Document zdgMpagpENjB0wBGwXDJvjo0B

TO: Distribution FROM: DATE: Interoffice SUBJ: Communication T. G. Grumbles October 26, 1987 UNION CARBIDE EPA 8(E) NOTIFICATION: TESTING RESULTS ETHOXY1ATE TOXICITY Attached is a copy of the notification given to EPA. In summary, Carbide has detected an unusual pattern of toxicity in rabbits exposed to high dose of ethoxylate in skin testing. The pattern was characterized by delayed deaths and evidence of lung injury. The evidence of lung injury as a result of skin absorption is unusual. The "delayed" deaths referenced In the letter appears to mean they observed deaths later than the normal observation period called for in the testing protocols. Carbide does note that the human significance is unknown. The letter says the effects were seen with long chain alcohol ethoxylates. Carbide has told me that this means C^q and above, with a broad range of ethoxylation levels. The impact of the 8(e) notification is difficult to judge. However Carbide will be informing all of their customers of the notification and the results. We need to prepare ourselves to address questions that may arise as a result of this development. I would propose a conference call with Surfactants Marketing, R&D, and others that may get customer questions regarding this issue. The purpose of the call would be to further discuss the contents of Carbide's letter and assure we all understand how we should respond to questions. This should be done soon. I would propose Wednesday, October 28. Please let me know if this can be arranged. I will be working with Carbide to determine further details on the testing results, and what steps Vista needs to take to further respond. T. G. Grumbles ai o .212 cc B. E. A. Larsen, W. J. B. Vogel, C. M. Starks, J. J. Langford R. E. Lehmkuhl, R. T. Ferrell, R. D. Gamblin, W. L. McClain DISTRIBUTION: H. W. Hilgers, C. J, Matson, 0. C. Kerfoot VVV 000014984 UNIONI CARBIDE CORPORATION INDUSTRIAL CHEMICALS DIVISION 39 OLD ROGeBURY HDAD, DANBURY, CT 00017-0001 October 21, 1987 Mr. Thomas G. Grumbles Vista Chemical Company 15990 North Barker's Landing Road Houston, Texas 77079 Dear Tom, Attached is a copy of the TSCA Section 8(e) letter which we recently sent to the Environmental Protection Agency. As I mentioned on the phone, we are in the process of preparing a letter to notify customers and co-producers of the results of our studies; and I will be sure you are included on the distribution list, Tom. Please don't hesitate to contact me again for additional information. I apologize for the delay in getting the enclosed information to you. Very truly yours, Attachments Product Safety Manager cc: D. C. Macauley V. H. Johnkoski UNION CARBIDE CORPORATION Health, Safety artd Environmental Affaires Chemicals and Plastics Group 39 OLO RIOGEBURY ROAD, DANBURY. CT 06817-0001 _ CERTIFIED WAIL RETURN RECEIPT REQUESTED October 13, 1987 Document Processing Center (TS-790) Office of Toxic Substances Environmental Protection Agency 401 M Street, SW Washington, D.C. 20460 ATTENTION: 8(e) Coordinator RE: Alkoxylate Nonionic Surfactants Dear Sir or Madam: Union Carbide Corporation believes that the following information regarding alkoxylate nonionic surfactants is reportable under Section 8(e) of the Toxic Substances Control Act. Over the past one-and-a-half years Union Carbide has sponsored acute toxicity studies on a series of 18 different alkoxylate nonionic surfactant materials. The acute lethal toxicity of these materials, as expressed by peroral or 24-hour percutaneous LDso> varied between moderate to very low (i.e., LDso values ranged between 0.4 to >16 ml/kg by peroral administration and between 0.8 to >16 ml/kg jy percutaneous application). An unusual pattern of toxicity, however, was observed in the 24--hour occluded cutaneous application in the rabbit portion of these studied The pattern was characterized by delayed deaths and macroscopic evidence of lung injury. Microscopic examination of lung tissue was recently conducted on animals treated with the last 7 of the 18 of these materials, these tissues being saved only after recognizing that this pattern of toxicity had emerged. Microscopic findings included bronchopneumonias pneumonitis, alveolar histiocytosis, edema, congestion and necrosis. In almost all cases, the injury was associated with the presence of foreign vegetable matter in the lower respiratory tract and lung. The foreign vegetable matter was presumably feed particles which had been aspirated. WV 000014986 Alkoxylate Nonionic Surfactants Page 2 No one of these studies by itself would trigger a concern regarding substantial risk of adverse health effects. However, when these results are considered together, and taken across the entire family of these surfactants, there appears to be a consistent pattern of toxicity. A review of acute toxicity studies conducted over the past 40 years on various alkoxylated nonionic surfactants further substantiates a pattern of delayed deaths and visual evidence of lung injury. Based upon this review and the recent studies, we believe that not only do long chain alcohol ethoxylates and ethoxy/propoxy copolymer surfactants produce this pattern of toxicity, but that nonylphenol ethoxylates may also exhibit a similar pattern of toxicity. However, the relevance of these studies to human health is unknown. We will provide copies of full reports when all have been issued which describe in detail the toxic response (days to death), macroscopic and microscopic observation on the recent surfactant acute toxicity and primary irritancy studies. We are advising employees and customers who handle, use, or otherwise may be potentially exposed to these types of surfactants, of these results and of this report to the Environmental Protection Agency. In addition, studies are currently being conducted and further information is being sought to clarify this toxic response and better place it in perspective to potential human health risks. Please communicate through my office (203/794-5292) or contact Dr. W. C. Kuryla (203/794-5230) of my staff if there are any questions concerning this report. Very truly yours, REB/cg 0832Y CC: Dr. W. C. Kuryla 0832Y R. E. Bollinger Director, Occupational Health; Product Safety/Liability vVV oooo*4987