Document xz9Vdgx8kORQrnr12x7bz6zvb

Chemical Manufacturers Association November 12,1996 Ms. Cynthia Oshita Office of Environmental Health Hazard Assessment California Environmental Protection Agency (CalEPA) P.O. Box 942732 Sacramento, CA 94234-7320 Re: Developmental and Reproductive Toxicant Identification Committee's Review of Vinyl Chloride: Developmental and Reproductive Toxicity Data Summary Dear Ms. Oshita: The Chemical Manufacturers Association (CMA) Vinyl Chloride Panel submits these comments for consideration by the Science Advisory Board's Developmental and Reproductive Toxicant (DART) Identification Committee at its December 4,1996 meeting. The Panel consists of the following U.S. manufacturers of vinyl chloride: Borden Chemicals and Plastics, Inc.; CONDEA Vista Company; The Dow Chemical Company; Formosa Plastics; The GEON Company; Georgia Gulf Corporation; Occidental Chemical Corp.; PPG Industries, Inc.; and Westlake Polymers. The Panel appreciates this opportunity to participate in the review of the draft document titled Vinyl Chloride: Developmental / Reproductive Toxicity Data Summary. After careful review of the draft Data Summary and available toxicological literature on vinyl chloride, the Panel believes that the available evidence suggests that vinyl chloride is unlikely to be a developmental or reproductive toxicant. However, the Panel is sponsoring an combined two-generation reproductive and developmental toxicity study of vinyl chloride in CD rats which is expected to provide important data needed to evaluate these endpoints. This study is being conducted under a Memorandum of Understanding between the Panel and the Agency for Toxic Substances and Disease Registry (ATSDR) to meet the research needs of ATSDR and the U.S. Environmental Protection Agency. The study protocol is enclosed for examination by the DART Identification Committee. The Panel recommends that the DART Identification Committee extend its review period for the Draft Summary until the combined reproduction and developmental toxicity study has concluded. At that time, the Panel would be pleased to make available to CalEPA the results of the research. CMA 114005 1300 Wilson Boulevard, Arlington, VA 22209 $Telephone 703-741-5000 Fax 703-741-6000 Responsible Care' A Public Commitment Langley A. Spurlock, Ph.D,, CAE November 12,1996 Page 2 The CMA Vinyl Chloride Panel hopes that this information will be of assistance to the DART Identification Committee. If you have any questions, please call Dr. Robert A. Venezia of my staff at (703) 741-5639. Sincerely, Enclosure Langley A. Spurlock, Ph.D,, CAE Vice President, CHEMSTAR CMA 114006