Document 85vDpnMMO1Jz97MDDgOXGMoQd

FILE NAME Manville JMA DATE 1977 DOC JMA380 DOCUMENT DESCRIPTION Union Carbide - Multiple Docs with BC Comments 7/20/98 Union Carbide Union Carbide comments to OSHA 1978 attached 9/16/77 letter also HB Rhodes UC asking that up to 500 day of friable asbestos- by containing wastes be treated as hazardous wastes by the state of California UC contracted survey analysing citizen attitudes on cancer risks 1977 circulated in AIA and shared with U.S. government officials Other letters by HB Rhodes as representative of AIA 1977 re coordination of industry comments to government ae . 10018 JUL 1978 INFORMATION STATEMENT BY THE ASBESTOS INFORMATION ASSOCIATION AMERICA in regard to the DEPARTMENT OF LABOR OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION DEPOSITION EXHIBIT 643 PROPOSED RULEMAKING IDENTIFICATION CLASSIFICATION AND REGULATION OF TOXIC SUBSTANCES POSING A POTENTIAL OCCUPATIONAL CARCINOGENIC RISK 29 CFR Part 1990 CFR 42 No. 192 - Tuesday October 4 1977 Presented at the public hearing in Washington DC on July 19 1978 by Dr. H. B. Rhodes Chairman AIA Standards Advisory Committee ee ee ee ee - ~. DRAFT June 22 1978 My namies Harrison B. Rhodes and I am employed as a Technology Manager in the Calidria Asbestos Department of the Union Carbide Corporation My educational background is in chemical engineering where I hold a degree of Dr. Eng Sci from Columbia University testimony xxxxxxxx is presented on in New York City behalf of the Asbestos Information Association America AIA is an incorporated nonprofit organization of 53 firms in the United States and Canada engaged in the manufacture or processing of containing products and in the mining and milling of asbestos fiber I serve the AIA as Chairman of the Standards Advisory Committee Chairman of the Committee on Air Monitoring and as a | member of the Executive Committee INTRODUCTION AND SCOPE OF COMMENTS The present rulemaking on a generic approach to the regulation of occupational exposure to carcinogens places the asbestos industry in a unique and somewhat ambiguous position As you are well aware asbestos was the subject of OSHA's first health standard promulgated in June 1972 Extensive revisions to this standard were proposed on October 9 1975. These revisions were to be applied to the manufacturing segment of the industry only The construction industry which is extremely important to us because it uses 70 of all of the containing products manufactured was excluded from the proposed revisions It is to be the subject of a separate rulemaking The wisdom of separate treatment for the construction industry was borne out by a series of OSHA Construction Industry Advisory Committee hearings on asbestos held during 1976. The Committee found numerous serious problems in the application of the requirements of the proposed asbestos manufacturing standard to the construction setting - At this time therefore the asbestos industry is approaching a combined rulemaking on asbestos exposure in both manufacturing and construction The position that OSHA takes in these upcoming asbestos hearings will We will however undoubtedly be influenced by this generic rulemaking / the asbestos questions in the future asbestos rulemaking proceedings and 39930979550 0365000 d O90. OV YS DICH e 2) OO ote BOs | Aves Hata ee PCE SERS address confine our remarks today DOGMETLIOUXIESXT^DBESXanebcandoremkiatdthe AAR BEX) RRA BA ny to a brief discussion of two DOGOMETELIOUXXXIESXXXT^ DDBESXainesbbescanudoreemksiatda PIO VD DOGOMETELIOUXXXIESXXXT^ DDBESXanebbecandorDOGMEeTLIOmUXIEkSXTi^DBaESXanetbcadndoremakiatd DOGMETLIOUXIESXT^DBESXanebcandoremkiatd DOGOMETELIOUXXXIESXXXT^DDBESXanebbecandoremkiatda DOGOMETELIOUXXXIESXXXT^ DDBESXanebbecandoremkiatda specific present rulemaking proposal which impact on us directly and which have not RAX RES SIP O FISV OIWIIVIIA Va), Cer Xs tr eee CUA ADU AR HO HOE TSE CRTC Kia a Se SEI been addressed by others They are 1 The relationship of existing standards to those that will be promulgated under a generic approach 2. The development of appropriate standards for the construction industry and other industries characterized . by fixed places of employment THE RELATIONSHIP OF THE PROPOSED GENERIC STANDARD TO EXISTING STANDARDS OSHA today has health standards in effect which cover asbestos 14 specific carcinogens vinyl chloride xxxxx oven emissions XO benzene and acrylonitrile.xxxxxxxxxx.kgrat acrylonitrile.xxxxxxxxxx.kgrat acrylonitrile.xxxxxxxxxx.kgrat acrylonitrile.xxxxxxxxxx.kgrat rh XXXXXXXEKY pensex All of these standards were developed during appropriate administrative hearings where the various parties involved could present their special problems and the consequences of various alternatives were examined The final regulations were in effect tailored in the arena of adversity for the particular conditions in the industries involved The generic approach proposed in this hearing is expressly intended to speed the promulgation of standards for substances for which standards do not exist Of necessity its model standards are broadly drawn and do not reflect specific adaptations for given industries or for segments of industry For substances now covered by OSHA standards the workers are already At EDACTED EDACTEDEDACTED EDACTED EDACTED extensively protected If new information becomes available by which OSHA can document an imminent selective changes in the standard can be made under the provisions of Section b of the Occupational Safety and Health Act Otherwise the urgency which is the rationale for the generic approach does not exist In view of the extensive records that have been developed in the promulgation of the existing standards we believe it is inappropriate for OSHA to override a standard based on the record with a broadly drawn formula standard Any changes in existing standards which OSHA believes to be appropriate should be made selectively under the current administrative and statutory procedures with no issues excluded from consideration because - of OSHA policy CONSIDERATIONS FOR OSHA HEALTH STANDARDS - INDUSTRIES WITH FIXED PLACES OF EMPLOYMENT Over the past six years OSHA has evolved a basic format for health standards which relies heavily upon widespread repeated monitoring to determine compliance Universal medical surveillance is also required with both medical and moitoring records stored by the employer for forty years or more These principles are well exemplified by the present generic proposal The Asbestos Information Association America has contracted with Equitable Environmental Health Inc. to conduct a detailed study of the use of containing products in the construction industry We have also been working closely with various trade and contractors associations As this work progresses it has become increasingly evident that there are two fundamental difficulties in applying the repeated monitoring and universal pinciples of OSHA standards to the construction industry medical surveillance 1. There are hundreds of thousands of transient work places i.e work places that generally exist for only a few months or less and are replaced by others A standard where each work place must be monitored is completely impractical A work force of several million persons is involved A majority of this force works for a number of different employers over the course of a year Contractors also enter and leave the market with great regularity Any sort of inclusive medical surveillance and record- keeping by individual emolovers is clearly unworkable Such a program would also be too fragmented to contribute to the protection of the worker or to research OSHA had had a similar study in progress for about two and a half years that is still not completed It seems reasonable to assume from this long delay that OSHA has also become well aware of the extraordinary complexity in the development of a feasible health standard for this industry RECOMMENDATIONS In order to clarify the relationship between existing health standards and the present generic proposal and to recognize that other specific approaches are necessary for industries characterized by fixed places of employment it is requested that the following words be added to Subpart A Paragraph 1990.1 Scope Substances for which health standards have been promulgated and are in effect shall not be subject to the provisions of Part 1990. This section does not apply to construction work within the scope of paragraph 1910.12 of this part or to other fixed places of employment We believe that this request is reasonable is consistent with the intent of the generic approach and necessary to avoid future misunderstanding this XX proposed rulemaking ARGINALIA ARGINALIA ARGINALIA ARGINALIA ARGINALIA ARGINALIA ARGINALIA REDAWUTED ARGINALIA REDAWUTED REDAWUTED REDAWUTED REDAWUTED REDAWUTED REDAWUTED REDAWUTED ARGINALIA ARGINALIA REDAWUTED ARGINALARIGINAALIA REDAWUTED REDAWUTED REDAWUTED REDAWUTED -. R. Allenbach T. H. Carmody E. M. Fenner Fusaro R. F. X. R. H. Mereness J. L. Myers F. Ottoboni P. C. Rekemeyer E. W. Shortridge {. W. C. Thurber P. Weisser File REIDIE alidria cinched 7 alidria alidria ASBESTOS NION CARBIDE CORPORATION METALS DIVISION BOX SLL AS bf NIAGARA FALLS N.Y. 14302 . TEL 716-278-3376 September 16 1977 Dr. Harvey Collins State of California Department of Health 714 P Street Sacramento CA 95814 Dear Dr. Collins This confirms my telephone conversation of September 16 1977 _ regarding a possible serious problem in the Proposed Regulations 71-76 of Title 22 Div 4 Hazardous and Extremely Hazardous Wastes as it relates to asbestos Both the present and the proposed regulations include asbestos as Item No. 77 in the specific listing of Hazardous Wastes and Hazardous Materials under paragraph 60281 c of Article 9. Asbestos waste is also included in the listing of common names under Part c of the same paragraph The regulations require that the wastes included in this list must be moved only by licensed haulers with proper manifests and be disposed of in Class I or Class II facilities which have permits to receive hazardous wastes In contrast to this Operation Information by the dated December 1976 states on publication a Disposal Site Design and California State Water Resources Control page 26 Board 3 2522. Group 3 Wastes Group wastes consist of nonwater soluble nondecomposable inert solids include but are not limited to the following entirely examples 2522 Industrial inert slags asbestos and inert plastics wastes such as clay products glass inert tailings inert rubber scrap Emphasis added Under this wording Group 3 wastes can be sent to Class III disposal sites which are much more plentiful and less expensive than Class I or Class II It is our understanding that the present enforcement practice for asbestoscontaining wastes is disposal in Class III dumps in the manner described in the recent letter to automotive brake shops A possible exception to this is demolition jobs where large quantities of friable asbestos materials have been used for fireproofing insulation In view of the very large civil and criminal penalties for violations of waste disposal regulations now included in Assembly Bill 1593 it seems most appropriate to try to resolve this in- . consistency in the statutes at this time 6167140 6167140 oe Harvey Collins ete -2- | September 16 1977 et ee We believe that the present approach wherein moderate quantities of asbestos or containing materials are allowed to go to Class III emin disposal sites is reasonable and realistic This should not pose a substantial present or potential hazard to human health or environment Large quantities of asbestos fiber or containing material which can easily release such fiber however can conceivably represent a hazard and may properly be handled under the hazardous waste provisions of the regulations A distinction in terms of the quantity of asbestos fiber involved should be made as permitted under the statutory authority contained in therefore AB 1593 25117. Hazardous waste means a waste a combination of wastes which because of its quantity concentration or physical chemical or infectious characteristics Emphasis added ) In making this distinction the amount of asbestos fiber that is present or which can be released easily is the critical factor Fiber which is firmly held in a binder presents little if any hazard should not be included On this basis the following approach is suggested ; , 1 Define a term friable asbestos waste as any waste that contains more than % asbestos by weight and that can be crumbled pulverized or reduced to powder when dry by hand pressure This would eliminate bound asbestos from treatment of a hazardous waste 2 Set a limit of up to 500 pounds of friable asbestos waste or up to 50 pounds of unbound asbestos fiber which any source can generate for disposal in a Class site per day as the maximum quantity These values are derived from the Federal EPA limit of 160 ft of friable asbestos material from demolition which is not required to be deposited in a regulated disposal site Thus an assumed insulation thickness of 3 inches a density of 15 pounds per cubic foot and an asbestos content of 10 . 1/2 160 15 = 600 lbs of friable material 1/2 0.10 = 60 lbs of contained asbestos There are several ways that these changes the proposed regulations but the simplest and most follows . could be incorporated into direct appears to be as 1 Deleted 77 Asbestos from 60218 d list since the regulations are only applicable to asbestos waste and it may be confusing to have asbestos wastes included in both lists 2. Expand the term asbestos waste in the list under paragraph 60218 e to 1 Harvey Collins -3- September 16 1977 Asbestos waste that contains more than % asbestos by weight and that can be crumbled pulverized or reduced to powder when dry by hand pressure Daily quantities of such material not to exceed 500 pounds of total material or 50 pounds of contained asbestos whichever is the less treated as hazardous waste from any one source may be We want to thank you for this opportunity for comments If there are any questions or if we can be of any further assistance please let us know Very truly yours Harrison B. Proces Harrison B. Rhodes Technology Manager HBR 7838 UNION CARBIDE CORPORATION 1730 PENNSYLVANIA Avenue W. WASHINGTON D.C. 20006 Ms. LESLYE A. ARSHT MANAGER PUBLIC RELATIONS WASHINGTON OFFICE TELEPHONE 202. 872-8335 October 19 1977 Dear Mr. Mereness Attached per the request of Harry Rhodes you will find the attitudinal survey data gathered by Cambridge Reports Inc. for Union Carbide Corporation on cancer risks which was the subject of recent presentations at Consumer Product Safety Commission and the Environmental Protection Agency on October 5th and Occupational Safety and Health Administration on October 13. J.B. Jack Browning Corporate Director of Safety Health and Environmental Affairs for Union Carbide and Gene Pokorny of Cambridge Reports Inc. made the presentations and answered the questions of those present I thought it would be helpful for those who study the findings and who attended the presentations on them to understand the thinking at Union Carbide that led to this survey As we all know cancer has become an issue of increasing concern to Americans who with alarming regularity are being told that substances in everyday use are potentially cancercausing The recently proposed ban on one of these substances saccharin has led to widespread public debate over what kind of roles the government should play whether the government should ban all public use of possible carcinogens or whether under certain circumstances it should also explore alternative regulatory strategies To shed more light on this public issue Union Carbide Corporation commissioned Cambridge Reports Inc. a respected opinion research organization to ask 1,500 Americans some questions about cancer -- its frequency and its risks -- and policies for dealing with carcinogens -2- Even though a limited number of questions were asked in this public attitude study the information developed from the in- depth personal interviews with a representative sampling of adult Americans appears to offer some fascinating -- and often conflicting -- insights into public perceptions of cancer risks and regulatory policy We believe that the findings of value to all in the public and cerned with controlling -- and this study have a special private sector who are - con- preventing -- cancer For they pinpoint some challenges and point to some possible guideposts on how Americans view their own role -- and the role of government in dealing with carcinogens Should you have any questions about the findings of survey I would be glad to discuss them with you the Sincerely a re < < - < < < Mr. Robert H. Mereness Asbestos Information Association North America 1745 Jefferson Crystal Square Suite 509 Davis Highway - Building 4 Arlington VA 22202 7852 AA ASBESTOS INFORMATION ASSOCIATION NORTH AMERICA Oey 1745 Jefferson Davis Highway Crystal Square 4. Suite 509 Arlington Virginia 22202 703 979-1150 29 November 1977 Memorandum For EXECUTIVE COMMITTEE Mssrs Gabrielson Alcorn Drs Cross Weill Kotin Enterline Pelnar Subject Cambridge Reports Inc. survey An Analysis of Citizen Attitudes Toward Cancer Risks Enclosed is a Reports Inc. of individual report of a survey conducted by at the request of Union Carbide attitudes toward cancer risks Cambridge on the subject Attention is invited to the covering letter which explains why Union Carbide contracted for the survey and notes that the results of the survey have been presented to officials of OSHA EPA and CPSC By separate communication it has been learned presentations of the survey will be given to other government agencies including FDA and NCI Transmittal of the enclosures was delayed pending permission for dissemination H. Mereness Executive Director RHM Enclosures 7837 An Analysis of Citizen Attitudes . Toward Cancer Risks Prepare fodr Union Carbide Corporation June 1977 pe SO a end ASBESTOS 1 ASBESTOS 1 e 1726 J : : wee oe This analysis is provided for the internal of the Union Carbide Corporation its employees consultants . : use and Should Union Carbide release any portion of the analysis to any public medium it is the responsibility of the Corporation to insure that the release is in strict conformity with that provided in these pages Cambridge Reports Incorporated reserves the right to correct any public release of erroneous data or analyses by the release of the correct information or such other measures as may be needed Union Carbide Methodology This is an analysis of a survey of the attitudes of the American people toward cancer and Federal regulation of carcinogens It is based on 1,500 depth personal interviews conducted with a representative sample of adult Americans from 1 June 1977 to 23 June 1977 of All of the thethe the interviews were conducted in person in the homes of the the the the respondents by trained professional interviewers A description of the basic survey methodology is available on request Objectives The major objectives of this this this this this survey were 1 To examine current attitudes about the. causes and frequency of cancer a Manmade vs. naturally occurring carcinogens To survey perceptions of the risks and benefits of carcinogens a Opinions about carcinogens with real social benefits b Levels of information about carcinogens Union Carbide To measure current attitudes toward Federal regulation of carcinogens a Attitudes toward the FDA bans on food dyes and saccharin Attitudes toward an alternative system of labeling for carcinogens Notes on Analysis It will be helpful to keep several points in mind 1 An asterisk * by a row or column of figures indicates that the numbers are based on a sample size too small to be entirely reliable and thus conclusions based on them should be treated with caution This does not mean that the figures are wrong but that an insufficient number of interviews makes it impossible to show that they are definitely right for that area For easy referral a complete listing of all the questions used in this survey has also been included at the end of the report in Appendix A. Union Carbide 3 A map delineating the areas used for analysis appears at the beginning of the report _ 7 at SS Po Rte Ea oe TLE VEE oo - chen oe ee IPRTIR RISO ayotes a hee Se L PY ee RCS GULOe ee St) et ee Ure toe Cd nt bemOmat,e Opm> pense Waleslah eges ng oluite Olay Ocrsngma MISOURI POurseand PBT A OterPent 2 et 570woe C@ort = ome onty hed ne STEI ET. Tet ea, CAILADA Northeast CAtt Te ny ADA Industrial natn . Industrial bacdla - . aan Carolina . Rr % 6 26 95 eocn os 5 e ote om 8 gh ores Union UnioU n nUni ion on Carbide -5- Cancer Cancer Cancer Cancer Cancer Cancer Knowledge Knowledge Knowledge KnowledgeKnowledgeKnowledge Knowledge Knowledge Knowledge and and and Attitudes At itudes At itudes Attitudes Attitudes Attitudes Attitudes At itudes Attitudes Attitudes Cancer has become an issue of increasing concern to many Americans With alarming regularity substances in wide- spread use have been accused of being carcinogenic Particu- larly after saccharin was accused a debate has sprung up over what role government should take in this area should the FDA be allowed to ban all suspected carcinogens or should an individual be allowed a choice even at the risk of cancer In this report we sought to explore popular feelings about cancer -- its causes and frequency -- and the role of Federal regula- tion We also presented two recent cases to highlight the basic question of who should decide whether an individual uses a carcinogen We began our analysis with a look at people's perceptions of cancer -- what are the causes frequencies and sources We also presented a number of statements about carcinogens in order to get a clearer idea of how much cancer people feel is attributable to environmental pollution by made substances What causes cancer We asked respondents what they feel the major causes of cancer are today Not surprisingly the table which follows Union Carbide However nearly one out of every five Americans thinks cigarette smoking is the major cause of cancer today Food additives and preservatives were the second most frequently mentioned cancer agents Taking all types of the disease cancer cancer cancer cancer cancer toyedkit what do you think is the major cause cause of cancer today Smoking cigarettes Food additives artificial preservativbeasd food contents Pollution pollutants polluted environment Heredbi ort n wa itr h iyt wheyt ouh hae ve r it in you a factor inside us all Virus Chemicals Air pollution smog pollution in atmosphere Our environment unspecified as to what environ - m phe ysn ict al , or life style Diet people don't eat right Stress nerves hectic society Life style General health genelr ackaolf care about health or your body wear and boondboy dy Many things combined God's will It is unknown no one really knows Other Don't know 18 tee) 544 544 2 22 4 Union Carbide -7- fourths of Americans cite a variety of other related to environmental pollution and the causes many American lifestyle we cancer increases As the frequency and diversity can expect to see a concurrent of increase in the number of things considered carcinogenic How much cancer is there Over amount of fifths of our respondents cancer is increasing or staying feel that the the same while only % feel cancer is decreasing of think Do you the amount is increasing decreasing same in cancer society or remaining the 618 Increasing 4 Decreasing 26 Femaining the same 8 Don't know The demographic tables which follow show women are to feel cancer is increasing m more ore inclined than men Jewish of the Midlands area also stand respondents and residents for the idea that cancer is We found virtually no support out decreasing not 10 of any group expressed that view Union Carbide -9- Do you think the amount of cancer in society is increasing continued same same Remaining oS know Increasing Increasing Increasing Don't Protestant Catholic . Jewish Other None Political ideology Liberal Moderate Conservative Urban Urban Suburban Rmai Area ' Northeast Industrial Midlands South Central Pacific 62 5 28428 0 0 -1 01 58 SHAU 28428 0 0 -1 01 69 SHAU 28428 0000-1101 72 SHAU 28428 00-101 53 53 SHAU 28428 7 59 5 222 0,00 64 222 0,00 222 10 1280 463 122 ... ... 62 6 122 ... ... 1280 463 122 368866 6 822222 265350 368866 4 822222 265350 368866 5 822222 265350 368866 6 822222 13 67 1 822222 265350 65 4 822222 9 -10- Union Carbide Next we asked people who felt cancer was increasing why they felt that way Their responses are shown in the following table IF INCREASING Why do you think it is increasing ~ _ Yohuear more about it 10 Pollution more pollutants pollution of environment water pollution 8 Population growth population boom 8 more people Smoking cigarettes more people 44 sucking Food addiat nd i artv ifice ial'ps re- servatives more chemicals in food 44 More people are Can froc m Ce ancr er everyone seems to be getting it more instance of it 7 Stress nerves hectic society life style the way we live 4 Chemicals increasing number of chemicals chemicals in fertilizers fertilizers chemicals in water 4 Air pollution air quality atmosphere 3 Smog Our environment unspecifieads to physical or life style 3 Poor diet what we eat improper diet bad eating habits 3 Docters eas it i eae sir er increased detection earlier diagnosis better methods of detecting it 3 More people being tested and more people 2 are aware 1 Haven't found a cure no cure No one knows it is unknown Life span increasing people live longer Fatal 1 Many things combined God's will Other Don't know 19 Union Carbide People mention a lot of the same factors that were mentioned as causes of cancer Thus it appears that Americans feel feel cancer is inextricably linked to the American lifestyle Notably one out of every ten respondents cited increased coverage i.e. increased public awareness of cancer as their Is cancer environmentally induced We presented respondents with two statements about the cause of cancer and found an even split in their choices Which of these statements is closer to your opinion Most cancer is caused by things like industrial pollutants cigarette smoke and food additivaensd subs bot th na atun ralc ane d rs an- made in the environment around us 41 18 Don't knoN While environmental factors play a part most cancer cannot be explained solely by environmental 42 factors -12- Union Carbide A review of the things cited as major causes for cancer and its increase shows that a majority of people clearly feel that the factors mentioneidn the first statement are the principal agents of cancer However the second statement is not wholly contradictory to the first since a predisposition or particular vulnerability to cancer does not preclude a significant environmental role in causing cancer This is in fact a view widely held in the medical profession Demographic tables which follow show that younger people liberals and residents of the Northeast feel that environmental factors cause most cancer Respondents with higher incomes feel cancer is not caused solely by environmental factors Though only a small percentage of the sample 66 a majority of respondents with graduate or professional degrees feel cancer can't be explained solely by environmental factors -13- Union Carbide Which of these statements is closer to your opinion Most cancer is caused by things like industrial pollutants cigarette smoke and food additives and substances both natural and made in the environment around us or while enviromental factors play a part most cancer cannot be explained solely by environmental factors Overall Total household income 0-3,999 0-3,999 4-6,999 7-9,999 10-12,999 13-14,999 13-14,999 15-19,999 20-24,999 Over 25,000 Age group 18-25 25-35 36-45 46-55 56-65 Over 65 Sex Female Male Race White Black Head of household Yes No Environmental Environmental Environmental Environmental Environmental 41 know know Don't Don't Don't 13 solely environmental solely environmental environmental Not environmental factors environmental 42 50 22243222 22 49 22243222 22 37 22243222 43 42 22243222 42 47 22243222 40 35 22243222 50 46 22243222 42 33 2 2432 2 52 277223 722428 My6nmn 277223 722428 My6nmn 41 722428 My6nmn 277223 722428 My6nmn 39 722428 My6nmn 35 722428 35 101 19 500 46 56 500 WA 16 WA WA 28 WA 42 18 04 38 17 45 -14- Union Carbide environmental Do you think that cancer is caused by factors or not continued Education Same grade school Same high school High school graduate Technical vocational Some college College graduate Graduate school Religion Protestant Catholic Jewish Other None Political ideology Liberal Moderate Conservative Urban Urban Suburban Rural Area Northeast Industrial Midlands South Central Pacific 233 39 37 300 300 40 053320 053320 053320 42 36 G252 G252 17 G252 G252 89 89 0000395 0000395 0000395 15 292 292 292 707 707 17 222220 222220 222220 222220 222220 18 39 220 220 33N 33N 33N 327700 44 327700 46 46 Union Carbide . -15- . Of course not all environmental factors are necessarily made Many of the substances that have been accused of causing cancer when ingested occur natur- ally While we saw our sample about evenly divided about the role of environmental factors we see them by a twoone margin endorsing the idea that not all cancer causing substances are madmade e Many cancer causing substances occur natau nd r area notl ml ady e Agree 51 Don't know 22 Disagree 27 Agreement was strong among 36 to 55 year olds while 18 to 25 year olds showed the strongest disagreement Jewish respondents and liberals are more likely to feel carcinogens are mainly made substances A clear majority of residents of the Industrial and Pacific areas argue that carcinogens are by and large naturally occuring Union Carbide Would you naturally agree or disagree Many and are not made causing cancer causing causing causing substances occur | Overall Total household 0-3,999 0-3,999 4-6,999 7-9,999 10-12,999 income . 15-19,999 15-19,999 20-24,999 Over 25,000 Age SICUR 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Female Male Race Minite Black Head of household Yes No Education Same grade school Same high school High school graduate Technical vocational Some college College graduate Graduate school Acree 51 Don't know 22 Disagree 27 22 29 27 23 19 23 28 26 6 33 16 28 23 33 18 27 47 222222 322222 52 222222 322222 56 222222 322222 55 222222 322222 222222 322222 49 31 322222 2899 22 26 22 29 200 239 289 200 239 289 223 200 223 200 47 2222222 2224322 2222222 2224322 54 2222222 2224322 38 2222222 2224322 50 2222222 2224322 54 2222222 2224322 53 18 29 Union Carbide Would you agree that many causing substances occur naturally continued Religion Protestant Catholic Jewish Other Nome Political ideology Liberal Liberal Liberal Moderate Conservative Agree 32357 32357 32357 32357 41 528 528 528 Don't know Disagree 22272 25 22272 28 22272 41 22272 32733 22272 32733 18 332 25 332 18 332 Urban Suburban Rural Area Northeast Industrial Midlands South Central Pacific 51 222 NNN 50 222 NNN ' 54 20 NNN . 51 259852 223203 56 259852 223203 51 259852 223203 45 259852 223203 56 259852 223203 48 259852 31 Union Carbide . -18- Risks and Benefits The Saccharin Controversy The proposed Food and Drug Administration ban on saccharin has raised questions about Federal regulation of carcinogenic substances The widespread opposition to the ban seems to indicate that Americans are not in favor of banning all carcinogens that is people are willing to incur some risk to them of cancer This same if they feel a product is of some benefit attitude is clearly seen in the case of cigarettes and no doubt people feel that allowing people to smoke which seems clearly established as a cause of cancer makes the banning of saccharin a rather inconsistent and irrational move Risks and benefits in the context of cancer Americans have been told countless times that cigarettes cause cancer yet nearly 50 continue to smoke see Cambridge Report 4 Thus there must be a benefit ratio for car- cinogens We asked respondents to describe what risks and benefits meant to them if they were deciding whether or not to use a carcinogen Union Carbide When you think of risks in the context we now discussing what does the word risk mean to you are Taking a chance people take chances a gamble Taking a chance with your health chance of illness Taking a chance with your life you could die putting yourself on the line Danger hazard some consequence Risk should be up to the person involved each person has the right to decide if people want to continue - let them do it Potential hazard or danger maybe some danger Being dangerous to yourself done at you own peril Slight chance potentially remote factor Hazard in use take a risk by using product By ignoring information you are taking a chance Preventable danger exposing yourself to needless danger Foolishness haphazardness Trying something give it a try Other Don't know 37 14 or 6 6 5 N N N N 260 -19- Union Carbide -20- benefits When you think of are now discussing in the what does the mean to you Improved health welfare to your health saving a life longer life To gain by gains coming cut ahead betterment improve- ment for the better sare10 10 thing better To help helping 9 Sametgh ooi d n gog od things For my good to do for you 5 good Good result goodwill evolve good in the end Pleasures of consumption good foods and smoke myself to death 4 To your advantage advantage 3 What I receive getting something 2 Reward reward . financial Freedom of choice let me be NN judge my own Removal of risk enjoy Advantage cutweighs risk something that cutweighscutweighs risk LE More than bad good For it it withit in agreement 7277 yes 727 Nothing Other 727 Don't know have fairly typical notions notions of risks and Respondents benefits A plurality feel risk implies taking a chance health in the case of carcinparticularly a chance with your particularly ogens Benefit implies coming out ahead ahead making a net gain ggaaiinn health or a longer life particularly in terms of improved Union Carbide -21- As these definitions of risk and benefit show people seem to clearly understand both concepts and use them in some mental equation to decide when the benefits outweigh the risks . Should the choice be left to the individual Two out of three Americans feel that the individual ought to have the right to make own decision whether to use a causing substance Some people say that people ought to be allowed to make the decision at their own risk as to whether or not the benefits gained from something outweigh the risks incurred That is if a person wants to risk getting cancer from using saccharin he should be allowed to as in the case of smoking tobacco Others say that many people aren't able to assess the risks involved and that the only solution is to ban potentially dangerous products at the Federal level Would you favor allowing individuals to make their own benefit decisions or do you favor bans at the Federal level Individual risk Don't know Ban at Federal level 66 12 22 Union Carbide . -22- Demographic tables which follow reveal that people making over 25,000 and residents of the Central area are the strongest proponents of individual risk decisions Jewish respondents show the strongest support for a Federal ban on potentially dangerous products Union Carbide -23- Some people say that people ought to be allowed to make the decision at their own risk as to whether or not the benefits gained from something the risks incurred That is if a person wants to risk getting outweich saccharin he should be allowed to as in the case of cancer from using aren't able to assess the smoking tobacco Others say that many people risks involved and that the only solution is to ban potentially dangerous at the Federal level Would you favor allowing individuals to mparkodeuctthseir own benefit decisions or do you favor bans at the Federal level Overall Total household income 0-3,999 4-6,999 7-9,999 7-9,999 10-12,999 13-14,999 15-19,999 20-24,999 Over 25,000 Age group 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Female Male Race Mite Black Head of household Yes No Individual Individual Individual Individual 66 56 56 63 65 . 68 73 67 78 460220 460220 460220 460220 460220 460220 56 66 80 $ 65 68 know know Don't Don't 12 Federal level level Ban 22 222290 22222222 222290 22222222 222290 22222222 222290 22222222 222290 22222222 222290 22222222 * 22222222 5n 2222 229700 222222 229700 222222 229700 222222 229700 222222 229700 222222 18 222222 22 223 11 223 22 22 24 22 . 220 22 220 22 Union Carbide -24- Would you favor allowing individuals to make their own risk or do you favor bans at the Federal level continued benefit decisions Education Same grade school Some high school High school graduate Technical vocational Some college College graduate Graduate school Felicion Protestant Catholic Jewish Other None Political ideolocy Liberal Moderate Conservative Urban Urban Suburban Rural Area Northeast Industrial Midlands South Central Pacific Don't 65250 22322 7322 65250 65250 22322 65250 22322 69 22322 63 222 66 21 22 71 32 32 17 222222 222222 222222 222222 222222 Union Carbide Carcinogenics with real social benefit We found strong majority support among survey participants for allowing causing substances with real social benefit to be available for public use Some argue the following They say that if a substance causes cancer and there is no social benefit from it - as in the case of food color- ing - then the substance should be banned Cn the other hand if a substance causes cancer but there is a real benefit from it for many -- as in the case of saccharin usage by diabet-itchesn the substance permbeipt ert mie ttd ed to be usetdo gain that benefit Do you think possible cancercausing substances should be permitted if they have real social benefits Yes Not sure No 59 24 16 The demographic tables which follow show there is support for permitting beneficial carcinogens to be available to the public among all groups The strongest proponents of this view are 18-35 year olds college graduates conservatives and respondents with more education and higher incomes People living in the Central and Pacific areas also feel carcinogens with real social benefit should not be restricted by Federal regulation A majority of every group opposes the banning of socially beneficial carcinogens -26- -26- Union Carbide Some argue the following They say that if a substance causes cancer and there is no social benefit from it - as in the case of food coloring - then the substance should be banned On the other hand if a substance causes carcer but there is a real benefit from it for many - as in the case of saccharin usage by diabetics - then the substance should be permitted to be used to gain that benefit Do you think possible causing substances should be permitted if they have real sccial benefit Overall Total household 0-3,999 0-3,999 4-6,999 4-6,999 7-9,999 10-12,999 10-12,999 income 15-19,999 . 20-24,999 Over 25,000 Yes Not sure 21 59 24 16 55 52 58 62 69 g 22222222 95223222 22222222 . 95223222 22222222 16 22222222 95223222 22222222 95223222 22222222 95223222 22222222 95223222 Age group 18-25 26-35 36-45 46-55 56-65 Over 65 . 65 222223 15 65 222223 14 55 222223 22 54 222223 24 64 . 222223 11 . 51 35 14 Sex Female Male Rece White Black Head of household Yes No 58 22 101 58 25 16 63 239 42 38 239 24 58 22 16 61 22 16 Education Some grade school Some high school High school graduate Technical vocational Same college College graduate Graduate school 2232667 35 5656566 2232667 26 5656566 2232667 27222 5656566 2232667 27222 5656566 2232667 27222 5656566 2232667 27222 5656566 2232667 27222 5656566 Should possible causing substances be permitted if they have social benefit continued Yes No Protestant Catholic Jewish Other Political ideology Liberal Liberal LiberalLiberalLiberal Moderate Conservative Urban Urban Rural Area Northeast Industrial Midlands South Central Pacific 22098 22098 22098 22098 70 53 56 65 57 61 . 63 53 56 60 61 64 63 22222 22222 22222 22222 16 222 23 222 20 25 26 29 22 24 28 20 23 59922 59922 59922 59922 59922 592 314 16 15 172 172 172 221227 221227 221227 221227 221227 221227 221227 -28- Union Carbide Of course real social benefit is a very subjective criterion which further argues for individual choice in the use of carcinogens At the same time people must know just what risk they are taking -- that is how much of a chance they have of getting cancer from a certain substance -- before they decide if the benefits outweigh the risks Federal government regulation of carcinogens Despite all this support for taking when we presented respondents with a statement that roughly approximates the Delaney amendment - the current model for Federal regulation of carcinogens -- we found a plurality support No substance or chemical should be permitted to be sold if it is found to induce cancer wirten consumed in any size dosace by man or animal Agree Don't know Disagree 49 18 34 In earlier questions a majority of respondents opposed Federal banning of all carcinogens while now a plurality supports very strict regulatory powers for the government This result is particularly surprising since the definition of carcinogen used in the above statement is very broad -29- Union Carbide Demographic tables which follow show that 46-55 year olds blacks and Jewish respondents agree most strongly with stringent regulation of carcinogens Respondents with more education incomes over 25,000 and residents of the Central area voice the strongest disagreement with broad Federal regulatory powers -30- -30- -30- -30- Union Carbide Would you agree or disagree to be sold if it is found to by man or animal No substance induce cancer or chemical should be permitted when consumed in any sized dosage . Overall Total household incore 0-3,999 4-6,999 7-9,999 10-12,999 13-14,999 15-19,999 20-24,999 Over 25,000 Age group 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Ferale Male Race White Black Head of household Yes No Education Same grade school Some high school High school graduate Technical vocational Same college College graduate Graduate school x ; , Agree 49 Don't know 18 Disacree 34 SEAUUUUU 22222222 203332EO SEAUUUUU 22222222 203332EO SEAUUUUU 22222222 203332EO SEAUUUUU 22222222 203332EO SEAUUUUU 22222222 203332EO SEAUUUUU 22222222 203332EO SEAUUUUU - 22222222 203332EO SEAUUUUU 22222222 203332EO ; 45 223242 33 41 223242 41 53 223242 34 58 223242 29 51 223242 33 51 21 28 49 49 48 54 50 47 X28844M X28844M X28844M X28844M X28844M X28844M X28844M 17 12299 22 24 16 19 2252227 (C 2252227 2252227 2252227 2252227 2252227 2252227 34 34 NU NU ww ww 20 232228 232228 232228 232228 232228 50 -31- Do you agree that no substance should be sold if it induces cancer continued Religion Protestant Catholic Jewish Other None Political ideology Liberal Liberal Moderate Conservative rural Urban Suburban Rumal Area Northeast Industrial Midlands South Central Pacific Don't know Disagree 53347 18 35 53347 18 28 53347 13 24 53347 8 46 41 19 41 1148 16 34 1148 GOR 34 50 GOR 35 884 18 333 884 001000 333 44 001000 ---- 227242 221370 227242 221370 227242 221370 227242 221370 227242 221370 227242 39 Union Carbide We found that people who favor stringent regulation of carcinogens are also overwhelmingly willing to sacrifice the diversity of products now available in order to facilitate this regulation IF RESPONDENT FILS THAT NO SUBSTANCE OR CHEMICAL SHOULD BE PERMITTED TO BE SOLD DP IT IS FOUND TO INDUCE CANCER WHEN CONSUMED IN ANY SIZE DOSAGE BY MAN OR ANIAL In order to do this would you be willing to sacrifice the diversity of goods you now have iif f many of them could not meet this standard . Yes Don't know No 74 16 10 over The demographic tables which follow show 25,000 annually Jewish respondents and that people making residents of the Northeast are most willing to sacrifice a diversity of goods if that is necessary to ban all carcinogens Union Carbide If respondent feels to be sold if it is that no found to substance or chemical should be permitted induce cancer when consumed in any size dosage by man or animal In order to do this would you be willing to sacrifice the diversity of goods you now have if many of them could not meat this star~ ard Overall Total household income 0-3,999 4-6,999 4-6,999 7-9,999 10-12,999 13-14,999 15-19,999 20-24,999 Over 25,000 Age group 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Female Male Race White Black Head of household Yes No Education Some grade school . Some high school High school graduate vocational Some college College graduate Graduate school Yes 74 sure 16 81 9852285 73 9852285 68 9852285 68 9852285 68 9852285 78 9852285 74 9852285 90 9852 85 N223ON 232222 N223ON 232222 N223ON 232222 N223ON 232222 N223ON 232222 . N223ON 232222 27 19 75 14 75 15 68 24 75 73 67 69 74 81 71 87 82 '" '" 2243492 2243492 16 2243492 2243492 2243492 2243492 No 10 5 S 15 15 13 11 8 3 15 17 7 7 7 6 ad 11 10 9 10 9 82-6576 82-6576 82-6576 82-6576 82-6576 82-6576 82-6576 Union Carbide Would you be willing to sacrifice diversity of goods by banning carcenogenic products continued Religion Protestant Catholic Jewish Other None Political ideology Liberal Moderate Conservative rural Urban Suburban Yes 72 73 92 80 78 2010 2010 76 Naw 76 Not sure Gul65 Gul65 Gul65 Gul65 Gul65 555 555 555 535 535 18 7000460 7000460 7000460 7000460 14 7000460 Area Northeast Industrial Midlands South Pacific 80 11 72 18 66 20 65 22 82 15 Union Carbide -35- What is the socially acceptable rastuibostoafnces benefit for carcinogenic the benefit ratio We asked people how they evaluate for carcinogenic substances that we always have to incur sare Same people say -- if we want to get risks in this case benefits cancer They argue that seldom does significant benefits of us without same kind of anything care to any hand other people say that price On the other to cancer ro this is not true That when it comes Which is benefits can outweigh the risks involved closer to your view Take some risks Don't know Take no risks 50 19 which follow show that The demographic breakdowns pluralities the risk of in all groups feel that some cancer that is respondents benefits can outweigh are willing to take some risks People and Pacific taking the who are regions risk of 36-45 years old and residents of the Central clearly feel that certain benefits can make cancer worthwhile Both blacks and Jewish are highly undecided on the issue respondents are willing to take the Thus it is clear that Americans chance of getting cancer attained from taking the some benefit can be if they perceive risk Now we will look at just what to take such a risk sort of benefit could cause people Union Carbide -36- Some people say that we always have to incur some risks - in this case cancer - if we want to get significant benefits They argue that seldom does anything come to any of us without some kind of price On the other hand other no benefits people say that this is not true can outweigh the risks involved That when it comes to cancer Which is closer to your view Overall _ Total household 0-3,999 0-3,999 4-6,999 4-6,999 7-9,999 7-9,999 10-12,999 13-14,999 15-19,999 20-24,999 Over 25,000 income Age group 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Female Male Race White Black Head of household Yes No Education Same grade school Some high school High school graduate Technical vocational , Same college College graduate . Graduate school Some risks 50 Don't know 19 No risks 31 43 22227822 42 22227822 45 22227822 53 22227822 56 22227822 55 22227822 54 22227822 63 22227822 51 222222 51 222222 58 222222 47 222222 51 222222 . 45 25 > > 99 > > 19 32 31 37 27 29 1222 1222 1222 232222 232222 232222 232222 232222 232222 23 31 33 17 30 35 31 34 18 LKW 50 21 LKW 3322338 2222232 C: 222203000 3322338 2222232 222203000 3322338 2222232 222203000 3322338 2222232 222203000 3322338 2222232 222203000 3322338 2222232 222203000 60 12 28 Union Carbide Do you think that it is worth it to make certain order to get significant benefits or that no benefits risks where cancer is involved continued Religion Protestant Catholic Jewish Other Same risks 52 47 35 46 57 Don't know 2222 2222 2222 18 Political ideology Liberal Moderate Conservative Urban Urban Sucumban Rural Area Northeast Industrial South Central Pacific Pacific 51 51 53 47 54 - 52 UKASEK 522624 UKASEK 522624 UKASEK 522624 UKASEK 522624 UKASEK 522624 UKASEK 522624 risks No risks 22363 22363 22363 22363 22363 22363 382 382 29 320 28 323880 323880 323880 323880 323880 323880 Union Carbide . -38- If the individual is to make the choice he must be able to evaluate the risk he is dealing with Although two- thirds of the respondents favor individual choice thirds also feel they do not personnaly know enough to evaluate the possible cancer risks of various chemicals Thus although some Americans want to be given the choice they do not have enough information to make an intelligent decision Do you personally feel you have enough information to decide about the possible cancer risks of varicus chemicals Yes Not sure No 20 12 68 Demographic tables which follow show blacks urban dwel- lers and residents of the Industrial and South areas feel strongly that they cannot evaluate the possible cancer risks of various chemicals Jewish respondents 36-45 year olds and respondents with graduate degrees all feel somewhat more able to make an informed decision However never do even third of the respondents consider themselves informed enough to decide on the potential cancer risks of various chemicals Clearly this finding argues for a dramatic increase in the information available to the public regarding potentially carcinogenic substances Reactions to possible solutions to this problem will be presented later on in this report Union Carbide Do you personally feel you have enough information to decide about the possible cancer risks of various chemicals . Overall Total household incore 0-3,999 4-6,999 7-9,999 7-9,999 10-12,999 13-14,999 15-19,999 20-24,999 20-24,999 Over 25,000 Age SEGU 18-25 26-35 36-45 46-55 56-65 Over 65 Sex Female Male Rece White Black Fead of household Yes No Education Some grade school Some high school High school graduate vocational Same college College graduate Graduate school Yes 20 97222222 97222222 97222222 97222222 97222222 97222222 97222222 97222222 222224 222224 222224 222224 222224 16 212 212 22 10 19 22 4282222 4282222 4282222 4282222 4282222 4282222 4282222 Not sure 12 F_55FF F_55FF F_55FF F_55FF F_55FF F_55FF # 5 272825 272825 272825 272825 272825 272825 11 12 11 14 13 56 72821270 72821270 72821270 72821270 72821270 72821270 72821270 70 75 66 72 71 60 71 66 70 R66228 61 R66228 70 R66228 68 68 13 13 888 68 Union Carbide Do you feel you know enough about possible cancer risks of various chemicals continued Religion Protestant Catholic Jewish Other None Political ideology Liberal Moderate Conservative Urban Urban Suburban Rural Area Northeast Industrial Midlands South Central Pacific Yes NANNE NANNE NANNE NANNE NANNE 20 18 23 232 232 232 Not sure 22877 22877 22877 22877 239 239 10 11 22 22 922197 922197 922197 922197 922197 -40- 26020 26020 26020 26020 26020 70 68 57 71 76 63 72 63 55 To this point we have seen that the public take somewhat contradictory positions on the issues involved They want to be allowed to make benefit decisions but they don't really feel qualified to do so They endorse the idea that some causing substances should be permitted endorse a if they version have real benefits but they also of the Delaney amendment that sets a strict flat ban on all causing substances . To try to sort this out we asked respondents to react in two specific cases -- the ban on saccharin and the ban on food dyes As the table shows a majority of Americans the first while one quarter of the public says saccharin oppose should be banned A majority of the public support the ban on food dyes while one quarter says no to that Thus we have about one quarter of the public who will always ban one who don't seem inclined to ever ban and about half quarter the population in the middle Union Carbide Do you approve the government ban on saccharin continued Religion Protestant Catholic Jewish Other _ None Political ideology Liberal Moderate Conservative Urban Urban Suburban Furral Area Northeast Industrial Midlands South Central Pacific Yes approve approve approve disapprodviesapprove disapprove disapprove disapprove Have Have 22222 37007 22017 22222 47 22017 22222 37007 22017 _ 22222 37007 15 5 31 61 7 I 238 00001 221 2 238 00001 221 20 61 16 3 222 51 222 333 222 55 222 333 25 52 20 333 208222 51 227272 NAAW2N 208222 47 227272 NAAW2N 208222 54 227272 NAAW2N 208222 49 227272 NAAW2N 208222 65 227272 NAAW2N 208222 55 227272 NAAW2N -45- Union Carbide Recently studies Recently the hot dogs about that banned certain food dyes used in things like cherries government showing they might cause cancer Did you hear because of or disapprove of what the IF YES Do you generally approve government did ' Overall Total household income 0-3,999 4-6.999 7-9,999 10-12,999 13-14,999 15-19,999 15-19,999 20-24,999 Over 25,000 Age group 18-25 26-35 36-45 46-55 56-65 Over 65 disapprove it approve disapprove not not about Yes approve disapprove disaprove Have about Yes Moves disapprove 51 Moves <akiesS 47 2222282 65652265 77697076 49 2222282 65652265 77697076 49 2222282 65652265 7 697076 51 2222282 65652265 77697076 52 2222282 65652265 77697076 52 2222282 65652265 7 697076 55 23 65652265 77697076 54 31 9 7 697076 | SZ UNNNNN 332295 376229 53 26 332295 376229 55 UNNNNN 332295 376229 53 UNNNNN 332295 376229 - 49 UNNNNN 332295 10 . 44 UNNNNN 332295 9 Sex Female Male Race White 39 20 8 49 20 10 233 200 21 Head of household Yes No Education Same grade school Same high school High school graduate vocational Same college College graduate Graduate school 38 101 15 9 38 25 14 10 7792366 .17 2229516 7792366 30 18 2229516 7792366 26 15 2229516 7792366 15 24 2229516 7792366 29 13 2 29516 7792366 28 8 2229516 7792366 15 12 2229516 Union Carbide Do you approve of the government's ban on certain food dyes continued sure heard disapprove disapprove approve approve approve disapprove disapprove Yes approvedisapprove sure heard not it aboutabout Have about - 51 26 26225 271- 49 24 26225 271- 46 25 26225 271- 54 24 26225 77 57 32 26225 77 Political ideology Liberal Moderate . Conservative 56 22 14 7 52 22 27 3 49 30 11 10 52 222 FER 51 222 FER 7 49 25 FER 12 762020 122222 822722 161225 762020 122222 822722 161225 762020 122222 822722 161225 762020 122222 822722 161225 762020 122222 822722 161225 762020 32 822722 161225 Union Carbide -47- residents are in this group A full 50 of Americans fall into the middle group those who two bans are inconsistenitn This group is most their attitudes towards the inclined to make individual benefit decisions regarding carcinogens Since we found so little support for the saccharin ban it is difficult to conclusively isolate this group However older middle people respondents with graduate degrees middle people and residents of the Northeast and South do show the largest variation between their attitudes toward the two bans All in all Americans are not willing to give up a desired substance if it is found to be carcinogenic though they wholeheartedly support the argument regulation of carcinogens when stated in for the stringent abstract An Alternative labeling with an alternative -- truth- When we presented respondents labeling -- we found overwhelming support This alternative to complete bans would satisfy two previously stated require- ments by increasing the amount of information available to the public about the cancer risks of various substances and Union Carbide -42- Recently the Federal government banned saccharin the artificial sweetener - because of tests showing it caused cancer in rats Did you hear about that YES Do you generally approve or disapdisapprpove rove of what the government did IF Yes approve Yes disapprove Yes not sure Have not heard about it 248 52 21 3 Recently the government banned certain food dyes used in things like cherries and hot dogs because of studies showing they might cause cancer Did you hear about . IF that YES Do you generally approve or disapprove of what the govemment did Yes approve Yes disapprova Yes not sure Have not heard about it 51 26. 15 9 Since both substances have been demonstrated to be carcinogenic the variance in responses must be due to a difference in the perceived benefits of the two substances People who are consistent in their approval of both bans comprise the quarter of the population that is usually inclined to support federal banning of all carcinogens This group includes college graduates liberals and residents of the Industrial area On the other hand people who oppose both bans are most likely to always disapprove of federal bans on carcinogens As seen in the following demographic tables conservatives people earning over 25,000 and Central region Union Carbide -43- Recently the Federal government banned saccharin because of tests showing it caused cancer in rats IF YES Do you generally approve or disapprove of the artificial sweetener Did you hear about that what the government did . Overall heard sure disapprove heard disapprove not aroidde disapprove - about Yes aroidde Yes disapprove Have 24 52 21 3 Total household 0-3,999 0-3,999 4-6,999 7-9,999 10-12,999 13-14,999 | 15-19,999 20-24,999 Over 25,000 incare Age 18-25 26-35 36-45 46-55 56-65 Over 65 , : " 41 222222007 072 2 H2 2825222 42 222222007 072 2 H2 2825222 52 22207 072 2 H2 2825222 50 222222007 072 2 H2 ' 2825222 56 25 072 2 H2 2825222 57 222222007 072 2 H2 2825222 59 222222007 072 2 H2 2825222 62 14 072 2 H2 . 222222 CONCUR 222222 S 222222 CONCUR 222222 1 222222 CONCUR 222222 1 222222 CONCUR 222222 2 . 222222 CONCUR 222222 2 20 50 222222 5 Sex Female Male Race White Black Head of household Yes ~S*=CSs sS:*~S No Education Same grade school Same high school High school graduate Technical vocational Some college College graduate . Graduate school 223 52 22 3 223 53 22 , , . 229 55 19 229 37 30 8 2109 38 22 N2 2109 52 22 N2 2222222 0454428 2220203 042 2- - 2222222 0454428 2220203 04222-- 2222222 0454428 2220203 04222-- 2222222 0454428 2220203 04222-- 2222222 0454428 2220203 04222-- 2222222 0454428 2220203 04222-- 2222222 0454428 2220203 1 Union Carbide -48- allowing people to make their own benefit decisions about whether or not to use a known carcinogen Some people say companies should tell us in plain English what the possible dangers are in a product as they do on cigarette packages and then leave it to us as individual consumers to decide whether or not we want to use that product Would you agree or disagree Agree 82 Don't know 9 Disagree 9 The demographic breakdowns which follow show strong afreenet song song all groups groups groups OnlyOnly Jarish Jarish Jarish respondrespondents eresnpondternesptondsentss and and people with graduate degrees show any significant disagree- ment 19 and 20 respectively Nearly 90 of all college graduates and Central area residents agree with truth labeling and individual choice Union Carbide -49- people Some say companies should tell us in plain English what the possible are in a product as they do on cigarette packages and then leave dangers it to us as individual consumers to decide whether or not we want to use that product Would you agree or disagree Agree Don't know Disagree Total household income 4-6,999 4-6,999 13-14,999 15-19,999 20-24,999 Over 25,000 -18-25 wots 26-35 36-45 46-55 56-65 Over 65 .. sete we . Sex Male Race White Black Head of household Yes No Education Same grade school Same high school High school graduate vocational Same college College graduate Graduate school 77 a32000 81 a32000 85 a32000 82 a32000 86 in nr a 82 Llouee, 83 82 80 85 . ; 79 10 - g 6 9 8 12 81 10 . 22 8 72 15 81 g 83 9 78 2294677 . 79 2294677 81 2294677 83 2 9467 85 29467 75 2 9467 28277-80 28277-80 2827 -80 28277-80 2827 -80 0 0 -0 0 0 0 -0 0 0000-0000 0000-0000 0 0 -0 0 0 0 -0 0 07 13 29 29 079mara 079mara 079mara 079mara 079mar 18 ewee Union Carbide Do you agree that companies should warn consumers in plain English of the possible dangers of using certain products continued Religion Protestant Catholic - Jewish Other None Political ideolory Liberal Moderate Conservative Urban Urban Suburban Rural Area Northeast Industrial Midlands South Central Pacific Agree 82 81 72 83 84 8080800 8080800 8080800 238 238 85 80 84 79 79 89 79 Don't know Disagree 8 27930 12 27930 9 19 4 27930 8 8 oor 709 oor 709 oor 10 11 225 7 225 9 225 200720 002001 200720 0 0 20 01 200720 000020001 200720 000020001 200720 0 0 20 01 10 11 Union Carbide -51- All in all these findings define a new role for Federal regulatory agencies like the FDA Such agencies ought to pro- vide information to the public through strict enforcement of labeling statutes but leave the decision of whether to use a product up to the individual If regulatory agencies feel they have enough data to support a ban they ought to be able to make that information available in comprehensive language to the public and let the public decide This is precisely what is done in the case of cigarettes Americans are aware of the risk of cancer and feel it is increasing however they are not willing to support Federal bans on ~ substances they want to use APPENDIX Union Carbide Al Taking do you all types of think is the the disease major cause cancer together of cancer today what 18 Smoking cigarettes Food additives artificial preservatives 8 8 bad food contents Pollution pollutants polluted 7 envirorment Here bord n wii th it t a whetr her y you 544 have it in you a factor inside us all 544 Virus 544 Chemicals Air pollution smog pollution in 4 atmosphere Our environment unspecifaisetdo what environment - physicaolr life style Diet people don't eat right Mm . 3 Stress nerves hectic society 2 life style General health general lack of care about health or your body wear NA and boondboy dy Many things combined God's will NA It is unknown no one really knows Other 34 Don't know Do you think the amount of cancer in society is increasing decreasing or remaining the same Increasing Decreasing Remaining the Don't know same 61 4 26 8 A2 A2 Union Carbide If increasing Why do you think cancer is increasing You hear more about it Pollution more pollutants pollution of environment water pollution Population growth population boom : more people Stoking cigarettes more people smoking Food additives and artificial preserv atives more chemicals in food More people are dying from cancer everyone seems to be getting it more instances of it Stress nerves hectic society life style the way he live Chemicals increasing number of chemicals chemicals in fertilizers fertilizers chemicals in water Air pollution air quality atmosphere smog Our environment unspecified as to physical or life style Poor diet what we eat improper diet bed eating habits Doctors find it easier increased detection earlier diagnosis better methods of detecting it More people being tested and more people are aware Haven't found a cure no cure No one knows it is unknown Life span increasing people live langer Fatal Many things combined God's will Other Don't know 10 8 8 7 7 7 4 4 3 3 3 3 ~~ ~~ ddddd69 ddddd69 ddddd69 ddddd69 ddddd69 d d d69 19 Union Carbide , A3 Which of these statements is closer to your opinion Most cancer is caused by things like industrial pollutants cigarette smoke and food additives and substances both natural and made in the environment around US Don't know While environmental factors play a part most cancer cannot be explained solely by environ- mental factors 41 18 42 Would you agree occur naturally or disagree Many causing and are not made substances Agree Don't know Disagree 51 . 22 27 Recently the Federal artificial sweetener cancer in rats Did generally approve or government banned saccharin -- the -- because of tests showing it caused you hear about that If yes Do you disapprove of what the government did Yes -- approve Yes -- disapprove Yes -- not sure Have not heard about it 248 52 21 3 Recently the government banned certain food dyes used in things like cherries and hot dogs because of studies showing they might cause cancer Did you hear about that If yes^ Do you generally approve or disapprove of what the government did Yes -- approve Yes -- disapprove Yes -- not sure Have not heard about it 51 26 15 9 A4 Union Carbide two cases consumers benefited from the In both of these banned as well chemicals or substances that the government have incurred some risks Some people say that we always as risks -- in this case cancer -- if we want to to incur some that seldom does anything get significant benefits They argue On the other hand come to any of us without some kind of price it comes other people say that this is not true That when outweigh the risks involved Which to cancer no benefits can is closer to your view Take some risks Don't know Take no risks 50 19 31 a that people ought to be allowed to make Some people say risk as to whether or not the the decision at their own the risks incurred benefits gained from something outweigh from using wants to risk getting cancer That is if person as in the case of smoking saccharin he should be allowed to aren't able to assess tobacco Others say thatthamtantyhe peoonpllye solution is to ban Would the risks involved and at the Federal level potentiallyaldlaonwgienrgouisndpirvoidduucatlss to make their own benefit Federal level ydeocuisfiaovnosr or do you favor bans at the Favor individual benefit decisions Don't know Ban at Federal level 66 12 22 think of risks in the context we When you discussing what does the work risk mean are now to you Taking a chance people take chances 37 a gamble Taking a chance with your health 14 your chance of illness Taking a chance with life you could die putting yourselofn 8 the line 6 Danger hazard some consequences the involved Risk should be up to person each person has the right- tloetdethceimdedoifit 6 people want to continue Union Carbide Risks continued Potential hazard or danger maybe 5 some danger ; Being dangerous to yourself done 2 at your own peril Slight chance potentially remote factor 2 Haza inrusde take a risk by using 2 product By ignoring information you are taking 2 a chance Preventable danger exposing yourself ALHEO to reedless danger ALHEO Foolishness haphazardness Trying something give it try ALHEO 6 Other 8 Don't know When you think of benefits in the context discussing what does the word benefits we are now mean to you Improved health welfare to your health saving a life longer life To gain by gains coming out ahead betterment improvement for the better something better To help helping Something good good things For my good to do good for you Good result good will evolve good in the end Pleasures of consumption good foods and smoke myself to death To your advantage advantage What I receive getting something Reward financial reward Freedom of choice let me be my own judge Removal of risk Advantages outweigh risk enjoy thing that outweighs risk same- . 128 200015 2015 4 4332 4332 43 2 22 1 | Union Carbide . 26 Benefits continued 22277 good More than bad 22277 For it with it in agreement yes 22277 Nothing 22277 Other 13 Don't know Do you decide personally feel you have enough about the possible cancer risks information to of various chemicals Yes Not No sure 20 12 .68 No substance or chemical Would you agree or disagree sold if it is found to induce should be permitted to be man or animal when consumed in any size dosage by cancer .49 Agree Don't know Disagree 18 ; 34 In order to do this would you be willing to have if many of If agree now sacrifice the diversity of goods you them could not meet this standard 74 Yes Not No sure 16 10 should tell us in plain English Some people say companies in a product as they do on what the possible dangers are it to us as individual and then leave to use that pro- cigarette patockdaegceisde whether or not we want consumers duct Would you agree or disagree 82 Agree 9 Don't know 9 Disagree A7 Union Carbide Some argue the following They say that if a substance social benefit from it -- as causes cancer and there is no then the substance should be in the case of food coloring -- causes cancer but banned On the other hand if a substance in the case is a real benefit from it for many -- as should be there diabetics -- then the substance of saccharin usage by that benefit Do you think permitted to be used to gain should be permitted if they possible causing substances - have real social benefit Yes Not No sure 59 24 16 Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid Calidrid ASBESTO UNION CARBIDE CORPORATION DIVISION . BOX NIAGARA FALLS N.Y. 14302 TEL 716-278-3376 October 6 1977 H. Mereness Mr. R. Association Asbestos Information Association North America 1745 Jefferson Davis Hwy Crystal Square 4 Suite 509 Arlington VA 22202 Dear Bob As we all know at the last Board of Directors meeting the JohnsManville Company proposed a change in the laws that would require a unanimous word approval by all members before any response is made to a governmental agency in the name of the AIA In cases where unanimous agreement cannot be reached the alternative of individual responses by member companies was suggested The most important functions of the AIA under this proposal would be to serve as an early warning system on regulatory activities and as an information dissemination organization It is not hard to understand Manville's concern as the largest asbestos company in the industry that the AIA might take a position which they consider to be detrimental to their interests Although we agree that the procedure by which the AIA develops an official position and prepares replies to governmental actions needs to be better defined we believe that it is both inappropriate and not in the best interests of the industry to adopt an operating format where a single member large or small has veto power and can prevent the organization from taking action This letter presents our reasons for this position and offers an alternative As one who has been extensively involved in the preparation of AIA responses over the past four years and who has worked closely with Manville in this operation I would like to offer some first insight into this activity Regulatory proposals where a response could be beneficial to industry come up almost weekly Our awareness of these frequently comes late and we are not staffed to prepare instant responses to submit to members in time for their comments Generally it is a major struggle to obtain and incorporate the suggestions from the Executive Committee into the final document before the deadline for submittal It can he stated categorically that with the possible exception of a major federal regulatory action which is delayed beyond the normal time sequence it is impossible from logistical considerations to obtain complete detailed approval from all members on responses With a unanimous rule the only sensible procedure is a policy of no responses at all Mr. R. H. Mereness -2- October 6 1977 A no response policy has two important detrimental effects In the past we have always worked in very close communication with Manville as a response is prepared They have a large competent well staff but unfortunately neither they nor the AIA are blessed with omnipotence There have been very few M responses that do not incorporate some worthwhile ideas from the AIA and it is fully acknowledge that the reverse is also true We believe that the old cliche two heads are better than one and in this case substantially better applies here and it would be a material loss to both the industry and to M not to continue this cooperative effort to The other detriment relates overall coverage As noted earlier governmental activities particularly at the state level spring up like mushrooms At the risk of belaboring the obvious the industry could succeed in obtaining reasonable federal regulations and still be driven out of business by more restrictive state statutes Early involvement in state activities is critical In the past in this area too we have worked closely with M and have found that it put a real strain on our combined efforts to keep up We believe that it is very important to continue to work at the state level and that J has neither the resources nor the priorities to do an effective job alone The last point to cover before presenting our recommendations relates to the suggestion that the member companies could where unanimous agreement is not reached make presentations to the government on their own In order to engage in effective dealings with regulatory agencies it is necessary to , have 1 A skilled contact staff with a detailed knowledge of the agency plus regular contact and rapport with the personnel In essence _ this means proper working channels of communications and the ability to select and use them to get results 2. Authorization to represent an important company or group of companies in the industry involved i.e. sufficient clout or constituency to merit the agency's attention 3. A full understanding of the central and peripheral issues and politics involved and the ability to put together a realistic creditable and defensible position We believe that the AIA by virtue of its activities over the last few years has developed the skills where they can be an effective industry representative Of the individual member companies however only J appears to have the combination of factors needed to speak strongly on their own The concept that the individual companies can represent themselves effectively is largely a fiction In this connection it should be noted that in the event the AIA should take a position different from that favored by M the latter can still present their side strongly With a unanimous agreement provision the reverse is not true and a large but still minority interest has overruled the majority As a reasonable alternative to unanimous consent of all members as a means to formalize policy and to define the proper precedure to prepare responses to governmental action we suggest the following approach for your consideration It is implicit herein that our organization continues to operate Mr. R. H. Mereness -3- October 6 1977 in the present manner i.e. responsibility for decisions on matters occur between meetings of the Board of Directors is delegated to the Committee subject to review by the Board at their next meeting that Executive 1 The AIA would adopt a basic policy that they will respond in the name of the AIA within the resources available to any governmental action that is in conflict with our basic position as developed in prior governmental responses and which can have a significant effect on any member Priorities would be set by unanimous approval of the Executive Committee subject to appeal "oT to the Board of Directors 2. Responses would normally be prepared by the Governmental Activities Group or Committee see my letter to Tom Dougherty dated October 6 1977 They would generally conform to the basic AIA position developed in previous responses and would be subject to unanimous approval bythe Executive Committee Individual members of this Committee would retain the option as to their own need to read every word but reasonable provisions to allow this would be made In the event any deviations from previously established guidelines become necessary these too would require unanimous consent of the Executive Committee 3 . i \ For any matters where the unanimous consent of the Executive Committee could not be reached any member could at their option appeal the decision to Board of Directors The Board would act by a simple majority of members as presently required or by whatever alternative formula less than unanimous consent that the Directors adopt as appropriate Any member who choses may go on record as not supporting any particular position If he so desires this dissent would be noted in any presentations to governmental agencies This approach obviously stops short of complete unanimous approval by all members but it does provide for a review of all presentations and a temporary veto power subject to review by the entire membership It defines and controls what positions are taken in the name of the entire organization while still retaining reasonable flexability to respond to governmental actions in the most effective manner In conclusion we believe that it is very important to the entire industry that the AIA continues to governmental regulatory proposals and to and depend on the AIA to fulfill individual companies is not generally take an active role in the response to that a great majority of the members look this function Effective response as practicable The AIA should have the authority after careful deliberation to take a stand differing from that of a minority of its members and such members should have the right to have their dissent noted Finally we believe that a formalization of the policy and procedures for presentations to governmental agencies is very necessary and offer the suggestions contained herein as a way that this can be achieved Very truly yours HBR CC T. A. Dougherty W. C. Thurber Harrison B. Rhodes Technology Manager CalidridCalidrid Calidrid Calidrid ASBESTOS UNION CARBIDE CORPORATION DIVISION BOX NIAGARA 14302 TEL 716-278-3376 October 6 1977 Mr. Tom Dougherty Senior Vice President Pipe & Plastics Group Certain Products P. O. Box 860 Corp. Valley Forge PA 19482 Dear Tom As you are probably aware Union Carbide management believes that my service as a member of the Executive Committee should be accompanied by at least a proportionate and preferably larger reduction in my present involvement with other AIA activities I certainly agree with this and have given the matter a great deal of thought in the last few days Some ideas that may be useful are outlined here for your consideration These are certainly not firm and I would be glad to discuss them further with you and Bob It is assumed that this matter will be discussed at the next Executive Committee meeting and it seems desirable that we have our ideas sorted out before then The approach used here is based on the assumption that the members will reject the M unanimous approval approach The AIA will therefore continue to operate in much the same manner as in the past Some more formalized control over the preparation and content of governmental responses seems likely however and is not unreasonable On this basis continued active participation by Guy Gabrielson is included in the suggestions and I feel strongly that we need to find a way to keep his continued interest He has brought a unique combination of senior managerial skills and a willingness to be concerned with details that is irreplaceable He should be at least an officio member of the Executive Committee and should attend all meetings Our immediate problem arises from the growth of the Standards and Technical Committee in the past several years to include an overlapping Ad Hoc Committee on a Construction Standard and a Subcommittee on Monitoring Partially by design and partially due to inability to find anyone willing to take the job has resulted in my service as chairman or chairman of all three of these committees Also the mission of each of these committees is now defined but only in broad terms The basic changes that follow are suggested to improve both the overlapping chairmanship and mission definition problems In presenting these ideas it should be emphasized that any specific names mentioned are my own thoughts about who could do a good job The matter has not been discussed with either the man or his company Mr. T. Dougherty -2- October 6 1977 : First the primary standards development and governmental response function would be removed from the Standards and Technical Committee so that it would become basically a Technical Committee Although it would still act as an important information clearing house on regulatory activities it would have two primary functions a Serve as a technical resource on standards matters on specific projects by request b Work on technical matters such as the development of work practices technical brochures on dust control and similar items for AIA publication A new chairman must be appointed and possibly some other member of the Executive Committee besides myself could serve as the overseer I would recommend Jim Heil as chairman It should also be noted here that this committee overdue is replaced to be revamped with a number of inactive members either removed or small Second the governmental response activity would be placed in a very Governmental Activities Committee as part of Guy Gabrielson's Government - Industry Task Group This committee should consist of a senior representative from M either Fenner or Carter and Ike Weaver I would serve as the Executive Committee representative and substantial involvement of the staff.woulbde a key requirement In general this group would communicate by mail or phone although I would expect that the preparation of testimony for major regulatory actions would require an occasional meeting If M would become active in this manner it would improve communications in both directions Possibly it would also help to alleviat thee current problem of a tion Third the Monitoring Subcommittee would be given the status committee Their mission be defined in three parts with authoriza- from the Executive Committee required to proceed beyond Phase I. a Phase I - Robin Exchange Program covering sample collection and analysis b Phase II - Contribution of the Counting Procedure to total variability c Phase III ... Development of recommended changes in the method This is an important specific task that has considerable contact with outside organizations and recognition of its status seems desirable As a practical matter four of the six members are also on the Standards and Technical Committee Past meetings have been as an adjunct to their meetings or under individual sponsorship so no additional financial burden on the AIA is envisioned I have a substantial personal interest here the time commitment is not large and there is no obvious or willing alternate alternative candidate for chairman so I would plan to continue in this role through Phase I. Mr. T. Dougherty -3- October 6 1977 Fourth the Ad Hoc Committee on the Construction Standard has been on the back burner for months and it is suggested that it be left that way for the present I would like however to set up a project for the Technical Committee to develop detailed critique of the EEH draft report and to look into the development of work practices of the type suggested in our draft Construction Standard Proposal We also need to move in the Governmental Activities Committee to get this draft proposal shaped up for possible discussion with OSHA in which not been This concludes my suggestions for rearrangement of the activities I have been involved Let me repeat that the people mentioned have contacted and that I think we should get our ideas sorted out before the Executive Committee Meeting Best regards Harry ' Harrison B. Rhodes Technology Manager HBR . CC R. H. Mereness W. C. Thurber