Document 2RJGRDdYqn6B9Oz2O9gJRQq2b
FILE NAME: Kentile (KEN) DATE: 1973 June 7 DOC#: KEN017 DOCUMENT DESCRIPTION: Internal Report - Asbestos
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/Qs g g s t o s Z i * -2LWAh>77 t u t ,
1 am sure that ?-ir.y cs you have asked yourselves.
as Z have asked nvseif. vhv
rn- . ,u
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-a s t..e asbestos industry seemi--
-b--een
sin-gledout
as
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ec^-ee _ --->--se
target
f,,or
so
Any assuits by
government, labor, " -e n-.,t
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* P-a s s , .attain segments or the medical
profession, and by various environments' a-d -on '
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-- a*.c onsmsteer activist
groups?
Why us? Can asbestos 53 r M l .-y fce ai- that bad? Are
the products we produce -c-- 'v
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-- . fgoi.., .o *i^l millions of American
as seme experts have predicted? ct- i3 shara seme sort of nefari
.conspiracy afoot to destroy t-e -*---
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1 "e --- Oj.oa industry?
a answer to the cucst'o* of "Why us* is both complex
and simple. Co.tt.t=1le5x because it i3 3
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'-o..ri_.ia.tion co three
interrelated but separate -,c--- - .. . * 31--?-i because each of* r.he
factors is, whan considered by --so'-- .... " -- "--Ate oovious.
rhd !ii" fAe::rs a-e (1) ashes--.- -_-_-_-__ C,lS&a*c* a/
(2) a spokesman arose to char--n
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c- n L..0 noun for tsa.f.soos c=.-.--~i .. - <
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and
'cornucopia or'new government agencies vera-set. u? ino-,..
ccnVroi tilings'chic cius''disease.-" Lee us:lock -at each.oi
' thes'e Ykceor's in'trn....
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:::. :- :Tirsc, there is -no doubt that the inhalation o: ,
substantial amounts of asbestos can lead to increased races of
various types of lung'disease* including two forms of cancer.
These are facts which car.nct he denied, even if they do not
apply'in' all'circumstancesand under all conditions..;The
medical literature is full of solid- evidence, linking asbestos
to disease. In my office, I have on rile more char. 2,COO
medical papers dealing with the health risks of asbestos and
hundreds more are published every year.
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Secondly, the spreading or alarm ever the heal:
of asbestos has as its prime spokesman c.-.e of the most talented medical publicists of the age --- Dr. Irving J. Selikoff ar
Kew Vork's hount Sir.ai Hospital. iioc only is Or. Selikoff
f u m a i.
capable of arousing the ire and "oral indignation of the mast'
cor.ser_va.tiye .reporter o;g.politician with his graphic descriptii
__ar.d predictions of the ravages of asbestos, .hut ha has also >
surrounded hi.tseif with a group or similarly talented publiciv
conscious, associates who have carried the .Mount Sinai message
.to the car corners or. the natron.
While Dr. Selikoff has, in his teal, unquestior.aily '
painted a far darker picture_ than the farts warrant, we should
ilvays remember, an. his defense that the insulation workers h<
"has been studying for more than a decade were and still are
j dying froa asbcstts related disease at an appalling rate.
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This would be enough to cloud any man's thinking.
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. Finally, in the past decade there has keen a -t
growth in cue lie and governmental interest in envirar_T.cn
and occupational health matters. This interest has been
translated into a scries of far-reaching lave affecting ,
ras;
i^wiaswcaas.
jw.r.erhith-ar-to, unknown in this or any ocher country. ;
Lrbelda.^3 ;df.tais accurate t,a say .that these new laws, such
as:rthft.^ccup.atiqnal ..Safety .and .Health Act, the Clean Air Act,
the. Cor-surier. protection Act, ati jo.thers, have forever altered
the.car.cept-ot the free enterprise system as it was known in
this country, for, a hundred and fifty years.
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_ ... Thus,_ in combination, these three factors created
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a. situation .in which a cadre of freshly created federal agent
with strong, statutory authority, were prodded into assigning
. priority.status to asbestos by Dr. Selikcff and his followers
who used and in seme cases misused the great wealth of .negate
asbestos-health data contained in the medical literature to
.^.achieve these, ends. - ...
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-- t I n :short, the asbestos industry was singled cut
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.because.it was vulnerable to attack, because there was sor.ee:
willing, almost anntoub. to lead that attack, ar.a because
Congress had graciously provided the vehicle.* for such an as:
. How much of vhao Dr. Selikarf says about asbesto
true, and the manner in which he has abused the available (
data in order ta blew up an essentially occupational prcblc
into a national calamity'are topics which we shall examine
bit later.
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The background of industry efforts to deal with ti asbestos-health problem as a national issue goes back nearly
a decade, to ur. Selikoffs now famous 19o4 seminar on asbes
disease at t..e hew York Academy or Sciences. While this sen* did much to prick the industry's conscience about asbestos ar health, the problem still remained or.a or limited oubiic and press interest until around 1957, when oka madia began beatir the medical bushes searching for sconces that would greohira! P-- -- 'waer-Cia.industry *s supposed complete disregarJ .^ the environment and ror the health and safacy of its workmen and tko American..public. The asbestos-health problem was
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to be tailor-mada for such stories ar.d Dr. Selikcff was r.oc
hesitant in-'catering-.to-the sensationalist whins of the presi
As a--resu-lc,--smarting,with. Paul Brodeur's ir.far.cus New Yorka:
artidl'-e of march..1963,. asbestos has since grown into an item
of major cress interest......
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In these years, industry efforts to combat the spat
of negative press articles on asbestos were carried on primar
by the Johns-Mar.ville' Corporation, which set up a task force ;
of specialists in various fields to do vhac it could to porrr,
the-problem-in.its proper perspective. While seme minor
successes were achieved, it was found that no one company act:
independently could, adequately or effectively represent an er.'
industry-in-dealing with:the press and with government office.
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As a -result, in late 1970, eight companies gathered
Now York- City to launch the. Asbestos Information Association
vis-a-vis as=<:sao3-l;eaL;ii.
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From our rather .-.arrow ini Lai public relations'cc-
the Association has grown in the las two years^ into an .. ' ;
organization with priorities in eigh' These are:
-aeld_s_pf er.deavo:
Medical Affairs
Legal Affairs
Governnant- Affa-irs ' ;
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Environmental Control
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Publicity and Public Relations
"Customer Relations' --
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Employee Relations, and
^--er-industry Relations
In briefly discussing AIA activiti.es n each of ties;
fields, I will leave government affairs for la; / not because-
it has a low priority within the Association
fac
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currently the test intertant - but because
is the
complicated and requires the m s ;- discussion.
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To taka our activities ana at a time chan .....
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medical affairs.
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It is an obvious fact that if an organization is c
speak authoritative!.'/ on a medical matter, it must not only J
seeped in the literature or that particular medical subject,
but it must also- keep itsalf constantly informed of new disco
and developments. This we have accomplished in a number of w
For example, .by sending representativesto important medical
meetings," such as the 1371 international conference on thf
biological effects of asbestos held at iyor. in Trance, which
sponsored by World Health Organization.
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_3oth John harsh,..the President cf the a ;a , and ;
.attended that .conference_on behalf cf the Association. *
dirt" ...
also meet on an irregular .basis with various ned;
fxperts in the field, both from the United States and aoztac,
to review ar.d discuss recent develccments t.-.c cisrcvertt--
Our literature research is eased considerably by receiving-.cha.jtanthly medical paper distribution pi the Institute..pi Occupational and Environmental Health in Montreal, which is .funded by the Quebec Asbestos Mining Association.
-.This ,,year # far the first time, the AIA has elected to sponsor medical research of its own. Currently underway is a completely AIA/HA funded study of chest sounds, which is being conducted by Sr. Raymond Murphy of the Harvard School of Public Health. The purpose of the study is to ii.-.d a new uetned of determining an individual's potential susceptibility to asbestc disease... .
The Association has also recently decided to cor.zribv to..soma very exciting research into a possible cure ter mesothelioma through electromotive treatment. This study is being conducted at Somerset Hospital in Mw Jersey.
legal affairs area, the Association parzicira: tr. an" amicus curai capacity in the law suit brought by the
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Industrial Union Department of. the A?1/CIC against the
Occupational-Safecy'ahd Keaith Administration on the asbestos
standards. -"In-cur""Brief, which was considered by the Justice
Department to be-the'best one filed, the Association supported
OSKA_aa inset he IUO, somewhat of a unices position for an '
industry to .find itself in vis-a-vis .a..governmental--regulacary-'"'''
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 Appeal
we are confident chat the case will be decided in our favor.
... . The Association has retained the services of C. L.
ShecJcIer, with whommany of you are familiar, as our special consultant on environmental control affairs. At the present *
time, Cliff is wording with the AlA/h'A environmental Contre!
Sub-Committee on the'development of a series of five Associt'on compliance manuals on 'the OS-A standards. We expect to have
these manuals available within a short oeried of time.
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-iasc ye*., because of- the-well established unreiiabi:
? f t f t & r f e h r k sr
teal
thV bestow
intiussry, ,the"_&IA--undertook- -zbfe^-spoRsoriiilp: o f a- study 'a t a
-"research laboratory in^California W d e t i r i i n e - ^ a effect' of
certain Vhriablus- c .t the overall accuracy of the method. The
'-reaulta'-of-the study .hewed an error factor of plus or minus
SO per cent trader the most favorable of- measuring conditions',
-These results were sent to- ho rh OS HA and to the National
' Institute far Cccupaticr.al Safety and Health. A number of the
recommendations- contained in- the- study for improving the
accuracy or the method have been incorporated into a sccn-to-
' be-released revised NIOSS operations manual on fib
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In Z% ^ = ^ SZ ralA=ii ^ e a . the total effect of
negative-press tublioity and g o v e r n n ^ - regulationo^n indcstry
C o m e r s is' still today rather poorly defined. Some members
of the Association have reported sartaus pronlema in this area,
while others have experienced fA- or no difficulties thus, -`a-
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where cusearner problems do exist, they normally' fail~m-
into one of five categories.
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' First, the customer has thoroughly investigated his
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situation and has found that he can no longer afford to continue:
iing asbestos or asiesaas-cor.tainir.g products, either because T` ' .'iSi
the cost of control is too high or because he would have to
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:V:^ raise the trice of his product to a level that-would make it
non-competitive with non-asbestos containing substitutes.
Second, the customer has not thoroughly investigated
his situation and only thinks that he can no longer afford to _
continue using asbestos.
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Third, the customer has read one or mere negative 'MM
articles on asbestos in the public press a.-.d has made the sr.
decision that "we ought to get that dangerous stuff cut of cur
plant." Ofen, decisions of this nature are forced on top
management by ill-informed medical advisors or safety and
.th directors.
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Tour, 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 ccmpetitiors whose finished products da r.ct contain asbestos will stress the adve j-.aalth effects of asbestos in trying to take business away from him. Customer fears of this nature are essentially "gut" reactions and hense extremely difficult to deal with. And ...
Five, the customer has none of these problems or fea but he has been advised by a government official cr inspector that he would he better off if he quit using asbestos or asbes containing products in his plant. While this problem does net appear to be widespread, we have learned cr a number of si oust where it has occurred. Actions of this nature by government officials arc totally uncalled for and should be dealt with promptly and decisively. Che best solution is to cbtatr. come details cn the incident and then to register a formal complain
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with.the off ending off icial's immediate superior or with the
u,,government agency .involved. . ..
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.... ..The Association* s .firsc reaction, to the overall.
. .cusacm.ar relations.problem was to approve funds for a c r i e s
.of four regional seminars at which industry customers would
. be given a number of basic presentations on the various aspects
of the asbestos-health problem. The seminars were tentatively
. scheduled.for the Spring o f .this year.
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However, the experiences or a number of our member
. .companies showed 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
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to do the job properly, it was found that customer presentations ~
...have to be tailored to the neeos and problems of the individua'
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As a result, Che Associaton cancelled its scheduled
1 series of seminars and instead elected to develop
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.' ... , a nunder of packaged slide presentations or. such
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.topics as "The Facts About Asbestos and Health," ar.d "UnderBgggk--
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standing the OSHA Regulations," which could be used by member i
| p i companies as part of a tailored presentation to individual
affl(iT i
agRy;i - .customers. These slide presentations are still in the works, '
SgjfEii?ui1 2g??: :
but should be available shortly.
JSr~.
As with customer relations, the Association feels .
_ that employee relations is a problem best handled by the
.individual render companies. Thus far, the Al.Vs sola cor.tri-
button in this area of industry concern has beer, to treoera ?
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..the draft of an Employee Safety and Health Guide on AsbestosHealth. The draft was made available to the member conoa.-vcs for their own use and at least one, Raybestos-hanhattar., has produced it in booklet form for distribution to all its er.tlove
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I personally believe that the employee relations aspect of
'the asbestos-health problem is one that has been sorely ;'5''S
neglected by cost companies within the industry. I feel that
this could develop into a'major problem area in the near future'-
"ano that steps should be taker, now to deal with it. We know J tCEiiS -WP
that Dr. Selikoff and various organired labor groups are ?
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planning a full scale campaign to bring their interpretation Jl .-H
"'the asbestos-health problem to the attention of asbestos
industry employees throughout the nation. if the industry ;i-
permits this interpretation to be disseminated unchallenged,
the'consequences could be grave indeed.
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. _____ .Inter-industry relations are best defined as keeping
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h?.' the .industry inf armed .about important new developments en the
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-S'-, governmental, medical .and press relations fronts that affect
S'- asbestos. This is .accomplished within the AIA by periodic
distributions ci documents and information to the member
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companies and to others on our mailing list.
The value of this acticioy can be gagued by the*fact that our overall mailing list increased from approximately a docen names in 1971 to mare than 60 a year later. While we have had to trim the list somewhat this year for logistical
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reasons, we assume iron the frequent requests we still receive
to be placed on the list that the material we send out is heir
read and is or considerable value to those receiving it.
Next to government affairs, our public relations and
publicity actitities constitute the single largest consumer
or time, effort and money within the Association. Those of yo
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, list
What you may not understand are the reasons why cur
extensive efforts in dealing with the nation's cress have been
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unsuccessful to cate in producing the theoretics
balanced" cr "positive" story on ashectos and health.-
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simply ..f-Act.-L3. tiiac;f-on ,tu -
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^ ^ -w m t..e -standpoint of . *--
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g n o c h i a ?;.ve dp,say r . a siim: can ever change-this impression.
| If we spend *100. m i l l i o n ^
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ought, to have.done.it. tea-years ago-
| ^ ^ V . - - " - ^ : ^ v e . s p e n t 200 million. If.we .sponsor
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I aedical resa-ch, they say.ve are.trying to buy favorable
results, Id we are opposed to ridicu'aus'y sc-,-
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w-cu.aus.y stringent standards,
r tiieY S*Y ue-are .in. favor of 'et-ina n,,-
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our employees die.
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A relevisica executive in Minneapolis described this
tr" d
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w b l i s h m e a n that '-hey.would blindly destroy the credibility . -
* the aedia in the ba-__- - . .
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' -'cciier TV executive, this -
tine in Chicago, st..a.ted 't-heeyy wv_--... ,,ra _-a<e _sral aad
<ii^d sac si
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' 3'~^-er.ss cn their as s i g n -- s a-d j a-.-s a..d -hen take sides.
Never mind ce----rr
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-- -9 tha tacts straight.'
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'`As'a' result'of this-"industry is .a..menster" philoscph. dsbesrcs~wiii'remain .a*hoc'news -item' only so..long, as the news is bad. The""good"'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 fren asbestos exposure will always be given minimal coverage, since such information is directly contrary to the portrait of an irresponsible industry producing a 'killer* product, that is the sale element of"news worthiness ih 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 ail. As long as negative news an asbestos-health'continues to be generated, the media will continue to eat it up. The media will only cease to carry such stories when the generation of negative news ceasea ...
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it is as simple as that. Positive or balanced scories are a
chimera, since they are, by definition, not newsworthy. "
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Let re give you a very specific example of this last.
principle in action. As most of you already know, the
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Association is currently engaged in an extensive campaign to -k
interest the trade press in articles on the benefits of asbestos
and on industry accomplishments in the environmental control
area. The trada press, unlike the national or public media, `
is much more receptive to articles of this nature and we expect
to he seeing a number of positive stories in the trade cress
in the next few months.
In any case, wo also from time to time put cut press releases
on various subjects relating to asbestos-health., a few weeks ^
ago, we issued a release cn the report of the advisory committee
on asbestos cancers cf the World Health Organitac-'or ,,
brief, tha report concluded that the general public is not in
danger from asbestos in the environment. Thus far, we have
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received nearly two dozen press clippings iron trade publications
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that carried .the story. To the best of our knowledge, not a
newspaper, news aagacir.e, radio or TV station, or any other
segaent of the public media ran the story, with the single
exception oi 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 coi.-.g 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 test recent effort in this regard has beer, the
preparation and printing of an Asbestos and'ifeaith Information
Fil^, -which -we-have-thilad to seta 3.CC0 .newspapers, magazines.
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trade publications, radio and TV stations,' scianca'writers'etc
across the United States. -I have brought~a"hal'f-vizn files
along with ce that you can take a look 'after the meeting.
Basically, the file contains copies of the five industry
position papers which were distributed'earlier, as well as a
ntrier or important medical papers and a pair of photographs
illustrating the benefits of asbestos and industry efforts at
environmental control. You may be interested to know that
tha item chosen to illustrate the benefits of asbestos is a
fire-proof asbestos suit. ' "
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While we don't expect our information file to change the whole attitude of the press coward asbestos, we are hoping that tha
media will make use or it to. accurately report the industry's position when doing stories on toe subject.
And now, having hoard the bad side of the public
relations problem, it's time for the good news.
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And the good news is .... despite all the negative
articles on asbestos-health that have appeared in the oress
over the past half-dozen years, very few people have been
spying attention. Let me explain.
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In February, the Association undertook a personal
interview research survey of the American public to dstermir.
its attitude toward asbestos and its awareness of the healt
issue. The survey was conducted by the Opinion Research
Corporation during March and April. More than 2,0CC
demograph!cully selected Americans were interviewed. I have
here with na sufficient espies for all of you of a summary
of the results.
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- ( CC.'C'i.N'T FROM .St'MMARV )
Before going c.n to describe cur activities in the
government relations area, I think it mig.-.t be
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at this point to'take a very brief look at the manner in
which Dr. Selikoff and his supporters have used his research
results ta dramatise and exaggerate the seriousness of the
asbestos-health problem. I have two slides which point thisi*
out "rather' conclusively.
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S U D S 1 --- RSIARCH DATA
' The first slide shews the actual results of Dr. Seiikc
four mortality studies of asbestos workers.' The numbers in
parenthesis beside the figures far total number or workers
indicate these who have so far died from ail causes. The
percentage figures alongside the total number of deaths from \
asbestoses, lung cancer and mesothelioma are based on the
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total number cf deaths from all causes, not on the numba- oJ " "
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workers in the study.
The most important study of the.lot is tha second .
from the :cp, showing the deaths from asbestos-related disease
amcr.g all members of tha insularuen workers union, regardless
oi length of exposure. You will- note 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 Or. Selikoff works free..
This is what he kr.cws fret his own investigations. Now let
us take a look at what he has done with, these figures in
order to dramatise the problem.
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S U D S 2 --- PREDICTIONS
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This slide shews Dr. Selikoffs predictions about
asbestos-related deaths in the L'nited Scatas. Without going
into details, Dr. Selikoff has arrived at his projections by
the simple procedure of multiplying the percentage of deaths
iron asbestos-related disease among his insulation workers
by the total number of employees in the entire industry.
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You will also note that ha has raised his projected death estimate to enormous heights over the past year by simply increasing the base figure of employees exposed, while 'still retaining the precentage multiplier of 24 per cent being experienced by the insulation workers.
I might point out that this tactic, however improper and deceptive, has baen an enormous success since each raising of che. estimate has earned Dr. Seiikoff correspondingly grater coverage by the media. So finer example exists of the total gullibility of the press than the manner in which Dr. Seiikoff manipulated and played on their prejudices to gain publicity. I can readily envision the let of then up there at haunt Sinai laughing themselves silly over the easa with which they bambeotied the press with these trumoed-up predictions
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Please.den't get me wrong, gentlemen. X have little
^_jdoubt -that the insulation ,,workers are in face dying as rapidly
.^.as Dr., aiikoif _says .they .are. The.problem is he has transiats
.. their mortality experience to the rest of the entire industry,!
; ..which is absolutely ridiculous....
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.In. the.first place, the_ es time.ted number of -employees 3
in the industry is too h i g h -- five tir.es too high to be
' precise. .Even more important, according to an analysis by the
_,,Association of .tore than a cozen mortality studies, including ;
.those of Dr. Seiiko.fi, 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 ii less than.cne-thirteen.th of Dr. Seiikaff's most recent
.
...Ia fd. r - oui figures show that 20 or the 25,000
deaths -- or SO per cent -- will occur among these in the
insulation traces.
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While these estimates should be reassuring to those '
'of us i.t the raining and manufacturing areas of the industry,
we should not forget that 3,000 of our workmen are still going
to die of asbestos-related disease and that, ail things
considered, there is absolutely nothing that we can do to
prevent it. The only thing we can do is to clean up our
Hm
plants to assure that those entering the industry in the
I?;- future will not have the'same experience.
SL1~ 3 --- G O V S ACZ'JCZZS
Within the past year a 1 a half, the main thrust of
it:
' Association effort has shifted to the government affairs front.
The principal agencies in Washington with which we have been 'S
dealing are, of course, the Occupational Safety and Health
Administration; the environmental Protection Agency; the Feed
and Drug Administration; the Bureau cf Mines; and, to a lesser
dagree, the National Institute of Occupational Safety ar.d Health,i
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and the National Institutes or Health, both cf which are
mainly involved in research efforts,
In addition,-a few weeks ago we were contacted by
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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.
S H O E -S--- OSHA
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The Occupational Safety and Health Administration has bean of enormous concern to the industry over the past
13 months. As most of you already knew, the Association
expended tremendous efforts during the six.month period
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leading :to "tho promulgation oi list 'June' s OSHA standards on asbesto's-.-- I thirds it is a gauge oi the effectiveness of the total industry involvement in this most crucial matter that of eleven main-requirements''in the standardsthe'industry " position"was'accepted totally by'OSHA on nine o; the eleven^ about fifty percent--oh a :cctth',~and totally rejected on only o:
--How'-, ofcourse,- 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 m a n 'advisory' committee-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 ether trade asscciati including your own, we'have selected four individuals as indust wide recommendations to OSHA for' the"four so-called employer
34
spots on the advisory committee. The cur people selected
were Guy Gabrielscn, President of Nicolet; Ike Weaver or
Ra.ybestos-Hanha.ttan; Dr. Fred Pundsack, Vica President for
Research and Development of Johns-Hanvilla; 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 sembian.ee of a selection. This
we have agreed to do.
The committee will be civen up to nine months co
complete trs deliberations and prepare for CSKA a revised
standard package. This will be followed by public hearinos, .
approximately a year from new. Wo dc not expect to see a
*
r.aw standard promulgated before the Fall of 137 4 .
- 35 -
it is or course impossible co determine at chis
v^orjthelf.ey standards will loch like, however, I would venture
to say that, they will certainly not be less strict than the
`vv .
.. ,
. 'f.
ones we have today, although they will probably be less
. '
....... ,
....... //:.- t-.. U ."*' .... :
' ' '''
confusing and leave less room tor employer interpretation.
Something will unquestionably be done to improve the current
difficulties with the monitoring requirements.
*
SLIDE '5 ----NIOSH
'
:.' i
These slides, by the way, are merely simplified
organization charts of the various agencies with which we deal
in Washington.
The main function of the National Institute for
'Occupational Safety and eaith is to conduct research and.to
^
prepre so-called Criteria Packages, which''are essentially
-
'
'
*
-
recommendations to'CSKAfor standards on various materials
:ie.ticais. Such a package on asbestos wa's pretarcd
26
by NIQSH at'the time of the.OSHA proceedings last year. MICSH
will.not be preparing. new or revised criteria package for the
uocsning review of the asbestos standards..
...........
.
I do not believe it would be unfair to say that of
all the. agendas in Washington dealing with asbestos,
Dr...Salikoff has had his greatest influence on the young
idealistic scientists and doctors at .vroSK. Consequently, _
industry influence is weakest in this agency. It was NlCSii,
after all, that made the original reccr.cer.dation for a two
fiber standard in the asbestos industry.
SX-TDS S --- E?A Next to OSfiA, the Environmental Protection Agency ha. the. greatest potential of any federal agency for adversely dfecrir.g tha future of the asbestos industry in this country.
h'Q0 only as t.na EPA. responsible or develcoi.tg and er.rcrdnr
atr and water pollution standards, but the Coxae Substances
37
Control Act, new pending ir." Congres-s-,. will.also, become an EPA unction at ter passage.
For this reason, I am pleased'to la able to say that the asbestos industry has an excellent relationship with the EPA. No finer proof o'f this- exists than the fact that there was not a single major industry recommendation or suggestion . made 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" standards ,which, were published in
Wa are presently working with the EPA on the developmen 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 oublished -the Federal Register in early July. This will be folicwad by
3S
public hearings, probably in late July or August, with the
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 of 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 cr.e interpretation question
that is of special interest to the asbestos textile industry.
Approximately two weeks ago I was asked by a member company c;
the Association to find out whether the 2?a was planning to require the manufacturers of asbestos safety clothing to
register as potential emission sources under the law.
In discussing the situation ever the phene with
'-i
compliance officials,'T argued chat the producers of asbestos safety clothing wera not manufacturers as defined in the regulations''but were'"instead only ;fabricatiors of an asbestos 'product/'arid as 'such, should not have -co register as potential' emission sources.*'
' After our phone conversation ended, a brief meeting ~k
was held among the EPA compliance people. I -was then called j bach and informed chat 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 tnroe phone calls to resolve, ; it is indicative of the type of day-to-duy services that the I
m Association orevides for its member ccmoanies. .
*C
'
" SLIDE 7 ---- FDA
Over the oast year the Food and Drug Administration
has shown an increasing interest in asbestos as a passible
hazardous contaminant in various foods, beverages and drugs.
Late in 1972 they sec up an asbestos task force to review the
situation and to propose regulations and guidelines where
appropriate.
.
.
Thus far they have concentrated their efforts in two
a r e a s -- on the use of asbestos-contaminated talc in food
packaging and in cosmetics, and secondly, on the use of asbest
celulose 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
igaoranca about the health hazards of asbestos. Since then,
they hava gotten one heck cf a lot smarter, due at least in
part to the tremendous amount of data and information which
- 41
tha Association has been supplying to chert. As a cense
the FDA is today less panicky about asbestos and therefc
less likely to propose foolish, ur.supportable regulation
Spokesmen from the FCA have, in fact, defended the filter
against environmentalist attacks in the press and elsewha
recent months. This is, cuita obviously, a healthy sign?
S L ID 2 8 ------- IJJTSRSST CROUPS
iff
Since our contacts with the National Institutes <
Health have been quite minimal, and since the health and .
safety section of the Bureau of Mines is presently being
reorganized, we can now proceed to taka a brief look at ch
various interest groups that have been in the forefront of
i-
the assault on asbestos. These are the groups and organic'
that constitute "the other side.*
.
As you can see. there are a lot af them, and betw.
them they cm, exert powerful pressure-on legislators and
administrators at all levels cf goverr..r.ant.
mPip\ M
fe? SS.
g:fO
gaWj:;; M m-
S V ' mi
mm
feeEV i
jpr;;
m
^ ^ 8 WS&
SE B apJ V i.; . | ^ 1 ||g p > .
E fgS W g C/ .*-, .
mm
|||||v f (
S g
S&fgaSn3E&fro!
W S
3?..-
W&
- 42 -
0.ySs \ iS S s l
*ir
gijj Sir.ee time'is not available to discuss each of their m M
say
that we keep a close watch on all of them and are always
prepared to cake whatever action 3 appropriate when they.
step out of line.
_
-W.=-' ......... _
' 5LID2 PROJECTOR O F F --- 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 tame asbestos is unquestionably
going to be racked over the coals by Dr. Selikofr and his
compatriots in organised labor. Unfortunately, the Association has neither the mar.psverHS
nor the time to embark cn a full-scale legislative information
program. We have met oh occasion with the legislative and
legal assistants to various ienators who have attached asbestos * ;:'i-
' ! '
M
however each..sore,needs to'be dona.in this area-and I am afraid
individual-member ..companies, are going, to have to be the prime
ball- carriers- and^not the-.Association-, r: -
.. . . . ,
;r For essentially the same reason-,:our-government 'activities at the state and local level have declined to
essentially zero.over'the"past year and a.half. This has not
been too serious-a deficiency as most of the authority of
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 oast
few years in resolving, .cha cornucopia, of interrelated problems
.- -
that constitute cha asbestos-health situation.
" ' ....
44
*' ' "cur- plants aria-cleaner-and our workmen. better prctectad.
Tha general public- has:beefv- 'shown to: be-in: no danger fron
asbestos;'l:f it' ever was.--While- we have been regulated
extensively, for the nose part the standards that have been .
\ developed have not been as bad as we feared they night be,
and in sore cases" they turned cut far better than we ever
dared hope. In addition, while we are still.taking our lumps
in the public press, the net effect of all this adverse
publicity has-been shown to ba surprisingly snail.
- - We have sweated a lot and wa have groaned a let, but
wa 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 ttr.u in tha past few years. =ut wa nust
not rest contented.- -
.
--^
"a
>c
4S -
We must remember that Dr. Sclikofr has to cate been
far i"e3s successful than our industry has in influencing the
decisions of the various governmental regulatory agencies.
v This will make him try harder. Just last weak X saw a speech
\
_ . ...
of his in which he purposely misinterpreted soma data by a
.
distinguished Eracish scientist in order to prove that even
two fibers is not a sufficiently safe level for occupational
exposure to asbestos. . '
.
' ' The struggle is far from over. We must not only
- continue but indeed expand our 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.
t.
~ fci |~|
f-
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