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M y name is Hugh M.Pet tigre v ; I am a mathematician at the National Cancer ' Institute.For the past15years,Ihave been engaged in the design of anim sl carcinogen es is experiments and the analysis and interpretation of their results.I have also had experience in the analysis of hunar! stu ? ies, both clinical and epidemiological.I have reviewed as carefully as the timeframe has allowed,the documents provided to the PHS Ad Hoc Beryl liu - Review Panel,both before and during the meeting in Atlanta on October9. I base this statement on the information provided there in and on the discussion by the panel and the cam n ents made by the public. I am insubstantial agreement with the answers provided to you by Dr.D is her t o t11e three specific questions posed to the panel.I would like to nak e the fc l loving additional Temarks in order to clarify 50me of the points raised at the meeting. The first of the questions the panel was asked to an s ver concerned the credibility of the animal studies in shoving beryllium carcinogen i city in atleast tv o species. The opinion of the panel vas that the an s ver to tn is question vas yes.I agree that there is convincing evidence that certain compounds of beryllium produce os teo sarcoma in rabbits.There is also co mincing evidence that certain beryllium containing substances can also produce tumors in rats.This does not mean that any particular beryl liu rr - cont2in ing substance has been sham to be carcinogenic in two s pez ies.Only the oxide sho vs strong evidence of carcinogenic it yin both rats ad rabbits. The evidence in the case of the rat Is qualified by the fact that it exists only in the form of technical reports (E-22 and E - 23). One further point concerns the evidence concerning the element beryl liu rr, to the testing of " beryllium metal". Since beryllium seems to oxidize reac!ily, it Is not clear tone whether this vas pure metal or metal particles coated with beryl liu in oxide.I am sure that the experts at NIOSH could clarify this point. The animal studies indicate to me that all compounds or alloys of beryllium and all particle sizes of any one campound or alloy may not pose an equal hazard to man, This would suggest that any standard for hwan exposure based solely on total beryllium content of the air,ignoring the f om In which it is present, may not protect all workers equally.