Document 6w23VZOE8y5yNr2pVKqkrd9g3

Monsanto APk U 6 From: James J. Collins, Epidemiology, A2SL, 4-8811 Date: April 2, 1993 cc: G. F. Fort B. R. Friedlander J. F- Acquavella B. K. Ireland Biohazards Committee Subject: Communication to Employees on Monsanto Update of the 1949 Accident at Nitro Reference: TO: D. Herndon T. Blank - Krummrich P. Conner T. Kokotovich - Queeny M. Strauss L. Wassell R. Kaley B. Vandenbeck P. Conlon - Nitro D. Snively Attached you will find a draft copy of a paper we will be submitting for pulication. This paper describes your communication efforts at ^Krummrich, QueenyX>and Nitro on the 1949 Nitro Accident Study. As you can~see from this write up, we have received substantial positive feedback from our communciation effort. I have also attached a recent article from Occupational Hazards which describes our efforts as well as those of Dow's in the area of worker communication. If you have any comments on this paper, please return them to me prior to April 22. J. J. Collins DSW 134145 STLCOPCB4034103 Communication to Workers of Epidemiology Study Results: An Industry Approach Draft (3/31/93) James J. Collins Patrick R. Conner Abstract Communication to workers of epidemiology study results is gaining increasing acceptance because of the need to notify study subjects and the responsibility to warn workers of potential workplace hazards. We argue that industry is in unique position to inform workers by presenting our recent efforts to notify 9,648 workers potentially impacted by the results of an epidemiology study reporting increased cancer rates. Because of payroll, medical and pension responsibilities, we were able to locate a substantial portion (71%) of employees working in processes operating between 1935 to 1969. We found that both study subjects and workers with exposure similar to study subjects were equally interested the findings. We conclude that most workers view the notification as evidence of the company's commitment to monitor their health, and are pleased that the company undertook the study and reported the results to them. Acknowledgements: We would like to thank the management, union representatives, and medical staffs at the Nitro, Krummrich, and Queeny plants for assisting us in putting together the communication package. 1 .............. ................... DSW 134146 STLCOPCB4034104 Worker notification of epidemiologic study results is gaining increasing acceptance not only because of the need to notify study subjects, but also because of the responsibility to inform workers of potential hazards from exposure.1,2,3 Tepper has pointed out, that while the obligation to inform workers about potential hazards in the workplace is shared by industry, government, and labor organizations, "the primary responsibility must rest with the employer (434)."1 We agree with Tepper and will argue that industry is in a unique position to inform workers or former workers about epidemiologic study results because of 1) knowledge of its plants, process and products, 2) information on who is or was exposed, and 3) access to current and former workers. While attention has been given to the importance of worker notification of epidemiology study results, little has been written about how this can best be done by a company and how the workers being notified may react.3 We report on our attempt to notify 9,648 former and current workers potentially impacted by study results and the response of our workers to this communication. As far as we know, this is the largest worker communication on epidemiology study results ever reported. Background We recently completed an epidemiology study in which increased 2 DSW 134147 STLCOPCB4034105 mortality rates were reported for bladder cancer, respiratory cancer and soft tissue sarcoma among a subcohort of workers at one our plants.4 This study examined 754 workers at the plant in 1949 present during the clean-up of an accidental release of a chemical mixture later recognized as containing 2,3,7,8tetrachlorodibenzo-p-dioxin (TCDD). Some workers in this study also had potential exposure to 4-aminobiphenyl, a bladder carcinogen. Currently, all epidemiology study results on Monsanto plants are reported to current workers. These communication efforts may include plant presentations, bulletin board announcements, or articles in plant newsletters. However, for the current study we decided to supplement our usual methods with a mailing to all persons working when exposure to either TCDD or 4-aminobiphenyl occurred at the plant. This additional communication effort was undertaken because the processes at the Nitro plant where increased cancer rates were report were discontinued long ago. We also notified workers at two additional plants (i.e., Queeny and Krummrich) who had potential for similar exposures even though they were not included in the present study. There is long history of communicating study results at these three plants. Notification and medical surveillance of workers with exposure to 4-aminobiphenyl began in the early 1950's at the 3 DSW 134148 STLCOPCB4034106 Nitro, Krummrich and Queeny plants.5,6 The medical surveillance continues today. Results of studies of potential TCDD exposure have also been reported to workers during the 1980's.7,8,9,10 Material and Methods As shown in Table 1, we identified 9,648 workers or former workers who worked 1 or more days during the time when there was potential exposure to either 4-aminobiphenyl or TCDD at each of the three plants and were currently alive. We decided to mail information to all employees who worked at the plant during the times when either substance was present rather than just employees with a high probability of exposure. We obtained 4,432 addresses from the company pension and payroll files, and 2,399 addresses from the Health Care Finance Administration (HCFA). HCFA has information on persons receiving Medicare and Medicaid, and will provide addresses of persons to researchers if called for in the study protocol and if specific confidentiality guidelines are agreed to. As shown in Table 1, there was a wide variation in the percentage of addresses obtained from payroll and pension files ranging from 87% at the Nitro plant to 52% at the Queeny plant. We obtained 2,399 additional addresses from HCFA a considerable portion of the total addresses (35%). Combining information from our own sources and HCFA's, we were able to obtain mailing address for 71% of the workers--75% at Queeny, 67% at Krummrich and 77% at 4 DSW 134149 STLCOPCB4034107 Nitro. We composed a letter describing the motivation for the study, the results, the uncertainties inherent in interpreting those results, and the investigators interpretation of the findings.11 The results of another study on dioxin thought to be relevant were also discussed.12 A list of departments and time periods where and when dioxin or 4-aminobiphenyl exposure was possible was included in the mailing to allow workers to evaluate their potential for exposure. This letter mentioned previous studies on dioxin and 4-aminobiphenyl which had been conducted at these three plants. It was also explained that a follow-up study was planned to further evaluate the findings of the latest study. Future communication of the follow-up study was also promised. We also enclosed a brief questionnaire and a return envelop for mailing. The questionnaire was included to gauge the effectiveness of the communication, to determine if the workers wanted more information, and to enlist the help of workers for future communication. The letter and questionnaire were reviewed and revised by groups of employees, including union representatives and management, at each of the three plants. We mailed 6,831 letters. Only 287 (4%) were returned with either "address unknown" or "person deceased." We assumed 6544 letters were delivered. 5 ......... DSW 134150 ..................... STLQQPCB4034108 To help reduce undue anxiety and to answer questions, we also provided a toll-free phone number of a company physician who was knowledgeable of the study. Sixty-eight calls were received (44 from workers, 23 from workers relatives, and 1 from a workers physician) by this physician. Our Institutional Review Board, composed of academics from outside the company, reviewed all documents before mailing. Confidentiality of respondents to the questionnaire was assured in the mailings. Because of the confidentiality considerations, no follow up with non respondents to the questionnaire was undertaken. Respondents were asked to provided a mailing address if they wanted to receive more information on the study. A reprint of the journal article was provided these respondents. Results Of the 6544 letters delivered, we received 1960 questionnaire responses (30%). Responses by plant of the workers are reported in Table 2. The category labeled "other" includes workers who reported working at more than one plant or failed to report a plant at all. Because salary workers would be more likely to work at multiple plants than hourly workers, the category "other" most likely has a high proportion of salary workers. Most respondents (96%) felt the correspondence was easy to read. 6 DSW 134151 STLCOPCB4034109 There was little variation in this response by plant. When asked if they received enough information about dioxin a little more than half of the respondents (55%) felt they did. Only the category "other" differed markedly (66%) from Nitro (55%), Krummrich (54%), and Queeny (53%) on this response. More than two-thirds (69%) wanted more information on the study mailed to them. Eighty percent of the Nitro plant respondents wanted a copy of the published report. Smaller percentages of respondents from Krummrich (69%), Queeny (71%), and the other category (53%) wanted a copy of report. When asked how important it was to report future study results, 93% of the respondents thought it was important. Almost all respondents at the Nitro plant (99%) thought it was important with slightly smaller percentage of respondents feeling it was important at Krummrich (93%), Queeny (93%) and the other category (92%). As mentioned previously, 68 phone calls were received on the communication. Not surprisingly, callers to the physician indicated more difficulty in interpreting the letter. Most of the questions from the phone calls concerned confusion over what to do with the questionnaire. Several formers workers, however, had serious health problems and wanted clarification of the meaning of the study to their personal diagnosis and treatment. A few callers asked if the company intended to provide additional 7 DSW 134152 STLCOPCB4034110 medical benefits and some wanted to know if the communication was in response to litigation. Discussion Since we were able to deliver letters to only 6,544 of 9,648 workers identified (68%), and since only 1960 response to the 6,544 delivered letters were returned (30%), the findings of our survey must be interpreted with caution. It is possible a more complete survey would yield different results. Keeping in mind the limitations of this survey, however, three findings seem clear. First, workers are very interested being informed of epidemiologic study results. Ninety-three percent of the respondents felt that it was important to inform them of future study results and 69 percent of the respondents wanted additional information. Other notification efforts which surveyed workers report similar high support for this sort of communication.13,14 While virtually all respondents from the Nitro plant, the plant where the epidemiology study was conducted, thought the communication was important, large portions of workers at Krummrich and Queeny also thought the communication was important even though the study was conducted at another plant. In the past worker communication of epidemiology study results have been mostly directed to study subjects. Our findings indicate non-study subjects also have great interest in study findings of workers with similar exposures. 8 DSW 134153 STLCOPCB4034111 Industry is in a unique position to undertake epidemiology studies and communicate findings to workers. Much of industry maintains detailed documentation of manufacturing procedures, industrial hygiene monitoring, toxicity testing, medical outcome information and demographic and workhistory information on each employee. No one has more information on potential hazards in the workplace or is in a better position to evaluate this information as it may relate to worker health than the company involved. At the Nitro plant seven studies have been done over a forty year period by the company.4*9,15 The communication of single study does tend to freeze evolving scientific knowledge and workers opinion at one point in time.11 An ongoing series of studies allows the incorporation of new information in the ongoing evaluation of potential hazard of a substance and can help to convince workers of the company's interest in their health. In addition, the communication of the study results is often accompanied with the announcement of a follow-up study. Study communication can be seen as the first step in a multistage process of surveillance and further study.16 The communication of study combined with the announcement of the follow-up study helps assure employees that while we may not have all the answers currently we will report new information as it becomes available. The employer because of payroll, medical and pension responsibilities also stays in contact with a large portion of 9 OSW 134154 STLCOPCB4034112 its total workforce. In the present communication effort we were able to obtain current addresses on 71% of our former employees. We had current address information form our payroll and pension files on 46% (4432 of 9648) of our former workers, and because of our detailed demographic information were able to obtain an additional 25% (2399 of 9648) from HCFA. Our ability to obtain addresses on so many former employees is remarkable given many of them terminated employment decades earlier. Other communication efforts of epidemiology studies which involved companies report percentages of current addresses of 91,17 79,18 76,18 and 66,19 while communication efforts in which companies for various reasons were not involved report percentages of current addresses of 2514 and 45.20 Company participation improves access to worker populations facilitating comprehensive communication. There are also lessons we learned from our phone contacts and written comments on our survey. Individuals with active serious medical conditions will likely want more in depth personalized communication about the implications of the findings to their own diagnosis, treatment and prognosis. Access to personalized follow-up such as through a toll-free number should be a feature of any employee communication effort. The questionnaire included in the mailing produce valuable feedback to us on the effectiveness and the importance of our communication effort. This questionnaire also helped us locate 10 DSW 134155 STLCOPCB4034113 former employees to help us with future communication and provided former employees a means to get more information on the study. However, the questionnaires themselves were a source of confusion to some employees. The advantages of including a questionnaire in mailings should be weighted against the possible confusion caused in asking someone to fill out and mail a form. Good communication of epidemiology study results is resource intensive. The development and the delivery of a communication package involved many meeting for several persons from four different locations. In addition, we were surprised at both how many requests we got for follow-up information and how many calls were received by our company physician. While it can be argued that employee communication increases study duration and takes scare resources from other important projects, we consider employee communication to be an essential feature of each epidemiology study.11,21 While some employees will be suspicious of a Company's motive behind communication, most will welcome it. Employees were pleased that the company not only undertook several studies of their health, but also took the time to communicate the findings to them. Our letter was viewed as tangible evidence of our commitment to monitor their health. One worker writes that, "keeping employees or former employees informed on all potential 11 DSW 134156 STLCOPCB4034114 hazards shows you are interested in their well being. Thank you." 12 DSW 134157 STLCOPCB4034115 References 1. Tepper LB. The right-to-know, the duty to inform. J Occup Med 1980;22:433-437. 2. Samuels, SW. Communicating with workers (and everyone else). Am Ind Hyg Assoc J. 1979;40:1159-63. 3. Schulte PA, Boal WL, Friedland JM, Walker JT, Connally LB, Mazzuckelli LF, Fine LJ. Am J Ind Med. 1993;23:3-9. 4. Collins JJ, Strauss ME, Levinskas GJ, Conner PR. The mortality experience of workers exposed to 2,3,7,8tetrachlorodibenzo-p-dioxin in a trichlorophenol process accident, 1993;4:7-13. 5. Melick WF, Escue HM, Naryka JJ, Mezera RA, Wheeler EP. The first reported cases of human bladder tumors due to new carcinogen--xenylamine. J Urol. 1955;74:760-66. 6. Melick WF, Naryka JJ, Kelly RE. Bladder cancer due to exposure to para-aminobiphenyl: a 17-year followup. J Urol 1971; 106:220-226. 7. Zack JA, Suskind RR. The mortality experience of workers exposed to tetrachlorodibenzodioxin in a trichlorophenol process accident. J Occup Med 1980; 22:11-14. 13 DSW 134158 .... , ' .. - . . - . . t : STLCOPCB4034116 8. Suskind RR, Hertzberg VS. Human health effects of 2,4,5-T and its toxic contaminants. J Amer Medical Assn 1984; 251:2372-2380. C* 9. Zack JA, Gaffey WR. A mortality study of workers employed at the Monsanto company plant in Nitro, West Virginia. In:Tucker RE, Young AL, Grey AP (eds) Human and environmental risks of chlorinated dioxins and related compounds. Plenum Press, New York, 1983:575-591. 10. Moses M, Lilis R, Crow KD, Thornton J, Fischbein A, Anderson HA, Selikoff IJ. Health status of workers with past exposure to 2,3,7,8-tetrachlorodibenzo-p-dioxin in the manufacture of 2,4,5-trichlorophenoxyacetic acid: comparison of findings with and without chloracne. Am J Ind Med. 1984;5:161-82. 11. Acquavella JF, Collins JJ. Perspective on the content of worker notification. Am J Ind Med. 1993;23:77-83. 12. Fingerhut MA, Halperin WE, Marlow DA, Piacitelli LA, Honchar PA, Sweeney MH, Griefe AL, Dill PA, Steenland K, Suruda AJ. Cancer mortality in workers exposed to 2,3,7,8tetrachlorodibenzo-p-dioxin. N Engl J Med 1991; 324:212 218. 14 DSW 134159 STLCOPCB4034117 13. Houts PS, McDougall V. Effects of informing workers of their health risks from exposure to toxic materials. Am J Ind Med 1988;13:271-79. 14. Bender AP, Williams AN, Parker DL. Experiences of a statesponsored notification and screening program for asbestos workers. Am J Ind Med. 1993;23:161-169. 15. Strauss ME, et al. MBT Study. Brit J Ind Med (in press). 16. Schulte PE. Problems in notification and screening of workers at high risk of disease. J Occup Med. 1986;28:951957. 17. Marsh GW, Leviton LC, Talbott EO, Callahan C, Pavlock D, Hemstreet G, Logue JN, Fox J, Schulte P. Drake chemical workers' health registry study: I. notification and medical surveillance of a group of workers at high risk of developing bladder cancer. Am J Ind Med. 1991;19:291-301. 18. Tillett S, Ringen K, Schulte P, McDougall V, Miller K, Samuels S. Interventions in high-risk occupational cohorts: a cross-sectional demonstration project. J Occup Med. 1986;28:719-727. 19. Schulte PA, Ringen K, Altekruse EB, Gullen WH, Davidson K, 15 DSW 134160 STLCOPCB4034118 Anderson SS, Patton MG. Notification of a cohort of workers at risk of bladder cancer. J Occup Med. 1985;27:19-28. 20. Rosenman KD, Stanbury M, Lemon A, Solice-Sample G, Kalush A. High-risk notification of chromate and bichromate production workers. Am J Ind Med. 1993;23:125-34. 21. The Chemical Manufacturers Association's Epidemiology Task Group. Guidelines for good epidemiology practices for occupational and environmental epidemiologic research. J Occup Med 1991;33:1221-1229. 16 DSW 134161 STLCOPCB4034119 Table 1. Description Workers Identified Letters Mailed Letters Delivered (% of identified) Address from company files (% of mailed) Address from HCFA (% of mailed) Letters Returned (% of letters mailed) Oueenv 3536 ? 2636 (75%) 1383 (52%) 1253 (48%) Krummrich 5122 ? 3428 (67%) 2378 (69%) 1050 (31%) Nitro 990 767 (77%) 671 (87%) 96 (13%) Total 9648 ? 6831 (71%) 4432 (65%) 2399 (35%) 287 (?) STLCOPCB4034120 o </> a: 17 Table 2 Ouestion and Response Was the letter easy to read? Number Yes (%) Did you receive enough information on dioxin? Number Yes (%) Nitro 157 (95%) 88 (55%) Would you like a complete copy of the published report mailed to you? Number Yes (%) How important is it to inform you of future study results? Number Important(%) 123 (80%) 162 (99%) Total Questionnaires Received 166 Krummrich 844 (95%) 447 (54%) 586 (69%) 818 (93%) 900 Oueenv 618 (97%) 314 (53%) 435 (71%) 592 (93%) 647 Other1 207 (95%) 133 (66%) 112 (53%) 194 (92%) 247 Total 1826 (96%) 982 (55%) 1256 (69%) 1766 (93%) 1960 DSW 1 3 4 1 6 3 18