1959-1973
No U.S. vinyl manufacturer placed any warning label indicating a chronic human health hazard on vinyl chloride monomer (VCM), polyvinyl chloride (PVC) resins or products. Throughout this time the CMA’s Safety Data Sheets (SD-56) contained the false assertion that vinyl chloride could be readily handled without stringent occupational safeguards for VCM or PVC workers in handling it, aside from fire and explosion, and unequivocally/uncritically recommended the 500 parts per million (ppm) Threshold Limit Value (TLV) established by ACGIH in 1962.
5/12/59 AND 11/24/59
Dow, BFG, and Carbide [2] recognized and admitted the inadequacy of the existing ACGIH TLV of 500 ppm, yet suppressed this information.
5/12/59
Dow, BFG, and Carbide openly discussed their mutual belief that exposures at levels permitted by existing standards would cause appreciable injury to VCM/PVC workers. [3]
5/27/59
UCC and Pantasote [4] were aware of toxicity problems in workers that had led to personal injury lawsuits and discussed conducting toxicological studies to “get them thrown out of court.
11/24/59
BFG Dow, and Carbide [5] exchanged off the record communications concerning unpublished toxicologic data from Dow, indicating liver pathology at every exposure level tested down to, and including, 100 ppm (1/5 the TLV for American workers). The UCC and Dow representatives admitted that VCM was more toxic than was generally known, but agreed to conceal the Dow toxicologic data reflecting this.
1959 – 1973
The MCA-coordinated vinyl manufacturers [6] distributed the MCA SD-56 to their customers, the government, and to the general public even though they knew it misrepresented the nature and extent of the hazards posed by exposure to vinyl chloride and of work in the American vinyl industry.
1959-1974
Neither BFG, UCC, Dow, nor any other American vinyl manufacturer ever conducted any follow-up studies to see how far below 100 ppm pathologic effects continued to occur.
10/5/60
Representatives of Monsanto (Dr. Emmet Kelly), Dow (General Hull), DuPont (Dr. A. Flemming), and UCC (Dr. Carl Dernehl) met with MCA Medical Advisory Committee (MAC) and Union Carbide discussed the need of the manufacturers [7] to defocus public concern from issues relating to chemical toxicity. [8]
This plan included the agreement to refrain from releasing any information on toxic effects of chemicals, even information that the companies thought might diminish the public’s concern over chemical hazards; the less said about toxic hazards from chemicals (whether positive or negative), the better off they would all be. Instead, the plan was to emphasize the benefits of chemicals to mankind and to work-up, what they openly referred to, as “feed the world propaganda.”
Recognizing that there was a public health problem that was not being addressed by the government, the MAC discussed their mutual need in slowing down any government interference with the rapidly growing chemical industry, and to insist that industry should regulate itself without government controls.
It was admitted that the lack of empirical evidence of harm was no proof that harm from chemical exposures was, in fact, not occurring. The rationalization that protecting workers would involve pumping the pollutants out into the atmosphere was offered. It was agreed that MCA [9] should liaison with the Public Health Service (PHS) and seek the representation of industry on any government committees dealing with the problem in the future.
If the MCA-coordinated companies were ever required to admit a public health problem existed from chemical hazards, the industry should work for a go-slow policy by the government.
1961-1973
Dow, and every other American vinyl manufacturer, failed to recommend to any interested party (including persons receiving their chemical Safety Data Sheets [SD-56] for VCM) any maximum exposure level for vinyl chloride other than the ACGIH TLV of 500 ppm, or even to Dow’s 1961 publication of its study.
1961
Dow (Torkelson, et al) published an article in the open scientific literature that suggested a maximum exposure limit identical to the same level reported to cause liver disease in animals, and an eight-hour time-weighted average (TWA) exposure limit of 50 ppm.
5/2/61
The MAC (of the MCA) recommended that ACGIH TLVs (including even the 500 ppm TLV for vinyl chloride) not be accepted by the government as “legislated maxima,” but only to be used as a guideline.
1962
The ACGIH TLV Committee lowered the TLV for vinyl chloride to 50 ppm, but, as a result of undue industry influence, never published this revision.
1962-PRESENT
Even in documents that purport to give the complete history of TLVs, proposed and established, by the ACGIH, all ACGIH publications and every public presentation made by any U.S. vinyl manufacturer failed to reflect, or refer to: The 1962 ACGIH TLV revision to 50 ppm, the proposed revision of the ACGIH TLV to 50 ppm in 1966, and the proposed revision of the ACGIH TLV to 50 ppm in 1970.
1963
Allied Chemical and Solvay et Cie (a large European vinyl manufacturer) published a study (authored by Lester & Greenburg) that had long been completed and left unpublished since the time it was conducted in the 1950s.
Although the Allied/Solvay study was begun and completed years before the 1961 Dow study and was a substantially different type of toxicologic study than Dow’s, the Allied/Solvay study was rushed to publication to serve as a pretext for the American vinyl industry (including, on information and belief, Dow) to discredit the findings of the Dow study that implicated a significant toxicologic effect from exposure to vinyl chloride at 100 ppm (1/5th the existing TLV).
3/18-19/64
As a result of the recent admission of truly independent public health professionals to the ACGIH TLV Committee, the MCA Safety and Fire Protection Committee (SFPC) expressed concern that the chemical industry was losing some of the enormous influence over the TLV setting process that it had previously enjoyed.
Because lower TLVs might result in increased safety expenses, the SFPC agreed to contact all MCA member companies to advise them of this potentially costly development.
The SFPC also advised the member companies how they could obtain more control over the TLV setting process, including, even possibly, eliminating ACGIH from the process altogether and placing responsibility for developing TLVs with some other group, such as the American National Standards Association (ANSI), which, unlike the ACGIH, would allow the MCA-coordinated companies more direct participation in, and influence on, the TLV setting process.
11/12/64
BFG, through Rex H. Wilson, M.D., O.F. Beckmeyer, Anton Vittone, and W.W. Baughman, instructed doctors, conducting routine examinations of BFG PVC workers, to examine them for evidence of occupational disease without letting them know about it.
BFG required that the examinations be conducted as quietly as possible and incidental to their employees’ routine examinations without, at any time, disclosing the nature of, what BFG described as, a potentially disabling disease to their employees, to the family doctors of the employees, or even notifying the state Worker’s Compensation Board, and certainly not unaffected employees or their unions, etc.
Even at this early date, BFG was specifically aware that the disease was potentially disabling, that the disability was likely to be misdiagnosed by doctors with no knowledge of the disease, that symptoms were not at all limited to degeneration of the terminal phalanges of the fingers, but also included systemic-type effects with symptoms resembling Reynaud’s phenomena, or even scleroderma.
1965 – PRESENT
At some time between 1965 and the present, BFG [10] spoliated evidence reflecting toxicologic studies it sponsored at the Kettering Laboratories and the Brooklyn Polytechnic Institute that revealed BFG’s knowledge that VCM was the cause of the so-called “occupational acroosteolysis.”
2/2/65 – 7/7/65
On BFG’s behalf, Doctor Kehoe, of the Kettering Laboratories, notified representatives of other American vinyl producers (including Dr. Kelly at Monsanto) of the existence of, what was recognized as, a new occupational disease in the PVC industry. The companies who were notified agreed to keep the information secret.
7/7/65
On BFG’s behalf, Dr. Kehoe informed the American companies (including Monsanto’s Dr. Kelly) that the occupational origins of the disease in PVC workers had been confirmed to be related to vinyl chloride exposure, for all practical purposes, and that an article on the subject was expected to be published by a European author in the near future.
The disease and the forthcoming article were recognized as posing a serious problem for the whole vinyl industry.
Dr. Kehoe’s message contained no mention of reactor cleaning because BFG had not yet fabricated its kettle-cleaning cover-story in order to conceal the threat the disease potentially posed to PVC workers, in general, and, by implication, to the general public, who were protected by the strictly enforced Food and Drug Act, prohibiting the chemical adulteration of food products.
7/9/65
Monsanto (Dr. Kelly) wrote all its American company doctors suggesting they quietly review employee records for evidence of the disease. On this same day, Dr. Kelly misled Dr. Kehoe by suggesting that Monsanto had not found evidence of the disease in its employees, when, in fact, the company had not even begun to look for it.
9/16/65
Kettering Laboratories translated an article from French to English, which had previously been translated by Solvay (Dr. Lefevre) from Rumanian to French. The article described a decisive connection between exposure to vinyl chloride and the development of a wide variety of systemic-type problems in PVC workers (including nervous disorders and liver disease).
10/13/65
BFG (W.E. McCormick, Manager of Industrial Hygiene and Toxicology) distributed the article referenced above (9/16/65) to American vinyl manufacturers, including Monsanto (Dr. Kelly), with instructions that the paper and its conclusions be held in strictest confidence.
1/7/66
Monsanto (Dr. Kelly, and Dr. Nessel) met with BFG in order to discuss, what was candidly referred to as, the problems BFG had discovered among workers exposed to vinyl chloride (and not, as industry would repeatedly suggest, impurities, trauma etc.).
The main revelation made by BFG to Monsanto was that BFG’s characterization of its so-called “hand problem” was understood as having nothing to do with kettle-cleaning per se. (This was a cover- story BFG had developed to conceal the true cause of the disease, which was the vinyl industry’s primary commodity chemical and raw ingredient, - a cause that, if publicly recognized, might have enormous financial vinyl chloride consequences for industry, including the potential applicability of the Food and Drug Act’s prohibition of chemical adulterants in food).
Since BFG had already begun to disseminate its “kettle-cleaning cover- story,” according to which the cause of the disease was unknown, but thought to be specifically related to the hand-cleaning of PVC reactor vessels (or “kettles”), and since Monsanto did not employ manual kettle-cleaning methods in its operations, Monsanto hoped to license its kettle-cleaning know-how that did not call for the use of supposedly suspect hand-cleaning of reactor vessels to BFG.
BFG was not interested in any alternative to manual cleaning because it was already well satisfied that, its cover-story notwithstanding, the problem did not lie in reactor cleaning per se.
Monsanto’s representatives at the meeting repeatedly emphasized the fact that the disease had been detected in employees who had never been involved with kettle-cleaning in its communications with Monsanto’s management, and that this was the likely explanation for the lack of action they had been getting from BFG on Monsanto’s kettle-cleaning license.
In attendance for BFG were Rex Wilson, BFG’s Medical Director, Mr. William McCormick, BFG’s Manager of Industrial Hygiene and Toxicology, and Mr. M. Miller, BFG’s Vice-President of Personnel.
BFG emphasized to Monsanto the importance of the disease having been found in workers who had never been involved in kettle-cleaning (workers like chemists, gate guards, etc.). Although BFG revealed an early version of its cover-story to Monsanto (i.e., that BFG just had no clue as to the cause and that no one knew whether VCM was indicted, speculating about plasticizers, etc.), clearly large American vinyl companies like Monsanto were not the intended audience for this cover-story.
BFG admitted that it had recently disclosed the situation (including the appearance of the disease in workers who never set foot inside a reactor vessel) to Union Carbide.
BFG also admitted to Monsanto that, notwithstanding BFG’s forthcoming misrepresentation that the disease was limited to BFG’s Louisville facility, many more cases had been found at four other BFG vinyl facilities (including Avon Lake, Henry, Welland, and Niagara Falls).
As a result of this meeting, Monsanto decided to perform x-rays on some of its workers at Springfield-Indian Orchard, MA, but not all of them – only the workers currently employed in the PVC polymerization room where the kettles were located (in conformity with the kettle-cleaning cover-story that would eventually be adopted throughout the American vinyl industry). Also, following BFG’s lead, even this deliberately limited x-ray program was to be conducted under utterly false pretenses and without the knowledge of the employees involved.
Dr. Nessel was specifically instructed to prepare and provide the physicians conducting the vinyl employee examinations with an adequate story so that no employee or public relations problem would exist and the existence and nature of the disease would remain secret, as per Monsanto’s specific agreement with BFG.
BFG openly admitted to Monsanto, as it had previously admitted to Union Carbide, that BFG’s management was so concerned about concealing the true cause of the disease, that BFG’s Dr. Wilson had been dispatched to Brussels, Belgium for the specific purpose of suppressing and stopping the imminent publication of an article by a Solvay doctor (Dr. Marcel Lefevre), who was reported to have detected the disease in European workers that had exhibited the same bone destruction that had occurred in the BFG cases that the American companies were actively engaged in concealing.
1/12/66
One day prior to the January 7, 1966 meeting between BFG and Monsanto, J.V. Waggoner (Monsanto) had informed at least five members of Monsanto’s upper-level management (Proctor Avon, F.E. Reese, L.W. Sessions, B.L. Williams, C.L. Knowles, and J.M. Chamberlain) of the same information Monsanto’s medical personnel would receive the next day in Akron, OH, as referenced above. Mr. Waggoner had obtained this information from Mr. Harry Warner, Corporate Vice-President of BFG and former President of BFG Chemical in the course of a conversation in a Cleveland, OH airport the previous December.
The most serious disclosure Mr. Harry Warner made to Mr. Waggoner was his admission of BFG’s extreme concern over the implications of the disease having been detected in employees that did not conform with the industry’s developing cover-story, i.e., workers who had never cleaned reactor vessels, who were never subjected to the “impurities” or “catalysts” present inside those vessels, and had certainly never been subjected to the so-called “trauma” of manually cleaning those vessels, etc., but who had, instead, merely worked in the area. In fact, Mr. Warner stated that this “phenomena” was first noticed years previously when he was only a BFG plant manager.
Mr. Warner also admitted that, at least as early as 1965, BFG had begun its efforts to contact the Solvay doctor (Lefevre) whose article it wanted to prevent being published in it’s original form, or at least change the author’s original conclusions so as to make sure that it did not implicate the entire PVC manufacturing process. BFG feared that unless it was able to discourage, influence, or edit the article, BFG’s cover-story would be undermined even before BFG had a chance to use it.
The Solvay doctor had previously stated, categorically, that the damage the doctor observed upon his examination of x-rays, in and of itself, demonstrated its cause: The damage was nothing more than the result of the afflicted workers having worked around PVC, and without any specific reference to kettle-cleaning, trauma, etc. (Such a finding, if publicly reported, would not be in the interest of BFG, Monsanto, or any other American company who – in contrast to the Europeans – were subject to the U.S. Food and Drug Act., including its o-called “Delaney Clause.”)
For this reason, Monsanto, through J.V. Waggoner, assured Mr. Warner that with Monsanto’s Europe headquarters being in Brussels, Belgium, Monsanto would be happy to cooperate with BFG in its attempts to suppress, or modify, the forthcoming publication in the manner BFG planned.
Following his meeting with BFG, Waggoner made it absolutely clear to Monsanto’s management that the disease had been found in employees who had never been involved with kettle-cleaning, and this was surely the explanation for BFG’s obvious lack of interest in actually adopting methods of reactor cleaning (like Monsanto’s) that did not require workers to enter the PVC reactor vessels at all.
Monsanto correctly appreciated that, even though manual cleaning of reactor vessels was the very type of work BFG claimed, at least publicly, was involved in the causation of the disease, in truth, BFG was not particularly interested (sincerely) in evaluating such methods for no better reason than this: BFG knew its public statements to the effect that some unknown something involved in the manual cleaning of reactor vessels (of course not VCM, specifically) was were untrue, misleading, part of a cover-story, and intended purely for public consumption.
It is not yet clear whether the Monsanto group that met with BFG’s Dr. Wilson, etc., in Akron, OH, had already been informed of the fact that Monsanto’s upper-level management had already determined that, at least by the previous month, Monsanto had already agreed to assist BFG in covering up the cause of the disease that both companies were already secretly studying.
However, by January 12, 1966, Monsanto’s Dr. Nessel was informed that Monsanto had agreed to cooperate with BFG in suppressing the anticipated publication of the article by the Solvay doctor (Lefevre) to discourage the author’s conclusions, edit them, or otherwise make sure that the Solvay publication would not implicate the PVC industry as a whole as at risk for the disease, and that Monsanto would be traveling in “like company” with BFG.
Waggoner instructed Monsanto’s management and medical personnel to determine whether an employee x-ray program could be conducted without notifying employees, or otherwise disclosing the existence and nature of the health problem it was determined to conceal.
3/30/66
Apparently, public concern over environmental pollution had reached the point where the MCA Medical Advisory Committee’s (MAC’s) recommendations to say nothing about environmental pollution, whether positive or negative, had become obsolete, and MCA Environmental Health Advisory Committee (EHAC) suggested MCA-coordinated companies publish case histories of pollution abatement, etc.’
(However, as the MAC already seemed well aware, the public’s primary concern was primarily with their own well-being and less with that of industrial workers – except in so far as occupational risks might imply a potential risk to themselves; i.e., the MAC appreciated that the general public considered the welfare of American industrial workers, including Vinyl Workers, most seriously as a sort of “canary in the coal mine” and were likely to receive scant public attention from the public, and that what was important was to assuage public concerns about the environmental pollution, rather than occupational health.)
EHAC coordinated the activities and policies of various other MCA committees concerned with matters relating to environmental or occupational health and safety. At some time prior to March 30, 1966, EHAC submitted recommendations to the MCA Board of Directors that, in the future, MCA should be more concerned with the effects of chemicals on the outside world (i.e., pollution) and less concerned with matters relating to occupational health and safety.
4/6/66 – 1967
At some point in 1966, the ACGIH TLV Committee again considered lowering the TLV for vinyl chloride to 50 ppm. UCC, through Dr. Carl U. Dernehl and Ken Lane, as well as C.P. Carpenter from the Mellon Institute, worked to counteract the proposed revision, although they admitted that they were not equipped with any specific data to support their position. The proposed revision was also known by BFG (W.E. McCormick, Anton Vittone, P.H. Lawrence, and W.W. Baughman) who was concerned that the ACGIH proposal might be adopted by the states as law, noting that this limit already governed BFG’s activities in Ontario, Canada.
Unlike 1962, when even the limited evidence that has not been destroyed indicates the TLV was lowered to 50 ppm, or 1970, when the final decision was to lower the TLV to 200 ppm, whether or not the proposed 50 ppm standard was adopted in 1966, is as yet unknown.
4/6/66 – PRESENT
Like the 1962 and 1970 action of the ACGIH TLV Committee, with regard to vinyl chloride, the fact that vinyl chloride was even included in the ACGIH’s list of proposed changes has been almost totally concealed or destroyed as a result of cover up activities undertaken by the MCA-coordinated vinyl manufacturers, with the knowing collaboration of the Chairman of the ACGIH TLV Committee, Dr. H. Stokinger.
Since 1966, and specifically including, vinyl manufacturer but not limited to, presentations made by Dr. Carl Dernehl, William McCormick, and Anton Vittone, in the course of the 1974 OSHA hearings on the vinyl chloride standard, there has never been any public disclosure that the ACGIH TLV Committee even considered lowering the TLV in 1966 (or 1962, or 1970, or, for that matter, at any time prior to 1972).
Even though ACGIH maintains and publishes what is held out as a complete history of its TLVs, supposedly including all proposed changes, and of course all final changes, there has never been any public reference to the 1966 proposed change in the ACGIH TLV for vinyl chloride.
4/7/66
BFG invited representatives of the largest vinyl companies (from Europe: Solvay, ICI, and British Geon; America: UCC, and Monsanto) in the world to a confidential meeting to take place on June 6-7, 1966 in Cleveland, OH.
All of these companies had become aware of the existence of the problem, as well as the industry’s planned course of action to cover it up and divert public attention from its true cause.
6/6-7/66
BFG presented its most recent findings at this MCA-coordinated meeting in Cincinnati, OH, and agreed to act as a central clearing-house for the submission of medical data gathered within the industry.
BFG warned the companies [11] that BFG would eventually need to present BFG’s “hand problem” to the American PVC manufacturers at-large [12], probably under the auspices of MCA. It was emphasized, both at the meeting and subsequently, clearing house notwithstanding, that BFG would not reveal the fact that the disease had been detected among workers employed by any of these large domestic and foreign vinyl companies, and that only BFG’s findings would ever be presented, even at this confidential MCA-coordinated meeting.
JULY 1966 – EARLY 1967
The MCA-coordinated vinyl manufacturers [13] deliberately created overly strict diagnostic criteria based upon misleading distinctions between various manifestations of systemic vinyl chloride disease. The 6-tiered diagnostic criteria was designed and used by the MCA-coordinated vinyl manufacturers involved in the MCA epidemiologic studies specifically in order to limit, to the greatest extent possible, the number of positive cases that would be classified as having the disease, and also in order to divert attention from the systemic nature of the disease.
This was accomplished by defining the disease in terms of its least common (< 2%) manifestation, Acroosteolysis, and to the exclusion of far more common manifestations of the disease such as Reynaud’s Disease, scleroderma, decreases in esophageal motility, liver disease, x-ray changes in bones other than in the hands, and the diminution in the number and size of blood vessels. In the future, the MCA-coordinated vinyl manufacturers would fraudulently use the term “Acroosteolysis” or even “Occupation Acroosteolysis” without qualification.
9/13/66
The MCA Board of Directors Executive Committee [14] agreed that the OHC and BFG would meet with American vinyl companies for the purpose of disclosing BFG’s findings, and suggested a three-part MCA-coordinated research program to consist of: (1) in-plant medical studies, (2) toxicologic research, and (3) a public symposium where the findings of the MCA studies would be publicly presented.
9/19/66
Although only BFG’s findings would be presented “on the record” at the meeting (with only these findings referenced in the official minutes, etc.), in the course of inviting the American companies to the October 6, 1966 meeting (and. apparently. in order to assure that the companies appreciated the gravity and potential industry-wide implications of the findings to be presented), the MCA advised each of the companies involved, [15]that, in effect, the October 6, 1966 meeting was going to be conducted under a completely false pretext in order to conceal the true nature and extent of the problem.
Although the official record of the meeting gives no indication whatsoever that the disease to be discussed had been detected anywhere else in the world, except at BFG, prior to the meeting the American producers that had been invited to the meeting were advised that at least seven companies, both in the U.S. and abroad, had found similar disease in their own workers.
The invited companies were advised to conduct their own studies in advance of the meeting, if possible, and, like the larger companies attending the June 6, 1966 meeting, were reassured that these findings would not be referenced in any official meeting minutes, etc., and would be held in the strictest of confidence by all attending companies.
Companies were also advised, in advance of the meeting, to confine their observations and reports to the experiences within their own company, thereby assuring that only findings of companies that desired them to be presented (even under assurances of strictest confidence) would be disclosed at the meeting.
The purpose of for the MCA-coordinated vinyl manufacturers’ keeping all references to the widespread (in fact, truly, “industry-wide”) distribution of the disease “off the record” was to avoid any chance that the true extent of the problem would ever become public. (For example, although Monsanto had found evidence of the disease in its workers, because Monsanto did not employ the manual reactor cleaning methods central to the kettle-cleaning cover-story no report of Monsanto’s findings would be presented at this meeting at all.
10/6/66 – 1973
No MCA-coordinated vinyl manufacturer identified vinyl chloride as a potential toxic hazard in any of their product literature, warning labels, or in any other public forum.
No MCA-coordinated vinyl manufacturers took any substantial remedial measures to prevent of lower worker exposure to vinyl chloride.
10/6/66
Forty representatives from over twenty companies met in Cleveland, OH under the auspices of the MCA OHC. The OHC [16], and then the potential sponsors [17] of the studies, adopted the Executive Committee recommendations of September 13, 1966 for a three-part program consisting of in-plant medical studies, toxicologic studies, and a public seminar, all to be completed by the Summer of 1967.
The companies were advised at the meeting that, prior to the meeting, only three U.S. companies had full knowledge of the secret health conditions discussed at the meeting, but that it was anticipated that the information would lose some of its secrecy because of the anticipated forthcoming publication of an article by BFG on the subject.
However, the misleading BFG publication, for reasons that will be shown, did not excite the public interest, as the sponsors apparently anticipated it would. As a result, the due date for the study (Summer of 1967) was allowed to pass, and pass again, and pass again for a total of at least eight different times before the MCA Group finally allowed a heavily sanitized version of the previously suppressed “final report” to be published.
As a result, the MCA Group was able to conduct and modify both its study and its report over the course of the next four years without any public attention whatsoever.
The PVC producers also voted to conduct the three-part program proposed by the OHC and the Executive Committee. The toxicology program was to be conducted concurrently with the in-plant study program, and the symposium was to occur in 1967, by which time both the in-plant studies and the toxicology program would be completed and ready for presentation to the public.
True to their word, the MCA minutes of the October 6 and 7, 1966 meeting contained no reference to any of the reported findings discussed at the meeting, except those of BFG. Similarly, the OHC recommendation to the MCA Executive Committee referred only to evidence made available by “a member company indicating a possible health problem associated with a step in the manufacture of polyvinyl chloride resins.”
In fact, the sponsors were specifically advised that, in addition to the seven cases referred to in the invitation, the disease had been confirmed even among workers employed by some of the companies in attendance.
Further, the companies were advised that the supposition was that vinyl chloride was responsible for the disease and there existed only a possibility that vinyl acetate might be involved.
There appears to have been no reference to “impurities or trauma” as having anything important to do with the disease. Additionally, the companies in attendance were told that the disease was not limited to reactor cleaners, but had been found in workers whose jobs were not related to actual manufacturing operations at most, if not all, of the plants where the disease had found (as gate guards, lab men, etc.). Finally, the disease had been detected at almost every plant that had taken the time to look for it; this was an industry-wide problem and all of the companies learned of it at this meeting, if they did not already know it before.
The kettle-cleaning cover-story that BFG, Monsanto, and UCC had been developing for several years was shared with all companies in attendance and, as will be shown, adopted by them. The extreme significance of promulgating it to the public was emphasized, with special emphasis placed on the potential cost to industry if that story did not cover-up the potential extremely serious implications the disease had under the U.S. Food and Drug Act.
As a result, all companies in attendance recognized the need for “bracketing the problem,” even if it meant conducting a fraudulent and misleading study, as set forth with more particularity below.
In conformity with this cover-story, Monsanto, who had been actively engaged in covering-up the disease since at least 1965, was reported to have found no cases in its plants, which, as previously stated, did not employ manual methods to clean its reactor vessels. This was false, however, as at least BFG and UCC very well knew.
All of the companies in attendance agreed to with BFG that it was in their mutual interest to keep the problem from becoming known to the public. The companies agreed that any new findings should be communicated to the OHC, or Dr. Wilson of BFG, since BFG had agreed to read x-rays for any of the companies in attendance.
The companies were specifically warned that the failure, on the part of any one of them, to keep the disease, and the studies they were conducting, a secret could result in exposes like the recently published Silent Spring, by Rachel Carson, and Unsafe At Any Speed, by Ralph Nader.
The companies were specifically advised that knowledgeable experts were extremely concerned that the disease was not, in any way, localized and limited to the hands, but gave every appearance of being a systemic disease with injury occurring in multiple organ systems.
It was specifically discussed at the meeting that whatever the workers were told about the MCA-sponsored study would be left entirely up to the companies involved. Additionally, who would, and who would not, be identified to be included in the study was left entirely to the employers.
As a result, companies like AIRCO were free to do even such outrageous things as x-ray everyone in their plants – including hundreds of workers who did not work in any aspect of PVC or VCM production – for no better reason than to keep from drawing any special attention to their vinyl workers (in the case of AIRCO, more workers from parts of the plant that manufactured ammonia, etc., and had absolutely nothing to do with vinyl chloride) were included than vinyl workers. This would, of course, tend to bias the study, but, then, the study was not being conducted in good faith anyway, as will be shown.
10/6/66 – PRESENT
Monsanto and the other MCA-coordinated companies suppressed evidence that acroosteolysis had been found in PVC plants, like Monsanto’s, that did not employ manual cleaning methods.
NOVEMBER 1966- MARCH 1967
Between November 1966 and March 1967 the MCA-coordinated vinyl manufacturers maintained representatives on the OHC and Plastics Committees who were overseeing the conduct of the MCA Vinyl Chloride or “Occupational Acroosteolysis” Program. [18]
11/1/66
BFG wrote UCC, ICI, Monsanto, Solvay, and the Distillers Company (the companies that had attended the June 6, 1966 meeting with BFG in Cleveland, OH), reassuring them that, as promised, no identification of any company, besides BFG, having the problem was disclosed.
At some time after November 1, 1966, BFG commissioned toxicologic studies at the Brooklyn Polytechnic Institute in an attempt to ascertain the precise mechanism whereby vinyl chloride caused the degeneration of bone in the extremities.
Since the very premise for Brooklyn Polytechnic Institute study (that vinyl chloride causes the degeneration of bone in the extremities) was completely inconsistent with BFG’s protestations that it did not know what was causing the disease, of course, in years to come, BFG would consistently conceal all reference to these studies, just as it concealed even earlier studies conducted at Kettering Laboratories that were interpreted as having developed an animal model for the toxic effect of VC exposure in at least two separate species.
11/21/66
When what the MCA-coordinated companies had in mind was revealed to the MCA Plastics Committee [19], several representatives of companies not involved in the vinyl industry spoke out very strongly against it, emphasizing that MCA was duty-bound to do something more about the problem. These non-vinyl producing companies even went so far as to offer to assist in the funding of a serious and honest research program.
The vinyl companies on the MCA Plastics Committee rejected these offers. Indeed, in the future, MCA would issue guidelines absolutely prohibiting the participation of companies without a direct sponsoring interest from participating in any committee activities relating to the so-called “product-oriented problems.”
12/2/66
Consistent with the agreement with the PVC producers attending the October 6, 1966 meeting, the OHC voted to report its only toxicologic study on VCM, with such studies to never be conducted unless the (fraudulent) University of Michigan (UOM) studies revealed significant disease.
By late 1966, the idea of actually conducting toxicology studies under the auspices of MCA, and of giving a seminar for the public, was completely abandoned. Even though money would subsequently be raised for these purposes, the money would not be used. The remainder of the unspent funds would eventually be returned to the subscribing companies in early 1974.
By no coincidence, as will be shown with more particularity below, this formal abandonment of this entire research program occurred immediately following the public disclosure of human cancers caused by vinyl chloride exposure occurring in workers at the same BFG Louisville facility where the first cases of vinyl chloride disease had been detected.
1/4/67
The MCA-coordinated vinyl companies [20] hired the Institute of Industrial Health at the University of Michigan (UOM) to conduct the in-plant medical studies that the group still wanted to perform. The idea of conducting toxicology had already been abandoned. However, the group did, at least, renew its commitment to finish its study by June 1967, and present the study findings at an open scientific meeting that summer. As will be shown, the sponsors of this study would not allow even what was left of this horribly compromised, and intentionally biased, epidemiologic study to be published until 1971, and no seminar would ever occur.
All of the companies attending this January 4, 1967 meeting agreed to avoid all discussion of the problem outside of the meeting.
The UOM study was deliberately sabotaged by its sponsors, and by early 1967, the MCA Group had prohibited the UOM from studying any workers who were not actively engaged in working for them, eliminating, of course, any worker, or former worker, who had either died or become too sick to work. The sponsors required this alteration of the protocol from a mortality study to a prevalence/morbidity study in order to prohibit the study from detecting significant occupational disease. As originally contemplated, the study was to include approximately 20,000 workers, including VCM workers, PVC workers, and PVC fabrication workers. In short order, the study population was reduced to a mere 5,000.
Further, the sponsors altered the protocol to completely eliminate VCM workers as a class and prevent the detection of disease in fabrication workers by stacking the deck in the study population (or cohort). Fabrication workers were grossly under-represented, and even those included in the study were selected precisely because they had not been employed in the industry long enough to even be at risk for the manifestation of the disease.
All of the foregoing was specifically intended to fraudulently misrepresent the hazards posed by exposure to vinyl chloride in general, and to VCM workers, fabrication workers, and PVC workers not engaged in reactor cleaning activities, in particular.
All of the companies attending this January 4, 1967 meeting agreed to avoid all discussion of the problem outside of the meeting.
The group discussed the fact that the FDA generally insisted that products Used in food contact applications be proven non-toxic, and that any study that even implied a risk involved with regard to exposure to finished PVC products, or the residual VCM contained in those products, could result in unfavorable publicity that could prove very damaging to the industry. In consequence, the group agreed that it was essential for their study to “bracket the problem area,” in such a way that neither VCM, nor fabricated PVC products, or even the PVC manufacturing process in general, was implicated as a potential etiologic agent.
The MCA-sponsored group believed it so essential that any problem revealed by the study be “bracketed,” or confined, to a single step in the PVC manufacturing process (i.e., kettle-cleaning), and provide no scientific evidence that would even imply a general health risk within the vinyl industry as a whole.
The major concern voiced by those companies in attendance was that the study should allay any fear of a threat to vinyl chloride workers in general, or to the public. (Instead, the health of their workers was a secondary concern; and conducting an honest scientific study of the vinyl industry was of hardly any concern to them whatsoever.)
The MCA-sponsored study was intentionally designed so as to allow each company complete control over the composition of the cohort, but, just in case someone in attendance did not know what to do with that control, Carl Dernehl (UCC) recommended that only workers employed in actual PVC production areas be included in the study. (Although there was some self-serving discussion of the need for “no cases to be concealed,” the sponsor-dictated alterations to the study protocol, the detailed provisions placing responsibility for conducting the x-rays, dealing with labor unions, and dealing with afflicted workers, and the otherwise unnecessary lack of safeguards, etc., speaks more loudly to the sponsors intent than mere words.)
Significantly, the fact that, today, the participating companies possess absolutely no records even consistent with an honest disclosure to diseased employees detected by the study, the absence of any workers’ compensation claims resulting from the study, or any other evidence, is strong circumstantial evidence that sick workers were never honestly informed of their condition and its cause.
The presence of evidence that the employment of diseased workers was terminated following their diagnosis, makes it all but certain that the corrupt study these companies conducted under the auspices of the MCA remained as closely guarded a secret after it was conducted as it was during the time it was being conducted.
On information and belief, at sometime during or after the study’s completion, all records indicating the precise manner in which the study was conducted have been deliberately destroyed by the participating companies in order to conceal their misconduct, and in order to allow similar misconduct, including additional secret epidemiological studies, to continue.
1/17/67
BFG prepared a misleading information sheet for the guidance of its public relations department. BFG specifically instructed its PR department that the information sheet was not to be considered a press release and that, in fact, BFG planned absolutely no release of information relating to the disease, whatsoever, about either the JAMA article, or the disease BFG had so meticulously mischaracterized in that article.
Much later, in 1974, after a rare form of liver cancer, whose presence in vinyl chloride exposed animals BFG had been concealing for years, turned up in BFG’s own workers, BFG would, finally, refer to vinyl chloride as the cause of a so-called “hand problem” in its workers.
Even then, the proposal to tell BFG’s workers why BFG had begun x-raying their hands years back was not uniformly welcomed by management – and this was at least ten years after BFG had first begun hiding the disease from them. (What’s more, even this disclosure was made as part of a cover up attempt to suggest, at least ten years after-the-fact, that the workers had somehow been told the truth about the disease all along. BFG told its workers that “old timers” at the plant would surely recall the “hand problem,” and how BFG had solved it many years before. However, BFG did not mention how many workers were led to believe their hand problems were the result of rheumatoid arthritis, carpal tunnel syndrome, or whatever they had been told besides the truth.)
In fact, though, even after BFG published its article and thereby publicized its problem (at least among careful readers of the Journal of American Medical Association – it was not even published in the Louisville newspapers), BFG deliberately decided not to release any information about the article, the disease, and certainly not its cause, to its workers, or anyone else who did not already know enough to ask about the article, the disease, or its cause. No one asked, so, notwithstanding all of the disinformation BFG would disseminate in the wake of the 1974 Louisville angiosarcomas, BFG never told anyone.
2/1/67
The OHC continued its previous plans to manipulate and control the consensus setting process by which threshold limit values (TLVs) were established, and specifically considered establishing some other official mechanism for recommending TLVs other than the ACGIH.
APRIL, 1967 – SEPTEMBER, 1967
Between April 1967 and June 1967 and between July 1967 [21] and September 1967 [22] the MCA-coordinated vinyl manufacturers maintained representatives on the OHC and Plastics Committees who were overseeing the conduct of the MCA Vinyl Chloride or “Occupational Acroosteolysis” Program.
Between October 1967 and May 1968 [23] and between June 1968 and August 1968 [24] – the MCA-coordinated vinyl manufacturers maintained representatives on the OHC and Plastics Committees who were overseeing the conduct of the MCA Vinyl Chloride or “Occupational Acroosteolysis” Program
7/1/67 - 2/1/69
The MCA-coordinated vinyl manufacturers extended the completion date for its UOM report at least eight times.
8/21/67
BFG (Dr. Rex Wilson) published an article in Journal of American Medical Association (JAMA) misleadingly entitled “Occupational Acroosteolysis.” The article misrepresented the nature and extent of the hazards of vinyl chloride exposure and of work in the vinyl industry. Among other deliberately misleading findings, the article focused almost entirely on the so-called “hand problem,” without emphasizing the systemic nature of the disease that the companies admitted in private.
Similarly, the paper made only passing reference to the occurrence of the disease among workers not involved in kettle-cleaning, and no reference at all to the occurrence of the disease in workers lacking even a history of direct involvement in actual PVC manufacturing operations – despite the extreme importance that, in private, industry attached to such cases. Also for similar fraudulent reasons, the article made no reference to the long-standing, and unrefuted, supposition the industry had entertained that VCM was the only common denominator shared by all the known cases.
The history of the development of knowledge within the industry pertaining to the disease was deliberately incomplete, and misleading, in many aspects, not the least significant of which was the total omission of any reference to the fact that the disease was ubiquitous in the vinyl industry, and had been found by almost every company in every country that bothered to make a serious effort to look for it.
The etiology of the disease was described as unknown but suspected of involving: (1) exposure to some chemical, the identity of which BFG did not so much as suggest, (2) trauma to the hands sustained in the manual cleaning of reactor vessels/kettles, and (3) personal idiosyncrasy of a type completely unspecified and not even suggested. (Recall that at this time BFG had already commissioned animal studies to determine the mechanism whereby vinyl chloride caused the very disease of whose cause BFG repeatedly professed to have no knowledge.)
11/16/67
The MCA Food Drug and Cosmetics Committee voted to seek out experts who believed, or could be persuaded to believe, that the concept of “thresholds” applied in the field of carcinogenesis as it did in other aspects of toxicology that did not involve cancer.
This committee also voted to fund a position paper that would reach the pre-ordained conclusion that the “philosophy” that chemical carcinogens should not be allowed in foods should be discredited, even though this committee openly recognized that the task would be next to impossible (because they recognized that what they were seeking to prove was unfounded in fact, not accepted in the scientific community, and, in fact, almost certainly not true, notwithstanding how much money it might save industry).
1969 – 1970
At some point prior to March 24, 1970, and, on information and belief, at least by the time of the 9th International Cancer Conference (ICC) in Japan, the MCA-coordinated vinyl manufacturers became aware that industry-sponsored toxicologic studies conducted in Europe by Dr. P.L. Viola had demonstrated a causal relationship between exposure to vinyl chloride and the development of cancer. Immediately after obtaining this knowledge, the group made the deliberate decision to stop studying the effects of vinyl chloride as quickly as possible, and terminated the ongoing research program they had made a commitment, but failed, to conduct since at least 1967.
3/24/69
BFG, Dow, Allied, and Carbide were aware that beauticians Using hair sprays containing VCM as a propellant were being routinely exposed to VCM equal to, or greater than, the most highly exposed vinyl workers in the industry. With this knowledge, the companies continued to sell VCM for propellant applications without warnings for the specific purpose of preventing what they considered to be undue and premature attention to industrial hygiene aspects of the problem.
4/7/69
MCA advised the MCA-coordinated vinyl manufacturers not to reveal the February 1, 1969 report to anyone until the sponsors had time to modify it’s findings and conclusions the way that they wanted it. The companies took MCA’s advice and failed to reveal the February 1, 1969 report to anyone.
4/30/69 – 1971
The MCA-coordinated vinyl manufacturers [25] accepted the February 1, 1969 UOM, but only after they had completed making improper substantive modifications to the report. Notwithstanding this, the MCA-coordinated vinyl manufacturers agreed to suppress even the modified version of the report even after they had previously sanitized the report’s most significant findings and recommendations.
4/30/69
At this meeting, the OHC voted not to accept the February 1, 1969 UOM final report and went on to make multiple substantive revisions to the report that the MCA-coordinated vinyl manufacturers’ so-called independent contractor (UOM) had made. The OHC voted to accept the report only if UOM would substitute the opinions of the MCA-coordinated vinyl manufacturers’ in place of their own.
The OHC removed from the UOM final report the author’s recommendation that vinyl chloride exposure be kept below 50 ppm on an eight-hour time weighted average (TWA), and included language specifically disavowing any knowledge of what the etiologic agent for the disease might be.
4/30/69 – PRESENT
The MCA-coordinated vinyl manufacturers misrepresented their knowledge of vinyl chloride’s odor threshold of 4,000 ppm, and never corrected the statement in MCA SD-56 (Safety Data Sheets) that the odor threshold for VCM was only 240 ppm. In 1974, any members of the Vinyl Panel that had joined after 1969 were brought up to date on vinyl chloride’s high odor threshold.
5/6/69 – PRESENT
The previously identified [26] MCA-coordinated vinyl manufacturers participating in the 1969 meetings of PVC manufacturers conducted under the auspices of the MCA Occupational Health Committee suppressed the February 1, 1969 confidential final report they had received from UOM. With few exceptions, at various times since 1969 the MCA-coordinated vinyl manufacturers have destroyed evidence concerning the UOM studies, including evidence of undue sponsor influence in the conduct of UOM studies and the reported results by the Institute of Industrial Health at the UOM, so-called independent contractors hired by the MCA-coordinated vinyl manufacturers.
5/6/69
The MCA-coordinated vinyl manufacturers met at the University Michigan, agreed to the OHC modifications of the February 1, 1969 UOM report, and made more changes of their own.
The MCA-coordinated vinyl manufacturers [27] made further substantive modifications to the February 1, 1969 UOM report in order to misrepresent the nature and extent of the hazards posed by exposure to vinyl chloride and of work in the American vinyl industry.
Although the group openly admitted (among themselves) that vinyl chloride might very well be the causative agent, (and although, because of sponsor-dictated changes to the protocol, such a finding was completely precluded from the outset by the way the study was designed), and although VCM was certainly the only possible chemical cause of the disease that the group could even name, the MCA-coordinated vinyl manufacturers voted not to allow UOM to even imply this.
Subject to the sponsor-dictated changes, the MCA voted to allow the February 1, 1969 UOM report to be presented at a medical association meeting the following April. However, the February 1, 1969 UOM report was never presented in a public forum.
As a result of the May 6, 1969 meeting, the MCA-coordinated vinyl manufacturers [28] learned that Pantosote, Firestone, Great American Plastics, and GenCorp had more cases of acroosteolysis than any other plants in the study, demonstrating significant historic exposure to vinyl chloride at those plants. It was for this reason that in 1973, the MCA Group (that included all four of those companies) deliberately excluded these plants from the human cancer study they were conducting, while, at the same time, including in the study companies that had demonstrated few or no cases of vinyl chloride disease in their cancer study.
Although aware that the cancer studies they conducted in 1974 and 1986 did not include any of these plants, and although aware that MCA’s cancer studies were represented and understood to be “industry-wide” studies, the MCA Group never revealed to anyone outside the group the fact that these studies did not include the very plants the MCA Group had reason to believe were most likely to show excess cancer.
The MCA-coordinated vinyl manufacturers [29] were aware that the symptoms of nonmalignant disease resulting from vinyl chloride exposure were all but indistinguishable from true Reynaud’s Disease, scleroderma, and bone changes resulting from traumatic injury, etc., and, as a result, would be commonly misdiagnosed by almost any medical practitioner other than the MCA Group’s company doctors.
The group also learned that UOM had determined that acroosteolysis was more widespread than previously recognized, but, despite this, the MCA Group made the conscious decision not to investigate the matter further. Notwithstanding this, in future years, BFG, MCA, and untold others would misrepresent the disease problem as having somehow been solved, and that the problem had resulted from exposure conditions far worse than those that existed “modern” plants.
The MCA-coordinated vinyl manufacturers misrepresented the findings of the UOM in that they did not allow UOM to reveal its conclusion that Reynaud’s Disease was a precursor to acroosteolysis, that toxicologic studies were needed, that the disease was likely to prove to be systemic, that the type of monitoring methods currently employed in industry were grossly inadequate to detect dangerous levels of vinyl chloride exposure, that VCM workers and, not only, PVC workers should receive pre-assignment and periodic medical examinations, and other important findings and conclusions that were not in the MCA Group’s financial interests to allow UOM to make public.
11/6/69
The OHC voted unanimously not only to abort their ongoing research program, but, also, not to even accept, or consider, any proposals for additional research in the future, including proposals they had previously solicited.
The committee recognized that, if their decision to totally abandon all of the research that they had committed to perform years before ever became publicly known, the group’s decision might be seen for the complete and indefensible abrogation of responsibility that it truly was.
As a result the group adopted what they all knew was a pretext for the decision, specifically, that the group preferred to spend its money “on the avoidance of the disease rather than its cause, since it was recognized that companies would be reluctant to reveal proprietary information for the study.” Under this “for the record” pretext, the ongoing primate toxicology program being conducted at Kettering Laboratories was terminated and the money the companies would supposedly spend on avoiding the disease rather than determining it’s cause was limited to no more than $3,000 per year, and to be shared by 20 companies, including many of the largest and most prosperous chemical companies in the world.
11/6/69
On November 6, 1969, the Occupational Health Committee (OHC) met at the Royal Orleans hotel in New Orleans, Louisiana
The OHC agreed unanimously not to accept any proposals for additional research into the causes of acroosteolysis, but to, instead, spend a token $3000 a year divided by at least twenty-five different manufacturers [30] for a so-called “Acroosteolysis Registry.” Even this paltry $3,000 per year divided among all of the participating companies (including some of the largest chemical companies in the world) was only money the MCA had left over from studies that the MCA raised money for, and then almost totally abandoned in the 1960s, a process that, by no coincidence, began just around the time extremely disturbing evidence of vinyl chloride’s carcinogenicity began to develop as a result toxicology conducted by the European vinyl manufacturers [31] in Italy.
11/24/69
The MCA Plastics Committee [32] made an absolutely unprecedented type of resolution at its November 14, 1974 meeting: It resolved that what it would not do, specifically that proposals for additional research on the causes of acroosteolysis not be accepted.
JANUARY 1970
On behalf of the MCA-coordinated vinyl manufacturers, Hendricks declined Dr. Viola’s invitation to form such a committee. After 1974, the MCA-coordinated vinyl manufacturers would claim that Dr. Viola was very secretive, evasive even.
The MCA-coordinated vinyl manufacturers caused to be published three papers in the Archives of Environmental Health based upon previously suppressed and concealed versions of the UOM “acroosteolysis” study.
This paper was sanitized of all its significant findings and gave no clue that vinyl chloride was even suspected as the etiologic agent for the disease, and was also sanitized of all UOM’s recommendations relating to a 50 ppm exposure limit, the need for better monitoring equipment, the need for medical monitoring of VCM workers, every reference to vinyl chloride’s odor threshold, systemic effects, and everything else the sponsors had, over the course of the last two years since UOM had issued its first “final” report, determined was adverse to their financial interests.
3/13/70
Dr. Herbert Stokinger (Chairman of the ACGIH TLV Committee, Government employee, and long-standing friend of industry) informed Dr. Richard Henderson (Olin Mathison) that the documentation for the ACGIH TLV Committee still contained references to the 1962 revision of the TLV to 50 ppm. These references were subsequently suppressed and not included in either any ACGIH publication, or any presentation made by the MCA-coordinated vinyl manufacturers, [33]even when the publication or presentation reported to accurately summarize the history of the development of the ACGIH TLV for vinyl chloride.
Dr. Stokinger also revealed that the ten-fold downward revision of the TLV for vinyl chloride in 1962 was simply never published, and then referred to the trumped up Lester & Greenburg study that had not even been published at the time the TLV was lowered in 1962. Dr. Stokinger expressed his understanding that Dow followed a 200 ppm TLV at that time (and not the 50 ppm internal exposure limit Dow would falsely claim, in future years, to have adopted in 1961).
4/6/70
During the week prior to 4/6/70, the ACGIH TLV Committee met with Dow’s V.K. Rowe in attendance. Dr. Rowe confirmed Dr. Stokinger’s understanding that Dow had not reduced its internal exposure limit to 50 ppm in accordance with its animal findings and 1961 recommendation. Rowe conveyed that Dow’s Turner and Mutchler had tentatively made a 200 ppm TLV at a scientific conference in 1968 and had not seen any evidence to alter that recommendation since that time.
The final decision of the ACGIH was to adopt this 200 ppm recommendation.
4/6/70 – PRESENT
Like the 1962 and 1966 action of the ACGIH TLV Committee, with regard to vinyl chloride, the fact that the committee adopted a lower standard for vinyl chloride than 500 ppm as its official TLV, in 1970, is completely absent from the historical record.
On information and belief, the MCA-coordinated vinyl manufacturers, with the knowing collaboration of Dr. Stokinger, made a concerted effort to destroy or conceal all evidence indicating the true activities of the ACGIH TLV Committee with regard to vinyl chloride in 1970, just as they had with regard to similar revisions that were made in, at least, 1962 and 1966, but whose existence was suppressed and concealed.
4/7/70
The OHC received a report on the acroosteolysis study. Even the OHC admitted that the one-year basis for the $3,000 proposal was deplorable, the OHC then rationalized the decision to abandon all ongoing and future research based upon a pretext of its own (that was completely different than the one the producers had Used). The OHC claimed that the change in plans was necessary “as a budgetary expedient.”
Since, as the OHC well knew, the program was being funded from unexpended funds, the cover-story was a poor one, but, apparently, good enough to put in their minutes since no one was likely to examine it but themselves. The remaining “surveillance” program referred to as the UOM “Acroosteolysis Registry” was, of course, funded on a one-year basis in order to allow the participating companies to pull the plug on the “Registry” whenever they wanted.
The OHC also openly discussed further editorial revision of the unknown number of recent reports from the University of Michigan.
Ross v. Conoco 90-4837 (14 Judicial District Louisiana)