Health Sciences Center School of Medicine in Shreveport Department of Medicine Section of Occupational and Environmental Medicine

School of Medicine in Shreveport School of Allied Health Professions School of Graduate Studies

October 8, 2003

David Groner, P.L.C. a Professional Law Corporation
724 S. Lewis St.
New Iberia, La. 70560

Dear Mr. Groner

I have reviewed the Honeywell Material Safety and Data Sheet (MSDS) that was furnished concerning the chemicals used in the roofing of the school in Iberia Parish. The MSDS lists the chemicals as follows: solvent naphtha (petroleum, light aromatic), asphalt, styrene-butadiene-styrene rubber, heavy naphthonic distillate (solvent naphtha (petroleum), medium aliphatic), and coal tar. There are other chemicals listed as trace impurities and additional material names that are on the "Right To Know" lists for communities.

In lay language, the chemical mixtures in use for the roofing repair contain known carcinogens, hematotoxins (capable of causing blood disorders including blood cancers), reproductive toxins (capable of causing reproductive health effects including birth defects and menstrual disturbances), central nervous system depressants, respiratory and gastrointestinal toxins. Pitch volatiles of coal tar are know to cause cancers of the skin, kidney, bladder, scrotum, and lung. Other adverse health effects to chemical components of the compound mixture in use are documented in the scientific literature.

Because the exposures may produce delayed subacute or chronic effects, it is advisable to seek medical surveillance with a physician who understands chemical exposure and the effects of such compounds on the body. Since there are not many such physicians in the State of Louisiana, I would be happy to consult with any physician that is in need of literature or other guidance on the laboratory procedures used to monitor warning signs of developing disease from chemical exposure. This is in keeping with the mission of the Occupational Toxicology Outreach Program through education, awareness. and prevention of disease from chemical exposure I am the Laboratory

Louisiana State University Health Sciences Center ∙ School of Medicine in Shreveport ∙ Department of Medicine ∙ Section of Occupational and Environmental Medicine ∙ Occupational Toxicology Outreach Office ∙ 5211 Essen Lane, Suite 6 ∙Baton Rouge, Louisiana 70809-3593 phone (225) 763-3960 fax (225) 763-3969 www.lsuhsc.edu

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Director of an in-house medical surveillance laboratory and have performed such medical surveillance on exposed communities. I do not perform the medical surveillance for litigation purposes in my laboratory, only for research or contract and in connection with physicians who order and also receive the results. I would be more than willing to assist any private physician who wishes to contact me for consultation at no charge. I routinely do this for any physician in the State of Louisiana.

Some of the adverse cellular effects that these above mentioned chemicals can cause include the following: lysis of red blood cells; depression of one or more blood cell lines, for example: anemia, thrombocytopenia (platelet decrease), leukopenia, primitive or differentiated stem cells; increase or decrease in relative or absolute values for leukocytes (white blood cells); increase in one or more blood cell lines: erythrocytic, leukocytic, or thrombocytic; decreasing trends of one or more blood cell lines within the normal range; cellular damage of blood cells, liver cells, kidney cells, and other organs, and much more.

In order to monitor the early warning signs of acute damage or developing disease, I recommend the following basic laboratory procedures:

Laboratory Tests

1. CBC with differential, including absolute and relative values, and indices (MCV, MCH, MCHC)
2. Platelet Count
3. Reticulocyte Count
4. Stipple Cell Count- Preparation must be done on a fresh specimen.
Must be performed using only Fresh Blood or Heparmnized blood. EDTA or other anticoagulants will interfere with the test.
5. Comprehensive Metabolic Panel including
Total, Direct, and Indirect Bilirubin
LDH
AST
ALT
Alkaline Phosphatase
GGT

6. Urinalysis with Macro and Microscopic analysis

I am enclosing excerpts from the Armor Flex™ MSDS sheet provided to me. Although the listing of the adverse health effects is not complete, it is a good start for the physicians to use in understanding some of the potential health effects of the chemicals that their patients report exposure to.

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If I can be of any further assistance, please do not hesitate to call on me. My Baton Rouge office is the best number for physicians to use in order to contact me, 225-763-3960.

Sincerely,

/s/ Patricia M. Willaims

Patricia M. Williams, Ph.D.
DIRECTOR, OCCUPATIONAL TOXICOLOGY OUTREACH PROGRAM
Associate Professor of Medicine