Document reQ3XJX5DqmZj6DGxYnGN1YOe

A 5LCtiv.Ec; Mr. 0. R. Smith Special Studies Staff Environmental Protection Agency National Environmental Research Center Research Triangle Park* North Carolina 27711 APR vWfc - g.Riwuw,* Dear Mr. Smith: This will furnish you further Information on the subject of reported non polymerization worker cases of angiosarcoma which we discussed by telephone on March 31 and April 2. Some confusion seems to have arisen over the nomenclature applied to the reported cases of angiosarcoma In Connecticut. They have been variously called "community cases" or "neighborhood cases" in the media, In EPA documents (STAR Document, p. 1), and In the EPA hearing (cross-examination of Barry Castleman by Dr. William Marcus, hearing transcript p. 42, copy attached), "non-polymerization cases" by NI05H, and "non-occupational cases" by CDC and in other places. Unfortunately, we seem to have added to the confusion by using both "non-occupational" and "non-polymerization" on page 19 of the Air Products' submittal to Dr. Goodwin, dated February 23, 1976. I will hereinafter use the NIOSH designation of "non-polymerization" for employees not workinq in PVC plants and "non-occupational" for persons not employed In any part of the PVC Industry. The cases with which we are concerned are therefore "non-polymerization" cases. NIOSH does list these In "Table II" which they maintain. The latest listing of these cases is dated September 12, 1976, and 'is attached. It has not been distributed routinely with Table I over the last few months, and Drs. Adams and Smith of this company were informed earlier this year by Dr. Lloyd that it had been discontinued. This led to the statement in the submittals by Air Products and the Society for the Plastics Industry that these cases had been dropped. In a conversa tion today with Dr. Pierre Decaufle of NIOSH, he confirmed that this list is not normally distributed now, but that It is still In existance and will be maintained. The burden of proof is on NIOSH to substantiate their listing of these cases, arid to show their relationship to vinyl chloride. No one presently exercises this responsibility. Angiosarcomas do occur in populations not exoosed to vinyl chloride. The CDC has recently published a survey of ten cases in Wisconsin which have no vinyl chloride relationship whatsoever (copy attached). The Connecticut cases would seem to fall into a similar classification except for the very casual relation ship to fabrication operations. This type of correspondence is expected to occur on a statistical basis from time to time. AP00011368 Mr. J. R. Smith -2- April 6, 1976 Regarding the foreign cases listed in NIOSH Table II, Germany 03 filled aerosol cans where the exposure from leakage was reported to be high. We have no more information than NIOSH on Germany 07, or Great Brltian 02. Italy 01 did not have primary liver angiosarcoma. Sweden 02 worked in an obsolete acetylene-process vinyl chloride plant where the exposure was high. The two U. S. (Connecticut) cases are discussed by you in the footnotes to Table 6-19 of the STAR Document, where you quote Dr. L. B. Thomas of the National Cancer Institute. ' He states that both cases are uncertain. Furthermore, EPA has stated that their measurements of vinyl chloride around fabrication plants show it to be "almost negligible" (Preamble to Standard 40 FR 59534). The highest found was 6 ppb, and none was found at 3 of the 5 plants tested. Thus, these "non polymerization" cases are doubtful in relationship to vinyl chloride, and do not support any concern for harm at "levels of exposure as low as 1-10 ppm" (STAR Document, p. 1 The exchange between Mr. Castleman and Dr. Marcus at the EPA hearing Indicates that the EPA has reached the same conclusion. This is supported -by-the statement fn Appendix E, page 5, of the Risk Assessment Document by A. M. Kusmak and R. E. McGaughy that, "This survey has produced no evidence that living around vinyl chloride plants is a risk.factor In the occurrence of liver angiosarcoma." Thus, we.stand on our position that there is no demonstrated risk to persons not exposed to high concentrations of vinyl chloride for long periods of time, and therefore, the proposed standard is unnecessary. I hope that this clarification is of help to you, and apologize for any confusion to which we may have contributed. We will be happy to discuss any other part. of. our. comments.with you. whenever you may wish. Very truly yours, Attachments,. , . Vc; ;Mr. G._ Baise/llucVelshVus, Beveridge, Fairbanks & Diamond, Wash., DC 0. R._ Goodwin, EPA, Research Triangle Park, NC ' : -Mr* 0* Hadley, Keller V Heckman, Wash, DC Mr. R. Harding, SPT," New York, NY bcc:" A.' R. Adams' R. Fleming R* H. Schenck W. M. Smith L. B. Tepoer AP000U369 TRANSCRIPT OF EPA HEARING ON vinyl chloride:, February 3, 1976 DR. MARCUS: po you know of any evidence of the increased rink in the general population, Dthor than the studies that have been done in work? MR. CA?TT.r?-tAtt: Aside from the fact that there were apparently two neighborhood canes with no known occupational e>rposure, no X don*rt. PR. MARCUS: I would like to say that EPA investigated very carefully those cases, and we consulted with our expert doctor, Hans Popper of Mount Sinai, and it was his expert opinion that these people did have * * ' r angiosarcoma.- that was of a different type then that caused by vinyl chloride monomer, and I must cay, to date va do not have any evidence that angiosarcoma has been produced by vinyl chloride monomer in the general population. MR. -CASTLEMATT: I think it is important, to realize that only about one-fourth of the present WC plants were operating 20 years ago. The latency .of this disease is 20 years or more, and of these ten plants, at least one-fourth of the present level of plants, which is about ten, the total production rate is one-tenth of the rate it is today. The population nay also have boon thinner around the plants than it is todays - . !*; ' Sc?, If you look at the present situation in terms of how many people lived near the plants of a certain sire, it boars little rcscmblencc to the situation 20 vJicm % /.V*i ' *li /* na AP00011370 ysjars ago. The mortality experience that wo obssrvo today started 20 years ago, I don't think the absence o eases is any proof of anything. Wouldn't you agree with that? i DR* MARCUS: In general I would say that is a very cogent comment. The only thing here is that vinyl chloride happens to offer us a unique opportunity to tv .n 12 (.> i M 19 If. IT i '*$ 3< i * i 22 33 see an extremely rare cancer, which wo can cay is maybe due to the substance in question, rather than an increased rate of cancer, which la a very difficult thing to assess. That is why I say, I was hoping somebody would have some information about VCM induced angiosarcoma in `the general public, because we have not been able to find it as yet.. . . * ' j MR* CASTLEMAM: I talk to the came people you do y CllAIRMAN DENNEY: Dr. McGaughy. DR. MC GAUGHY: I just have cno short question. * Re are interested in getting as accurate a picture as we can as to 'what the risk is to the population due to vinyl chloride exposure. You mentioned there were two or three factors that ve have not considered. Mainly the carcinogieity of vinyl chloride and other chemicals and the transplancental effects that might *3 caused to expectant mothers. AP0001)371 Vo!. 25, No. 0 WEEKLY UEruTT For Week Ending February 28, 137G U.S.DEPARTMENT OF HEALTH. EDUCATION. AND WELFARE PUDUC HEALTH SERVICE DATE OF RELEASE: MARCH S. 1976 - ATLANTA. GEORGIA 30333 EPIDEMIOLOGIC .VOTES AND REPORTS ANGIOSARCOMA OF THE LIVER - Wisconsin In the period June 1973-Novcmbcr 1975, 4 esses of ngiosircoma Of the liver (ASL) were diagnosed at the Marsh field Clinic, Marshfield. Wisconsin. One wm based on hepatic Arteriography and 3 on tissue findings later confirmed by pathologic review at the National Cancer Institute (NCI). An additional 6 cases, confirmed on pathologic review at NCI and identified through a national ASL case surveil lance project initiated at CDC in 1974, have been diagnosed since 1904 in Wisconsin residents. This total of JO cases is foughly twice as large as might be expected (5.5 cases), based on CDC surveillance estimates of erode ASL incidence for the entire United States. (Five additional cases had been re CONTENTS Epidemiologic Norn and Reports Angiosarcoma of the Liver -- Wisconsin........................... 67 Possible Lasu Fever - Washington, D.C..................... ...... 6A Current Trends Influent* -- Worldwide ....................................... .. S3 Interactional Notes Solmanttti typhimurkm -- Canary Islands, Finland, and the Federal Republic of Germany .... 64 ported for Wisconsin; 4 were not confirmed, and I was in a resident fanolhersuic.) In view of this relative frequency of cases, together with the recent succession of cases at the Marshfield Clinic, epi demiologic information concerning each of these 10 caves -. TABLE 1. CASES OF Sl'ECli-TLl) NOTIFIABLE DISEASES: UNITED STATES (Cumulative totals include revised and delayed reports through previous weeks! DISEASE WEEK ENDING February 38 1976 February 23 1975 MEDIAN 1971*1975 CUMULATIVE. FIRST & February 23 1976 February 22 1975' WEEKS MEDIAN 1971-1475 . Encephalitis Hepatitis, Viral Type U ................................ .. Henififococctl infections total.............................. 28 5,764 A 13 A 242 12 6 133 3 405 - 53 53 2 Tbbrrculosis . * ( 1 aa aa^at aa** t - -570 Tvhremi* .... aa<4e*4*idd4 r * IVphtu, (tclt-barne (Ricy. Mt. spotted fever).... Venerea! Diseases: ll.M) 562 . SypWlb, primary and secondary . * *' 52 B . Rabies ia inimafs ...................................................... 31 35 4,311 14 IT 7 210 707 150 6 578 41 41 1*425 285 *05 12 33 6 15 5 172 [ 690 6 622 41 40 1 1,892 445 .2 4 17,273 419 S31 1 4$ ' 56 307 39 ,268 62 129 32 1,935 5*409 1*365 *3 4,316 284 261 3 9,366 194 1 *670 6 4,572 - 21 * 56 3 ''151,748 4,708 4,132 -64 . ,249 292 29,493 64 96 33 1 *566 $.426 1,123 42 2*668 270 263 7 11*136 201 1*937 9 4,105 8 29 10 141,258 4 *776 3*936 52 284 292 15 23 120 33 1*314 42 4,167. 270 263 9 14,241 3*534 6 13 31 9 448 TABLEil. NOTIFIABLE DISEASES OF LOW FREQUENCY Cum. Cum. 2 Poliomyelitis, total: ............ e 2 2 19 Hague:................................ ......................................................... fKrpuH l<> ,, Trirltinosiv. NJ. 1 , . ....................... .................................... 33 2 *t ... AP000I1372 'I i j < t\ ii } l i :r . *, . ;j * i * -! .1 1 O' ; o 58 MorlntUly ou<l Mortality Weekly Report FEBRUARY IS. 1976 ANCIOSARCOMA - Continued his been BiiwmbleJ tltrour.lt medical record review and family interview (l.-tble !). Farneiihr attention bat bet'!) given to potential occupational or environmental exposure to chemicals known to induce ASL (vinyl chloride, arsenic, and thorium dioxide). Most cases (7 of I0)were diagnosed since 1970, prob ably reflecting better ease ascertainment in recent years. Ages ranged from 36-71 (mean age 58 years). All but 1 pa tient were male, and all but 1 were white. Places of usual residence for all cases were widely scattered across the state, roughly corresponding with the state's population (figure 1). One patient had a history of prior thorium dioxide ex posure. For none of the remaining cases was tumor etiology obvious. Occupations and histories of exposure to potential environmental toxins differed widely, with no more than 1 case associated with any particular industry or mode of exposure. In several instances, however, individual patient occupations or exposures were suggestive of possible onco genic*ly (Table I). Patient 10 had had exposure to a vinyl compound; he had worked in paper and plywood products with potential contact with various chemicals, including poly vinyl acetate. Two other patients gave histories of possible exposure to arsenic: patient 9. who had exposure to insecti tides while farming,, and patient 8, who worked with wood probably treated with arsenic preservatives in the manu facture.of bleachers. AM.but 3 of the 10 patients were known to have lived on farms during their lifetimes, 2 Tot all of their Jives (Table 1).. (Reported by J Fiechtner, .1/0, C Reyes. MD, Marshfield Clinic; K Retumcssisr, MPli, JIG Skinner, MD, State Epi demiologist, Wisconsin State Dept of Health and Social Serv ices; Office of Cxtramural Coordination end Special ProfcctS, National Institute of Safety and Health; and the Cancer and Birth Defects Div. Bur of Epidemiology, CDCJ Editorial Note These data indicate no obvious common-source origins among recent cases of ASL in Wisconsin. The marked male preponderance among cases, however, suggests occupational Figure I GEOGRAPHIC tStSTTtl NUT t ON Of CONFlUMm CASES Of ANGJOSAKCUMA titHit. l.l\ fit IN WIMONMSl 111 MIM.NIS. 1904-1975. HY PLACE OF USUAL KCSTUCM.C exposure as the potential origin for at least some of the eases. Anecdotal histories of occupational and environmental exposures in several of the eases may warrant further tttvcjtigation. particularly in relation to contact wirh arsenic. Al though at present only vinyl chloride monomer (/). thorium dioxide (J). and arsenic (S.S) are clearly implicated as causes of ASL. Investigations such as the one described here may well provide useful leads in defining further causes. 'References ). Creech JL, Johnson MN: Angioureeraa of liver in the manufacture Of polyvinyl chloride. J Oecup Med 16:1 J0-J3J, 1974 2. MacMahon HE. Murphy AS. Bites Ml: Endothelial-Cell sarcoma of liver following ThorottJSl injection. Am J Pathol 23:SS5-59S, 19J7 3. Leader Si, Stanly RJ, Sumner HW, <t s[: Angiosarcoma of she liver associated with Fowier'i solution (potaicium irunue). Gastroenterology 69:I5S2-15S6,1975 4. Roth F: The sequels of chronic irsenie poisoning in Moselle vinsers. Ger Med Mon 2:172-175,19S7 _______ . Table 1 Ow of ASL In SVjtcomin Resident* 1964--1975 6k Month and Year L'sttji Town Age at Number Diagnosis Death Of Residence Diagnosis Race Sex Occupation Comments Farm Residence 1 4/64 2/65 Sheybogan 71 W 3 5/67 2/67 Oshkosh . 3 6/67 6167 Necedah 61 W 36 W 4 7/71 7/71 Milwaukee 68 * ^ B :j 4/72 4/72 Milwaukee 64 1 "V 6 4/74 6/74 Drown Deer 46 W 7 ' 1/74 7/74 Wausau 57 W -9/74- -9/74 --Wjupon------ ---46-- w T' " 9 10 5/74 S/74 SlratM ` * C6 * w 11/75 11/75 Marshfield 65 w -- ----- ------- ---1 ----- - 7 -------- * -- . . 4 M University Teacher Lived near a chemical company Youth M Foundry Welder which made plastics ud resin Exposure to welding materials None F Secretary and resins Infectious hepatitis in childhood. Youth mother and sister had liver disease M HogScatder None 91 Unknown Exposure to tlrorium dioxide Unknown M Lutheran Pastor Lived near a paper mill. 1955-1959 Youth M Rock OushvrjGhie- Exposure to silica dust, rubber Youth Liner for rubber cement raincoats, 1940s M Postal Mail Carrier Contact with lumber, paints, wood Lifetime formerly employed preservatives, lanttnoniacal-coppcr- by company that arsenate wood prcscrvaiiveM?) made Mv.ulicrs M Retired farmer No tissue diagnosis; ARLdiapnowd Lilciime by hepatic artcno|tr.tftsy M Press operator for Contact with wood, plywood. Youth paper and pfywtoJ t;luv, polyvinyl acetate, others company (23 years) ' j AP00011373 TABLE II i | REPORTED CASES OT ANGIOSARCOMA OF THE LIVER AMONG ........ | NON-POLYMERIZATION WORKERS EXPOSED TO VINYL CHLORIDE i' ,r ' COUj NTRY i Fed. Rep. Germany Fed. Rep. Germany Great;Britain Italy Sweden United States United States - CASS j BIRTH #; DATE ; i1 03* 07-16-30 07* 05-09-36 02* 09-08-14 01 ' 06-15-34 02* 11-27-11 14 00-00-13 15* 00-00-25 1st VC or PVC EXPOSURE 06-09-52 00-00-60 00-00-46* 00-00-65 , 00-00-45 08-18-38 i00-00-00 DX ANGI0 SARCOMA 03-00-73 00-00-74 02-00-70 04-19-71 05-15-72 06-00-73 07-00-72 AGE YRS TOT AT 1st EXP YRS DX TO DX EXP 43 21 38 14 55 24 36 6 61 27 60 36 47 00 14 03 . 11 3 23 00* 00 DATE OF DEATH * 10-10-73 Note 6 12-16-74 Note 9 12-00-70 Note 1 04-16-71 Note 2 & 7 08-16-72 Note 3 07-03-73 Note 4&8 02-15--73 Note 5 Note L Note 2 'Note 3 Note 4 Note 5 'Note 6 Note 7 Note 8 Kota 9 Pouring PVC oil mixture j onto fabric bases Production of PVC sacks Production of Vinyl Chloride ... Machine operator covering electrical vlre vith PVC plastic Insulation -- Accountant at plant making PVC fabric Loading pesticide cans with VC propellant i 1 Angiosarcoma Involving live^, lung, and pericardium. Although difficult to determine, primary site seems to be pericardium. Diagnosis: Sarcoma (possibly "angiosarcoma")* liver. Possibility of generalised neoplasm of the reticuloendothelial cell system cannot be ruled out. Assistant Factory Chemist t * Indicates microscopically confirmed! angiosarcoma of the liver. "00" Indicates unknown data. | AP00011374