+ri1 21, 19El Xiss !%:ary: .!-;6rtLa Me:;ar;lara 3ushnell: Gage, Reizen and Byington 1111 !;ineteenth Street, N.\<. --- kzashinyton, D. C. 20036 Dear Ikry, Thank you fcr forwarding a copy of the testimony given by Drs. Infante and Kang at the Consumer Product Safety Co;nmission Public Eearing on Proposed Regulation for Urea Formaldehyde Foam Installa- tion, Earth 20, 1981. Although the contents of the testimony xere far from accurate, I am not surprised at the tone established dilring the testimony. I was suite surprised, however, when they stated that their "xriews do not necessarily represent those of our employment agency (OSEA)." Drs. Infante and Kang's opinions were quite implicit during our meeting in December with OSIi4 to discuss the IQIOSH Bulletin entitled "Formaldehyde: Zvidence For Carcino- genicity." In particular, they reA 'used to even consider a more comprehensive, balanced review of formaldehyde toxicity for the Bulletin and rejected outright all constructive comments. These views were further supported by 14r. Froines. In view of the credentials presented by Drs'. Infante and Kang,.I t;-as dismayed to read their interpretation of the findings taken from a Xational Cancer Institute Study entitled "Proportionate Wrtality Among New York Embalmers." Drs. Infante and Kang stated t*nat "The most significant finding was an unusually high proportion of deaths from skin cancer, aboi;t 2.5 times greater than the expected (8 observed vs. 2.2 expected deaths). The study also Dresents suggestive evidence for the deuelop,ment of skin cancer in rel ation to the degree of formaldehyde exposure and latency." If Drs. Infante and Kang would have conducted an appropriate review of Dr. skin Walrath's study, they would have found that eight cancers \<ere uncovered during the research, four were clas- sified as malignant melanonzs, three as squa.;;~ous cell carcinomas and one t;as unclassified. There are distinct differences of origin .