I j1 [f]COPY . .. CHROME COALITION ,- i. CHROME COALITION AD HOC PEL COMMITTEE Special Meeting with CheinRisk February 13, 1996 I. i-j Pittsburgh International Airport Pittsburgh, Pa. [ ! r u , oJ " Those in attendance were: Dr. Donald Billmaier Dr. Joel Barnhart Dr. Mark Harris Dr. Brent Findley Dr. Dennis Paustenbach Ms Deborah Proctor Dr. William Butler Mr. Michael Buczynski Ms Stephanie Siegel (via phone) Mr. James Boldt . o! Ms Marianne Kaschak AlliedSignal, Inc. American Chrome and Chemicals Chemical Land Holdings ChemRisk Division of McLaren/Hart ChemRisk Division ofMcLarenlHart ChemRisk Division ofMcLaren/Hart Environmental Risk Analysis Occidental Chemical Corporation Specialty Steel Industry of the U.S. Wayne Pigment Corporation/Color Pigments Manufacturers Association Industrial Health Foundation The meeting was called to order at 10:05 a.m. by Dr. Joel Barnhart, Chairman of the Chrome Coalition and member of the ad hoc committee. J J !1 Ms Kaschak read the Coalition Policy with respect to meetings covered by the antitrust laws. The Chairman emphasized the intent of the Policy and cautioned those present to observe both the letter and spirit of the antitrust laws. Counsel is present, via speaker phone, to insure against inftingement. Introductions of the attendees followed. Dr. Barnhart stated that the purpose of this meeting was to meet with the scientific principals specificto the proposal for critiquing OSHArisk assessmenttechniques and its standard-settingprocess relative to a proposed Cr+6PEL. The proposal was jointly prepared by ChemRisk and EnvironmentalRisk Analysis. Of initial concern was the number of hoUrsallocated for secretarial time for Phase I. Considering all tasks within Phase I, it totaled 136 hours. Dr. Paustenbachjustified the secretarial time expenditure,listing the activities of thisjob function to include assisting with the Administered by: . . INDUSTRIALHEALTHFOUNDATION, INC.. 34PennCircleWest. Pittsburgh,Pa. 15206. (412)363-6600 FAX (412) 363-6605 CHROME COALITION Chrome CoalitionAd Hoc PEL Committee February 13, 1996 Page 2 literature search,photocopying,preparingspreadsheets,time sheets, and billing invoices,taking dictation,and acquiringthe OSHAdocketmaterials. Respondingto an inquiry from Dr. Billmaier,Dr. Butler indicatedthe secretarialservicesrelativeto Environmental Risk Analysis (ERA)would be providedby ChemRiskand are includedin the proposal. Dr. Barnhart askedfor an explanationof involvementof the other identified team members. Ms Proctorsaid that J. Panko, M. Gargas,and T. Long would provide input into industrial hygiene issuesand supportto the literaturereviews. P. Scott will be involvedwith statistical analyses,and T. Ye will supportthe risk assessmentcritique and review. Addressing Phase II of the proposal, Dr. Barnhart asked that ChemRisk and ERA expand and express their perception regarding scope and accompanying costs. Ms Proctor stated that the latter was contingent on the amount of effort put forth. Dr. Paustenbach concurred and stated that he is quite certain that a positive impact can be made, basically because of the weak database. He then offered a detailed comparison between ChemRisk's activities specific to the benzene rulemaking and similar expected results using the same effort for the ct rulemaking. He further indicated that, during this process, Adam Finkel may be willing to establish a compromise agreement as he had done with 1,3-butadiene. Discussion ensued relative to a threshold concept which was not an issue with benzene. L [ ~ L: [j Q o c [ [ Dr. Billmaier stated that the Coalition's primary concern in requesting a proposal was to concentrate on the cancer potency. Dr. Paustenbach stated that he has had informal discussions with the principal researchers at Johns ~opkins involved with the chromium epidemiology study. They verified that EPA will not offer additional financial support to complete the study. However, Genevieve Matanowski of Johns Hopkins discussed the possibility of pro bono confidential involvement of ChemRisk to see the study to completion. Dr: Paustenbach suggested that, if this were to come about, the Coalition may wish to approach the regulators with a program designed to fill a "data gap," thus entering into a data gap agreement, to forestall the rulemaking. Ms Siegel indicated skepticism with this tack since the OSHA activity initiated from a union petition and the process is so far along. In additionto the Mancusowork, ChemRisk/ERAwould review and critique all the other relevantepidemiologystudies,addingweight to the effortof convincingOSHA not to go forwardwith what they presentlyhave. This wouldalso insurethat there would be enoughin the docketto mount a significantlegal challenge. As an aside,Ms Proctor said that Dr. Mancusois about to publish a semi-updateof his originalstudy. r -. r CHROME COALITION Chrome Coalition Ad Hoc PEL Committee February 13, 1996 Page 3 r" [ [j , "1 t! In an effort to summarize an appropriateprogression of activities, Dr. Billmaier asked Dr. Paustenbachto outline tasks which would provide the Coalition with a concrete base of informationto impact the rulemaking and upon which additional :futurearguments can be made. Dr. Paustenbachsaid that he would ad¥ise completingPhase I and exploring additional work with Peter Lees' data. He concluded by offeringthe following list of activities and their chronology: Activi1y L 1. PhaseI (asdescribed- exclusive of meetings) 2. Meetings 3. Manuscript describing how to properly do the analysis (dosimetry) 4. Meeting with Drs. Lees and Matanowski 5. Developing an anti-Mancuso manuscript [ C L [ r [ , Proposed Cost After ChemRisk and ERA departed, discussionensued relative to the comparison of the proposals received from ChemRisk and Ogden Environmental. It was concluded that Ogden will provide information for the record; ChemRisk, on the other hand, affords an opportunity to build for future regulatory impact. Within the next few weeks,Dr. Barnhart will prepare a summary of activities proposed by ChemRisk which will be sent to the ad hoc committee for consideration and approval. In addition, thought must be directedto how and what can be financially supported. Respectfullysubmitted, ~{!~ Marianne C. Kaschak Project Coordinator -, ... , 45K 15K 30-45 K Dr. Barnhart thanked ChemRisk and ERA for answering questions'regarding their proposal and for putting the issues into perspective. The meeting adjourned. ., $30K ? MCK/sk