Document 6e3zrXoDvpbooX0ZLbyL7aj9

THE CHLORINE INSTITUTE, INC. 342 MADljlSON AVE., NEW YORK, N.Y. 10017 DEC 2 9 RECTO DATE TO FROM SUBJECT December 27, 1977 OFFICIAL CORRESPONDENTS - ACTIVE MEMBERS /J , ft Y Tt4oC'`+S*~5 Edmund J Laubusch OSHA's PROPOSED GENERIC CARCINOGEN POLICY Representatives of the American Industrial Health Council plan tc be available in Washington from January 9th-12th to help comoanies prepare testimony for April 4th hearings on OSHA's proposed generic standard on carcinogenicity. The deadline for submitting written comments, requesting time to appear at the April 4th hearings and submitting at least an outline of that April 4th testimony, is January (-------- JUl.l. ' L-- AIHC is putting together a team of experts in the areas of economic, science, alternatives and legal who will be in Washington at the offices of AIHC Counsel, Cleary, Gottlieb, Steen Hamilton, 1250 Connecticut Ave., NW, Washington, DC from January 9th-12th from 9 a.m. - 4:30 p.m. each day. They will be available to discuss individually and jointly questions involving an analysis of OSHA's regulations as well as to assist in drafting testimony. In addition, if there is a demand for it, assistance can be provided that week by a teanf in Chicago, Atlanta or other appropriate cities. Companies planning to take advantage of this free service V should let AIHC know when they plan to be in Washington by contacting Ms. Terri Brown at 914-725-1492. \ 1 EJL/dlm ALCOA0004466 economic and technological aspects and thus meant "practicable", a construction "in accord with the clear intent of Congress and the purpose of the Occupational Safety and Health Act". D. Different approach to animal data. The OSHA proposal is relatively indiscriminate in attri buting significance to mammalian test data irrespective of the size of dosage used, the overwhelming of normal detoxification mechanisms, and other experimental test conditions that are unrealistic for occupational purposes. Two biological circumstances dramatize the need for careful appraisal of animal data. Estrogens and androgens are carcinogenic to experimental species, and for estrogens, the occurrence of disease in humans has been documented. Yet estrogenic hormones are ever present at subthreshold or no-effect levels in the entire earth's population and are essential to life. Similarly, metals such as chromium, nickel, cobalt, selenium, and perhaps even ` arsenic are essential to man in small amounts but carcinogenic in excessive amounts. The following proposal would substantially differentiate among test results depending upon such criteria. While the following proposal would require positive re sults in two different mammalian.species in well designed and con ducted experiments to warrant regulation as a carcinogen, it would not preclude OSHA from instituting a normal Section 6(b) rulemaking on a specific substance on the basis of a single such experiment where, in light of the best information available at the time, regu lation for carcinogenic hazards might be appropriate. E. The role of short-term tests. OSHA's proposal would attribute some potentially signi- 22 ALCOA0044S3