EPA  Contract No.  68-03-3268
                                            Work Assignment No. 1-10
FEASIBILITY OF CHROMIUM SPECIATION FOR EPIDEMIOLOGICAL EXPOSURE MODEL
                            Submitted to:

                U.S. Environmental Protection Agency
               Office of Research and Development/ECAO
                       Cincinnati, Ohio  45268

                 Project Officer:  Linda Schwaegerle
               Technical Project Monitor:  Herman Gibb
                            Submitted by:

                      Technical Resources, Inc.
                    3202 Monroe Street, Suite 300
                     Rockville, Maryland   20852
                            Prepared by:

                   Peter S.J. Lees, Ph.D.,  C.I.H.
                     The John Hopkins University
                 School of Hygiene and Public Health
             Department of Environmental Health Sciences
            Division of Environmental Health  Engineering
                       615 North Wolfe  Street
                     Baltimore, Maryland  21205

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                               EXECUTIVE SUMMARY
    A summary of the existing database  to be utilized  in  the  modeling  of
chromium (Cr) exposures at the Baltimore Chromate Works of  the  Allied
Corporation is presented.  Description  and discussion  focus on  documentation
of exposures to various Cr species in response  to EPA's request to  evaluate
the feasibility of isolating risks by disease by Cr  species.  Data  from  the
Allied Corporation, U.S. Public Health  Service, Baltimore City  Health
Department and Dr. Anna Baetjer's archives are  reviewed.  Although  all records
have not been collected or examined, it appears that the  U.S. Public Health
Service study (ca. 1952) contains the only direct measures  of employee
exposure which differentiate exposure by Cr species.   More  recent exposure
data differentiating chromium species are not available;  all  samples have
apparently been analyzed for Cr   content only.

    Although the existing database contains limited  information about  worker
exposures by Cr species, it may be possible to  partition  historical exposures
by species.  It is recommended that  the existing epidemiological data  be
re-analyzed to assess the difference in disease incidence (if any)  between
workers in the mill and roast plant  (with a mixed Cr  /Cr  exposure)  and
the special products/acid plant (with a pure Cr   exposure) to  assess  the
separate risks of disease.  In addition it is recommended that  historical
process quality control data and settled dust samples  be  utilized to estimate
quantitative levels of exposure Cr   for inclusion in  the Cr    exposure
model.

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                               TABLE  OF CONTENTS









  I.   PURPOSE/OBJECTIVES	1




 II.   DESCRIPTION AND DISCUSSION OF EXISTING DATA




      A.   Allied Corporation Data	1




      B.   U.S.  Public Health Service Data	3




      C.   Baltimore City Health Department Data	4




      D.   Dr. Anna Baetjer's Archives	4




III.   FEASIBILITY ASSESSMENT/CONCLUSIONS	4




 IV.   RECOMMENDATIONS	6

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I.   PURPOSE/OBJECTIVES

     This report has been prepared  to describe,  in  general,  the  existing
database to be utilized in the modeling of chromium exposures  at  the  Baltimore
Chromate Works of the Allied Corporation.  The  following  description  and
discussion focus on documentation of exposures  to various  chromium (Cr)
species in response to EPA's specific request  to determine  the feasibility  of
utilizing the database to isolate the risk of  disease  (if  any) from exposure
to Cr   and the generally recognized risk of disease from exposure to
Cr  .  As the environmental exposure database  has not  been fully  assembled
at this writing, the discussions and conclusions may be somewhat  premature  and
are, therefore, subject to change as additional  data are  gathered.

II.  DESCRIPTION AND DISCUSSION OF  EXISTING DATA

A.   Allied Corporation Data

     To date several meetings have  been held with representatives of  the
Allied Corporation to define the data required  for  this study.  The Allied
Corporation has been very receptive to our requests and continues to  be very
co-operative.  Because of a major change in administrative structure  and
personnel during the course of these discussions, however,  the actual transfer
of the Allied exposure data to the  project investigators  has been delayed.
The following description of the existing database  is  based on discussions  and
meetings with the last chief industrial hygienist at the  plant before it
closed, and with the current director of environmental operations at  the  plant
who is responsible for, among many  other things, the collection  and archiving
of all records related to the plant.

     The plant which is the subject of this study was  constructed in  1952.   It
is a large industrial complex, but  can be divided into two basic  parts:   the
mill and roast department and the special products/chromic acid  departments.
Only monor changes were made in the mill and roast  portions of the plant
between 1950 and the plant closing  in 1985.  The special  products and chromic
acid portion of the plant underwent major renovations  in  1960-61.  Both  parts
of the plant are located in separate buildings  which are  large open structures
in which personnel moved about freely during the course of a day.  The

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physical separation of these two plants and the frequent crossover of the
working populations has important implications for measurement of the risk of
disease by chromium species.  Exposure in the mill and roast department was to
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a mixed Cr  /Cr   dust while in the special products/chromic acid
departments exposure was limited to a pure Cr   dust.

     From 1952 until 1985 the plant operated, with very few interruptions, at
essentially 100% of capacity.  Process quality control data associated with
production records are a potential source of exposure speciation information.
Investigation to date has shown that process quality control measurements were
probably limited to soluble chromium compounds and iron at various points in
the manufacturing process.  Insoluble chromium species were not normally
measured as a part of quality control activities.  Insoluble species may,
however, be estimated from the data by difference at each stage of the
process.  The location and state of the old process quality control records is
not known at  this time; there is, however, the possibility that additional
information exists.

     The Allied Corporation bought the Mutual Chemical Company Chromate Works
in the late 1950's (?) and inherited all records from the plant dating back to
at least the  last century.  The Allied Corporation and its predecessor have
collected environmental exposure data at least from the late 1940's.  These
data were collected by the process engineering department until approximately
1970 when a separate department for health and environment was formed.  The
environmental data for the 1940-70 era are not currently stored at the
Baltimore Works and, due to delays caused by administrative changes, have only
been positively located in the last week.

     Environmental exposure data from the 1940-70 era are said to be
considerable  (perhaps 100 samples per year on average) but have not been
examined to date.   The quality of the data has, therefore, not be assessed.
It is the recollection of plant personnel that, although exposure
concentrations are available, there is little documentation as to sampling and
analytical methods employed, measurement units are often missing, etc.

     In the post-1970 era extensive environmental exposure data were
collected.  From 1970 until the plant closed in 1985, area air samples were
collected on  a monthly basis from a standardized grid system within the plant.

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This grid system was modified in i960 to a system of twenty sampling  zones.
Approximately 1500 samples were collected per year as part of  these systems.
Beginning in approximately 1978, these area samples were supplemented with
personal samples of exposure.  A total of some 1500 personal samples were
collected before the plant closed.  The extensive and complete nature of  the
data greatly facilitate the development of a general Cr exposure model  for
workers at the plant.

     All personal and area samples collected by Allied and Mutual at  least
since the 1940's were only analyzed for Cr   content; Cr   and/or total Cr
were never measured on a regular basis and, to the extent permitted by  our
limited examination of the data, were probably never collected.  The  sampling
and analytical methods employed in the 1940-70 era are not known at this  time,
although it is generally believed that RAC tape samplers were  employed
extensively in the 1960's.  Although documents have not yet been found  to
verify recollections, it is believed that all samples during this period  were
analyzed for Cr   only.  The ai
known positively at this time.
analyzed for Cr   only.  The analytical method employed, however,  is not
     In the post-1970 period samples were collected  by  RAC  tape  samplers  (area
samples) and personal sampling pumps and filters  (peronal samples).
Apparently all of these samples were analyzed utilizing the diphenylcarbazide
method.  This is a widely used standard method for the  analysis  of  Cr
The Allied Corporation, however, modified the method somewhat  by utilizing
acidified diphenylcarbazide instead of the sequential addition of
diphenylcarbizide and acid specified in the method.   The bias  introduced  by
this variation (if any) will have to be independently evaluated. No direct
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information on Cr   or total Cr exposure is, thus, available for this  era.
At least some of the post-1980 exposure data are  said to be available  on
computer tape, but have not seen located as of this  writing.

B.   U.S. Public Health Service Data

     Copies of the original raw data from the U.S. Public Health Service  study
of the plant in the early 1950's have been obtained  as  has  a copy of  the
resulting analysis of the data published as "Health  of  Workers in ...  Chromate
Producing Industry" (Public Health Service Publication  No.  192). This study

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contains measures of air concentrations, settled dusts, and  processes  analyses
of various forms of chromium.  In most instances, total Cr,  Cr   ,  soluble
and insoluble Cr concentration data are presented.  The sampling and
analytical methods employed are well documented as a part of the final
report.  The data contained in this study can serve as a solid basis for
estimation of Cr exposure concentrations by species for the  early  1950's.

C.   Baltimore City Health Department Data

     The Bureau of Industrial Hygiene of the Baltimore City  Health Department
made frequent measurements of employee exposures at the chromate plant from  at
least the mid-1930's.  Records of several hundred exposure measurements are
available in the Health Department's files.  To date, these  records have not
been scrutinized because a confidentiality agreement to protect  individuals
named in the exposure records has not been reached between the Health
Department and the investigators.

D.   Dr. Anna Baetjer's Archives

     Dr. Anna Baetjer was closely associated with health- and exposure-related
studies at the chromate plant from the late 1940's until her death in  1984.
At this time it is known that her extensive records of this  association
contain detailed observations of processes, controls, work practices,  etc. at
the plant.  These records will be extremely valuable in helping  to interpret
the quanitative exposure data.  It is believed at this time  that Dr. Baetjer
did not conduct any quantitative exposure measurements herself,  and that all
such data In her records may be found in its original form elsewhere.   This
assumption, however, is unverified to date.

III.  FEASIBILITY ASSESSMENT/CONCLUSIONS

     Although all records have not been collected or examined, It  appears  that
the U.S. Public Health Service study contains the only direct measures of
employee exposure which differentiate exposure as to chromium species. These
data were all collected in the early 1950's.  More recent exposure data
differentiating chromium species are not available; all samples  have
apparently been analyzed for Cr   content only.

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     Several methods of estimating Cr   exposure  and  risk  of  disease  are
possible utilizing the existing database.   The most direct method  of
differentiating disease risk by species would be  to analyze existing  (and
updated) vital status data treating employees of  the  mill  and the  roast plant
and the special products/acid plant as separate populations.   As stated
earlier, exposure in the mill and roast department was  to  a mixed  Cr   /
Cr   dust while in the special products/chromic acid  departments exposure
was limited to a pure Cr   dust.  Independent analysis  of  the risk of
disease in these two plant populations, while probably  requiring extensive
adjustments to make the populations otherwise comparable,  would  have  the
direct advantage of showing a differences  in risk which could be attributed  to
the differences in exposure.  Quantification of those exposures, however,  is
not possible as a part of this type of study.

     In the absence of direct measures of  worker  exposure  by  Cr  species,  the
most promising source of quantitative information may be derived from process
quality control data.  These measurements,  made on a  regular  basis at numerous
points in the manufacturing process, provide a direct measure of soluble  Cr
content of the product.  It may be possible to deduce insoluble  Cr content  by
calculating the difference in soluble Cr concentration  from the  preceding
step.  The use of process quality control  information to estimate  worker
exposure by Cr species has two major implicit assumptions:  1) it  must be
assumed that the partition of Cr species in the process materials  was mimicked
in the dust in the air and 2) it must be assumed  that the  soluble  and
insoluble fractions correspond in some fashion to the Cr   and Cr
species.  Specific Information may be present in  the  existing data set and/or
laboratory simulations could be designed to substantiate or refute these
assumptions.

     A second possible source of quantitative information  on  the Cr species  of
workers exposures would be the analysis of  settled dust samples.   This was
done as a part of the U.S. Public Health Service  study  In  the early 1950's  and
could be duplicated today.  The use of these data to  segregate worker
exposures by species would involve two assumptions similar to those required
above:  1) a straight line relationship would have to be assumed to explain
any changes in the partition of the Cr species between  the Public  Health

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Service measurements of the early 1950's and today  (In addition, methods would
have to be carefully cross-calibrated) and 2) it must be assumed that  the
partition of Cr species in the settled dust was mimicked in  the dust inhaled
by the workers.

IV.  RECOMMENDATIONS

     Although the existing database contains only very limited (and old)
information about worker exposures by Cr species, it may nonetheless be
possible to partition historical exposures by species with a fair  degree of
reliability.  It is recommended Initially that the  existing  epidemiological
data be re-analyzed to assess the difference in disease incidence  (if  any)
between workers in the mill and roast plant (with a mixed Cr  /Cr
exposure) and the special products/acid plant (with a pure Cr  exposure)  to
assess the separate risk of disease.

     In addition it is recommended that if the epidemiological study outlined
above shows any hint of risk associated with Cr   exposure that analysis of
historical process quality control data and settled dust samples be undertaken
to quantitate the level of exposure to Cr   for inclusion in the Cr
exposure model.  Due to time considerations, however, it may be desirable  to
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begin efforts to quantitate Cr   exposures immediately.

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