Document 71Kb445qYOyZ4bJ0r3Eb3B78a

S December 1975 Mr. Kenneth W. Nelson, Vice Jxaaident.................................... Environmental Affairs ...................................................... New York Office ................ ... . Comments on OSHA's Medical S.urv,ftllanc.a jfar Qaa.upa.tianal Exposure .to Asbestos........................................................................................................... In accordance with our diacuasioix .of. .Z .Qacamfaer,- .1-have .pre pared a statement regarding; .the .proposed .medical .surveillance which appears in the Department of. .labor .Notice .a .P.rapased Rulemaking on Occupational -Exposure to .Asbestos- . .Iha .statement is attached. . ............................... . It is my understanding that .you .wish .to .include this, in A3ARC0' reply to the proposed rules- . -Please ..use -as -y.au sea .fit. . . . .CHH CHHjjdg ................... attachment: as above, 2 pages... cc: DHSoutar, MOVarner .................. i ASARCO ELP 0000746 The Assessment of Proposed Medical Surveillance for Persons with Occupational Exposure to Asbestos Section (j), Paragraphs 1-7 deals with medical surveillance of employees "exposed to asbestos." These paragraphs, among other items, define the type of examination which must be performed. "Minimum examination" requirementsare described as including a history to elicit symptoms of respiratory disease, pulmonary function tests, chest x-ray (14"x 17"), and a sputum cytology examination. The examinations pertain to pre-placement, annual, and separation. The sputum-examina tion is to be carried out only after certain years of expo sure (10) or upon reaching a specific age (45). * An objection is raised to the inclusion of the sputum cytology examination. This objection is based on the lack of sufficient data to support the conclusion that this diagnostic .procedure is of sufficient value to warrant its.inclusion. The present state of the art is not sufficiently developed so that this furnishes the diagnostician any real assistance in predicting the presence of cancer. It is improbable that the procedure would yield positive results in the absence of other simpler findings, i.e., positive x-ray findings or positive signs and symptoms. The test has use in clinical medicine, but as a confirmatory, not a prognostic, tool. Further, it may give a false sense of security to the employee whose measurement does not indi cate the presence of malignant or suspicious cells. The present technique has a large "background noise" as far as classification of other than malignant cells are concerned. There are not enough well trained cytologic technicians or laboratories to process the tremendous numbers of samples which would be needed by following this requirement. Finally, unfortunately the salvage potential would not justify the cost, even at $15-20 per cytologic evaluation. A second point of disagreement is the definition of an "exposed" person. Under the new regulations, this would include persons with as little- exposure as 0.5 fibers/cc of air. This require ment, ..would- the necessity of subjecting almost all employees whO"'wor)c iir-any-area where asbestos is used to the examination. The_.inclusiarL at every person who works in an area where there is- a~.Biiauta. quantity of asbestos does not seem to be in keeping with-.whafc. ia~rauonabla in occupational medicine. It is my medical, opinion- that this is not required and that the present level of 2 fibers/cc better defines the group which would profit from medical surveillance. A third objection is made to the material contained under Para graph 6. Clarification should be made of what constitutes a written "opinion." If a format can be devised in which a check off system, initialed by the physician, can be utilized, this ASARCO ELP 0000747 does not pose an undue demand on the physician's time; if the statement truly has to be written, then there is unnec essary wastage of time and additional cost involved in the operation. Finally, reference is made to the maintenance of medical records which appears under Paragraph (n), sub-paragraph (2) Medical Records. A requirement is made for maintenance of records for 40 years, or longer periods if the employee's employment exceeds this. This will result in an unwieldly and unnecessarily complicated procedure for storage. Pre vision should be made for condensing the records on a tenyear, or some other reasonable, basis. 1 severely question whether the epidemiologic data quoted substantiates the conclusion that there is a doubling of the rates for. cancer of the stomach and rectum. Perhaps we can reply to this in greater detail at a later time. Further, of course, is the question as to whether or not the data which was obtained on persons exposed at concentrations of fibers of 15-50/cc is really relatable to present day ex posures . CHH : jdg 5 December 1975 Charles H. Hine, M.D., Ph. I ASARCO ELP 0000748