Document 4aYQ3z9Exx90Kge7owdrwv3E1

Occupational Safety k Health Adninis Oration Office of Consumer Affairs Room N-3635 U.S. Department of Labor Third Street and Constitution Avenue, N.W. Washington, D.C. 20210 Re: Docket # H 090 Dear Sirs: Enclosed is my Post-Hearing Comment. The statements, data and arguments in it .should not be interpreted as being those of the Nevr York University Medical Center, as an institution. H3D:nz Enclosures Yours truly. Harry 3. Demopculos, M.D. Associate Professor (for identification purposes only) rec'TM'*'' FEB 1.4 1979 R E. UCC 057465 Pest Hearing Ccrnns.nts: A Dispassionate, Scientific Heview of the Predominant Causes of the Major Lethal Cancers in People, in the United States ' by Harry 3. Denopoulos, M.D. Regarding the proposed new regulation concerning the*identification, classi fication and regulation of tonic sub stances posing a potential occupational carcinogenic risk, 'ey CSHA, docket # H C90 The coanents, data and arguments herein should not be interpreted as being those of the New 'fork University Medical Center, as an Institution ucc 057466 In* auction t have participated in the- recent OSSA. Hearings- that have focused on the proposed regulations to control carcinogens in one workplace tecause "the studies that were conducted while I was the Director cf the fledgling Cancer Center Insolence of New Jerse 7 (CINJ) in I?76 are directly relevant to the fears and concerns expressed by OSHA, the labor unions, and selected academicians This Post-Hearing Comment is made for the same reasons, and on the same basis, i.e., the responsibility to report to the public, the results of studies performed with public funds, that have a bearing on the public welfare. . A great deal of effort was expended at CINJ to probe the bedeviling question of what was causing so much cancer in the scare of New Jersey, aa.--iadicated by .the.National Cancer-Institute's LT.S . Cancer Mortality by County:. 195Q-1969. In these probes we sough0 help'for one public at large," and 'for the workers in the enormous chemical/petroleum plants in New Jersey by turning to the best available", objective data for clues as to the major causes cf the lethal cancers. The weapons that could bring about a signifleant reduction in the cancer statistics that had placed New Jersey at the top of the mortality rate were: 1) Prevention and 2) Early Detection. The latter weapon was clear cut in chat several leading" cancer killers, like breast, colon, and uterine cancer, were amenable to inexpensive screening tests, and numerous studies had demonstrated that early diagnosis, while the primary cancer was still small and asymptomatic, could result in immediate strik ing decreases in the projected, future death rates. Prevention, however, required the knowledge of who the "real culprits'1 were in cancer causation; we recognized that if we chased the wrong ones, then the real culprits would continue to get away to add to the toll. When resources are limited, as ours were at CINJ then, and as the nation's are new, there is no margin for error. This search had become clouded in 1976 in New Jersey, with the media carrying almost daily reoorts provided by various officials that "... it's in the water --7|, "..'.it's in the air...", "...it's industry!" Now, in 1978, at the national level, the direction that Prevention efforts should proceed in are similarly enshrouded. The studies conducted at CINJ provide directions for Prevention efforts at a national level and are reviewed herein. Cur data resources in cluded the bibliographic references in this document as well as two major works by the National Cancer Institute: ucc 057467 the.NCI's Third National^Cancer Survey: Incidence Data (1969a 1971J,'"which "yields' age-corrected cancer data" on approximately 1056 of the nation's population with sample areas that include: urban areas with heavy chemical industry (Detroit, Pittsburg, Birmingham); urban areas without heavy chemical industry (Atlanta, Dallas, Minnea polis); comparatively rural areas devoid of heavy chemical industry (States of Iowa and Colorado). The data is pro vided according to sex, race, age, standardized anatomic site cf the original primary malignancy, and geographic areas. The data is expressed per 100,000 population and wa certified as accurate by high-cuaiity microscopic examina tions of the malignancies. '. page -2 ^Cc 05^68 the NCI's UTS. Cancer Mortality by County: 195C-l?c?, which, provides age-ccrrectea" cancer ceatn ~rata3,. o/sax,, race and' county, per 100,000 population for the 20 year period, 1550-1369; this data covered every county in the United States; by cross-checking with other federal studies and with encyclopedic references, we were able to compare geographic areas of similar urban density, with and without heavy chemical and petroleum industry. II. Consideration of Major Variables in Cancer Causation. Oar rationale for conducting these studies was as follows. If the Heavy Chemical and Petroleum Industries do pose a carcino genic threat to their employees, and worse yet, to..the public at large who live in juxtaposed communities, "then there..should be higher cancer incidence and higher ..cancer "mortality rates in these geographic, areas ..of the United States*"that have Eeavy Chemical/ Petroleum Industries, compared to other areas of the U.S.A. that are similar in urban density and'in'other major variables. Before embarhing on studies that could guide Prevention efforts, we re viewed the major variables in cancer causation. Other studies, published by noted epidemiologists, including those from the NCI, have substantiated the need to control for che variable of urban density when malting comparisons of cancer inci dence and cancer mortality. (Hoover, R., Mason, T.J., McKay, F.W., and Prauaeni, J.F. Geographic patterns of cancer mortality in the United States. In: 'Persons At High Rish. (ed) J.F. Frauneni, New Torh, Academic Press, Ip. 3^3} Urban density Is as 'important as age, sex and race in the development of" cancer; the percentage differences between urban and rural areas are on the average larger than the differences seen between the sexes ana tne races. For specific types of cancers the urban-rural differen ces can be very large, as shown in the accompanying Table I from Hoover's cited paper. The listed ratios can be converted co per cent by subtracting I from the ratio and then multiplying by 100, e.g., a ratio of 3.08 1s 20d$, a ratio of 2.96 is 196$, etc. The ` increases due to urbanization are substantial and as other studies to be cited in this presentation will show, the increases are not due to air pollution from cars and industry (see Section III Cancer and Air Pollution in this document). Table 2 from Hoover's cited paper, shows the relationship of Socio Economic Status (SES) within a race, and increased cancer risk with higher SES, certain major cancers are increased, e.g., reccua 113/6, thyroid 72$, colon 67$, bladder 67$, etc. The generally higher incomes and higher standards of living, particularly for whites, v;ith in urban areas compared to rural, may account for some of the 'urbanrural differences. The question now at CINJ was, in view of the fact that New Jersey's population is the most urbanized of any state (near'--'Jv CO5'-'/ ) v/ere the rates really high? The surprising answer-was no. In facCj areas such as Nassau County, and Westcheste"f"Uounty (wealthy j ** n ,, ized suburbs of New City devoid of industry), San Frans usco, and district of Columbia, had higher or equally high cancer msrtali y 32-30R AP'-'lC 5 ` "5s*'IS 3 - -'.C33 UC37ul;'Tv TABLE 1 Urban-rurai maos of ase-au.iusted cancer mortality raws4* among white* ;r. the contiguous United Sates. according :o cancer site end sex. 1950*1969 Male cits Urban) rural Female Site Urban; rural Esophagus Larynx Mouth and throar Rectum Nasoph. jynx Btadde* Colon Lung Breast All malignant neoplasms Thyroid giand Other endocrine glands Stomach Kidney Non-Hodgkin's lymphoma Other and unspecified Connective tissue Pancreas Biliary passages and liver1primary) Salivary giands Hodgkin's disease Brain Multiple myeloma Nasal sinuses Leukemia Bone Melanoma of skin Prostate Testis Eye Other skin Lip 3.08 L96 138 in 117 110 1.97 i.89 1.77 Uo 1-56 1-53 i.45 1.44 1-39 US U5 U4 l J4 U1 1.25 1.21 1.12 t.10 1.07 1.05 1.01 .96 .96 .77 .67 J7 Esophagus *> 11 Rectum Larynx 2.11 1.92 Nasopharynx 1.66 Lung 1.64 Breast Bladder 1.61 1.58 Other endocrine giands 1.52 Ovary 1.52 Colon 1.51 Non-Hodekufi lymohcma L.42 Hudgkin'i disease 1.39 Thyroid 1.38 Ail malignant neoplasms 1-36 Stomach Pancreas US U4 Mouth and throat 1.29 Connective tissue 1.28 8 ram 1.26 Multiple myeloma Other and unspecified 1.25 : ;7 Leukemia Kidney Salivary giands Masai sinuses 1.15 1.12 1.12 1.08 Biliary passage* and liver 1.04 Corpus uteri Cervix uteri Eye Bone 1.00 1.00 .92 .89 Melanoma of skin .37 Other *km .65 Up .29 Rates tvere latrciataJ for 100 percent urban and 100 percent rural euuntmt- ucc 057469 C'rO HCOV 5A tzai. table: Social-class ratios of ace-adjusted conce: mortality rates^ among wnites m ths contiguous Luted States, according to cases.* sits and sex. 1950*1969 Male Social- *uss ratio Site (.hi it: lovVj Female Scciai<iass ratio Site ('high.* low) Rectum Thyroid gland Colon Bladder Other endocrine glands Connective tissue Kidney Esophagus Mon-Hodgkin's lymphoma Multiple myeloma Mouth and throat Testis Breast Brain Ail malignant neoplasms Hodgkin's disease Leukemia Lung Nasopharynx Prostate Stomach Larynx Pancreas Melanoma of skin Nasal sinuses Biliary passages and liver Eye Other and unspecified Salivary glands Up Bone Other skin 113 1.72 1.67 1.67 1.59 IM I.+9 1.49 U7 US 1.19 1.13 US 1.18 1.16' 1.14 U1 t.10 1.10 1.09 1.09 1.02 1.01 .98 .96 .98 .87 .33 .81 .31 .53 Rectum Breast Ovary Other endocrine giands Nan-Hodgkin`s lymphoma Colon Connective tissue Multiple myeloma Hodgkin's disease Brain Nasopharynx Lung Bladder All malignant neoplasms Kidney Eye Pancreas Thyroid gland Leukemia Stomach Nasai sinuses Esophagus Corpus uteri Biliary passages and liver Salivary giands Other and unspecified Meianoma of skin Mouth and throat Cervix uteri Bone Larynx Other skin Up 1.5" 1.54 1.52 1.52 1.49 1.45 1.43 U9 IJ7 1J5 i.:s 1.27 1.19 1.18 1.14 1.12 UO 1.09 1.06 1.03 1.01 .97 .9* .94 .36 .35 .85 .73 .74 .69 .67 .47 JZ aSt* ttxt for mctftwi of cAcmmui; hign mii low tocial-class counties. ucc 057470 page -5 UCC 057471 Philadelphia St. Louis, Missouri New York City Nassau County (an Eastern suburb of New York City) San Francisco Chicago New Jersey District of Columbia Westchester County (a Northernsuburb of New York City) U.S.A. Nationwide 221/100,000 220/100,000 215/100,000 212/100,000 206/100,000 206/100,000 205 100,000 203/100,000 270/100,000 17V100,000 This initial CINJ study demonstrated that serious mis lain re ss ions could be made if comparisons were made against invalid controls, wherein a hey variable, such as urbanisation, is not considered. In -DrSamuel S. Epstein's booh,, the Politics of Cancer (Sierra Club Boohs, San Fransisco, 1978) this type of erroris made in his Table 1.10, p. 29* wherein he compares New Jersey, Wyoming and North Carolina. As a result of this comparison.he concludes that New Jersey's higher-races are due to the Chemical, Petroleum Industries. Unfortunately, .uncontrolled comparisons such as these by Epstein form the basis for muck of the 'oooh, and for much of the document submitted to OSHA by NI0S3, NCI, and NIZHS, entitled Estimates of-theFraction of Cancer in the United States Related to bccupaclcnal factors'? The latter document," quite erroneously, relies heavily on extrapolations from an article published in Ca- A Journal for Clinicians (volume 28, 1973, p.87) by I.J. Selihoff and E.C. Hammond, entitled Asbestos-associated disease in United States shipyards. In this article, comparisons are made between the cancer deaths in. asbestos insulation worhers, and those expected cancer deaths in the average white male, as obtained from age-specific mortality data from the U.S, National Center for Health Statistics. As seen in Table 1 and Table 3 of this article by Selihoff and Hammond, a comparison with the average U.S. white male suggests that asbestos"worhers have approximately a 20C# greater cancer rate; for example. Table 1, 319 total cancer deaths Expected, versus 994- Observed in the worhers. Many-,--if-nor most _of^the_asbes to s_insu]^tion_#orhers^were.. in urban- areas.,-which uould^-in^nd^f^itselX;.accounfiLfbr._muchl..ofsu.the2.20QS6=-apoarent: in-creasa. in.cancer. rates ..among- the..asbestos_worhers. 7urtner7 Selihoffs data does not take into account other factors, besides urban-rural differences, that markedly increase the risk for sever al forms of cancer. For example, socio-economic status, cigarette sticking, alcohol consumption, and fat ingestion (see References at end of this document). The asbestos insulation workers were : Selihoff's follow-up pe ace of job turn-over; however, iic status. The lack of asbestos cancer deaths is serious since several forms of cancer are caused by smoking. Hammond (Tobacco TABUS 1 Oaatftt among 17,300 woettot insulation woritert in th United State* and Canada January 1, 19S7-January 1, 1977 1 Mumoar. at man iVlan-vtariai cos#rvitiar* , 17.300 16S.2S5 j | Saoaeted* Cbterved Total deaths, til autaa Total cancer. ill iitaa Uung canear PIaural meiomefioma Pvritenaal mstomaltama Cancer ol ueohagu* Cancar ot rtomacn Cancer at ttiar-fttrjn All other san ear AAeotcsii All other cause* 1.660.36 319.90 105.97 * % 7.01 14.23 37.38 154.33 * IASI.08 1270 994 485 86 109 18 32 9 335 182 1,114 'Ixoected dtattis arc oaaao uoon whits mats sea toaaifie mortality data ot tna U.S. National Cantor tor Naaiot Siartrttes tor 19*7-1973 mo sjitfseoiaoon to 1978. *'Those are rare causae at 3sam In the jenersl popuUtian. The mwndarmlo of Ole Intamstlonsi Asaoolation at Hast and ftaat insulatom and Asoeetos Wore an, APL-C1Q, CUC, wso enroll'd en January 1. 1987. and has seen | aawrvK unct. j ?2* TABUS 3 Daathi among 17,300 asbtfto* insulation worker* in the Unittd State* and Canada January 1,19S7-Juiary 1, 1977: Anaiyu* by duration from onitc of employment Total men Men-yeart of odserration 12.583 89,488 11081 77.383 Salat* 20 year* from onset 20 or more yean front onset tapsetad* Ob --rved Capsetad* Obierred Total deaUta, all causae 383.93 324 U77.01 1,948 Cancar. all sites 4ZS5 83 277.25 911 Lung cancer Pleural mesothelioma Peritoneal metometiome Caneer ol esoonaou* Cancer of ttomacn Canetf ot coien-/eTum Ai0etatt 1103 * * 0.68 1.56 4.07 38 3 3 1 1 4 3 93.94 3JS 1157 33.79 - 449 S4 106 17 21 53 154 ***** oeatn* *re eased uoon waits mate 4q saiM mommy Sara at tna u Nations* Centar tar nsatm Statistics tar 1*e7-I97S and ttMuan to 197*. **Thaae are rar* causes at caaot In the |wil eesuiarien. uoo 057472 pae -7- ucc 057473 In: Persons at ; igh ?,isk of Cancer. (ad.) J.?. FTaumsni, ITs*..* York, Acs.i2.ilc" rress, ' "fcj ? 131,/ .nas snown--s tatisc icaily-significant i ..creases la. cance: - death- re, tes in- 'Smokers-' in- 'the following fores, od ea. buccal cavity b90 lung bSH-% larynx 50955 esophagus 3175$ pancreas 169$ bladder 100g It is imperative when comparing cancer data for the purposes jf stratagizlng a Prevention program to control for the variables dis cussed in this section. In using national data, it is often inpessi; to obtain information on socio-economic status, and the consumption c cigarettes, alcohol and fats. However, urban densities can be read-1 controlled and can prove valuable, as indicated in the next sectier. IH. Urban Centers With and Without Chenical/Fetroieum Industry In studying the Third National Cancer Survey: Incidence Data (1569-1971) comparative data was' ootainec wnicn is summarized in the accompanying Table. The tabular data lists all cancers for all the standardized anatomic sites, as well as for tnree anatomic sites that are allegedly more likely to develop malignancy if the person lives in a county with heavy chemical/petroleum industry (see 31ot, W.J., that the risk of developing cancers of the lung, nasopharynx and stomach were.significantly greater in the 39 petroleum/uhemical coun ties studied. It should be pointed out, incidentally, that Slot's selection of these 39 counties was not based on any attempt to choose a representative saida of the 604 petroleum counties in the U.3, This'is freely" admittea in Blot's article. Hence, although Blot's study-was not meant to be representative, many individuals have made unwarranted extrapolations and have concluded that Blot's study shews that the chemical/petroleua industries in the 60^ petroleum counties pose a higher cancer risk to the public, and to the workers. There fore, these extrapolators of Slot's work continue, there is an urgent need to have far more stringent control over occupational exposures tochemicals. Many of the extrapolations of Blot's work show serious inconsistencies, e.g., there was no increase in lymphomas and leukemias in Blot's, yet, Epstein, in his book, The Politics of Cancer, p. 122, states that benzene causes lymphomas and aeuxemias, ana cnac the petroleua/chemical industries therefore cause these types of cancers through environmental pollution with ber.eze .The data in. the table show,, quite..surprisingly/-that over-all cancer incidence-is lower in those-urban areas-with-Industry (average -99/100,000) ccnparsa. _ca_urban .areas., without incus try (average ;!-/ 100,000), and that'there is no significant cifference in the incioer.c 'of cancers that some individuals believe are more likely tc occur in areas with heavy chemical/petroleum Industry, i.e., .rates for lung, nasopharynx, and stomach are almost identical for the two types of Jlrheja..*_____ __ -- --- Taels l. page -3- Averaga Annual- Cancer*-Incidence- In*' Urban. Areas, -with. and without Heavy Chssicsl/Petroleum Industrv (free. the Third - ICc, 11c, 12c, 13c. 1-c, IOC, l<be: age-adjusted , white rales oar lCC-CCOT Urban Areas with Heavy Chemical/ Petroleum Industry- All Cancers Lung Hasopharynx 5 tcmach Detroit Pittsburg Birmingham average 303 57 0.8 13.5 299 67 0.8 14.5 294 83 0.4 7-6 299 72 0.7 U.9 Urban Areas without Heavy Chemical/ Petroleum Industry1 Atlanta San Fransisco^ Dallas Minnaaoolis average . 304 72 1.1 7.4 330 68 0.8 14.2 321 73 1.0 9.2 311 IL Hal 314 69 0.8 11.0 Footnotes: 1. Heavy Cheaical/Pstroleua Industry includes those industries where chemical/?etroleum products are produced, or used extensively in manufacture, e.g., automobile industry. 2. San Fransisco's data in the Third National Cancer Survey includes the city or San Fransisco, plus the counties of Alaneca, Contra Costa, Marin ana San Mateo. A study of the U.S. Cancer Mor taiitv bv Countv --. ge v:as 174, indicating that the San Fransisco data in the Third National Cancer Surrey is diluted by the inclusion of the low cancer r.orta_ity counties'. L*o attempt, however, was made to correct for this In the above Table; the San Fransisco data was used as it appeared in the Third National Cancer Survey. UCC 057474 page -9 o^^^cans_scu^cs_p^ou^Ci.II^3.jtudisaa;Wa-j2!3rLciused that according _ta.-.fids, beau available.-,, -cata^.. th.ereislna^-carreiatiGa- oe.z-.-iee. high-cancer-rate aland-: theroiesence-of*- heavy..-chemical/pet^oi *um- IndusI: therefore seems ur11asly. with the exception of a faw very speeds.: instances," that occupational exposures of chemical/petroleum worsens or pollution of communities juxtaposed to industrial sites have con- whereia an occupational exposure, .plus.nore^generaluyuusec. oarctnoge: .such-as--cigaretf3_snoke_ar.alcohol, 'oring about additive or synergis ' effects under unusual circumstances, e.g., extra-ordinary asbestos exposure and cigarette smohe leading to bronchogenic cancer. Such Instances are quite rare, when put into perspective. .-If additive or synergistic^effects were generally, significant for.human carcino gen? sis, -^then we -should --have been, higher..cancer .rates in those_ urban areas, that--have heavy chemica/petroleua industries. Instead, we sa* slightly lower rates in such urban, industrialized areas. It should oe noted chat the seven cities compared (Detroit, Pittsburg, and Birmingham versus Atlanta, San Fransisco, Dallas and Minnea polis) represent 16 million people out of the 21 million total in che Third National Cancer Survey. Hence, the data do not re present seme type of exception. IV. Cancer and Air Pollution With respect to "..Twhat is 'it~Voout urbanization that 1 eads to higher cancer rates...?" seme people would Jump to the ccnclusion t it is the air pollution in crowded, urban areas. The cbjecti ve answ to this is, "...not so...", based on NCI data, as well as data from of the most heavily air-polluted countries in the world, Japaa * Let us examine California first since it provides excellent dace on the question of air pollution. Los Angeles'is notorious in the :J. and averages over 3CQ days per year of air quality that is "unhealthful, or hazardous" according to the National Wildlife Federation. San Fransisco has about 125 such days per year. Further, in Los Angeles, there is heavy petroleum industry concentrated near the coastline so that the prevailing west to east winds carry the pollutants inland and add them to the stagnant automotive exhaust. 'San Fransisco is bathed in pure Pacific Ocean breezes.- Tet, according to the NCI's N.5. Cancer Mortality by Countv: 1950-1969. the figures are as follows for waite maie deatas in Los angeles and San Fransisco.: ucc 057475 page -10- All cvpes of Cancers. Ucc "57478 Los Angelas San-Fransisco (alone) U.3`. Nationwide 173/100,000 212/100,000 174/100,000 Lung Los Angeles San Fransisco.(alone) 17. S- Nationwide 41/100,000 47/100,000 38/100,000 Nasopharynx Los xngeles San r'ransisco (alone) U.S, Nationwide 0. VICO, 000 0,6/100,000 0.38/100,000 S tonach Los Angeles San Fransisco (alone) U.A. Natiowide 15/100,000 20/100,000 15/100,000 Again, there is an absence of the/'expected" correlation, that air-pollution, must cause cancer, especially in a petroleum county. From Japan, Sunio Aoki and Hiroyuki Shimizu published a paper entitled15Lung Cancer and Air Pollution"in an NCI Monograph, #47*, called ipideaiology and Cancer Registries in the Pacific Basin. The; V. The Predominant Causes cf the Major Lethal Cancers .The question then is what urban factors do causa cancer, if it is not industry,, and it is not air-pollution? The answer nay lie in life-styles and the consequent habits that develop in urban areas .with respect_.to cigarette; use, alcoholisa, and poor nutritional practises. Cigarettes alone account for virtually all of the lung cancers, and major percentages of cancer of the urinary bladder and pancreas; all told, cigarettes- alone-.acoun.Vfor_3C$S~of. tha_cancer mortality-rata.. When cigarette smoking is coupled with alcoholism, an additional 10% of the cancer mortality is explained by the causer of cancers of the mouth, larynx and esophagus following the conjoint use of cigarettes and alcohol. Poor nutritional practises> such as page -11- Angsles. They do ot smoke, or drink and are vegetarians. Ho Phillips ar.d Jar. N. 11c.ora found that the over-ail cancer races 7 th Day Advent is t' male s- was cne half. that, of the U.3. National ce rate for white males. (see Rations! and nethods for an ernicem.ioiogic study of cancer among Seventh Day Adventists, in Epidemiol and Cancer Registries in the Pacific Basin, NCI mcnograpn rr-'t'~ (.oee attacnec references). VI. The Role of Occupational Exposures With respect to the idea that "occupational'exposures cause betwe 20-4C# of cancers, as expresrod in the recently subaitted 'document. "Estimates of the Traction of Canber in the United States Related to Occupational Factors ', prepared by individuals from ZTIOSE, NCI, NIZEB and subnittad to OSEA for che hearings on occupacicnal carcinogens, c following should oe borne in Bind: major reliance is pliced on Selikoff's data which purports to show that asbestos insulation workers have higher cancer death rates from cancers of the lung and gastro-intestinal tract, compared to the average U.S. white male; this is a serious error in comparisons, since nose of one workers were centrated within urban centers. The valid control groups are white males in urban areas, not average U.S. figures. extensive extrapolations are made upon data bases that are in themselves very limited, and*uncontrolled, s.g., smoking, alcohol and nutritional factors are generally not considered in the original studies that were extra polated. The "Estimate" that 20-40# of cancers are occupationally relates with directly causal agents in the workplace, or-.additive/synergistic effeces is wrong. If the massive extrapolations in this "Estimate" document were valid then we should see more cancer in urban areas that have a great deal of industry. Instead, we do nor see this when we use National Cancer Institute data, e.g.. Third National Cancer Survey, (see Section III of this document). The pervasive question raised by.the "Estimate" document is whether potentially carcinogenic Indus trial substances have escaped into the communities and have caused cancer. The studies in Section III show that this is not the case. However, we went further in view of the continuing public remarks of some individuals that asbestos has not only escaped, but is ubiquitous, particularly in urban areas. An asbestos-risk study was initiated by.CINJ in la e 1?75 in view of the fact that New Jersey has a major asbestos inous try in Manville, N.J. One of the components of this study was to det ermi: the numbers of mesotheliomas seen in large urban medica.1 r* A 7-T* ci rs the Greaser New York/ITew Jersey Area over the ten years , --- t<-ev e m -k * as one of several bases for future comparisons. Among the lar; most complete contributors to this data peel were the f our aff; hospitals of the New York University Medical Center: 3e ilevue, w i *. _ v s " vj Manhattan "'iA,3 and Booth Memorial. The data from these hosp: .tal particularly interesting in ^ 1 < .*W m of tua T1 1 i Cja tions ade ucc 057477 page others that the 1 -- *" . w -- W w >y -* ^ w ccr.e = _ nssocne-ncnas; are harbinger.: cf a zassive ware of cancers m- ducec by exposures to incus"rial, sources.. Supposedly., even- a one-tin exposure to small cuantities of asbestos' will pose an increased risk tor one suture ce vehement of r.cz. omy < C si W `W bronchogenic and gastrc-intestinal tract cancers,-11 :r ru'*n"5e* --g<eneral. cublic as well as industry worhers. If Selikoff's dire or edict ions have objective, scientific validity, then there shc'uld be a clear 1v evident trend in the appearance of pleural/peritoneal mesotheliomas ever the ten years, 1367-1376. The Third National Cancer Survey: Incidence Data catalogued, a total of ~lb4 pie.ural/peritoneal, mesothe liomas in"the years 1969, 1970, 1971 in thj approximate 163,000 cancers included in the survey of 11 the geographic areas. This is approximately 1 mesothelioma per every 1,000 new cancer cases seen. The Third National Cancer Survey did net provide a breakdown of the distribution of these mesotheliomas according to geographic areas, but the figure of 1/iOGC new cancer cases _s useful. At the N.Y.Y. hospitals an average of 3,000 new cancer cases are seen each year (Squamous and Basal Cell Carcinomas of Skin are not included). The excellence of the anatomic pathology services, coupled with good records and tumor registries provided the numbers of cases summarized in the accompanying Table. There was slightly less than one meso thelioma per 1C0C new cancer cases (26 mesotheliomas in ten years, with 3C,CC0 new cancer cases), or 0.S6/10CO cancer cases/per year. The NYU figures are of interest for several reasons: there is no trend over the years, as would be expected if Selikoff's fears were valid the four hospitals provide a significant cross-sec tier, of the public free the New Ycrk/New Jersey areas, and include balanced percentages of lower, middle and upper income patients New York City and New Jersey have had significant asbestos exposure, according to Selikoff, because of the wartime ship building industry, extensive construecion, the use of asbesco in New York City grace-school materials, demolitions, heaw use of automobiles with release of asbestos from the brakes, the clothing industry which sometimes has included asbestos fibers, etc. ucc 051478 Ts.b i o page Mascthelicr-a cases ac ohe ITz'-r Ye.:-: U.oiversi: Mecical Csjccsc ( `i976-' 1 Probable or Ccscacibla- 1567 1968 1969 1970 1971 1972 1973 1371975 1976 V 1 0 2 0 0 0 1 2 2 TOTAL: 8 Deficit 3 v X 3 2 1 2 1 2 2 1 IS To cal = for bice four Hospitals 3 23 d 1 2 x 3 i; 3 26 ^Footnote: rfev/ Ycru university Medical Center Includes four Hospitals : University, Bellevue, Manizaotan Veterans Administration and the Booth'Memorial Hospital in Queens. ucc 057479 page -ld- VTT.. Summary ' I summary-although-we have-searched- extensively, ..we have .bean unaoxe to find any. direct,-positive--correlations between the -presence cJaaavy,,chenic8jx/petroleu3^industry-anc. the development cancer. This is true for the New Jersey and New York areas, as well as for the rest of the country as shewn in the Third National Cancer Survey and in the U.5. Cancer Mortality by Conner: r?rO-13677 We also found no increase in the ursan areas -wlta, neavy cnenical/petroleum industry, in selected anatomic sites thsc are thought to be at greater risk, e.g. lung, nasopharynx, and stomach. These studies, plus the serious flaws in'the data base used for extrapolations in the NI0SH/NCI/NIEE3 ''Estimates" documert submitted to OSEA, indicate that in no way can occupational facto: s account for 20-iC% of the cancer mortality in the U*.S.A. Dr. Donald Louria, Chairman of the Department of Preventive Medicine and Community Health, in the New Jersey Medical School, studied this question in New Jersey, with New Jersey state funds. His paper, "Cancer in New Jersey: An Overview, was presented at the ``Seminar for Physicians: Cancer Fisk Identification Within New Jersey and Methods of Cancer Control", May 1-2, l$7b. He con cludes his paper by stating, "...only about 6C0 or d percent of the deaths can be felt to be related to industrial exposure". Wynder recently ascribed a similar low percentage to industrial exposure (Toward the Prevention of Cancer. Cancer Bulletin 29: p. 186, 1977). There are many inconsistencies to CSHA*s approach to the cancer problem. Some of these inconsistencies have been demonstrao by the studies we conducted at the Cancer Institute of New Je rsey w che aid of an NCI "Planning grant". Other serious inconsiste that we did not specifically study are pointed out in closing it is widely acknowledged that cancer of the stomach is a .rapidly disappearing disease, and the causes for this striding downturn over the past lo-20 years are not known; in any case, this most dramatic event (stomach cancer used to be the leading cancer 'siller in men) is not in seeping with the implications made from Blot's work (Science l9o: p.51, 1377)* that petroleum/chemical industries pose an increased risk for the development of certain cancers,.like stomach, in the public at large. if--lung^concers-are-'excluded y=chai-aver-all-nancer ,rates have l not. changed in-any- statistic'ally^significant...way-la the past .15 years: the lung cancers that we are seeing now were initiated 20-35 years ago, when filter tips were rare, and the great bulk of the smoking was dene by males; current trends in the use of greater filtration and more female smokers will not beneficially affect the rale lung ** -- r* a * rates for another 10-15 years. See attached tables, re printed from Ca - A Journal for Clinicians (volume 28, 137b, ??. 20, 21). uoc 057480 page -15 ACE-AC.L-STED :.-\'CSR DEATH rates* ,=0R SELECTED SITES Yor Sources U-S. National Cantor far Hooltft Stattttiea *no U.5. luroau l tit* Cantu*. * Stanoaroiaao on mo *# antrioution of tno 1940 u.S. Caniut Aaouiation. 20 CA-A QAhCV* JOUWWL *C-q CUNiGANS ucc 057481 page -15. AES-ADJUSTED CANCE.R DEATH RATHE* rCR SELECTED 5iTH3 3ur*i: u.S. Hattana* Cantor tor Hintn Science* and U.S. Suraau at tno Canauu 'Sttnoorottoa on m* autrioodon at mo 19*0 U.S, Cantui Paeuiacian. VCL 2S 'iO : jAMC*fr* esapjjAffr :07J j- ucc 057482 page -17' Recent rsfs--3i". **s .-a-s ana :: life-style .in t'n cancers, .with rale-.-*nr - . cl 8S Cf d * o *- a '* wXw*.*, W_ na.jorit V& tnano_. 1 Armstrong B.., ar.d Doll, ?.. ' Environmental factors and cancerIncidence anc mortality in different countries, with special reference to dietary practises. Int. J. Cancer 1?: 617, 1975- 2. Lynch, 5.T., Guirgis,-E., Lynch, J., Brodkey, F.D. and Magee, K. Cancer of the colon: socioeconomic variables in a community. Am. J. Epic? am. IQS: 119, 1975.. 3. Doll, R , and Mill, A.3. Mortality in relation to smoking-ten years' observations of British doctors. 3r. Med. J. lj_ 1399, 1966. *. Wynder, 3.L. Nutrition and cancer. Fed. Proc. ~5: 1*09*, 1976. 5. Xuratsune, M. Test of alcoholic beverages and ethanol solution for carcinogenicity and tumor promoting activity. Gann 6?: 395, 1971. ------ 5. Wynder, E.L.. Reddy, B.S., McCoy, G.D., Weisburzer, J.H., and Williams, G,M. Diet and Gastrointestinal cancer. In: Clinics in Gastroenterology, Vol. 5, 1976, p.*63. 7. Wynder, E.L., and Reddy, B.S. Diet and cancer of the colon. In: Nutrition and Cancer, (ed.) M. Winick. J. Wiley and Sons, Inc.,.1977, p-55. 8. Drasar, B.S , and Irving, D. Environmental factors and cancer of the colon and breast. 3r. J. Cancer 27: 167, 1973. 9. Wyr.der, E.L., MacCornack, F., Hill, ?., Cohen, L.A., Chan, ?.C, and Weisburger, J.H. Nutrition and the etiology and preve of breast cancer. Cancer Detection and Prevention 1:*293, 1576. IP. Gortner, W.A. Nutrition in the United States 19CC-197*. Cancer Res. 35 32*6, 1975. 11. Alcantara, E.N., and Speckaan, E.W. Diet, nutrition and cancer. Am. J. Clin. 2Tu.tr. 29: 1035, 1976. 12. Oiso, T. Incidence of stomach cancer and its relation to dietary habits and nutrition in Jaoan between 19PC and 1975* Cancer Res. 35** 325*, 1975. 13. Phillips, R.L. Role of life-style and dietary habits in risk of cancer among Seventh-Day Adventists. Cancer Res. 35: 3513, 1975 1*. Rao, 3.A., and Abraham, S. Enhanced growth rate of transplanted tia.unary adenocarcinoma induced in C-jH mice by die tar:-* lir.oleate J. Nac'i Cancer Inst. 56: *31, 1976. ucc 057483 page -13- Phillips. R.L. "r'.uz": . Rationale and methods for an epidemiologic stud"':;' m->-;ter among. Seventh-Day Adventists. ' rn: %idenioictrv aho R.ecitrias * * tha Pacific National Cancer 7 \Ftit_u:"^.-Ionograoh Publication y (NIH) 77-1273, p. 107.- i a Aoki, IC., and Shinlco, H. Lung cancer and air pollution. In: idle p. 17. (n.'c., no relation found between lung cancer and industrial air pollution in Japan). 17 3asa, G.F., Hirayaaa, T., and Cruz-3asa, A.G. Cancer epidemiology in the Phiilipines. In: ibid p. U5. (n.'o., elevated risks for several forms of cancer as a result of cigarette s no kins noted in the Phiilipines, as well as other "developing" .nations). *16. Sill, Chan, ?., Cohin, L. , Wynder. E.L., and Runo, S. Diet and endocrine-related cancer. Cancer 39: 1320, 1977. *19- 20. 21. .22 Wattencerg, L.W. Effects of dietary constituents on the metabolism of chemical carcinogens. Cancer Res. 35: 3326, 1975- Walker, A.R.P. and Burkitt, D.P. Colonic cancer-hypotheses of causation, dietary orophylatcis, and future research*. Digestive Dis. 21i 910. 1976.* Reddy, 3.S., Martin, .C.W., and Vynder, E.L. Fecal bile acids and cholesterol metabolites.of patients with ulcerative colitis,a high-risk grouo for develooment of colon cancer. Cancer Res. 37: 1697, 1977. Wilkins, T.D., and Hackman, A.S. Two patterns of neutral steroid conversion in the feces of normal Worth Americans. Cancer Res, 3^: 2250, 197k. j * Williams, R.R. and Horm, J.W, Association of cancer sites with tobacco and alcohol consumption and socioeconomic status of patients: Interviex* study from the Third National Cancer Survey. J. Nat'l Cancer Inst. 53: 525, 1977. Sit. Adelscein, A.M. Occuoational mortality: Cancer. Ann. Occuo. Hyg. 121 53, 1972. 25- Pearce, M.L., and Dayton, S. Incidence of cancer in men on a diet high in polyunsaturated fat. Lancet 91: k64, 1971. 26. Modan, 3.. Bareli, V., Lubin, F., and Modan, M. Dietary factors and cancer in Israel. Cancer Res. 35: 35^3, 1975- 27. Modan, B. Cancer in Israel: Seme ethnic considerations In: Cancer Genetics (ed.) H.T. Lynch Springfield. Illinois: C.C. Thcma 19^2, p~. lop. 23, Carter, R.L., and Roe. F.J.'C, Chemical carcinogens and industry. J. Soc. Occup. Med. ?5: 36, 1975. (n.'o. indicates types of cancers, by sites, that are caused by industrial substances, e.g., bladder, lung, liver). ijqc _________________ . _______________________________________________________________________________ ________________________ _______________________________________________________ 057494 < 29- Bloc, "`nJ., Brinson, I....... Praumer.i,. J.P., and Stone, 3.J. Cane a r nor tali"** in ^. counties with petroleum industries. Science xc-3: --" "pv-y (n.b. indicates vpes os' cancers, by sitesthat are industryrelated, e.g., 1nasal cavity/sinuses, and stomach: also takes cognizance of controlling for percentage of population that is urban, population density, and socioeconomic factors). !0. Hamaand, Z.C. Tobacco In: Parsons at High Risk of Cancer Etiology and Control (ed.) jTr'. Praumeni, Jr. mew lork: Academic Press, 1975, p. 111. (n.b. cigarettes, alone and with ethanol, in causing cancers at numerous anatonic sites). .21 Rothman, K.J. Alcohol. In: ibid, p. 139. 32. U.S. Public Health Service. Cancer. In: Health Conseouences of Smoking 1975. p. 41. 33. Clarke, M. Carcinoma of the Cervix - An epidemiological perspectiv In: Gynaecological Malignancy: Clinical and Experimental' Studies. ( ed .), H. G. Brush, and R.vi. Taylor 3a.ltl.-3rg; '.'*1 Iliads a-ri w-ilk-ir? 1975. P.3. (n.b. association of "life-style" and cancer of the cervix). 3*. Vigliani, E.C. Leukemia associated with benzene exaosure. Ann. N.Y. Acad. Sci. 271: 1^3, 1976. 35. Lijinsky, N. Health problems with nitrites and nitrosamir.es. Ambio. 21 57, 1976. 26. Issenberg, P. Nitrite, nitrosamir.es ar.d cancer. Red. Prcc. 35: 1322, 1976. 37. Mack, T.M.,?ike, M.C., Henderson, 3.E., Pfeffer, R.I., Gerkir.s, V. Arthur, M., and 3rown, S.E. Estrogens and endometrial cancer in a retirement community. New Engl. J. Med. ?9h; 1262. 1976. 23. Blitter, P.H., Blitzer, E.C., and Rimm, A.A. Association between teen-age obesity and cancer in =6,111 women: all cancers and endo metrial carcinoma. Prev. Mec. ^ 20, 1976. 39- Higgins, I.T. Smoking and cancer. Am. J. Public Health. 66: 159, 1976. ii.0. Toxicants Occuring Naturellv in Poods. National Academy of Scieces TITT. in Nutrition and Cancer (ed.) M. Ninick. New York: John Niley ar.d 3c1977. -2. The Changing America r. Diet. L. Brewster, and M.P. Jacobsen. Center -or Science in the Public Interest. Washington, D.C.1973. ucc 057485