Document regdOM7QrGBkZ9emejo5yk1Ma

UNION CAk BIDE CORPORATION Chemicals & Plastics 270 Park Avenue, New York, New Y rk 10017 To: Mr. T. W. Carmody Mr. M. S. Eisenhour Mr. A. W. Lutz Dr. W. R. Manning Mr. R. N. Wheeler/ Mr. J. W. Whittlesey Dr. N. L. Zutty From: Dr. A. B. Steele Date: September 220ftK?EiVED SEP 23 1974 R. N. WHEEL**. JR. Subject: Comments on: FINAL ENVIRONMENTAL IMPACT STATEMENT - PROPOSED REGU LATION - VINYL CHLORIDE (As Released by OSHA) During the past week, the Department of Labor has released its FINAL ENVIRONMENTAL IMPACT STATEMENT - PROPOSED REGULATION VINYL CHLORIDE for com ment by interested parties to be received by September 25, 1974. After a con* plete reading of the document, I conclude that the new Impact Statement is de signed for compliance with the National Environmental Policy Act rather than as a record of findings related to the total Impact of the proposed Standard on ex posure to vinyl chloride. The present Statement represents in substance only a minor Improvement over the draft Statement; it fails to incorporate the many con structive proposals made by members of the industry and of other departments of government, including the constructive comments authored by Messrs. J. W. Whittlesey and R. N. Wheeler. The present Statement: Fails to present medical and scientific evidence sufficient to support any specific level of exposure to vinyl chloride below concentra tions of 50 ppm or even to describe the extent of risk to humans from exposure to vinyl chloride at concentrations of 50 ppm and higher. Fails to consider the hunan experience and epidemiological surveys in evaluating the effects on humans of occupational exposure to vinyl chloride at low concentrations (below 200 ppm). Falls to reflect accurately the trend in exposure levels that has oc curred during the past twenty years in plant operations and to relate this trend to the assessment of the degree of hazard faced by workers today compared to the hazard of approximately twenty years ago. Fails to present sufficient bases in fact to permit a reasonable estimate of the technical feasibility and economic practicality of achieving any particular maximum level of vinyl chloride emission. Falls to recognize the efforts at compliance may call forth unlimited capital and operating costs and still fail in achieving the goal; such risk being great when measured against the hazard to be met. ucc 036115 -2- September 20, 1974 In summary, the new Statement represents only modest revision of the Draft Statement and continues the unrealistic, unsupported position to which the comments of Messrs. Whittlesey and Wheeler were addressed but to no avail. Since these comments are reproduced as a part of Appendix C of the Final State ment, I see no advantage to Issue again detailed conments on the Final State ment. Yet, it Is unfortunate that such an inadequate document as this be used in the decision making on such an important and sensitive matter as regulating the PVC industry. Conments of those familiar with the Final Statement will be greatly ap preciated. ABS:ml A. B. Steele ucc 036116