Document 6BKEj6xLXVQ5B9pk7Mn2pELv9

WORKPLACE CARCINOGENS i ( Why the delay in cancer-protection standards? Does Hie lag In coming out with enforcement action to protect workers against cancer signify a breakdown In die regulatory process? What's to be done about It? I have .somewhat of a unique vantage point and set of experiences in regard to setting standards for control of occupational exposure to carcinogens. In 1973, I was on detail from HEW to OSHA The majority of my time during this period was devoted to the development and subsequent promulgation of emergen cy and permanent standards for the control of 14 carcinogens. There were numerous occasions on which the appropriateness of the requirements in the standards was hotly debated. Indeed, even the cover age of certain compounds, especially those for which no information as to human cancer was available, was thought by some to be going too far. Rejection of MOCA standards was bassd on Invalid procedures. PROCEDURES The courts have ruled in favor of the government's right to base such decisions on factors other than the records of human cases At least they understand the concepts of preventive medicine. But I couldn't help reflect on their dec\Bion to vacate certain parts of the 14 standards and indeed to vacate the whole MOCA standard due to OSHA's failure to follow certain administrative pro cedures in the development of this standard And it seemed as though people had lost reason While lawyers debated By Vernon Rose. Director, Division of Cnterle Documents sod Standards Development, Nations/ Institute for Occupations/ Safety and Health Rockville, Md fine technicalities of law, the lack of concern for human life was resulting in continuing exposure of workers to carcinogenic substances But of even greater concern regarding the impact on worker health is that almost two years have elapsed since the MOCA standard and the laboratory sections of the other carcinogen standards, were vacated, and OSHA has yet to take the appropriate action to have them reinstated However, I think there is even a tragedy of even greater proportions with which we should be concerned. In the past five years, HEW has submit ted more than 250 recommended occu pational health standards to OSHA under the standards completion pro gram and the criteria document activ ity. THREE STANDARDS Excluding the 14 carcinogen standards, to date OSHA has developed only three stan dards based on these recommenda tions. Certainly not all of the 250 recommended standards are of equal importance as regarding immediacy of need. However, as regards serious ness of health effects and the number of workers potentially at risk, it takes no great genius to identify those hazards for which the lack of adequate standards constitutes a great injustice to the workers of this country Today, workers are sick and dying because of exposures to classical prob lems, such as silica and lead, even though recommended standards for these substances were developed sev eral years ago. Of importance in our discussion today is the lack of rule-making for the control of carcinogens in the work place. Although recommendations for the control of a number of carcinogens have been made by the Department of Health, Education and Welfare, OSHA, since the action on the 14 substances, has regulated only vinyl chloride and coke-oven emissions. As noted earlier, MOCA, one of the most widely used of the original 14 carcin ogens, is no longer regulated. DEAD CENTER In the two and a half years siftce the first occupational carcinogen standards were promul gated, the net result was essentially no movement forward, while the list of identified carcinogens continues to increase. Certainly, one does not wish to consider these facts as representing a disregard for the health and well being of workers It therefore must signify a break down of the regulatory process as more and more complexities are added to the system. NIOSH is greatly concerned regarding the continual Hie number of Identified carcinogens Is rising but protection Is lagging. unregulated exposure of workere to carcinogenic substances. We also note that the 14 carcinogen standards and the standard on vinyl chloride were finally promulgated only as a result of the immediacy associated with rolemaking requirements under Section 6(c) of the Occupational Safety and Health Act, that dealing with emer gency temporary standards. NIOSH will therefore recommend that OSHA immediately implement emergency temporary standards for three carcinogenic substances which we feel pose the greatest potential to adversely affect the health of work ers These are benzene, MOCA, and certain hexavaient chromium com pounds, including lead and zinc chro mate i MAY/JUNE 1977 RSV0033739 BENZENE For benzene, NIOSH has updated and revised its recommenda tions originally transmitted to OSHA in July of 1974 Based on reevaluation of the evidence, we find sufficient data to conclude that benzene does produce leukemia and should be con trolled as a carcinogen Our evaluation and recommenda tions were transmitted to the Depart ment of Labor two months ago With MOCA we were of the opinion that the evidence used to justify the initial standard was a satisfactory basis on i The lack of action presents us with a "sad and shocking" situation. which to initiate new rule-making However, in addition to that data, we were verbally informed several months ago by representatives of DuPont that the results of their long term feeding studies with dogs showed the induction of bladder tumors There was a basis for emergency rule-making for MOCA almost three years ago, and these latest data now make the need even more urgent. LAG The hexavalent chromium com pounds are in widespread use, and the data involved not only animal studies but human results Again the recom mended standards were forwarded to OSHA a year ago. I have hoped to convey my impres sion that efforts to prevent occupa tional diseases, with emphasis on occupational cancers, are not moving forward In the most straightforward terms, this lack of inaction is resulting in sickness and death in our work force, and by and large we know it is preventable That is the sad and shocking state of affairs that exists today in efforts to protect the health of American workers. Needed: an overall strategy for control of carcinogens on the job. It is also a fact that we, as profes sionals dedicated to the control of occupational injuries and illnesses, must be deeply concerned with. In discussing strategies for OSHA'b con trol of carcinogens in the workplace, I think the fundamental concept should Ik.1 what is our overall strategy? What arc the philosophies that should guide us as we move to providing this needed protection0 ***** 50 OCCUPATIONAL HEALTH AND SAFETY RSV0033740