Document 10nR43nG4jvNRvQxxQb4N3Oo

3By._ PLAINTIFFS EXHIBIT monism. -------------a -2 - A. 005-12 / ,7/. ^ ^ y *-- PH _T Tfl Tl c /v 6/7/73 . /jSB&STOS T^XTtLl JTMST/ TcrE. I am sure chat many cf you have asked yourselves. as I have asked myself, why has eke asbestos industry seemingly been singled out as the prime target for so many assults by government, labor, the press, certain segments of the medical procession, and by various environmental and consumer activist groups? Why us? Can asbestos really be ail that bad? Are the products we produce -truly going to kill millions of Americans, as seme experts have predicted? Cm is there seme sort of nefarious conspiracy afoot to destroy the asbestos industry? The answer to the question of "Why us" is both complex and simple. Complex because it :s a combination cf three interrelated but separate factors. simple because each of the factors is, when considered by itself, quits envious. The three factors ere <Li asbestos rtusss disease. (2) a spokesman arose to champion the need ::: csre.-ito t*Si PLAINTIFFS EXHIBIT IW-0OOM5 -3- IlMWTIiTWn ---'SS&Ij sra and"'(3} a"cornucopia of'new government agendas were-secu? :ro: control things'that cause' disease.--'Lac us lock at each.of these 'factors in'`turn............. '...... - - : fctv- "............ First, there is no doubt that the inhalation of substantial amounts of asbestos can lead to increased rates of various types c lung disease, including two forms of cancer. These are facts which cannot be denied, even if they do not apply" in' all "circumstances -ar.d under all conditions.. ;The medical literature is full of solid- evidence linking asbestos to disease. In my office, I have on file mere char. 2,COO IL medical papers dealing with the health risks of asbestos an hundreds more are published every year. Secondly, the spreading of alarm ever the health risk: of asbestos has as its prime spokesman one of the most talontad medical publicists of the age ------- Dr. Irving J. Seiikaii if Now Vork's hor.nt Sinai Hospital. Not only is Dr. Selikoff *%*: V. capable of arousing the ire and -oral indignation of the tost conser.vajcive.reporter or..politician with his graphic description: ____ and predict,ions of the ravages of asbestos, but he has also surrounded himself with a group of similarly talented public!tyccnscious. associates who have carried the Mount Sinai message ..to the far corners of. .the nation. While Dr. Selikoff has, in his seal, unquestionally . painted a far darker picture than the facts warrant, we should always remember, an his defense that the insulation workers he has been studying for more than a decade were and still are dying from asbestos related disease at an appalling rate. This would be enough to cloud any man's thinking. finally, in the cast dacada there has baer. a tre.mandcuus g.row-h in public and governmental interest in environmental and occupational health matters. This interest has been translated into a series of far-reaching laws affecting indus__ / in::*: jwnr.er hither-co in this or. any ocher country, trbeiiaxe-.-i t cis accurate. _to .say that these new laws, such as:rtilft.-5ccu?aciqnaltSa_fety ,and .Health Act, the Clean Air Act, the.Consumer.protection Act, and .others, have forever altered the: concept;.oc the free enterprise system as it was known in this country, for a hundred and forty years Thus, in combination, these three factors created a. situation,in which a cadre of freshly created federal agencies with strong, statutory authority, were prodded into assigning .priority.status to asbestos by Dr. Selikcff and his rollovers, who used.and in some cases misused the great wealth of .negative asbestos-health data contained in the medical literature to achieve these.ends. rrIn- short, che asbestos industry was singled out .because it was vulnerable to attack, because there was scmecr.e willing, almost anxious, to lead that attack, ar.c because Congress had graciously provided the vehicles for such an assaul 6 Kcvr much of what Dr. Solikoff says about asbestos i. true, and the manner in which he has abused the available mec: data in order to blew up an essentially occupational problem into a national calamity are topics which we shall examine a bit later. The background cf industry efforts to deal with the asbestos-health problem as a national issue goes back nearly m a decade, to Dr. Selikoff'a now famous 1964 seminar on asbestci disease at the Mew fork Academy of Sciences. While this serina did much to prick the industry's conscience about asbestos and health, the problem still remained one of limited public and press interest until around 1967, when the media began beating the medical bushes searching for stories that would graphically portray American industry's supposed complete disregard for the environment and for the health and safety of izs workmen and the American public. The asbestos-health problem was found 7 to be tailor-made for.such stories and Dr. Selikcff was r.ot hesitant in-'catering-, to-the sensationalist whims o: the press. As a~resu-l.t,-.sxa.rti.ng_with. Paul 3rodeur's ir.far.cus Mev/ Yorker artioT-ef of .-Mar-ch 1962asbestos has since grown into an item or major cress interest. In these years, industry efforts to combat the spate of negative press articles on asbestos were carried on primarily by the Johns-Mar.viiie' Corporation, which set up a task force of specialists in various fields to do what it could to portray the;problem-in.its proper, perspective. While scr.a minor successes v/ere achieved, it was found that no one company acting independently could, adequately or effectively represent an er.tir industry-in-dealing with-the press and with government officials As a-result,, in late 1970 , eight companies gathered in New York- City to launch the Asbestos Information Association of North America, which was frankly patterned after the British Asbestos Information Committee, which had been established sene three years earlier In our original concept, the Association would lini: its activities to providing accurate, unbiased infcreation on asbestos and health to the press, to the public and to interested politicians and other government oifiicals. It must be remembers that at this particular time, the enormous problems that would later develop with regard to OSHA and other Federal regulatory agencies were as yet on the distant horizon and basically unrecognized by the industry. Fortunately----- and properly --- the Association has had the wisdom to alter its original limited concept of i: proper functions, and now endeavors to assume whatever activities and responsibilities it deems necessary to protect the interests of the asbestez manufacturing industry m the United Stat es 9 From our ra.tr.er narrow initial public relations concept the Association has grown in the last two years, into an organization with priorities in eight major fields_pf endeavor. These are: Medical Affairs Legal Affairs Government-'Affa-irs ` : Environmental Control Publicity and Public.Relations Customer Relations........... Employee Relations, and Inter-industry Relations In briefly discussing AIA activities in each or these fields, I will leave government affairs for last. *ot because.t has a low priority within the Association ----- in f act at is currently the most important ----- but becaus e it is the most complicated and requires the most discussion. 10 Tl o taka our activi_ties or.e at a time then...................... medical affairs. It is an obvious fact chat if an organization is to soeak authoritatively on a medical matter, it must not only be seeped in the literature of that particular medical subject, but it must also- keep itself constantly informed of new discover: and developments. This we have accomplished in a number of ways. For example, .by sending representatives to important medical' ! meetings,"Such as the' 1972 international conference on the biological effects of asbestos held at Lyon in France, which was sponsored by World Health Organization. .Both John Marsh, the President cf the AIA, and I attended th^t ^conference. or. behalf .of . the Association. We also meet an an irregular .basis with various medic'ai .experts in the field, both from the United States and abroad, Mi L - 11 - Our literature research is eased considerably by receiving.. che..nanchly medical paper distribution pi the Inscicute..of Occupational and Environmental Health in Montreal, which is .funded by the Quebec Asbestos Mining Association. ..... ...This _year, for the first time, the AIA has elected to sponsor medical research of its own. Currently underway is a completely AIA/MA funded study of chest sounds, which is being conducted by 2r. Raymond Murphy of the Harvard School of Public Health. Che purpose of the study is to find a new method of determining an individual's potential susceptibility to asbestos Che Association has also recently decided to contribute to..soma very exciting research into a possible cure fer mesothelioma through electromotive treatment. Chis study is -being concurred at Somerset Hospital in Mew Jersey. In the legal affairs area, the Association particioated in an"amicus curai capacity in the law suit brought by the - 12 - e " T:' :: )) Industrial Union Department of. the AFL/CIC against the * Occupational-Safety and Keaith Administration on the asbestos ; - ift ` T-A: standards. In 'our"'brief/ which was considered by the Justice Department to be-the'best one filed, the Association supported OSHA.against'the IUO, somewhat of a unique position for an industry to .find itself in vis-a-vis a ..governmental-regulator*/-'-"5-- :-r; in ii.hii'k(\l Mil si r'tl|d. I agency. Oral argument on _the_case -was held April 4 in Washington While a decision has yet to be handed down by the Court of Appeals, we are confident that the case will be decided in our favor. The Association has retained the services of C. L. IrI-. !i , !:i i iiS i 111: Shechler, with whom many cf you are familiar, as cur special consultant cn environmental control affairs. At the eraser.t time, Cliff is wording with the AI A/:.'A Invircnmantal Control Sub-Committee cn the development of a -series of five Association > -l : i'5t-\ 'v- 1 ji compliance manuals on the OSHA standards. We expect to have these manuals available within a short teriod of time. - 13 - - -- 'La'sc yearv-bccau-se of- the-well established ur.reliability wfVh*jatebrinte^ fi-i-Vsr-me-thod-ets-a-moni co-ring tccrl 'ihr the' asbestos *y~s "Industry, the^ AiA'iandortboh' the'-sobr/so-rsh-ip' of a- study at a "'`research laboratory In California to"dater.-aine -the effect of "" certain'variables' cn the overall accuracy of the method. The "" results -of the s tudy showed "an error factor of plus or minus "'*'50 per cent under the most favorable of measuring conditions* "These results were sent to" both GSHA and to the .National Institute for Occupational Safety and Health. A number of the recommendations' contained in the study for improving the accuracy of the method have been incorporated into a sccr.-co' - be^re'leased revised NICSH opera-tens manual on fiber ccuntino. In the customer relations area, the total effect of negative'press publicity and government regulations or. i.-.dustrv customers is still today rather poorly defined. Some membero -o: cne Association have reported serious proolems in this area while others have experienced fev. or r.c difficulties thus. far. into one of five categories. First, the customer has thoroughly investigated his situation and has found that he can no longer afford to continue using asbestos or asbestos-containing products, either because the cost of control is too high or because he would have to raise the price of his product to a level that-would make if non-competitive with non-asbestos containing substitutes. Sec o continue using asbestos he customer has read ono or mere negative articles on asbestos in decision that "we oug get that dangerous management by ill-informed medical adv ers or safety and health directors IS Four, the customer has neither a control problem nor is he particularly afraid of using asbestos in his own plant. However, he is fearful that those of his ccxtpeticiors whose finished products do net contain asbestos will stress the adverse health effects of asbestos in crying to cake business away from him. Customer fears of this nacure are essencially "guc" reactions and hense extremely difficult co deal wich. And .... Five, the customer has none of chese problems or fears but he has been advised by a government official or inspector that he would be becter off if he quit using asbescos or asbestos containing products in his plane. While this problem does net appear to be widespread, we have learned cf a number of situation whore it has occurred. Actions of this nature by government officials arc totally uncalled for and should bo dealt with promptly and decisively. The best solution is to obtain ccmoiat with.the offending official's immediate superior or with the ..gpvernnent agency.involved.. .. . ___ ................The.Association!s first reaction to the overall customer relations. problem was to approve funds for a -.Ties- of four regional seminars at which industry customers would be given a number of basic presentations on the various aspects m . of the asbestos-health problem. The seminars were tentatively scheduled.for the Spring of_this year. However, the experiences of a number of cur member .companies shewed that general catchall type seminars of the -.type originally contemplated would.net be effective in dealing .with the majority of customer relations problems. In order to do the job properly, it was found that customer presentation .have to be tailored to the needs and problems of the individual customer - 17 - As a result, the Associaton cancelled its scheduled t series of seminars and instead elected to develop a nunder of packaged slide presentations on such -top. 'ic__s_ a.s...."..T..h...e. Fac-ts. . .A.bout Asbestos and Health," and "Understanding the OSHA Regulations," which could be used by member '<1 companies as part of a tailored presentation to individual customers. These slide presentations are still in the works, but should be available shortly. As with customer relations, the Association feels that employee relations is a problem best handled by the individual mender companies. Thus tar, the AI.Vs sole contri bution m thas area ct incus cry concern has been to oreoare the draft of an employee Safety and Health Guide or. Asb estosHealth. The draft was made available to the member com.tanies for their own use and at least or.e, Raybestcs-Manhatten, has 13&.' produced it in booklet form for distribution to all its em.tlcve I personally believe that the employee relations aspect or the asbestos-health problem is one that has been sorely neglected by most companies within the industry. I feel that this could develop into a major problem area in the near future "and that steps should be taken now to deal with it. We know that Or. Selikoff and various organized labor groups are planning a full scale campaign to bring their interpretation "of the asbestos-health problem to the attention of asbestos industry employees throughout the nation. If the industry permits this interpretation to be disseminated unchallenged, the consequences could be grave indeed. the .industry inioraed vabout..important new developments cn the governmental, medical ar.d press relations fronts that affect asbestos. This is accomplished within the AIA by periodic distributions of documents ar.d information to the member companies and to others cn our mailing list. The value of this octroity con be gagued by the fac that our overall mailing list increased from approximately a doren namos in 1971 to more than 60 a year later. While we have hud to trim the list somewhat this year for logistical 20 reasons, we assume from the frequent requests we still receive to be placed on the list that the material we send out is being read and is of considerable value to these receiving it. Next to government affairs, our public relations and publicity, actitities constitute the single largest consumer of tine, effort and money within the Association. Those of you who are familiar with the treatment that asbestos has been * receiving in the public press over the years can readily understand why this activity ranks so high on our priority lis What you may not understand are the reasons why cur extensive efforts in dealing with the nation's cress have been so unsuccessful to cate in prod r.g the theoretica "balanced- cr "positive- story on asbestos and hea 21 - -,, .Tii.e simple: ..f-.act::is. that :fr-on the standpoint of today' s;young. ao.tivist..-reporrarr -industry- is -the bad guy/ and nothin? we do,say or achiaye; can ever change this impression. If we spend 5100 million: dollars on. environmental- control, the press either sayswe ought.to have,done-it ten-years ago- or that ye should .have spent 200 million. If.we sponsor medical research, they say we are.trying to buy favorable ........-- - . results. Id we are opposed to ridiculously stringent standards, they say. we_.are in favor of letting our employees die. A television executive in Minneapolis described this new breed of reporter as being "so intent on demolishing the establishment that they.would. blindly destroy the credibility of the media in the bargain." Another TV executive, this time in Chicago, stated "they want to make moral and political * and social judgments on their assignments and then take sides. Never mind getting the facts straight." ^ 22 ' As*a* result' of ' this-" industry is a..monster* philosophy asbestos "will'remain a'hot'news-item only so. long, as the,news is bad. The'*gccd"`that asbestos does-ih protecting lives and property is of no* concern to the press-.- Likewise, industry efforts to protect workmen and the general public from asbestos .. , exposure will always be given minimal coverage, since such informat:Lon is directly contrary to the portrait of an irresponsible industry producing a "killer* product.that is the sole element of*hews worthiness in the asbestos story. The press relations -battle will, therefore be won. not when the media starts to print positive or balanced articles about asbestos, but-when the press ceases to print anything about asbestos at all. As long as negative news on asbestos-health continues to be generated, the media will continue to eat it uupp. The media wall only cease to carry it is as sir.ole as that. Positive or balanced stories are a chimera, since they are, by definition, not newsworthy. Let tie give you a very specific example of this last principle in action. As most of you already know, the Association is currently engaged in an extensive campaign to "interest the trade press in articles on the benefits of asbestos and on industry accomplishments in the environmental control area. The trade press, unlike the national or public media, is much more receptive to articles of this nature and we expect to be seeing a number or positive stories m me trade press in the next few months. In any case, we also from time to time put out press releases on various subjects relating to asbestos-bealth. few weeks "ago, we issUXad a release cn the report of m.e advisory committe "on asbastcs cancers cf the World Health Crganiration. brief, the resort concluded that the general public is not in danger from asbestos in the environment. Thus far, we have 2-l' rec ived nearly two dozen press clippings iron trade publicatic that carried the story. To the best of our knowledge, not a newspaper, news magazine, radio or TV station, or any other segment of the public media ran the story, with the single exception of a French language paper in Toronto. As I said before, if the news is good, the press ain't interested. Nonetheless, the Association has no intention of abandoning our efforts vis-a-vis'the national'media. We will continue to issue appropriate press releases, cooperate with feature writers doing stories on asbestos., write scathing letters to the editor when those stories appear, and in short, do all we can to present the press with, a balanced view of the asbestos-health situation. Cur most recent effort in this regard has beer, the preparation and printing of an Asbestos and health Information Fil-*,--which -we--have mailed to scr.e j,CC3 newspapers, magazines. ----TiriiTTr- trade publications, radio and" TV stations,' science "writers'etc across the United States, -i have"brought"a"half-dozen files along with ire that you can take a look at" after the 'meeting. Basically, the file contains copies of the five industry position papers which were distributed'earlier, as well as a number of important medical papers and a pair of photographs illustrating the benefits of asbestos and industry efforts at m environmental control. You may-be interested to know that tha item chosen to iilus'crace the benefits of asbestos is a fire-proof asbestos suit. While we don't expect our information file to change the whole attitude of the press toward asbestos, we are hoping that tha media will make use of it to.accurately report the industry's position when doing stories c.n the subject. knc. new, having heard the bad side of the public relations problem, it's time for tha good news. 26 And the good news is .... despite all the negative articles on asbestos-health that have appeared in the press over the past half-dozen years, very few people have been ^gying attention. Let rse explain. , ... In February, the Association undertook a personal interview research survey of the American public to determine its attitude toward asbestos and its awareness of the health issue. The survey was conducted by the Opinion Research Corporation during March and April. More than 2,0CC dencgraphicaily selected Americans were interviewed. I have . here with ne sufficient copies for all of you of a summary of the results. { comment FROM-SUMMARY ) Before going on to describe cur activities in the government relations area, I think it might be interesting at this point to take a very brief Ieoh at the manner in which Or. Selikoff and his supporters have used his research results cc drarcatice and exaggerate the seriousness of the asbestos-health problem. I have "two slides which point this out 'r'athef' conclusively. SLIDE 1------- RESEARCH DATA The first slide shows the actual results of Dr. Selikof four mortality studies of asbestos workers. The numbers in " parenthesis beside the figures for total number of workers indicate these who have so far died from all causes. The percentage figures alongside the total number of deaths from asbestosis, lung cancer and mesothelioma are based on the total number cf deaths from all causes, not on the number of workers in the study. The most mportant study of the lot is the second from the top, show *g -..e deaths from asbestos-related disease among all members f the insulation workers union, regardless - 23 - o length of exposure, Tou will- nota that 34 per cent of those workers who have died thus far have died from one of the three asbestos-related diseases. These, then, are the facts Dr. Selikoff works frets. This is. what he knows from his own investigations. Now let us take a look at what he has done with these figures in order to dramatize the problem. SLID! 2 ------- PREDICTIONS This slide shows Dr. Selikoffs predictions about asbestos-related deaths in the United States. Without going into details, Dr. Selikoff has arrived at his projections by the simple procedure of multiplying the percentage of deaths from asbestos-related disease among his insulation workers by tha. total number of employees in the entire industry. h M MS-. - 29 - You will also note that ha has raised his projected death estimate to enormous heights over the past year hy ST1'-- simply increasing the base figure of employees exposed, while still retaining the orecentage multiplier of 14 per cent being experienced by the insulation workers. I might point out that this tactic, however improper and deceptive, has baen an enornous success since each raising of the. estimate has earned Dr. Selikoff -correspondingly grater coverage by the media. No finer example exists of the total gullibility of the press char, the manner in which Dr. Selikoff manipulated and played on their prejudices to gain publicity. I can readily envision the let of them up there at Mount Sinai laughing themselves silly over the ease with which they bamboozled the trass with these trumoed-uo predictions. 30 Please .den't get me wrong, gentlemen. 1 have little -doubt .that .the insulation .workers are in fact dying as rapidly _aa Dr.,Selikoff says .they .are. .The. problem is he has translate their mortality experience to the rest of the entire industry, .which is absolutely ridiculous. .In. the..first place, the. estimated number of employees in the industry is too high ----- five times too high to be precise. . Even more important, according to an analysis by the Association of more than a coten mortality studies, including those of Dr. Seiikoff, our prediction is that approximately 25,000 past and present employees in the asbestos industry have died or will eventually die of asbestos-related disease. This is leas than one-thirteenth of Dr. Seiikoff s most recent estimate.. In addition, our figures shew that 20 of the 25,000 deaths ------ or 30 per cent ---- will occur among these in tha insulation trades. - 31 - While these estimates should be reassuring to these of us in the raining and manufacturing areas of the industry, we should not forget that 5,000 of our workmen are still going to die of asbestos-related disease and that, all things . considered, there is absolutely nothing that we can do to ^ prevent it. The only thing we can do is to clean up our plants to assure that those entering the industry in the future will not have the'same experience. SLIDE 3 ------- GOVERNMENT AGENCIES Within the past year a :d a half, the main thrust of Association effort has shifted to the government affairs front. The principal agencies in Washington with which we have been dealing are, of course, the Occupational Safety and Health Administration; the Environmental Protection Agency; the Feed and Drag Administration; the Bureau of Mines; and, to a lesser degree, the National Institute of Occupational Safety and Health, 32 and the National Institutes of Health, both cf which are .,,, . ... * I* - " , mainly involved in research efforts. * In addition,*a few weeks ago we were contacted by the Federal Trade Commission, which had received a petition from the Center for Science in the Public Interest requesting an investigation of consumer uses of asbestos for the purpose of determining whether certain products ought to be labeled as hazardous and whether warnings should be required on all advertisements for those products. On the basis of my meeting with an investigator from the FTC I would say that we have little to worry about in this particular area. SLICE 4------- OSHA ... The Occupational Safety and Health Administration has been of enormous concern to the industry over the past 13 months. As most of you already know, the Association expended tremendous efforts during the six month period 33 leading'to cho promulgation of last 'June's OSHA standard's on asbestos-.-- I think it is a`gauge of the effectiveness of the total industry involvement in this most crucial matter that of eleven main-requirements 'in the standards, the'industry position"was -accepted totally by"OSHA on nine of the eleven, about fifty percent--ton a ;tcrrth-, "and totally rejected on only one. -- Now-, of- course,- OSHA is planning to redo the standard package and we- are working closely with them on this project. The first step-will be-the-formation'of`a IS man advisory connittea-to review'the current standards and any additional data and- information that has been developed in the year since the standards were promulgated. Working-in cooperation with nine other trade associations, including your own, we-have selected four.individuals as industry wide recommendations to OSHA for the" "four so-called employer spots on the advisory committee. The four pecplo selected were Guy Gabrieiscn, President of Nicolet; Ike Weaver of Raybestos-Manha.ttan; or. Fred Pundsack, Vica President for Research and Development of Johns-Manvilia; and Cliff Sheckler In discussing the formation of the advisory committee with John O'Neill of the OSKA Standards Development Section,' we were asked to add a couple of names to the list so that OSHA would have at least the semblan.ee of a selection. This we have agreed to do. The committee will be given up to nine months to complete tis deliberations and prepare for CSHA a revised standard package. This will be followed by public hearings, approximately a year from new. We do not expect to see a - -* new standard promulgated before the Fall of 1974. 35 It is of course impossible to determine at this time whitJtiveLr.ew standards will lock like, however, I would venture to say chat they will certainly not be less strict than the ones we have today, although they will probably be less contusing and leave less room tor employer interpretation. Something will unquestionably be done to improve the current difficulties with the monitoring requirements. SLIDE 5 ------- NIOSH These slides, by the way, are merely simplified, organisation charts of the various agencies with which we deal in Washington. The r.3in function of the National Institute for 'O'ccupational Safety and Health is to conduct research and to prepare so-called Criteria Packages, which' are essentially recommendations to CSHA for standards on various materials by NIOSH at the time of the.OSHA proceedings last year, NICSH will.not he preparing.a new or revised criteria package for the upcoming review of the asbestos standards. I do not believe it would be unfair to say that of all the agencies in Washington dealing with asbestos, Dr,.Selikoff has had his greatest influence on the young idealistic scientists and doctors at NIOSK. Consequently, industry influence is weakest in this agency. It was NIOSK, after all, that made the original recommendation for a two fiber, standard in the asbestos industry. SLIIS 6------- EPA Next to OSKA, the Environmental Protection Agency ha., the. greatest potential of any federal agency for adversely affecting the future cf the asbestos industry in this ccuntrv. Not only is the EPA responsible for developing and er.fcrcir.c air and water pollution standards, but the TCXiC Subs canoes 37 Control Act, new p'ending ir.~ Congress-,- will. also, become an EPA i function after passage. ~... . ....... .. ..... For this reason, I am pleased to be able to say that the asbestos industry has an excellent relationship with the EPA. No finer proof of this- exists than the fact that there was not a single major industry recommendation or suggestion Dade to the EPA at the public hearings on the proposed asbestos emission regulations that was not accepted either in toto or in principle*in the final" standardswhich.were published in early April of this year. We are presently working with the EPA on the development of waste -water effluent standards for asbestos manufacturing plants. We fully expect that these standards will turn out to be as reasonable as the air pollution regulations. The proposed effluent standard's are scheduled to be published in the Federal Regisue in early July. This will be followed by 3S public hearings, probably in late July or August, with tha final standards being promulgated in the Fall, perhaps as early as October. We are also planning, in the near future, to meet in Washington with representatives from the standards development and enforcement branches or the E?A to discuss with them questions of interpretation and compliance policy with regard to the new air pollution regulations. We have already resolved one interpretation question that is of special interest to the asbestos textile industry. Approximately two weeks ago I was asked by a member company of the Association to find out whether the ZPA was planning to require the manufacturers of asbestos safety clothing to register as potential emission sources under the law. li ` i: l iI J fI !: r !>!' til \u .;i \ 39 In discussing the situition ever the phene with Z?A compliance officials,' T argued that the producers of asbestos safety clothing were not manufacturers as defined in the regulations''but were instead only fabricatiors of an asbestos product,'and as such, should not have-'to register as potential emission sources."' --- v -- After our phone conversation ended, a brief meeting was held among the EPA compliance people. I was then called back and informed that they agreed with me that the safety clothing producers should not be required to register. While this rather minor problem cook approximately an hour and a half and two or three phone calls to resolve, it is indicative of the type of day-to-day'services that the Association provides for its member companies. 40 " SLIDE 7------- FOA 'over the past year the Food and Drug Administration has shown an increasing interest in asbestos as a possible hazardous contaminant in various foods, beverages and drugs. Late in 1972 they set up an asbestos task force to review the situation and to propose regulations and guidelines where appropriate. Thus far they hava concentrated their efforts in two areas --- on the use of asbestos-contaminated talc in food packaging and in cosmetics, and secondly, on the use of asbestos celuiose filter pads in the beverage and drug industries. In our first meeting with the FDA task force last November on the filter problem, they demonstrated an appalling ignorance about the. health hazards of asbestos. Since then, they have gotten one heck of a lot smarter, due at least in part to the tremendous amount of data and information which 41 the Association has been supplying to them. As a ccnsccuo: the FDA i3 today less panicky about asbestos and therefore less likely to propose fooiish, ur.supportabie regulations. Spokesmen from the FDA have, in fact, defended the filter ir. against environmentalist attacks in the press and elsewhere recent months. This is, quite obviously, a healthy sign. SLIDE 8 ------- INTEREST GROUPS Since our contacts with the National Institutes of I Health have been o* uite mi.n, imal, and since the health and safety section of the Bureau of Mines is presently being I reorganised, we can now proceed to take a brief look at the i various intorast groups that have been in the forefront of the assault on asbestos. These are the groups and erganirati. that constitute "tha other sida." As you can see, there are a lot of them, and between then they can exert powerful pressure on legislators and - administrators at all levels of government. \ 42 - Sir.ce time is not available to discuss each of their activities and philosophies' in detail, I would like to say that we keep a close watch on all of them and are always prepared to take whatever action is appropriate when they step out of line. 5 LI Cl PROJECTOR CFF-------- LIGHT ON _ Our activities in the area of Congressional relations have been quite minimal to date, although we are preparing for the upcoming struggle in Congress-over workmen's compensation reform legislation, at which time asbestcs is unquestionably going to be racked over the coals by Dr- Selikoff and his compatriots in organized labor. Unfortunately, the Association has neither the manpcwe nor the tine to embark on a full-scale legislative information program. We have mat on occasion with the legislative and legal assistants to various Senators who have attacked asbestos - 43 - however r.uch .more,.needs to-be done-in this area-and I a.T. afraid individual: member ..companies, are going, to have to be the prime ball-carriers-and:not the-Association-, t. - for essentially the same reason-,: our government 'activities at the.state and local level have declined to essentially zerpioverthe"past year and a.half. This has not been too serious-a deficiency as most of the authority of m the cities and states in asbestos control has been usurped by .the .various Federal regulatory agencies. Nonetheless, mere individual company activity, is required at these levels of government. .In conclusion, I think we can all be justifiably * pleased with what, we have been able to. accomplish in the cast few years in resolving, .the cornucopia, of interrelated problems that constitute the asbestos-health situation. 44 ' :Cur'- plants are-c leaner- and our workmen. better protected. The general public--has-been-shown to:ba in. no danger froa asbestos>;i;f if ever was.- While- we have been regulated extensively, for the most part the standards that have been `j developed have act been as bad as wa feared.they night be, and in'scme cases" they turned cut far better than we ever dared hope. In addition, while we are still.taking our lumps in tha public press, the net effect of all this adverse publicity has-been shown to be-surprisingly small. ----- -We have sweated a lot and we have groaned a lot, but we are still standing and we are still viable. I sense today within the industry a. greater feeling of confidence in the future than at any time in tha past few years. But we must not'rase contented.- - IfTlMT tL 45 - *4J0i ' llTWfrt--TftfT We must remember that Dr. Sclikofi has to data teen far less successful than our industry has in influencing the decisions of the various governmental regulatory agencies, v This will make him try harder. Just last week 1 saw a speech s of his in which he purposely misinterpreted soma data by a distinguished'British scientist in order to prove that even two fibers is not a sufficiently safe level for occupational m exposure to asbestos. The struggle is far from over. We must not only continue but indeed expand cur activities in the various areas of concern if we are to assure the future well-being of the asbestos industry in the United States. Thank you very much. A ijt` i- i m * -?5 ;,h+;-i?w. m :& ' U *tSL riirnFiiatiiiiiirTIWl