Document vEgzRM15dgywbVD59vYBkyd8

CHEMICAL MANUFACTURERS ASSOCIATION July 31, 1987 TO HEALTH AND SAFETY CONTACTS OF CMA MEMBER COMPANIES Dear Health and Safety Contact: As you know from my letter to you of May 11, 1987, the health-related authorities of the Superfund Amendments and Reauthorization Act (SARA) of 1986 will have a significant impact on your company. I alerted you to CMA's intentions to begin various advocacy activities to cooperate with and promote sound science during government implementation of Section 110 of SARA. Initiation of some of these advocacy activities involves your company's unique expertise. I solicit your participation. Initial efforts to implement the broad health-related authorities under Section 110 of SARA have already begun. On April 17, 1987, the Agency for Toxic Substances and Disease Registry (ATSDR) and EPA published a list of the 100 most hazardous substances found at waste sites and guidelines for development of "toxicological profiles" on those sub stances (52 Federal Register 12866, 12870). These profiles will be used to estimate "significant human exposure levels," to identify data needs, and to recommend further testing. On July 16, 1987, CMA submitted written comments to ATSDR and EPA on the criteria for listing hazardous substances and on the proposed guidelines for toxicological profile development. (Copies of these comments are available from CMA upon request.) ATSDR's next step is to develop draft BOR 007421 Formerly Manufacturing Chemists Association--Serving the Chemical Industry Since 1872, 2501 M Street, NW Washington, DC 20037 Telephone 202/887-1100 Telex 89617 (CMA WSH) CMA Health and Safety Contacts July 31, 1987 Page 2 toxicological profiles on the first 25 substances from the list of 100 substances by October 1987. These 25 substances are identified below: CAS No. 50328 53703 56553 57125 60571 67663 71432 75014 75092 76448 79016 86306 106467 117817 127184 205992 218019 1745016 7439921 7440020 7440382 7440417 7440439 7440473 11196825 Substance Name Benzo(a)pyrene Dibenzo(a),h)anthracene Benzo(a)anthracene Cyanide Dieldrin/aldrin Chloroform Benzene Vinyl chloride Methylene chloride Heptachlor/heptachlor epoxide Trichloroethene N-Nitrosodiphenylamine 1,4-Dichlorobenzene Bis(2-ethylhexyl)phthalate Tetrachlorethene Benzo(b)fluorantheneChrysene p-Dioxin Lead Nickel Arsenic Beryllium Cadmium Chromium PCB-1260,54,48,42,32,21,1016 Although ATSDR will conduct its own scientific peer review on each of these chemical-specific toxicological profiles prior to public dis closure, CMA believes that a similar industry review of the profiles is warranted. I solicit your help in volunteering knowledgeable industry scientists, reputable consultants or other industry trade groups to participate in evaluating the first 25 draft toxicological profiles scheduled for release this October. Each industry peer review panel will consist of at least three persons with expertise on and familiarity with the health and environmental effects database for a given substance. Although this CMA activity is focused on specific chemicals, the reviews prepared by industry panelists will be the basis for an overall CMA evaluation of the general content, format, and process by which these first 25 draft toxicological profiles were developed. Our assessment of the profiles on a chemical-specific and general basis will be important to the development of profiles on other listed chemicals during the next few years. As you know, the profiles will likely be used not only for BOR 007422 CMA Health and Safety Contacts July 31, 1987 Page 3 the purposes originally intended by SARA, but as the basis for other federal and state regulatory activities. The "significant human exposure levels" estimated in the toxicological profiles and testing recommenda tions on specific chemicals carry particularly onerous implications for industry. You can help CMA ensure that the data and conclusions in the profiles are supportable by Industry. Please return the attached form by Tuesday, September 1, 1987, indicating each substance of interest to your company and the industry health scientists that will help review and evaluate the toxicological profiles on those substances. Remember to note the names, address and the phone numbers of other persons outside of industry known to have expertise on any of the substances. Note that while it is unlikely that member companies will submit confi dential data to CMA in response to this request or as a result of re viewing the toxicological profiles, CMA has set up special safeguards to protect confidential information on.specific chemicals from disclosure to competitors or the public. To assure this protection against disclosure, please clearly designate such documents submitted to CMA as "CONFIDENTIAL." Further communication will be made in September 1987 to the persons you've designated as participants in this important activity. Please call Nancy G. Doerrer of my staff at 202/887-1282 if you.have questions or need more" information about the list of 100 substances or the develop ment of toxicological profiles. Sincerely yours Geraldine V. Cox, Ph.D. Vice President-Technical Director Enclosure BOR 007423 CHEMICAL MANUFACTURERS ASSOCIATION INDUSTRY PEER REVIEW PANELS TO EVALUATE TOXICOLOGICAL PROFILES ON THE FIRST 25 PRIORITY LIST SUBSTANCES UNDER SECTION 110 of SARA RETURN BY: RETURN TO: Tuesday, September 1, 1987 Nancy G. Doerrer Associate Director Health, Safety and Chemical Regulations Chemical Manufacturers Association 2501 M Street, NW Washington, DC 20037 (202) 887-1282 Substances (Circle one or more) Benzo(a)pyrene * it Health Scientist(s) Address and Telephone Number ____________________________ Dibenzo(a),h)anthracene Benzo(a)anthracene Cyanide Dieldrin/aldrin Chloroform Benzene Vinyl chloride Methylene chloride Heptachlor/heptachlor epoxide Trichloroethene BOR 007424 Substances __ (Circle one or more) N-Nitrosodiphenylamine Health Scientist(s) _______________________ 1,4-Dichlorobenzene _ Bis(2-ethylhexyl)phthalate __ Tetrachlorethene _ Benzo(b)fluoranthene ________________________ Chrysene ________________________ p-Dioxin _ Lead Nickel __ Arsenic ________________ . Beryllium ______________________ _ Cadmium ________________________ Chromium _____________________ PCB-1260,54,48,42,32,21,1016 *** SUBMITTED BY: NAME: COMPANY: ADDRESS: TELEPHONE NUMBER: SIGNED Address and Telephone Number BOR 007425