Document wDoeg624JbX0X1Xe0E3Kq9b3J

in untecs iieaun W&&& i* I <rtSQd like to take this oppor The Society of the tunity to commend The Inquirer' Plastics Industry, Inc. an^jn particular, staff writer S^^BQ. Stranahan for the fivepa^BKries concerning the Occu- I )al Safety and Health Act of li>. My organization was very ac tive in the ultimate enactment of this law and is currently doing its best to have Congress provide the necessary funds so that its intent can be properly carried out. I have read a lot of material on 355 Lexington Avenue Mew York, Mew York 10017 # (212) 573 9400 March 30, 1976 ixE CE 1VED ,.-K 14 1976 G. D: LLOYD RECElVEn APR 6-1976 ,-P-AW* this law but nothing has been bet ter than Ms. Stranahan's articles. She must have put literally untold hours, days and months into her preparation. It was an excellent job for .vbich roe are very grateful The Editor The Philadelphia Inquirer 400 N. Broad Street Philadelphia, Pa. 19101 .w^7' Deceived " t 4 1976 JULIUS UEHLEIN Secretary-Treasurer ' Dear Sir: R. W. ARNOLD Legislative Commitee of Pennsylvania Harrisburg. , The article on occupational health by Susan Q. Stranahan from the March 21 issue of the Inquirer contains a sig nificant number of errors and distortions, especially with regard to the vinyl chloride situation. The article's assertion that no research efforts were undertaken by the American PVC industry is totally incorrect Beginning in early 1973, an extensive animal inhalation study was launched at Industrial Bio-Test Laboratories in Illinois, and a survey of present and past PVC workers was started by Tabershaw-Cooper Associates of Berkeley, CalifornThese studies were both announced publicly, and their result: released to the American people in 1974. In fact, it was th( American industry sponsored animal study, and not that of Dr, Maltoni in Italy, that first produced angiosarcomas in test animals at 50 ppm. * * t-- P"* _ c.O .lav / 4 mfi RECEIVED ARR 23 1976 ' r r V Y The totally fallacious issue of what research was undertaken at what time, and who knew about it, and who he told and whe has been rehashed in the press for more than two years. The essential facts are, nonetheless, quite simple. It was the PVC indust ry -- and not the government, or labor unions, or the so-cal led "independent" medical community ~that initiated and sp onsored essential ly all of the medical research on vinyl chi oride before 1974 including that of Drs. Viola and Malton i in Europe. And it was a member of th< industry who made the first tenuous co nnection between VC exposure and angiosar coma in humans, In fact, v/ere it not fdr the actions taken by industry from 1970 onv/ard, we might still today know next to nothing about the health effects of vinyl chloride inhala ^fifeCEIVED r": jn*. sfSLd.1--'iZ.1 v -- w APR 2 0 )y/6 RECEIVED inued, LUfciVcL/ , AMIS'- u- M* HASKELLAPR l'Am m 19 m ,'J. L,. KoGS.-' ` !MK4' - J. J. TaylqrP^OT PLANT. OCC 0685 The Philadelphia Inquirer Page 2 While there are obviously still disagreements over the precise information relayed at the meeting between the industry and NIOSH in July, 1973, the fact remains that it was the industry which requested the meeting because it felt an obligation to keep the government informed of devel opments in the research area. It might appear in hindsight that both the industry and government failed to appreciate the significance of the earl research findings, and that subsequent studies were under taken at a somewhat leisurely pace. It cannot be emphasized too strongly, however, that at the time there was no estab lished link between exposure to vinyl chloride and cancer in humans. The industry sponsored worker studies were under taken to determine if such a link existed, but events pro ceeded faster than the research. The article is totally incorrect with regard to certain basi facts concerning the OSHA hearings in 1974. The standard proposed by OSHA was not 1 ppm, it was very specifically "no detectab`1 e level The industry testified then, and it stil believes today, that such a standard would be technological! infeasible. Obviously, OSHA agreed because it changed the standard to 1 ppm, and added a peak exposure value of 5 ppm for any 15 minute period. .These and other significant changes in the original OSHA proposal, plus the rapid development of revolutionary new control devices, permitted the industry to continue in oper ation. Furthermore, the estimated $300 million cost for compliance with the standards breaks down into $50,000 for each of the approximately 6,000 employees in the VCM and P\ resin industry, a not insubstantial commitment to worker health. With regard to the general public, your reporter is obvious unaware of a recent extensive study undertaken by the Envir mental Protection Agency which concluded that there is "no evidence that living around vinyl chloride plants is a risk factor in the occurrence of liver angiosarcoma." There are numerous other errors, both.large and small, in 1 article, e.g. the OSHA standard went into effect April 1, not 1974; the American industry did not co-sponsor Dr. Maltoni's research, it undertook its own instead; the origOSHA standard of 500 ppm was an ACGIH standard, not one de1 oped by the Manufacturing Chemists Association; the 1949 continued OCC 0686 The Philadelphia Inquirer Page 3 Russian study identified PCB exposure, not vinyl chloride, as the cause, of hepatitis, etc. The essential question in the vinyl chloride experience, and the only one worthy of the nation's attention, is whether any segment of the American public is currently in danger from exposure to excessive amounts of vinyl chloride. It is our firm conviction, based on all the available evidence, tha the threat to the American people, whatever it might have bee in the past, has been eliminated. Over a period of two years plant exposure levels have been reduced a hundredfold or more and the same is largely true of emissions into the environmen Never before in occupational health history has an industry labored .so arduously, rapidly and successfully to eliminate a recognized hazard -- one which the industry itself discovered. This is the record on which we feel, we deserve t be judged. Veny truly yours, Ralph L. Harding, Jr. President X-', RLH/IS :bcc/ Russell A. Park -SI . 1 A51s i OCC 0687