Document v6LamLMb50MmEG2jjd58Zp29

i' ' ' ' * ^ / O UNION CARBIDE CORPORATION CHEMICALS AND PLASTICS >t0 ivum /WLNUI , Ml W voim, N. V. 10017 July 18, 1974 ) Dr* Robert VI. Cairns Executive Director-An*erican Chemical Society 1155 Sixteenth Street N.W. Washington D. C, Dear Dr. Cairns: I am writing you this letter in part, to protest the position of the American Chemical Society in its statement to the Occupational Safety and Health Administration on the proposed standard for occupational exposure to vinyl chloride and, in part, to ask that you give public notice of the fact that the position of ACS in this matter does not represent consensus of the membership but rather the view of a limited group of committeemen having only a most limited understanding of Che facts related to .his most sensitive matter. Perhaps had you or your a-sociate, Dr. S. T. Quigley, attended the regular sessions of the Hearing, you would have seer, first-hand how inoot was the presenter ion of the ACS; the ACS' presented no facts or experimental evidence as to the biological activity of VCM; produced no study as to the value of the proposed monitoring, assay, medical surveillance, and protective equiptment recommendations; put on the record no information as the engineering or economic feasibility; offered no epidemiological evidence. As the record now shews, the ACS offered opinion in support of the "no detectable" staniard proposes hv 03HA while the evidence presented in fact contravenes the need of such a drastic standard # Support oi the OSILA proposal by the ACS is especially unrealistic in light of tiie massive contrary evidence presented by various industry spokesmen (including well-informed ACS members) that: 1. Not even continurus exposure to vinyl chloride monomer in high concentrations over a period of time will vecc-suar i ly result in any deleterious effects in humans. No evidence of any such effects at levels helot; 2-50 pnvts per million exposure were shown. 2. The eniinal data n vinyl chloride monomer exposure which Is the only porsiIle .hasis cited for imposing any exposure limits Is not only sol f-contrail ictory inconclusive and lion-probative in itself hut also enunot be and has not been related or translated Into lnti'ini experience , The Le,simony on the hni.i.m experience as for example that, of Hi . IVrneltl , shows Lhal little If any inirtti has if fact (oi*.e 1 row employee exposure to vinvl chloride Monomer. even over ext on led period;, at high tom eal: at ions; sec also Lhe How Lliomioal *6mpany testimony that no ill effects on lumuns at less RSV0033656 o3 (3) providing factual evidence generated by the AC'S through research or survey on which to enlarge the total understanding of the sensitive matter of VCM toxicology. The participation implied that the ACS position was that of its membership which, by iny standards, is a gross misrepresentation. As a minimum crrrective action, I ask you to put on the public record the fact that the presentation by ACS. at the Hearing is the view of a limited number of Director members and not the consensus of the ACS membership. Additionally. I would hope that the ACS refrains from continuing to create a public record on the matter of VCM toxicity until such time as the ACS itself has a factual contribut ion to snake to the issue. With kindest personal regards and the hope that the views of an active ACS member of core than 35 years will be heard. Very truly yours. ABS/nn A. B, Steele RSV0033657