this Malaria and Other Vector-Uorne Diseases magnitude may be encountered in the environ World Health Organization Report No, U0 ment. Critical experiments not done: extension 47/W1V14, World Health Organization, Go* of dosage*rcsponsc curves to realistic environ heva, )971). mental levels and parallel experiments with re* latcd NTA chelates, citric acid, humic acids, salicylates, and others. 4. P. Scou. B, Coldwcll. C. Wiberg. Food Casmet. Toxicol, 9, 179 (1971); N. Medvedits* kova, Vop, Pitan. 28, 76 (1969). 3. S. Peters and M. Strassburg, ArweitnittelFonchuttf 19, 1106 (1969), 27- The court order was usued on 15 January ' 1971. On 18 March, the EnMronmem.il pro* lection Agency announced that "DDT and Aldnn, Dicldrin, and Mircx may stay on the market.*' 28. II. Mapnuson, D, Fasten, If. Gerardc, V. Kowc, H. Smyth, H, Stokingcr, Atner, Ind. Hyg.*Asst A 25, 185 (1964). 17 Novrunre rovj BOR 008963 THE LANCET, FEBRUARY 22, 1975 459 release of low concentrations of proteolytic enzyme* in the skin due to the nno-spedfic cytotoxic effects of bile salt* could account for both the pigmentation end the pruritus of patients with chronic obstructive )aundioe. Pipmiinm of Dermatology, Bristol Royal Infirmary, Bristol BS2 IHW. J. L. Buxton J. Kjwjt. CHROMOSOME ABERRATIONS IN WORKERS EXPOSED TO VINYL CHLORIDE Six,--Epidemiological evidence suggests that the risk of malignancy is increased in workers chronically exposed' to vinyl chloride (v.c.).1-2* 3T4he* 6ca7rc8in9og1e0nicity of v.c. has been demonstrated in animal experiments.* In-vitro ' and in-vivo * experiments suggest that the carcinogenicity of V.C. probably depends on the formation of an alkylating compound, presumably dbloruethylene oxide. Since carcinogenic chemicals are often,mutagenic,* we wondered if v.C is also mutagenic. In fact v.c. has been reported as indiwiwg mutations in Salmontlla typhimuruon in the presence of metabolkally active liver homogenates.1* If alkylstion of D.N.A. by V.C metabolites also produces chromosomal aberrations in man, chromosomal analyses could be used as an indicator of risk and also possibly be helpful in establishing a genetically meaningful maxi mum allowable concentration of v.c We report an in creased frequency of chromosomal aberrations in workers exposed to v.c Seven occupationally exposed male workers and three non-exposed control subjects, all employed in the same factory, were studied. The level of exposure to v.c. had continuously decreased during past years. In the weeks preceding the collection of blood-samples for chromosomal analysis (before the summer holidays in 1974) the air concentration in the polymerisation department was estimated to be 20-30 p.p.m. Workers had been exposed 1. Creech, J. L-, Johnson, M. N. J. setup. Mid. 1974, IS, 150. 2. Lee, F. I., Hetty, D. S. Lanai, 1974, i, 1316. 3. Monion, R. R., Peters, J. At, Johnson, M. N. ibid. 1974, ii, 397. 4. Block, J. B J. Am. mid. An. 1974, 229, 53. f. Holmberg, B., Moline, C. ITS. imnrtm. Hlifi. 1974, 11, 138. 6. Meltoni, C,, Lefemine, G. Environ. Hti. 1974, 7, 387. 7. Gothc, R,, Cslleman, C. J., Ehrenberg, L,, Wschmeiiter, C A. Amino, 1974, 3, 234. 8. Osierman-Golker, S., SeserbAck, D,, Ehrenberg, L. Unpublished. 9. Miller, E. C., Miller, J. A. m Chemical Mutagens, Principles and Methods for their Detection (edited by A. Hollaender); vol. 1, p. 83. New York, 1971. 10. Rsnnug, U,, Johsnsson, A,, Rimel, C., Wschmeiiter, C A. Amtio, 1974, 3, 194. to v.c. far 9-29 years. Clinical examinations had bees carried out at tegular intervals. None of the workers had showed disturbed liver function, signs of acro-osteolysi* or hematological changes, except for esse A in which these was slight thrombocytopenia and an fit-antitrypsin defici ency. Chromosomal analyses were made on cells from con ventional lymphocyte-culture* incubated for 48 and 72 hours. All blood specimen* and slides were coded and analysed blindly. The mult of the chromosome analysis is given in the accompanying table. The data for the control subjects were homogenous and therefore pooled. Altogether they comprised 56b cells, 11 of which (1-94%) contained chro mosomal aberrations. This finding might be explained by previous diagnostic X-rays. The frequency of aberra tions nevertheless accorded with that of a male population selected at random.11 1450 cells from the group exposed to v.c. were analysed, 800 in the 48-hour cultures and 650 in the 72-hour cultures. In none of the esses was there s statistically significant difference in the frequency of aberrations between the 48 and 72 hour cultures. Therefore these data were pooled. The frequency of abnormal cells in the group exposed to v.c. (9-52%) was significantly greater than in the controls (p < 0-P01). This was also true for chromatid and isochto- rnatid breaks when analysed separately, but not for the remaining types of aberrations. The highest frequency of abnormal cells was found -in those subjects who had the shortest duration of exposure (see table), and two cases (C and F) did not differ signific antly from the controls. A ** test of the frequencies of abnormal cells also revealed a significant deviation from homogeneity (p< 0-001). The negative correlation of the frequency of abnormal cells with the time of exposure was not significant. Therefore, on the basis of the present data it is not. possible to discuss the biological background of this heterogeneity. We thank the staff at KemiNord, Stockviksverken, for cooperation and Miss Anita Tillberg for technical assistance. The expenses for the present study were covered by grants from the Swedish Medical Research Council (3681) and the Swedish Board of Occupational Safety and Health. Department of Clinical Generics, Ksnlinska Hospital, Francisco Funes-Cravioto Bo Lambert Stockholm. Sweden, Jan Lindsten. Department of Ridiobiolegy, Wallenberg Laboratory, University of Stockholm. Sweden. Lars Ehrenberg A. T. Natarajan SlV OSTERMAN-COLKAR. 11. Court-Brown, W. M. Human Population Cytngcntlici; p, 17. Amsterdam, 1967. CHROMOSOMAL ABERRATIONS IN WOBXBBS EXPOSED TO VINYL CHLORIDE Subject* Centrals (J) Exposed; A B C D F G Total (A-G) in Duration of Ow poaure <n.) cells analysed Q>ipt Chroma* Isochro* tid mitid Chroma* tid break* No. of different types of aberrations Chro matid CTchanges Isochro- Dicentric marid ehromo* breaks omes Ring chromo some) Other types 0 $66 5 4 41 42 i 0 9 300 22 6 19 2 19 0 9 250 IS 14 24 1 17 3 12 250 4 6 51 52 U 200 8 5 12 i 9O 19 130 3 2 40 50 20 200 l 1 00 10 29 200 1450 9 62 12 48 7 71 0 5 9 65 1 6 01 12 10 02 02 02 11 3 10 Total 12 41 48 14 24 a 3 19 160 No. of abnormal cells Tool % 11 1-94 36 1800 37 14-80 12 4-80 22 11*00 a 7-33 3 1*50 17 g-50 318 9-S2* A teat of heterogeneity gave **-47-72,6 d.f., r< 0-001. BOR 008964 17, 1875 y-' ^ Ufue No.J>SA-e280 March ERCE BUSINESS DAILY Pas* 3 A-*-OESIGN AND DEVELOP1 A MICRO\eMVt-^A--LOW LUIGI HT LEVEL SENSOR TUBE DE J^FRREEIBUENCV COUNTER -- Negotiation* ^^condiuctad with SRI, Menlo Perk. CA. See Note 27 ^^fPf0P077II) A--DESIGN, DEVELOP AND FABRICATE A PROTOTYPE PULSED LASER INTERCEPT RE CEIVER.. -- Negotiations will be conducted with Argo Systems, Inc., Palo Alto, CA. See Note 27 (PD71) A--CONSTRUCT AND TEST A 2I.S TO 40GHZ RF MODULE to replace a Rf Module in the AN/ WLR-II -- Negotiations will be conducted with Argo Systems Inc., Palo Alto, CA. See Note 27. {P07IJ .. vVEeLtOPMENT. A System Program Office of the Electronic Systems Division, L. G. Hanseom AFS, MA is surveying the field for firms with experience. Specific cheracteristics of the sen sor tub* must be high resolution, large format, sensitive in the visible spectrum, and must operate in the photon noise limited mode. In addition, the sensor tube must have a flat raster response and have minimum geometric distortion. A laboratory device may be considered but it is highly desirable that the sensor tube be capable of ahipment to a testing facility for evaluation. Naval Electronic Systems Command, . . Washington, DC 201M The System Program Office is also surveying the field for firms with experience in Moving Target indicator techniques. This involves dis A--STUDY OF RADIATION EXPOSURE DUE TO BUILDING MATERIALS. In order to establish baseline levels of population exposure due to the presence of natural radioactivity in construction materials, the contractor will be required to de crimination of objects in earth orbit against a star background with electro-optical systems based on the earth's surface. Doppler techniques are to be excluded and the output of the sys tem will be as near real time as possible. termine the distribution and use of various Interested firms who have demonstrated cap building materials in the United States, develop abilities and experience in these areas should a methodology of investigative techniques to submit information in accordance with Note 6S obtain meaningful data, and develop a mathe in four copies within ten days from the date matical model which may be used to compute of publication. This is not a request for proposal. population exposure due to naturally occurring Telephone inquiries will not be honored. Specific radioactivity in building materials. Firms desiring data must be forwarded to the program office in a copy of this RFP should send their requests writing. See Note 48 (7*071) in writing -- RFPs will be issued 1 Apr 75 -- RFP WA 75-R236. (P071) Deputy for Surveillance and Navigation Systems, OCTE, Electronics Systems Environmental Protection Agency. Division, AfSC, Hanseom AFB, MA 01731 Contracts Management Division, RAO Procurement Section, Crystal Mall #2, A--DEVELOPMENT OF MANNED SPACECRAFT (PM-214), Room 700, Washington, DC 20400 AUDIO TERMINAL EQUIPMENT--RFP No. 9-BC73- Attm L. . McKay, Tat: 703/557-7400 38-51QBP. It is anticipated that RFP will be A--PERFORM STUDIES AND DEFINE PARAM ETERS OF OVER THE HORIZON (OTH) SYSTEMS FOR SURFACE SHIPS -- NAVSEASYSCOMM is seeking expansions of interest and qualifications from capable firms willing to participate in an unfunded preliminary systems analysis to define ^parameters required of various potential OTH ensor and relay systems to determine if they Ire to be of value to surface units in tactical Situations. It is anticipated that these studies will require 1 to 2 man-months of effort. Firms issued o7a 17 Mar 75. Proposals are due 30 days after release of RFP. See Notes 2, 32 and 82. (P071) A--DEVELOPMENT OF A LIGHTWEIGHT, FIRERETARDANT, THERMAL AND ACOUSTICAL AIR CRAFT INSULATION--Job--RFP 9-BC72-3-5-1S3P. It is anticipated that RFP will be issued o/a 17 Mar 75. Proposals are due 30 days after re lease of RFP. See Notes 2, 32 and 82. (P071) NASA, Lyndon B. Johnson Space Center, BF/Small Business and Industry Affairs experienced in systems analysis, elevated sensors, Office, Houston, TX weapon guidance and control, electronic CM and Tol A/C 713, 483-4511 thoroughly familiar with the state of electronic microminiturization, are invited to submit ex A SPACE PROCESSING PAYLOAD EQUIP pressions of interest and a brief summary of MENT STUDY. RFP DCN l-S-31-00383; RFP due .luahfications to Attn: Code 03C. Refer to Synop- date 10 Apr 75. Copies of RFP will be available is Number 279 by 4 Apr 75. Respondents will upon written request. (P071) not be notified of the results of Command's evaluation of information submitted. Only firms judged capable will be invited to the subsequent informal technical system symposium at NAVSEA , Procurement Office, NASA, George C. Marshall Space Flight Center, AL 35812 Attn: AP14, C. H. Brown to discuss proposed system concepts. This effort will require a Secret Security Clearance. This Is not a Request for Proposal. (P071) * A CONDUCT AN IRID PROGRAM ENTITLED "HELICOPTER TRANSMISSIONS INPUT MODULE MODEL 4, EMERGENCY LUBRICATION. Follow Npval Sea Systems Command, on to Contract DAAD05-74-C-0788. Negotiations ./Washington, DC 203S0 will be conducted with SKF Industries, Inc., Engineering 8i Research Center, King of Prussia, A- -PATHOGENICITY OF VINYL CHLORIDE -- PA. See Note 46. (P071) EFFECT OF AGE AND EXPOSURE DURATION. The National Institute for Occupational Safety ind Health is soliciting proposals from organi Procurement Directorate, Aberdeen Proving Ground (AA), MO 21005 zations interested in: (1) determine the effect of exposure duration on the incidence of vinyl chloride induced lesions, (2) define the histologic alterations that can be used to predict the de velopment of vinyl chloride induced tumors, !3) determine the effect of the age of the .inimal on the incidence of vinyl chloride in duced lesions, (4) determine the usefulness o' some clinical tests in the diagnosis of vipyl chloride induced lesions in rats--Job issue dtd 21 Mar 75, of contract proposals is C.O.B., 9 May 75. RFP due date 9 May 75. (P071) A--EVALUATE FEASIBILITY OF INCREASED IN-PLANT ELECTRICAL GENERATION IN THE PAPER, CHEMICALS AND PETROLEUM REFINING INDUSTRIES and develop recommended mechan isms as warranted, on an industry by industry and regional basis for enhancement of in-plant generation. Technical, materials, economic, en vironmental, legal and regulatory, social and political impacts of increased in-plant generation will be studied for each industry -- Job -- RFP 224 -- RFP due date 25 Apr 75 -- RFP will be distributed until the limited supply is exhausted. National Institute for Occupational Safety (P071) and Health, SS00 Fishers Lane, I\ Rockville, MO 20152, Room 3-44 \ Attn: L. A. Sanders, Federal Energy Administration, Office of Contracts A Procurement Monagement, 12th & Pennsylvania Ave. NW, Washington, DC 20441, Attn: R. Marshall Tel: 202/941-4434 La--STUDY TO PRODUCE MORE ENERGY FFICIENT WATER HEATERS AND REFRIGERA TORS--Job--RFP 5022B, Anticipated release dtd IB Mar 75j RFP due date Thirty days after re lease date, requests for RFP's must be in writing: (P071) Federal Energy Administration Room 4447 Washington, DC 204G1 Attn: R. Marshall, Tel (202) 951-4434 H Expert and Consultant Services. H--PROVIDE EXPERT TECHNICAL SUPPORT IN THE EVALUATION OF VARIOUS HEALTH PROGRAMS FOR THE JOB CORPS HEALTH OFFICE. The Services under this requirement will be to provide qualified personnel, services, facilities and materials to evaluate, maintain and administer currant Job Corps Enroll** Health Programs to embrace the medical, dental and mental health aspects, in support of this program. Request lor proposal availability is limited to 195 copies and will be furnished to requestor on a first received, first served basis. The period of performance will be 24 months from date of award.--Job--RFP ONP75-1 RFP due date 14 Apr 75. L- Harley, 202/376-7244 (P071) U. S. Department af Labor Manpower . Administration Office of National Programs Patrick Henry Building, Roam 4444 441 "0" Strest. N. W, Washington, DC 24213 e M-- ENGINEERING AND TECHNICAL SERVICES in support of the 5-/54 Caliber Gun Mount Mk 42 Mods 1 through 10 Negotiations are being conducted withFMC Corporation, Northern Ord nance Division. Columbia Heights Post Office, Minneapolis, MN. See Note 46. (P070) Naval Ordnance Station, Indian Head, MD 20444 H -- INSPECTION SERVICES. For Level |, SubSafe Stock Program material. Contractor to perform ail work on location at the Mara Island Naval Shipyard, Vallejo. CA -- MIL-I-45204A applies--Total quantity, 3 Lina Items--Delivery point, Mare Island, NSY, Vallejo, CA -- Must be qualified in one of following trades: Machinist. Shipfitter, sheetmetal, pipefitter, welder, pattern maker -- Sol. NO0224-75-R-4168. See Notes 23 and 56. (P071) Regional Procurement Department, Naval Supply Canter, Oakland, CA 44425 H-- HOUSEHOLD PRODUCT SURVEY. The consumer product safety commission is inter ested in conducting a household survey to gather use data on selected products and to develop a method to obtain user data on other specified product categories in a short period of time-- job--RFP CPSC-75-325; RFP due date 0/a 14 Apr 75. (P071) Contracts Branch, Consumer Product Safety Commission, Washington, DC 24207 Attn: R. Nance, Tel 301/414-7354 H - - IMPACT ANALYSIS PROJECT. -- Impact assessment(s) of experimental projects funded by the Foundation to increase the numbers of ethnic minorities and women pursuing careers in science and technology Respondents must possess sci ence competency and experience in science edu cation as well as m the professional problems of ethnic minorities and women. Qualification statements for this RFP were solicited in the CBD dated 23 Sep 74 -- RFP 75-129 -- Correction to PSA-6274. (P071) National Science Foundation, Contracts Offica, Room 610, 1444 "G" Street, NW, Washington, DC 24554 * H-- PREPARING A TOTAL PROCUREMENT HANDBOOK LIBRARY- The Procurement Menage- ment Division is planning to enter into negotia tions with Management Concepts, inc., Arlington, VA. See Note 46. (1*071) .... NASA, Goddard Spaca Flight Center, Greanbelt Road, Greenbelt, MD 24771 H--FLOOD INSURANCE STUDIES. The Depart ment has selected the Ohio Department of Natur al Resources, State of Ohio, Columbus, OH 43215 to conduct Flood Insurance Studies for Canal Winchester and Gahanna, OH. See Note 27. (PQ71) Department of Housing and Urban Development, Office at Procurement and Contracts, 451 Seventh Street, Southwest, Room 2142, Washington. DC 20414 * H--TECHNICAL SUPPORT FOR THE NAVY WEAPONS SYSTEMS TEST, EVALUATION AND TRAINING RANGES. The Naval Air Systems Com mand intends to negotiate with Stanford Research Institute, 333 Ravenswood Ave., Menlo Park, CA 94025. This is a continuation of a program already undertaken by Stanford Research Institute. Sea Note 46 -- PR 75-AN042 -- NAVAIR Synopsis 319*75. (IP071) Naval Air Systems Command Headquarters Washington, DC 20341 BOR 008965 Th Ch mical World This We k VINYL CHLORIDE MAKERS MBT OSHA STANDARD The Occupational Safety & Health tions at Shin-tech's new polyvinyl dards will cost is still uncertain. In Administration's permanent stan chloride facility at Freeport, Tex., addition to the capital expenses for dards for worker exposure to the are well below the OSHA require engineering controls and respirators, suspected carcinogen vinyl chloride ment, according to spokesmen for worker productivity is expected to went into effect last week over the Robintech, manager and part owner decline whenever the use of respira protests of vinyl chloride makers of the Shin-tech plant along with tors is necessary. Diamond Sham that the new standards are unneces Shin-Etsu Chemical Industry Co. rock estimates that meeting the sarily low. Nevertheless, major of Japan. Although OSHA has not OSHA regulations will raise the manufacturers say that they are in scheduled an inspection visit for the price of PVC about 5%. Other com compliance with the standards Shin-tech plant yet, Robintech says panies suggest that this estimate and have not had to curtail vinyl that both its own monitoring and may be low. But most agree that chloride production even at older that of an independent third party production probably will not be plants to meet the standards. indicate compliance with the 1-ppm curtailed because of the new stan The Society of the Plastics Indus standard via engineering controls. dard. either by an inability to keep try, acting for the vinyl chloride Robintech is optimistic that it can certain plants in operation or by makers, has requested a Supreme lower vinyl chloride exposure at its price increases so severe as to Court review of a court of appeals older, Painesville, Ohio, plant to reduce demand for the product. Q decision last February upholding within the OSHA standard through the OSHA standards (C&EN, Feb. engineering changes currently under 10, page 5). The industry group also has requested a delay in im way. The modifications are scheduled for completion next year, NAS agrees SST plementation of the standards while the court decided whether to hear hopefully in time to meet the April 1 requirement for mandatory use of would reduce ozone the case. The Supreme Court re-' respirators. For now, respirators are fused the delay last week, allowing available for workers who want the standards to go into effect April them at the Painesville plant. 1. The court has not yet decided Exposure levels at most other pro whether it will hear the appeal. ducers' plants are much lower than Under the present OSHA stan they were a year ago, and frequently dard. worker exposure limits are set lower than the 50-ppm interim at 1 ppm for a time-weighted standard that was in effect until The National Academy of Sciences' Climatic Impact Committee issued a report last week that agreed with earlier predictions by scientists that emissions of nitrogen oxides and sul fur oxides from supersonic and sub sonic aircraft would react with and deplete ozone in the stratosphere. average over an eight-hour day last week. Exposure levels at Dow Because ozone absorbs ultraviolet with brief exposures of up to 5 ppm Chemical's vinyl chloride plant, for radiation in the upper atmosphere, allowed for periods of less than In example, have been less than 10 its depletion would lead to more .minutes. Engineering controls are ppm for the past year. And B. F. ultraviolet radiation reaching to be used to lower vinyl chloride Goodrich says it has lowered vinyl ground level, causing increased in levels in plants as low as practi cable. with respirators available for workers whenever vinyl chloride concentration levels exceed the standards. For the first year, work ers can choose not to wear respira tors as long as concentrations of the monomer are less than 25 ppm. Beginning next April 1, however, respirator use will be mandatory whenever vinyl chloride concentra tions exceed the standards. Only one major manufacturer claims to be able to meet the new standards without the use of res pirators. Vinyl chloride concentra chloride levels at its polymeriza tion plants to about 6 ppm and even lower at its vinyl chloride produc tion plant. The Society of the Plastics Indus try and others had expressed doubts that there were enough res pirators available to allow full pro duction of vinyl chloride if the stan dard was set so low that respirators were required. OSHA has modified its position on this point somewhat, according to SPI, and now allows a more available canister-type res pirator to be used.' How much meeting OSHA stan cidence of skin cancer among the earth's white population. The com mittee, chaired by Dr. Henry C. Booker of the University of Cali fornia, San Diego, recommends modification of aircraft engines and fuel as well as close international cooperation. The committee was formed in 1972 to advise the Depart ment of Transportation on its Cli matic Impact Assessment Program. The committee's 348-page report, based in part on mathematic model ing, points out that a fleet of 300 t< 400 SST aircraft of the type former ly considered by the U.S. govern ment in 1970 "in all probability' Worker exposure to vinyl chloride is restricted around polymerization tanks would cause stratospheric ozone i< decrease 10% (and then stabiliz1 at that reduced level) after th planes had been in service for number of years (the report doesn specify how many). That ozon reduction, according to the repor would cause a 20% increase in ski cancer over a long period of time. A hundred of today's SST ai craft--Anglo-French Concorde ar Soviet TU-144--cruising at 16 k BOR 008966 THE W ALL STREET JOURNAL, T ueidty, A p ril 1, 1975 jVinyl Chloride Exposure Curbs Go Into Effect High Court Refuses Delay; It Doesn't Set Halt Date In Reserve Mining Case By a Wall Street Journal Staff Reporter WASHINGTON-The Supreme Court re fused to delay federal standards that re quire, by today, a sharp reduction in work-; era' exposure to vinyl chloride gas. Separately, the Justices declined to set a specific timetable for Reserve Mining Co. to' stop dumping wastes from its Silver Bay, Minn., taconite-processing plant into Lake Superior. The vinyl chloride petition was filed by Firestone Plastics Co. and the Society of the piRatios ipdiintry inc., a trade association. They asked the Supreme Court to stay the new federal regulations while it considers whether to hear their full-fledged appeal seeking to invalidate the standards. Under, a ruling by the Labor Depart ment's Occupational Safety and Health Ad ministration, vinyl chloride producers must reduce workers' exposure to the gas to onefiftieth of current standards. Long-term ex! posure to the gas, which Is the raw material ! for the widely used polyvinyl chloride plas tics, has been linked to a rare but fatal liver cancer. The society and several individual manufacturers have argued that the reduc* tion isn't technologically and economically feasible, and that it isn't necessary on the basis of existing medical evidence. On Jan. 31, the U.S. Appeals Court in New York upheld the standards. The indus try's appeal of that ruling still is pending! before the Supreme Court. In the Reserve Mining case, the states of Minnesota, Wisconsin and Michigan and a half dozen environmental groups had asked the Supreme Court to set a two-year dead line for Reserve Mining to halt any dumping of wastes Into Lake Superior. Reserve is ' owned jointly by Republic Steel Corp. and! Armco Steel Corp. It supplies taconite iron, ore pellets to both companies. The latest move was technically t amendment to a petition, filed in ea iy March, that asked the Supreme Court io reinstate a federal district court injunction that closed the Silver Bay plant for a few days last April. That injunction was lifted by the federal appeals court in St. Louis. Last week, the appeals court handed down a final ruling ordering the company to switch ` to on-land disposal of wastes and to reduce . air emissions. The decision didn't sot a | timetable for the changes and that is what j the states and environmentalists sought to J have the Supreme Court impose. While their petition for a deadline was rejected, the states and environmental groups still have the right to aeek a full Su preme Court review of the appeals-court de cision. BOR 008967 THE JO U R N A L O f CO M M ERCE Tuesday, April 1,1975 High Court High Court Won't Delay Won't Delay Vinyl Rule Vinyl Rule (Continued from Page 1) a postponement from the orig By LEAH YOUNG Journal of Commerce Staff inal date of Jan. 1. OSHA pro mulgated the vinyl chloride standard following reports of WASHINGTON |-- New stri 13 deaths from a rare liver ngent occupational health and cancer traceable to exposure safety standards for the vinyl to the chemical in the work chloride industry will go into place. effect today following a Su The chemicals industry has preme Court decision Monday been fighting the standard at not to delay the standards. the grounds that it does not The decision affects all have the technical ability to manufacturers of vinyl chlo reduce exposure to VCM to ride monomer (VCM), widely- practically zero. used in the plastics industry. Labor Department attor The standards will require /that workers be exposed to no more than one part vinyl chlo ride per million parts of air in any eight-hour period, with no more than five parts per mil lion permitted in any 15-minute period. Firestone Plastics Co. divi sion of Firestone Tire and Rubber, IVon Carbide O-rp. and.the Society of the Plastics Industry have all appealed to the Supreme Court to overturn a lower court decision uphol ding the new standard. There is no way of knowing whether the refusal to grant a stay of the new standard means the high court will af firm or decline to hear the de cision of the 2nd Circuit Court of Appeals which agreed with the Occupational Health and Safely Administration that the standard is rational. 'Good Indication' But, lawyers for the Depart ment of 'Labor are optimistic. They say that the denied stay is a -`good indication" that the court will not grant review. OSHA spokesmen say that the standard will foe in effect April 1. They note that this is neys, however, say they do not expect any massive closings of chemical plants. They do expect, however, that many companies will apply for tem porary variances while res pirator equipment needed to protect workers is on order. In a friend of the court 'brief, the National Association of Manufacturers (NAM) ar gues that if the lower court is upheld the secretary of labor will be able to "disregard the statutory mandate which re quires the secretary to give due consideration- to economic and technological feasibility factors in promulgating stan dards dealing with toxic sub stances and harmful physical agents and predicate such standards essentially on me dical considerations. Thus, the ramifications of the decision below are not limited .to the vinyl chloride industry but can have application to many oth er industries which are sub- j e c t to the (Occupational Health and Safety) Act." 1 The Chamber of Commerce has filed a friend of the court brief charging the lower court with considering only the evi 'Continued on Page 211 dence in favor of the standard and none that questioned the data. But U. S. Soli.i-or Gnifr.i' Robert H. Bork argues that the tabor secretary "is not ob ligated to await human deaths at a particular level of exposure before he may bar ex posure at that level." The industry has argued that the standard should re main at the current 50 parts per million until technology is developed. "All of the factual evidence demonstrates that the engi neering controls and work practices necessary to comply . with the OSHA standard do | not now exist, and that there is no reason to believe they can be developed in the fore seeable future," the plastics industry told the court. No reason was given by the justices for denying the stay. Justices William O, Douglas and Lewis Powell took no part i" Hit; determination. BOR 008968 CMA JOURNAL/FEBRUARY 8, 1975/VOL. 112 269 tauoriaisa Vinyl chloride and cancer Every supermarket contains goods packaged in polyvinyl chloride (PVC) and it has so far been assumed, prob ably correctly, that this substance is free from carcinogenic properties. How ever, some disturbing information has recently come to light with regard to the vinyl chloride monomer that is produced in a monomer plant, such as that owned by B. F. Goodrich in Kentucky, from petrochemical feed stock combined with chlorine. The monomer is then fed to an autoclave in the polymerization plant, where water and catalysts are added, and by heat and pressure the end product, a fine powder, is produced. Information was obtained by B. F. Goodrich that several of their longservice employees had died of angio sarcoma of the liver. Nineteen cases of angiosarcoma of the liver have been identified in individuals in various parts of the world who had been exposed over a long period to vinyl chloride and in addition often had had massive exposure to the chemical some years ago when manufacturing processes were not so carefully controlled. In this re spect the study of Jacob and Theriault in this issue of the Journal (page 307) is of interest. Block* summarizes six cases in pa tients who had previously had from 15 to 30 years of exposure to vinyl chloride, all of whom were found at postmortem to have angiosarcoma of the liver. Two of these patients pre sented with enlargement of the spleen and liver; two with gastrointestinal tract bleeding, diagnosed originally as being due to gastic ulcer; and two with vague pain in the right hypochondrium. suspected of being due to cholecystitis. The pathologists also reported that four of these patients had an unusual, non alcoholic type of cirrhosis of the liver, which may have played a role in the genesis of the angiosarcoma. Such cases have also been identified in the United Kingdom, Sweden and Germany, and all occurred in persons exposed for 12 to 27 years to vinyl chloride. This sub stance had already been indicted as a cause of Raynaud's phenomenon, which fortunately is apparently self-limiting, and also of disease of a variety of systems, particularly by the Germans, who recognized a "vinyl chloride dis ease". Block suggested that the serum alka line phosphatase value is a sensitive early indicator of the disease; other enzyme values rise only late. He specu lates on the possible use of a-fetoprotein measurements to screen vinyl chloride workers, but believes that liver biopsy in suspected cases is not without risk of bleeding. In the first report from the United Kingdom Lee and Harry1 describe the case of a 71-year-old man who was admitted to hospital because of edema of the legs, ascites and liver enlarge ment. He had no definite indication of a liver tumour. He died suddenly 2 weeks later and was found at autopsy to have angiosarcoma of the liver. Monson. Peters and Johnson5 dis cussed a retrospective analysis of mor tality in 161 deceased workers who had been exposed to vinyl chloride in two plants. The patterns of mortality among the workers in the two plants were similar, and the most striking feature was a 50Cr excess of deaths due to can cer in these workers over the number in the general population. There were five deaths from angiosarcoma of the liver. In addition, cancer had occurred in the gallbladder, common bile duct and liver. There were also five brain tumours and a 60cr excess of cancer of the lung, together with two cases of unusual cancer in the thyroid and the nasopharynx. The excessive mor tality due to cancer was seen primarily in men dying before the age of 60. This excess has been identified only in persons dying from 1970 onwards. It would appear that the relative fre quency of all cancers m vinyl chloride workers is increasing with time and there is no evidence that the trend has stopped. The authors point out that it may be several years before a final con clusion can be arrived at with respect to the carcinogenic potential of vinyl chloride; meanwhile, current exposure must be controlled. As The Lancet points out in a recent editorial,4 it is surprising that nobody has paid, attention to the work of ex perimental pathologists who reported in 1971 a variety of cancers induced in rats exposed to 30 000 ppm vinyl chloride for 20 hours a week. But experimental pathologists have too often cried wolf in relation to cancer, and 30 000 ppm is a very high level of exposure. Because of the findings of vinyl chloride disease other than cancer the exposure limit had been reduced to 200 ppm in some countries, and in Britain it has now been reduced to 50 ppm. However, this limit may be further lowered since at a meeting on May 10. 1974 at the New York Aca demy of Sciences Maltoni claimed to have produced angiosarcoma of the liver by exposing rats to only 50 ppm of vinyl chloride. Apart from the occupational health angle, there is a wider question of public health. Newly manufactured PVC may release vinyl chloride during storage, and although there is no evid ence that this constitutes a hazard to the buyer of food, there is a need for further information about the release of vinyl chloride from packaging such as that used in the food industry. The alarming news that vinyl chlo ride exposure might be associated with angiosarcoma of the liver later in life caused the Goodrich Company to start a medical screening program at their Louisville plant, aimed at earlier detec tion of liver abnormalities. Results have recently been reported.5 Two additional cases of hepatic angiosarcoma in vinyl chloride polymerization workers with out notable symptoms or signs were detected by liver biopsy. In addition, three cases of portal fibrosis were dis covered.* It is hoped that continuous health monitoring in polymerization plants may aid detection of liver ab normalities while they are still in a reversible or curable state. References 1. Block JB: Angiosarcoma .of the liver fot- lowing vinyl chloride exposure. JAMA 229: 93. 1974 2. Leg FI, Harry DS: Angiosarcoma of (he liver in a vinyl-chloridc worker. Lancet 1: 131ft. 1974 3, Monson RR, Peters JM. Johnson MN: Proportional mortality nmong vinyl-chloridc workers. Lancet 2: 397. 1974 4. Vinyl chloride, F.V.C., and cancer (editorial). Laneti 1: 1316, 1974 5. Falk H, CattiH JL, Heath CW J*. et al: Hepatic disease among worker, ai a vinyl chloride polymerization plant. JAMA 230; 39. 1974 6. Makk L, CaEECH JL, Whelan 30 Jk, et al: IMd, p 64 BOR 008969 No. 58: Vinyl Chloride Vinyl chloride is a monater, or molecule, which is used as the propellant in many aerosols, such as hairsprays, insecticides, and spray paints. In its polyneric (combination of molecules) state, vinyl chloride is kncwn as polyvinyl chloride (FVC). In that form, it is a plastic used for containers of shampoo and detergent, for water pipes, and for plastic upholstery on furniture. Vinyl chloride has been linked in laboratory tests to a rare form of liver cancer, and it also has been named as the cause of liver cancer found in same workers at a plant which processes the chemical. Various Federal agencies have taken action in response to the hazards of vinyl chloride and FVC: 1. U.S. Consumer Product Safety Comnission-- On Aug. 16, 1974, CPSC announced that it will ban vinyl chloride for use in aerosol household products. Under the Federal Hazardous Substances Act such products will be declared banned hazardous substances and may not be sold. Consumers who purchased products covered by the ban should return them for complete refunds. 2. Food and Drug Administration-- FDA has recalled 52 brands of products, many of which were hairsprays, because they used vinyl chloride as a propellant. FDA has proposed a ban on the use of vinyl chloride in drug and cosmetic aerosol products in general. 3. Environmental Protection Agency-- On April 24, 1974, EPA issued an emergency ban on 28 brands of pesticide sprays containing vinyl chloride, requiring the recall of 19,000 cans of aerosol pesticides already on the market. 4. Occupational Safety and Health Administration-- OSHA has set a temporary exposure limit for workers of 50 parts per million (vinyl chloride in air) and proposes to reduce that limit by October, 1974, to no detectable parts per million. 5. Treasury Department (Bureau of Alcohol, TPbacco, and Firearms)-- Ihe bureau ended the use of FVC plastic bottles which were used to package liquor because it was demonstrated that the chemical "migrated" (leached) into liquor stored in such bottles. FDA recently announced that it will ban the use of FVC containers for all food because of similar "migration" to nonalcoholic foods. , # BOR 008970 vinyl chloride -- 2 Products covered by the CPSC ban include seme spray paints , finishes, paint recovers, degreasers, and adhesives. Retailers are required to post lists of specific products which are covered by the ban, and you will be able to return these products for refunds. To report a product hazard or a product-related injury, write to the U.S. Consuner Product Safety Caimission, Washington, D.C. 20207. In the continental United States, call the toll-free safety hot line 800-638-2666. Maryland residents only, call 800-492-2937.____________________;_____________ G PO 8BJ -9 3 5 October 1974 ~ BOR 008971 Q. According to osha's vinyl chloride standard, dur ing the first year each worker may decide whether to wear a respirator if vc exposure levels are under 25 parts per million (ppm). Are the United Rubber Workers making a special effort to educate their members about respirators? A. We've already done that. When the vc situation was first brought to light in January of last year, Mr. Bommarito [president of the urw] or I person ally visited every polyvinyl chloride maufacturing plant we had. Since we had good rapport and under standing with the management people, our first ap proach was: "Give the workers protection as soon as you possibly can." We immediately initiated input to get everybody into an air-supplied type of respi rator with special emphasis on protection for our members who enter reactor vessels. After the osha standard came out, each of our locals involved in manufacturing polyvinyl chloride resin and each plant that fabricates it into a finished product received communications from Mr. Bommarito's office and from my office emphasizing the absolute need to wear a respirator and giving guid ance on the various types. We've informed the com panies, and our people in the plant: "If you can't get down to one ppm, you're going to have to learn to live with an air-supplied respirator." As far as I'm concerned, it's the only kind of respirator that gives the worker adequate protection at the present time. Q. When will the workers in these plants be able to take off their respirators? In other words, how soon is the engineering technology to cut vc levels below one ppm likely to become available? Louis Beliczky, director of industrial hygiene for the United Rubber Workers, talks about the pitfalls of hazard pay, the need for chemical safety data sheets, and the lack of trained industrial hygienists. At professional meetings Louis Beliczky is often in troduced as the first industrial hygienist employed full-time by a labor union. Beliczky spends most of that time as a traveling trouble-shooter who helps "put out the fires," as he calls it, for many urw locals around the country. He has also served as a member of osha Standards Advisory Committees on heat stress, carcinogens, and hazardous materials labelling. And you can bet that when osha holds public hearings for almost any new health standard, the Rubber Workers' testimony will be among the loudest and clearest. A. I think you're referring primarily to the plants that manufacture polyvinyl chloride resin. I must qualify my answer by stating that perhaps three or four of the larger plants will probably be able to meet osha's one ppm requirement within six or seven months. However, I do feel that there are some plants--those built in the late 1940's and early 1950's--that will have great difficulty ever meeting this level. Because of the structure of the reactor vessels and the physical layout of the plants them selves, workers in these plants are likely to be wear ing respirators for the foreseeable future. It's true that most of the companies that have these older facilities also have some new facilities, built at the plant location, to handle increased pro duction demands. I have the feeling, then, that the companies may wind up phasing out or temporarily closing some of these older portions of plant facili ties. 23 BOR 008972 Q. The urw local at Uniroyal's polyvinyl chloride plant in Painesville, Ohio, recently walked out over working conditions. How did the walkout relate to the vc situation? A. I can't make any official statement at this point, but I would like to comment. First, there had just been a change in local union leadership when that unauthorized work stoppage occurred. Frankly, it came as a surprise to me. I live in that county, and I visited the plant on numerous occasions in 1974. The initial issue, as I understand it. was an effort to reopen wage negotiations in the contract, possibly related to the cost-of-living escalator that we're try ing to renegotiate in some of our other contracts. This issue may have been tied inadvertently to a safety and health matter. 1 saw statements in the local newspaper to the effect that "if the workers were going to be exposed to vc. they wanted to get monetary compensation for it.'' hygienbb togoWoo plant get iheir hands dirty, get involved w8h management, and straighten brings out.** Q. "Hazard pay" was the term l saw, A, That's a term 1 shy away from using. I don't think we should ever get "hazard pay" for any kind of environmental health condition. Our basic philos ophy is that the company should use any extra money to make improvements that would make the work environment safer. What hazard pay boils down to is this: "If you pay me 75^ more an hour, I don't mind getting killed or exposing myself to a hazardous situation." This whole concept came Up when our union had its first reported angiosarcoma death at Firestone's plant in Pottstown, Pennsylvania. Naturally, the workers were concerned. I spent three full days in the plant and at the union hall, and I spoke to each shift for at least a couple of hours in an effort to help them understand the problem, make them aware of the vc hazards, and let them see that all that could be done was being done. Most people accepted the situation, but there were some in the local union-- mostly the younger people--who expressed the same 24 kind of feeling as the newspapers have reported about the Painesville plant: "Let's get maybe 10(* or 25<t or 30{* more an hour because we're working with vc." Now, 10(5 more an hour comes out to be about $200 more a year. If I were to offer you $1,000,000 for your life, would you take it? You know you wouldn't. Life's pretty damn precious to everyone. So, after we spent a fair amount of time talking to our people at Pottstown, they understood this concept of hazard pay, and they didn't press the issue further. As you can imagine, then, I was surprised to see the news accounts of the Painesville walkout. Mr. Bommarito was concerned. It is our international union's policy not to become involved in local union matters unless the local president personally requests it. I did call our district director for that area and state, "If there is any way we can help in the Painesville situation, have them give me a call." Be cause the walkout was unauthorized and the issue itself was not a valid one, we can't say that this local represents the official position of the urw. I'm not sure how the situation was resolved, but in the end the plant did go back to work. Yesterday the district director responsible for that plant told me that, to date, the local union has not made any effort to con tact his office on this matter. I feel it's unfortunate that this particular situation was given such wide publicity since it doesn't really reflect good policy from the standpoint of environmental health. Q. Can you make any predictions about what the next "vinyl chloride" will be? What general types of substances deserve a closer look now? A. Well, I have to qualify my statements by saying that they are based on my experience in the rubber and plastics industries. I have a feeling that there will be further studies involving other polymers besides vc. There are a lot of synthetic rubbers that fall in this category--styrene, butadiene, and other types of isoprene polymers. We already have an indication that some of our people are being affected in plants where styrene monomer is used or released as a by product. We have found an increased incidence of nodes and tumors on the vocal cords, though so far no tumors have been classed as malignant. Another area of concern, based on epidemiolog ical studies by Harvard and the University of North Carolina, is the relatively high incidence of various forms of cancer, especially the leukemias. I think we had better take a good, hard look at the petroleum distillates, particularly benzene. Everyone knows that benzene is a toxic material; it's considered a leukemogenic agent. We don't find much of it in the plants we're involved with. But T think we have to be aware that even gasoline, which is sometimes OR OO8973 used in making rubber cement, can contain any where from two to ten percent benzene. Petroleum napthas may contain from two to 20 percent ben zene. 1 also think it's high time wc stopped placing the big emphasis on chemicals that are carcinogens. We must start looking more closely at materials which may not cause cancer but can shorten the worker's life by causing other disabling diseases such as sili cosis or emphysema or heart disease. From the work er's standpoint, these problems can be just as inca pacitating and final as cancer. Simply because of our increased awareness of the problems, then, wc are likely to see other epidemics involving substances as hazardous as vc. 1 think last year was the beginning of a new consciousness in this country. It was the year of enlightenment where occupational health hazards arc concerned and at the same time the year of fear. It's unfortunate that it takes situations like those involving vc or inorganic arsenic to make most Americans aware of the health hazards that confront us. Q. What kind of intpitblicized health problems do yon. ns an industrial hygienist for the URW, become involved in? A. Last year one of our plants in Pennsylvania, to give one example, was using a material called dichloroethanc as a solvent base in a cement to make a plastic product. Thirteen of the women who were putting together small parts in the operation had to be hospitalized. They had all the classic symptoms of dichlorocthanc exposure--loss of memory, un consciousness, double vision, possible corneal dam age, kidney and liver damage. One would expect that in this day and age the company, which manufactured environmental health equipment, would have studied the hazards related to this material. But they had no awareness of a hazard and did not apply local exhaust ventilation or dilution ventilation. So, when I went to the plant, I told the management, "I am making a strong rec ommendation to stop using dicholoroethane. In this modern world of advanced science and technology, you can certainly find a substitute for this material." They said. "Well, we don't think we can," and I told them 1 didn't believe that. The company did stop the operation for awhile but began it again three or four weeks later. I kept in touch with the local union and managed to get it stopped again. The company finally promised to get physical exams for the work ers affected to check their kidneys, livers, and eyes for permanent damage. Our staff representative is keeping us posted on the progress being made. Q. So right now this situation is unresolved? A. Well, they have stopped the operation. When I got niosh to check into the problem, the company told them that they were not using dichloroethane anymore and in all probability would phase out the process. That's one of the things we hear all the time. A company will say that if they have to spend money controlling an environmental health problem --on ventilation, for instance--then they're better off shutting down the operation. Almost always it turns out to be a threat by the company. Somehow, in the end. they manage to reset their priorities and continue the operation. Q. As a member of osha's Advisory Committee on Hazardous Materials Labelling, yon are in a position to help formulate a standard that could keep this kind of situation from occurring. I've noticed that you're chairman of a subcommittee on safety data sheets and training. What is a "safety data sheet?" A. In order to understand the concept, we have to go back historically to the maritime trades. In 1958. before o.sha existed, the federal government legis lated a special standard for the maritime industries, including longshoring. shipbuilding, shipbreaking, and ship repair work. The problem was that dockworkers and printers or welders in shipyards really weren't aware of the potential hazards of the mate rials they were dealing with every day. Under the maritime standard's requirement for material safety data sheets, then, the employer must provide the employees enough information to make him aware of the health hazards related to a particular material. The subcommittee I head is working on extend ing this kind of requirement to all industry'. I per sonally feel that one thing that would make my job much easier and greatly help local unions and safety committees, would be specific information on the physical characteristics of a chemical, the haz ards related to it. and the kind of control measures required--exactly what a safety data sheet should tell von. 25 BOR 008974 The current practice in most industries is just to designate a chemical by a number or series of letters. I know that in rubber plants, the chemicals are coded with designations such as 51 A-B-C. and most of the time even the management people don't have much awareness of that particular chemical. If they called a chemical "benzene" rather than its code name, this would immediately ring a bell of warning This is one area where I've tried to get some input into the language of our union contracts. In some of our contracts, we do have requirements for the com panies to provide the chemical names and other haz ard information to a worker if he so requests. Now, this idea is a two-way street. Many com panies, both large and small, are relatively unin formed about the chemicals they're using. If the company itself had the responsibility of filling out a material safety data sheet, it would have to become aware of the hazards related to a particular chemical. Q. Do you foresee any problems in getting com panies to reveal what they might consider trade secrets--the names of the chemicals they use? A. I think that the matter of the proprietary nature of some chemicals and processes can be handled relatively easily. Section 15 of the Act says that the Secretary of Labor can issue orders "to protect the confidentiality of trade secrets." I'd say that in the rubber industry, maybe one percent or half of one percent of all commonly used chemicals could be considered secret. So industry's argument that it will have to divulge trade secrets to give you the name of a chemical is more often fictitious than factual. Q. At a recent conference of international unions in Switzerland, the president of the URW, Peter Bommarito, said that collective bargaining is the "most fundamental, the most effective" method of getting safety and health protection for workers. What, then, is the government's role in occupational health? A. Each national or international union has its own approach in this area. Some unions feel that most of their efforts should be put into enacting laws and standards to protect the worker. We in the urw feel that effective and enforceable legislation is good, but generally speaking our philosophy of dealing with these problems is: "Let's try to work it out, keep it in the family, and get the company to com ply voluntarily without the threat of an osha inspec tion." Wc find that companies cooperate much better if wc have language in our contracts covering safety and health issues. That doesn't mean that we don't care about government involvement. In fact, some of our contract language "dove-tails" with the osha standards. The majority of companies just seem more concerned about their contractual obligations 26 to a local or international union than about their legal commitments to osha and the various state programs. Q. What do you see as the most pressing current problem in the field of occupational health? A. It is probably the lack of trained professionals to handle the multitude of jobs that have to be done. I'm not only talking about the development of stan dards, or the pre-testing of chemical compounds, or large-scale toxicological studies, but also about the plain old "gut" kind of work required--things like air sampling in a plant or testing a worker's lung function. If you look at the membership roster of the American Industrial Hygiene Association, you'll see about 1.800 people, among them university re searchers. company medical directors, and people in related fields. I would guess, though, that only 500 at most are actually going out in the field, taking air samples, recommending control measures, and so on. What we need is more professionally trained indus trial hygienists to go into a plant, get their hands dirty, get involved with management, and straighten things out. Q. How would you rapidly increase the supply of industrial hygienists? A. 1 see no solution to this dilemma at present. Be cause of budget cutbacks in the Department of Health, Education, and Welfare, the schools of pub lic health, which had been turning out some indus trial hygienists, are no longer getting funds for re search and training grunts. Consequently, the supply of new industrial hygienists is drying up at its source. We will really suffer from this problem four, five, or six years from now when wc look around and see how few industrial hygienists wc have. The only solution I see, and it's a long-range one, is to make enough training funds available to interest college students in an environmental health career. Q. I've seen you introduced at occupational health meetings as one who has "jumped the fence to labor" or "gone over to the other side," Why does this kind of introduction disturb you? A. What we're talking about here are the age-old adversary roles of labor and management. 1 feel generally that where workers' health is concerned there should be no adversary roles. We should all try to work objectively. However, if objectivity fails, if there are attempts to misrepresent the facts, then representatives of the labor movement have to assume the adversary stance to accomplish the goals to which they've professionally dedicated themselves. Mr, Beliczky was interviewed by George Clack. BOR 008975 Vinyl Cnloride Firm Says It Has Answer " Z'T'V*\.d...H ** _ J .ltl\'t- ^ LIcVi.*. 'M7/7j ` By United Press Intematumai material in plastics production, recently FORT WORTH. Tex. -- Industrialist was linked with cancer of the liver. Brad Corbett is confident that his vinyl Stringent new government standards, chloride resin factories pose no health formulated to cut exposure of factory threat to his employes. They're new and workers, took effect April 1. meet stringent federal standards. Corbett, principal owner at Texas Inhalation of vinyl chloride, a raw Rangers baseball club, is president of Robintech, Inc., based in Fort Worth. He says the company's plastics factories are new and comply with the federal standards. The new chloride resin plant at Freeport in South Texas, for instance, uses a Japanese production technique which Corbett says virtually eliminates worker exposure to the substance. Following publication of studies link ing inhalation of vinyl chloride with' angiosarcoma of the liver, the U.S- Labor Department imposed standards on the plastics industry calling for reduc tion of the chloride to an undetectable level, or at most one part per million parts, in the air of the factory. The in dustry level had been 500 parts per million. Several large companies and thesocie ty of the plastics industry filed suit challenging the standards. Corbett. 37, a native of New York, parlayed a $300,000 loan from the Small Business Administration into a thriving plastics and chemical firm. He did not join in the industry suit. He said the in dustry could easily achieve between one and three parts per million of vinyl chloride by improving the quality of the plants. There are 49vinyl chloride plants in the United States, with a total of 6,500 workers engaged in turning thechemical into polyvinyl chloride plastic. Two dozen cases of liver cancer were found among vinyl chloride workers and 13 deaths recorded before the government set new standards effective Jan. 1. The Second U.S. Circuit Court of Ap peals upheld the order but pushed the ef fective date forward to April 1. The Supreme Court is considering the decision. It refused to delay the stan dards beyond April 1. The government argued that the labor Department "is not obligated to await human deaths at a particular Iwel of exposure" before barring exposure at that level. The plastic is used in thousands of products, ranging from industrial pipeline to shower curtains and phonograph records. Vinyl chloride also was used as a propellant in some aerosal cans until the Food and Drug Ad ministration and Consumer Products Safety Commission banned it last year. OR 00897$