Document zDzpr41KZOK1erx866aLbzKR

Interoffice Communication To From John Friend, A1 Sather j. j. Hall Date May 7, 1982 Subject NIOSH EXPOSURE STUDY FOR DEHP < f -A-rff The attached letter from Keller & Heckman explains NIOSHTs Intent to do an exposure study on DEHP. I would expect this study. If properly conducted, to verify what we already know -- exposure levels are very low. The CMA Phthalate Committee has already met with NIOSH to explain some of 4| Attachment cc HRF, SKS VAB.0001034001 JOSEPH E. KELLER JEROME M. HECKMAN Charles m. mecman WILLIAM H. SOROMESANI. JR. roscrt r. tiernah MALC0LM a MACARTHUR WAYNE V. SLACK DAVID L. HILL MARTIN W. SERCOVIO JOHN S. ELORED CAROLE C. HARRIS MICHAEL P. MORROHE LARRY S. SOLOMON 04410 IM OHtr LAW OFFICES Keller and Heckman U30 IT"* STREET, N. W. SUITE lOOO JOHN B. OUSECK CHRISTINE A. MEAGHER SHIRLEY S. PUJIMOTO RETER L. M la CRUZ'* LAWRENCE P. HALPRIN DEBORAH SHUR TRINKER C. OOUOLAS JARRETT EDWARD L. HORWEK ROBERT L. PLESHNER JONATHAN P. LEVINE SHEILA A. MILLAR RUSSELL H. POX LEE M. WEINER (308) 437 11OO May 4 , 1982 RtCElVED Mi rt. I *i 0 rl; 10 YELECOPIER (Z0*> 2RS-7SS2 CABLE AOORESS "KELMAN" WRITER'S OIMECT DIAL NUMBER (202) 457-1110 To: SPI--Food, Drug, and Cosmetic Packaging Materials Committee SPI--Polymeric Materials Producers Division SPI--PVC Safety Group Re: DEHP; NIOSH Exposure Study Ladies and Gentlemen: He have just been informed that the National Institute of Occupational Safety and Health (NIOSH), under the impetus provided by the carcinogenesis bioassay of di(2-ethylhexyl) phthalate (DEHP) is turning its attention to the question of occupa tional exposures to this chemical. More specifically, our under standing is that NIOSH is undertaking a feasibility study to determine whether industrial exposures to DEHP are near the currently permitted level of 5 mg/M3 */ time weighted average (TWA) or whether they are significantly below this level. If occupational exposures are adequately low, NIOSH will recommend that no further attention be given to this matter; if the feasi bility study indicates the possibility of undesirably high expo sures, a more comprehensive survey of exposure levels as well as possible health effects will follow. As always, the ultimate objective is preparation of a report for the Occupational Safety and Health Administration (OSHA) which will undoubtedly give NIOSH's recommendations as to whether new standards need to be developed to assure worker safety. */ Milligrams of particulates per cubic meter of air. 29 C.F.R. S 1910.1000, Table Z-l. VAB.0001034002 * May 4, 1982 Page 2 So that you will have all o the background available on this matter, on Friday, April 30, and again on Monday, May 3, we were contacted by Dennis Roberts o NIOSH1s Industrial Hygiene Section in Cincinnati. Mr. Roberts noted that the Na tional Toxicology Program (NTP) recently announced the avail ability of the final report of the carcinogensis bioassay of DEHP. This report concluded that "[ujnder the conditions of this bioassay, di(2-ethylhexyl) phthalate was carcinogenic for F344 rats and B6C3F1 mice ..." Combined with the knowledge that DEHP is used extensively in the plastics industry, the report led NIOSH to direct its attention to the levels of occu pational exposure to DEHP with a view to determining whether these levels of exposure pose any health concerns. In response to Mr. Roberts queries as to where DEHP is used in the plastics industry, we informed him that the major use in the industry is in the preparation of some--but by no means all--flexible polyvinyl chloride (PVC) products. We also informed him that The Society of the Plastics Industry, Inc. (SPI), as a matter of policy, would cooperate with NIOSH in any reason able way but that we were unable to tell him which companies utilize DEHP in their formulations; it was suggested that he refer to some of the standard references for information on users of DEHP or suppliers of plasticized products. We were requested by Mr. Roberts to notify the industry, to the extent possible, of the NIOSH interest so that commercial users of DEHP will not be surprised if they receive inquiries from the Agency. The inquiries will ask whether DEHP is used and exposure levels may be measured. In this connection, Mr. Roberts noted his awareness of the need to exercise great care because of the potential for accidental DEHP contamination of samples that are not properly taken and analyzed. This is all the information we have at this time but we will make every effort to follow the progress of this program wmmm m VAB.0001034003 Hay 4, 1982 Page 3 * and keep you ully informed. By the sane token, we would wel come any information that any of you can provide, particularly if you are contacted by NXOSH personnel. Cordially yours. cc: Mr. Dennis Roberts Jerome H. Heckman VAB.0001034004