Document zoq4BLve2NJkNoBE3GqJQo3Dg

SOCIETY OF PLASTICS ENGINEERS, INC. Palisades Section * Vinyl Plastics Division New York. City October 31, 1974 VINYL CHLORIDE: THE TIP OF THE ICEBERG? Glenn E. Schweitzer Director, Office of Toxic Substances Environmental Protection Agency " 401 M Street, S.W. Washington, DC 20460 SPI-23642 VINYL CHLORIDE; THE TIP OF THE iC CHEMICALS, 1NDL5TTY AND THE ENVIRONMENT About. 20,000 eh_.mm2.i substances are corr.merciaiiv mo A.:-.; erf ami the L'rutoc! States, with aC0-700 new substances entering coir,me re e imm.: They find a wide vancy m. uses as industrial chemicals, in consumer p r and m specialized use.- s h. as drugs, food additives, and pcs:: .-Lies, mate thaisbjut ten pom LAS. industry is directly involved m mtroda; cnemical changes into us products. The problems rr mining from the presence in the environmont o: s chemical substances a: .- HI Loo well known. Others arc' bHm'.mi to Lucnl imultfi or cnvirocunental threat, while the effects associated ;wm w. the remaining chemicals, acting individually or synergmticuilv, .mo Hm comnlou ly unknown. However, it seems clear that the prHiloc . v.-i:h. tku presence of many cdomical substances in the efivinve: ".:.t wdl edly continue to grow in. number, severity, and complexity in toe veurs - boine of the hazards associated with chemical substances mm : recognized and are controlled by the Government, e.g. pcstie imcs -:.r . Other aspects of the problem have only recently been identified, and e ... regulatory measures do not yet exist. Still other pieces of me problem to be identified. Many gaps remain in understanding why, how, and wr.c stance can have a negative impact on health or the environment, and r control or prevent such hazards. Thus, our concern is two-fold: Identification and assessment of m associated with the manufacture, distribution, use, and disposal of er.e-m which could adversely affect health and environmental quality; and pracii steps, including regulatory actions as appropriate, to prevent or mitigat problems posed hy such chemicals. In addressing these concerns ve m. course, maintain an appreciation of the role of these chemicals in our ei and of the societal benefits that chemicals have brought to all of us. THE CASE OF VINYL CHLORIDE: BETTER LATE TILTN NEVER? The Emergence of the Problem In January U)74, the [3. F. Goodrich Company, the larges: U. S. p of idVC resin, notified the National Institute of Occupational SHety : m-.; I that four workers from its PVC polymerization plant in Louisville, K. e n . apparently had died from a rare cancer, angiosarcoma of ihe liver. SPI-23643 2 workers had been closely associated for many years with the production of PVC resins. The rarity of the tumor and the clustering of deaths at a single plant raised suspicions that an occupational disease related to vinvl chloride closure had been found. Since that time, at least 10 additional cases of this tumor, which developed in U.S. PVC polymerization workers since 1061. have been confirmed. This tumor has also been reported in a number of. workers at European polymcri '/.ation and monomer plants, one worker at a U.S. PVC fabrication plant, two workers at European fabrication plants, and two residents in the general popula tion near U.S. fabrication plants. Concurrently, toxicological data from animal studies became available which further strengthened the suspicion of vinyl chloride as the etiological agent in the formation of the liver cancer. A broad spectrum of cancers was reported by Professor Cesare Maltoni of Italy in different animal species at various exposure levels. His inhalation studies of rats exposed to 50 .ppm at repeated intervals approximating occupational exposures have produced angiosarcomas of the liver and abdomen as well as tumors of the kidney and skin. In mice exposed to vinyl chloride the same tumors have been observed, with the addition of lung tumors. Animal studies sponsored by U.S. industry have confirmed Maltoni' s observations at 50 ppm. Recent epidemiological studies also suggest the possibility of multiple cancers attributable to exposure to vinyl chloride. Meanwhile, statements by industry and Government officials indicated that the material loss to the environment during the PVC polymerization process may be about tiix percent, with more than 75. percent of the losses being vinyl chloride air emissions. Also, it soon came to light that vinyl chloride was being used a^; a propellant in aerosol sprays, and we were becoming more aware of railroad accidents involving vinyl chloride tank cars. This series of events finally stimulated a broad range of corrective actions by Government and industry -- actions that should have been taken many years ago. Given the long history of PVC production which in the past resulted in much higher levels of exposure to workers and to the general population than are encountered today -- together with the long latency period between exposure and the development of angiosarcoma -- we obviously are very concerned that many of the corxKeqiaiHpBMOf the somewhat reckless handling of vinyl chloride in the past will ejMfiMItaLbe uncovered for some years to come* TlbsWBfrnltnn Process ManV^^ywntay be particularly concerned with the possibility of a vinyl chloride hazard associated with PVC fabrication activities. Initially, the Government*s primary concern and investigative activities centered on thr; poly merizatipn process. Only very recently, v/ith the reports of angiosarcoma amo:t former fabricators, has attention been directed to the more than 8,000 fabrication plants. A first step obviously is reliable monitoring -- and t emphasize reliable -to determine existing levels. I regret to report that at present we do not have good SPI-23644 "> W'' ;.: I'm'.! . I r'i c_ ! i<)/1 XU 'he only w 1; \ o ,\>r r.) > `'.-'Si.' plains is .he uri re,. . i r J uienonK- iIkT may hr p it sc pi. si 'iu :!(' i m i l`" 1 " ` *!' ' i1' i '' 11' sj x 1 >' 11ip! i. , \ r. ij i r ` ,si -, ' - w c i i.t ms , e .,, > :i i11 :. ,,e 'u 'Op: '! i lax a. r v. inch c nulcl "C Mb t : n ' -"pc iHur,lv,M s ,, i' pconLe. ;; ,x - ; ( ,-r s- : - -. l. A' i u- >..: -v l .he -;i.: [nr .'cn-ns <h I he Hnvi nj:\, r rnhiJ f 1 r - < - c ; i m r i Ayr :k v . :' ' i ;p wi P } . h n< . i b ; >n < 1. ri;: c3 1 ;il<_<{ In ol Ik-1 eh cm u- cl y . h'o . > xx (m dr, - r '-lien ; s :-.)! r i '.'iti > lv < \ .,u h >lr i1 kI i< -x > i 11<.; whether any xuhe1on tj j 1 r; rp in i pi n .'i ' n . i >.i \. i.-<i I'lnin -pc ingestion r i ;ii riba i ion ni' I'VC parti i a Lbe. Al.'O, a hair nUiviuT of flicii1 :c.uls ;:rc used in J'YC products as antioxidants, n n'c sin f i c s , ; Aomints, fillers, plasticizers, and stabilizers, ami many cl them can roach men or. luau a variety of routes. The health effects of some of these chemicals are i 'jsonably well Amown; the effects of others have yet to be e?mlored. Several of ;'.o:n are particularly good candidates for more detailed investigations, c.g. 'udmium, barium. Disposal of Products Containing PVC Hvdrogen chloride is the major toxic material released when PVC is burner], bn -.he order of of, 000 tons of I5VC arc burned annually, releasing approx:rna:civ VhfiOO tons per year of I1C1 as air emissions. At the same time muon raws PCI prubuMy now omitted to ilic atmosphere from coal-burning power plums ' Vi : from municipal incinerators. However, there still could be a hazard in hie nr;:.- :.j ir vif inity of mi incinerator as a direct result of its PCI emissions. [;(.'! uni . Iso bo major- factor rehiLrd lo I'orrosicn during i-n iiw-rn! ion u. , : x.m u-nipc ru Ui i a.-s. h'pecificully, im:inc;-afors with heat exchangers wiJ.J. have corrosion problems on the lire side of 1 lie exchange equipment when the co;. < " r-a --a cases coni.act the outer metal surface. Also, about 95 percent of our iiixnexbrc have some type of air pollution control equipment that is exposed to the high chloride environment resulting-from refuse combustion. The cooling and precipitat ing water from the scrubbers that contacts the flue gas contains large quantities of chloride and is extremely corrosive to the structure. It is highly unlikely thai large quantities of vinyl chloride will be emitted during incineration oi PVC. There is no evidence that PVC will chemically re\ett to vinyl chloride. Some small amounts of entrapped mpnomer might conceivably survive incineration, but these quantities would be very low. Other air, water, or soil contaminants could-result during disposal of PVC products. The types of additives of particular concern are: antioxidants -- phenols, amines, phosphates, and sulfur compounds; antistatics -- amine derivatives, quai.cn nary ammonium salts, phosphate esters, polyethylene glyeolesters; colorants -salts or oxides of metals, aluminum, copper, and inorganic pigments; tillers -- SPI-23645 -4 # k.iF'.s, Iciiun i-u rl m;. !< t m i::; 11J i i < >; kb'*. i ailjtni, - | ] n l> >s<` I ill c r:j, :i sbo^to: ; plu^Lici/.crs -- phduiktles, orgunii: phosphates; stubi) izo i*s -- lead ol` acids barium, cadmium, calcium, zinc, alkyl tin compounds. KcrunijjrCMdatjony ot ii;c JZPA Task Jroree* I C- M Last month the EPA Vinyl Ciiloridc Task Force, which had been established in February, submitted its Report to the Administrator. This RcporFincluded t'-c results of our initial monitoring- program at ten PVC resin and two monomer plant preliminary analyses of the health effects of vinyl chloride, studies on the fate ?.u environmental effects of vinyl chloride, and investigations of industrial practices. Upon receipt of the Report, Mr. Tram announced that he had accepted the recom mendation for the Agency to establish an air pollution emission standard formononmr and PVC resin plants and concurrently to investigate further the need for a standard applicable to fabrication plants. The eighteen other recommendations for Agency action are currently in various stages of implementation. The process of setting an air emission standard under the Clean Air Act will involve several months of additional monitoring and other investigations, data collection, public hearings, and other regulatory steps as required by the Act. An environmental impact statement will be prepared, and public hearings held, to insure full public participation in the development of this standard. The current timetable is to promulgate the standard within about one year. Initial estimates indicate that using available control technology emissions could be reduced by about 75 percent from PVC resin plants and 90 percent from monomer plants, with a concomitant cumulative increase in the cost of PVC resin of about four percent. Also, it is estimated that the available control technology, which includes a variety of control measures applicable to the multiple emission points within the plants, could be in place from within several months to two years after promulgation of appropriate regulations. With regard to fabrication plants, monitoring of the vinyl chloride levels in the ambient air near five plants is planned as an early step to determining the need for an air emission standard* I do not pla%torlint the other recommendations set forth in the Task Force Report. Howevesfcrecent activities directed to carrying, out several of the recommendatlnnaunsjE b of interest. - Studies*am currently in progress to determine the amount of vinyl chloride migrating oufro# PVC products used in water distribution systems, such as PVC pipe or storage tank liners. In laboratory experiments, 3/4 inch PVC pipe simu lating household.installations is being used. Also, water samples from a reservoir that had recently installed a new PVC liner arc being analyzed. SPI-23646 An-.; lier urea of i m n .ed ;a tc conrcrn -o 1 - -y- ,.|V r,n vcv.ronrurntal RAe and effects oi' vinyl i'1^ n:.i . V.W below.' ^ major responsibility to carry out such research: howover, oi th . of this area EPA is conducting limited investigation* that will he In point th . - as to the most appropriate typos of studies. Our reseuren It Mmu; m ^Minnesota, has begun acute bioassay studies and wp.l soon miaam limited Am bioassay tests on selected aquatic species. Meanv.-hile, our lab^rrory in At.oe-. Georgia, '.ill expand its previous work on the aquatic fate of vinyl chloride v/u experiments on the uptake and degradation by microorganisms, chemical and photochemical transformation, and air-water exchange, i'inaliv, research, at w laboratory at Research Triar ede Park, North C irolina, ceibers on phoiochcm u degradation products of vinyl chloride. Another )'ocomniciu!a l r jc. called foe uhidms 11 !<! ' (I j. S' >0 : . d sd'-s ot waste products from PVC plants and >d municipal waste- to dc*t o '`mit if toxic substam arc leaching into the soil or ground waters. The first study . ill soon begin. Industry1 s Responsibility Reducing Dz s ch,a.rg e s o f Vinyl Chloride and Other Cor.ic: Che^ioa. . There is no doubt that industry has taken and can continue to take a vane of immediate steps at relatively little cost to reduce vinyl chloride discharges. During the past few months many plants have already started to tighten rmbm and operating procedures; oiher plants are installing improved pumps, seals, disconnect devices; while still other plants are introducing more significant or changes. One company is reportedly spending SZ million to tighten the process at a single PVC facility; another company reports that it has 100 engineer?, wo r to introduce modifications that will dramatically cut vinyl chloride losses at sr.plants. Mcdi'-al Surveillance Clearly, recent concerns have triggered extensive medical surveillance programs of workers throughout the industry; these programs should beemne routine to c over a far broader swath of chemicals and other chemical comple.xe Published analyses of the results of such programs would be very valuable to Government agencies. Fence line Monitoring for Chemical Discharges Traditionally* the chemical industry has conducted very little fenecime monitoring not required by federal, state, or local agencies to determine dm chemical discharges leaving plant property. Clearly, a plant manager should know the chemical mix of Ihe air emissions drifting over the plant fence into n; neighborhoods. Similarly, he should be fully aware of the chemical cross seeof his liquic and solid waste streams. Thus, a far more intensive physical mm tuning offer: on the part: of industry is needed. SPI-23647 - (l - 7'^.r.ii-o 1 l j\:f L Umil i crriitly, Ibo efforts of U. S. industry to clarity tin: chronic loxicily <>f vinyl chloride.: wore nearly j/ilylo, despite 1110 rommerc ial importance cm* this `chemical . The tuciies to dale have not been adequate. - in ten ns of ciiucci <`nn. scope, or quality, ncer*. the additional toxicological studies which have been pro posed calling for animal exposures down to 1 ppm may not be sufficient. Testing for Persistence and Environmental Effects A related area is industry's responsibility to clarify the environmental fate anil effects of the chemicals j.t manufactures, and in this case the behavior nf vinyl chloride in water and air1 (including degradation products) and the fate and effects of products containing PVC in soil and water. The research by EPA should help structure such tests, but the primary responsibility rests with industry. Testing for Levels of Unraacted Monomer Tn view of the likelihood that FDA will limit the levels ol unrcacted monomer allowed in PVC food packaging, industry has recently accelerated efforts to analyze the levels of vinyl chloride that are present in PVC resin used for food packaging and in the packaging itself. This procedure should be extended to other types of products as well. It is particularly important that the manufacturers of resin, who in general are well equipped to carry out the necessary sampling and analysis', advise their customers (i. e., the fabricators) of the quality of the r^sin in terms of unreacted monomer in addition to the usual quality criteria. The fabricators in turn have a responsibility to be aware of the levels of unrcacted monomer that persist in the products that eventually reach the marketplace. LESSONS LEARNED FROM THE VINYL CHLORIDE EXPERIENCE Many environmentalists arc convinced that the problems of vinyl chloride arc but the tin of a chemical iceberg - -an iceberg of problems that will continue to float to the surface during the decades ahead* It certainly appears that except for continuing concern over spills and acci dents, Govei-nmen* and industry have been rather complacent with regard to the potential cnvirq^BMiital threat from the high volfxrne industrial chemicals. This complucencysflHifclarge measure attributable to the relative absence of visible and uncontwdiadtdangers from exposure to the chemicals during their long hi.stories%'; &i.addition* since each of these chemicals is manufactured by a num ber of companiesv firms may lack incentive to invest individual company resources to clarify the safety aspects of their usage* Clearly* the experience with vinyl chloride -- the twenty-second leading chemical in terms of production -- under scores the problems that can result from such complacency. Despite the Spl-23648 be assumed that ucie be taken by industry essential. Tiie experience with vinyl chloride lias triggered a le? r ,v.: lee L\m.Ic:r*al Government directed to a broader range of cinanc ais of ; inter; st to the plastics industry. Let me touch or just thee;: of dies':' -- Interagency efforts in Washington to identify problem chcmical.j e . in the plastics industry have expanded considerably in recent merer. Beginning with a mooting at Pinehurst, North C molina, m Angus . there have been a number of interagency consultations end diserns; concerning various aspens of ;.he plastics industry. [ do not know what actions, if any, will result from this upsurge of interest. -- In accordance with one of the Tdsk Lorre recommendations, L L \ : currently reviewing governmental regulatory ancl research, activiwe directed to high volume industrial chemicals in general. A number of these chemicals are clearly of interest to the plastics industry. Again no specific actions are being contemplated at this time. -- The World Health Organization has recently entered the plasms w During a meeting earlier this month considerable attention was gwto the health and environmental aspects of plasticizers and :lnnw retardants used in plastics ancl in textiles. Also, as most of you know, the fate of the much needed Toxic Subs'.urv:Control Act, which has been delayed in the Congress for three years, wdi bo decided during the next few weeks. This legislation can provide tlie basis :oi more tv incerted efforts bv Government and industry to assess the problems <"> toxic chemicals and to take corrective sicps, when needed. The aim is r> kb these slops early in the life of a chemical, thus minimizing health and enviro mental risks, and also reducing the attendant economic dislocations. LOOKING AHEAD In the decades ahead, more chemicals will be in commerce, the or p of many chemicals will be better understood, and consequently the lis. of eke cals considered to be hazardous to man ar.d the environment will uncouth"'ty much longer. Also, improved research and analytical capabilities will ir.ow the effects of these chemicals -- acting individually and synergistic-ally much farther reaching than currently suspected effects. SPI-23649 a 'nw ' -.-n' S the omission STac'.s md ^Pinout pmm v. ill hr l-.r-^iv p'<-:-i-d, : .ills sensible land disposal of hn ~a rdcui s w.-rlrs will i>,' i-.-.uimi. ."M llw 0 i mo, iio'.vi'Vc'.T, more people wjLl 'or exposed 1i> uvur t T iro ;,ls in nine h U n.rms -- ev.visure from conl.aminanis, m>n-point mum.'-. ibiv; prodm-l << n, and gencrnl'y unal! ei ' u.i table buildup of vhc-micals m il:r c. >v i -nmc nl. I am dv-nt that mcieiy can develop the tierossarv prveaui 10;m; y measures mat v/id c rpiosure to chemicals when necessary, but not unnecessarily curtail commc;a cavities. There is. of course, a danger that society will not act responsibly in yniicic;r etui remedying toxic chemical problems through its governmental and other d.iiiions, with the inevitable outcome of endless legal confrontations. The entire _ np coach to toxic substances could become bogged down in the courts -- which would lie'"1 tr-agedy for us all. The iceberg is emerging. Wirli increasing frequency we are being awakened to the latent health hazard ;'ro: n chemicals that have not been adequately tested or analyzed. We arc becomin- :nore and more concerned not only with the problems of today but with those dm will only be recognized tomorrow. Preventive actions are the key; corrective ar'i -'its can only be inadequate and disruptive. We have met the future, and it is now. SPI-23650 * PLASTIC BOTTLE DIVISION Arthur R. McCsmey, Chairman The Division cancelled its promotional program to present its side of the ecology question to consumers. In its place the Division members have wholeheartedly endorsed the objectives of the Public Affairs Council and have pledged to financially support the Council. The Market Development Comaittee continues in its program to monitor all potential problem areas which may hinder the growth of plastic bottles. The Technical Comnlttee has finished its review of the final report from the Institute of Paper Chemistry and has prepared a "layman's" summary of the Institute report. It is anticipated that the report will be published In the next couple of months. The Technical Coamltcee has established a close liaison with the Glass Container Manufacturers Institute to develop eeceptable safety closures which will be compatible with both plaatic and glass containers. The Division members have assisted Mr. Jerome H. Heckman. S.P.I. general counsel. In preparing comments for the Alcohol. Firearms and Tobacco Division of the IRS' environmental impact statement on the approval of PVC liquor bottlea. The Division members are working closely with Mr. Heckman and tha IRS to be of assistance wherever and whenever possible in this important area. The Traffic and Transportation Committee, with the assistance of Martin Bercovici from the staff of Keller and Heckaoan, was success ful in having withdrawn proposals filed in the Central and Southern Motor Freight Territories Association which would have substantially increased the traffic rates for PVC liquor bottles placing them at a substantial disadvantage to glass bottles. The Promotion Comslttee is tentatively planning a seminar on plastic bottles for the Fall of 1972. A final decision whether or not the seminar will be held will be mada at tha next Executive Comaittee meeting in mid-March* The Executive Coimittee, aware of S.P.I.'s tight financial condition, ia of thm opinion that tha S.P.l. regional officea ere not financially self-sustaining* A motion vae made at tha Septe^ar meeting of tha Executives Cosmittee that tha Division1 a chairman recc^mend to tha S.P.l* Board of Directors that tha Plaatic Bottle Division aembtrs no longer wish to support tha regional offices* This motion was reconsldsred and approved at tha Division's Semi-Annual meeting in' January. Thomas J. McGrath January 25, 1972 SPI-23651