Docket # (99P-2077CP 1)

[GCJeffrey@aol.com]

cc. US POPs Negotiator in Geneva Switzerland this week. 
      Mr Brooks Yeager
      US Department of State.
      c/o Intercontinental Hotel
      geneva@interconti.com
      Separate E-mail

Docket # (99P-2077CP 1)
"Citizen Petition for a Regulation or
Guideline to Label Medical Devices
Containing Phthalate plasticizers and
to Establish a Program to Promote
Alternatives."



- PVC & plasticizer free alternatives are
already on the market.

- DEHP (the plasticizer for iv bags, tubes, etc.)
has serious health effects, at doses to which
regular users of i.v. already receive!),
according to Health Care without Harm..

DEHP is a carcinogen and is toxic
to many organs.  Unlike many other situations, 
you approve the highly leachable toxin being
delivered directly to the blood.

- Developing organisms are generally a little to
millions of times more sensitive than adults,
yet much of the data relied on by FDA to market
these medical devices rely on toxicologic tests
using adult animals.

Thus FDA is failing in its mission to protect the
public.

In fact, FDA does run the proper toxicology
"experiment", except that it is uncontrolled
(therefore the results are unknowable), and
the risks make it unethical, as FDA is using
the American people as its subjects.

This instant petition is an excellent way to
achieve a measure of informed consent (and
reduce tort liabilty that health providers,
perhaps even the federal government, might
face).

-Such PVC medical devices add to the
medical waste stream, much of which is
incinerated, leading to one of the largest
sources of dioxins and other highly toxic,
persistent & bioaccumulative organo-chlorine
compounds being dispersed into our
breathing air.


George C. Jeffrey BS ChE
Citizens Reaction Against Pollution
PO Box 11622
Jacksonville FL 32239
(904)564-2620
GCJeffrey@aol.com

Citizens Reaction Against Pollution was
started in 1986 by John Austin after finding
PCB's leaking on a childrens play area at the
Jacksonville Naval Air Station.

Citizens Reaction Against Pollution is
listed in the Poison Control Center and
library book "Chemical Exposure and
Human Health" by Cynthia Wilson
http://biz-comm.com/CIIN/   click on Book