Document 9L6M23qbremNdvLN7p0xNanG6

FILE NAME: Asbestos Information Association (AIA) DATE: 1973 Aug DOC#: AIA052 DOCUMENT DESCRIPTION: Unpublished AIA/NA Conference Presentation - "WhyAsbestos?" I P lain tiffs Exhibit - S-UC-151 A sb esto s Information Association/North America ' distribution 22 East 40th Street New York, N. Y. 10016 212-689-3378 August 3, 1973 Hr. William So Sneath President , Union Carbide Corporation 270 Park Avenue Hew York, New York 10017 f.h . 3' 8.0. ' R. J. K.-P1: - J.M. Ar.*S.T=a A. A. D C. F.~ ~"n RA.C- ' g a..o. ; u H. U 2 D. . --'*7 O D. . C .-* D D. J. C " ti3 O G. L V3KSI M. K.W Fite D Dear Hr. Sneath: . V> ij 3 Over the past two and one-half years, the Asbestos Information Association/North America, of which your company is J "*"***< played, a major role in defending the asbestos industry from unwarranted and irresponsible attacks by labor, the press, certain segments of the .p5 f ' and by various environmental and consumer activist groups* . 1 I |i | ft i i I | ! t- |iti^ H W it! I | < 1-- |i#* Ml I While most executives within the industry nkave kkeeppii up-tio-d vlth developments on the asbestos-health front during this time period, many of the details relating to the 9iesis and current status of the overall problem, as well a* on AIA/NA activities and accomplishments, bave never been collected in a single document for industry dissemination. Thi* deficiency has now been corrected. Attached for your information is a copy of a presentation made by Matthew K. Swetonic, Executive Secretary of the AIA/NA, to the Asbestos Textile Institute in June. Entitled Why Asbestos?* the speech outlines the growth of the asbestoshealth problem as a national issue, the philosophy of the ^ nation's press with regard to asbestos, and the efforts being aade.Jby the AIA/HA to deal-with the prtfjlem on the medical, legal, governmental, customer and public relations fronts. WBY a s b e s t o s ? A \ 9573 control materials and products that can cause disease. Let us look at each of these factors in turn. firsts there is no doubt that the inhalation of substantial amounts of asbestos can lead to inereased rates of various types of lung disease, including two forms of cancer. are facts which cannot be denied, even if they do not apply in all circumstanced and under all conditions. The medical literature is full of solid evidence linking asbestos to disease. In my office, 2 have on file more than 2,000 medical papers dealing with the health risks of asbestos and ' hundreds more are published every year. ' 8 Secondly, the spreading of concern oyer the health risks of asbestos has as its prime spokesman .one of the most talented medical publicists cf the age -- Dr. Irving J. Selikoff of Hew York's Mount Sinai Hospital. Not only is Dr. Selikoff capable of eurousing the ire and moral indignation of the most conservative reporter or politician with his graphic descriptions and predictions of the .ravages -of .asbestos,, but he has also surrounded himself with a group of similarly talented associates who have carried the Mount Sinai message to the far corners of the nation. While Dr. selikoff has, in his zeal, unquestionally painted a far darker picture than the facts warrent, we should always remember in his defense that the insulation workers he A 1957? i - 4- The background of industry efforts to deal with the asbestos-health problem as a national issue goes back nearly . ' a decade, to Dr. Selikoff's now famous 1964 seminar on asbestos disease at the. New York Academy of Sciences. While this seminar did much to prick the industry's conscience about asbestos and health, the problem still.remained one of limited public end press interest until around 1967, when the media began beating the medical bushes searching for stories that would graphically portray American industry's supposed disregard for the environment and for the health and safety of its workmen and the American 4 public. The asbestos-health problem was found to be tailor-made for such stories. As a result> starting with PaulBrodeur's . infamous New Yorker article of March 1968, asbestos has since grown into an item of major press interest. ' In those years, industry effcarts to combat the spate Of negative press articles on asbestos were carried on primarily by the Jehns-Manville Corporation, which set up a task force of specialists in various fields to do what it could to portray the problem in Its proper perspective. While some minor successes were achieved, it was found that no one company acting independently could adequately or effectively represent an entire : industry in dealing with the press and with government officials. As a result, in lata 1970, eight companies gathered ' in New York City to launch the Asbestos information Association I C ' i I j . ' I 1 - . A 19573 of Berth America# which was patterned after the British Asbestos information Committee, which had been established some three years earlier . In our original concept, the Association would limit it activities to providing accurate, unbiased information on asbestos and health to the press# to the public and to interested politicians and other government officials. It must be remembered that at this particular time, the enormous problems that would later develop with regard to QSH and other Federal regulatory agencies were as yet on the distant horizon and basically unrecognized by the industry, - Fortunately --- and properly -- the Association has had the wisdom to alter its original limited concept of its proper functions# and now endeavors to assume whatever activities and responsibilities it deems necessary to protect the interests . of the asbestos manufacturing industry in the United States "vis-a-vis asbestos-health . From this rather narrow initial public relations concept, the Association.has ^grown in the -last"two-year into an organization with' priorities in eight major fields of endeavor, These are: Medical Affairs Legal Affairs . Environmental Control Customer Relations Employee Relations# Inter-industry Relations Publicity and Public Relations Government Affairs 1953C  6," . 1 , ; ; | ` ' ; !. . ! To take these activities one at a time, let us start with medical affairs. . . It is an obvious fact that if an organisation is to .pole authoritatively on . c a l - * , it eat not only be ,rT-r-* in the literature of that particular medical subject, . but it 1st also keep itself constantly informed of new discoveries and developments.' This we heve accomplished in a number of ways. ,or example, by . d i n g representatives to important madical meetingst such as the 1,72 tyon, franca international conference on the biological effects of asbestos, which was sponsored by % the World Health organisation. He also meet on an irregular basis with various medical experts in the field, both from the United States and abroad. SO review and discuss recent development, and discoveries. 0ur literature research is eased considerably by receiving the monthly madical paper distribution of the ; institute of occupational and Environmental Health in Montreal, which is funded by the Quebec Asbestos Mining Association. , This year, for the first time, the AIA ha. elected to sponsor medical resiareh of it. own. currently underway is a completely AIA/HA funded study of cheat sounds, which is being conducted by Dr. Raymond Murphy of the Harvard School of Public . Health. The purpose of the study ia to find a new method of datUrmining an individual's potential.susceptibility to asbestos disease. * A 19531 f -- 1 -- The Association has also recently decided to contribute to some very exciting research into a possible cure for mesothelioma through electromotive treatment. This study is being conducted at Somerset Hospital in New Jersey. in the legal affairs area, the Association participated in an amicus curiae capacity in the law suit brought by the Industrial Union Department of the AFL/CIO against the Occupational Safety and Hea.lth Administration on the asbestos standards. In our brief the Association supported OSHA against the IUD, somewhat of a unique position for an industry to find itself in vis-a-vis a governmental regulatory agency, oral ^ argument on the case was held April 4 in Washington. .While a decision has yet to be handed down by the Court of Appeals, we are confident that the case will be decided in our favor. The Association has retained the services of a special technical consultant on environmental control affairs. At the present time, he is working with the AIA/NA Environmental Control Sub-Committee on the development of a series of five Association coapli-anoe manuals on the -OSHA -standards. Last year, because of the well established unreliability of the membrane filter method as a monitoring tool in the asbestos industry, the AIA undertook the sponsorship of a study at a research laboratory in California to determine the effect of certain variables on the overall accuracy of the method. ' 19582 The results of the study showed an error factor of plus or minus 50 per cent under the most favorable of measuring conditions. These results were seat to both OSHA and to the National Institute for Occupational Safety and Health. A number of the recommen dations contained in the study for improving the accuracy of the method have been incorporated into a soon-to-be-released revised NIOSH operations manual on fiber counting. In the customer relations area, the total effect of negative press publicity and government regulations on industry customers is still today rather poorly defined. Some members of the Association have reported serious problems in-this area, . while others have experienced few or no difficulties thus far. Where customer problems do exist, they normally fall into one of five categories. First, the customer has thoroughly investigated his situation and has found that he can no longer afford to continue using asbestos or asbestos--containing products, either because the cost of control is too high or because he would have to raise the-price .of .his product ,to a level that would make it non-competitive with non-asbestos containing substitutes. Second, the customer has not throughly investigated his situation and only thinks that he can no longer afford to continue using asbestos. - A 19 5 3 3  $ sm Third, the customer has seed one or more negative articles on asbestos in the public press and has made the snap decision that 'v. ought to get that dangerous stuff out of our plant." Often, decisions of this nature are forced on top management by ill-informed medical advisors or safety and health directorsa Fourth, the customer ban neither a control problem nor . i, he particularly afraid of using asbestos in his ovn plant. However, he is fearful that those of his competitors whose . products do not contain asbestos will, stress the adverse health effects of asbestos in trying to take business' away free, him. Customer fears of this nature are essentially "gut" ' reactions and are hense extremely difficult to deal with. Fifth, the customer ham none of theae problems or fears but he has beau edvieed by e government official or inspector . that he would be better off if .he guit using asbestos or asbestos` containing product, in his plant. While this problem doe. not a p p OE to be widespread, we have learned of a number of situation, where it has occurrsd. Actions of this nature try"government official, ere totally uncalled for and should be dealt with promptly and decisively. The best solution is to obtain complet, details on tha incident and then to register s formal complaint with the offending official's immediate superior or with the government agency involved.. A 19584 - 10 - The Association's first rssetlon to ths overall customer relations problem uss to approve funis for a series of four regional seminars at which industry customers w o l d M given a number of basic presentations on the various aspects of the asbestos-health problem. Mis seminars wore tentatively scheduled for the Spring of 19?3. However, the experiences of a number of our member companies shoved that general catchall- type seminars of the type originally contemplated would not be effective in dealing with the majority of customer relations problems. In order to do the job properly, it was found that customer presentation have to be tailored to the need, and problems of th. individual customer. As a result, the Association cancelled Its scheduled , i . s of seminars and instead elected to develop a numbar of packaged slide presentations cn such topic, as -Mi. Facts About Asbestos and Health," and "Understanding the OSHA Regulations," could be used by member companies ae part of a tailored. presentation to individual customers. As with customer relations, the Association feels that employee relations is a problem best handled by the individual member companies. Thus far' the m 8 so1 . contribution in this area of industry concern has been to prepare the draft of an Employee Safety and Health Guide on Asbestos-Health. The draft was made available to the ember 1 958b companies for their own use and at least one has produced it in booklet form for distribution to all its employees. 2 personally believe that the employee relations aspect of the asbestos-health problem is one that has been sorely neglected by most companies within the industry, and that it could develop into a major problem area in the near future and that steps should be taken now to deal with it. We know that various organized labor groups are planning a full scale campaign to bring their interpretation of the asbestos-health problem to the attention of asbestos industry employees throughout the nation. If the industry permits this interpretation to be1 i pi i II r i l l U H 4I I M I IflfillM I iu *i I IllllU il I giM mini IIHIIMt... oiihimih cons 9 jim 1 njS Q H ilK .......... t a r a c e a m u , . 1 Issemina indeed. Inter-industry relations are best defined as keeping the industry informed about important new developments on the - 12 - Hext to gov.roo.nt .{fair., our public rotation. nd publicity activities conatitnt. the- .ingl. U r * V of tin., f o r t and money within the M .oci.aon. t h o * wh0 are familiar with th. tr.atm.nt that a.b.sto. has b e receiving in the public pr... over th. y.ar. can readily understand why this activity ran*. . 0 high on our prior ty 1st. hat you may not understand ar. th. s o n . why our extensive effort, in dealing with the nation', pr... U * ' ,, unsuccessful to date in producing th. tior.tic.l balance or "positive" story on asbestos and health. i . siraple fact is that from the standpoint of today . young activist reporter, industry is the bad guy. and nothin, uo do, say or achieve can ever bang, this impression. we apend $100 million dollar, on environmental control, th. pres, either says w. ought to have don. it tan years ago or that we . should have spent 0 0 million. If we sponsor medical rasearc , .they say we are trying to buy favorable result.. are opposed to ridiculously stringent standard., they .say w. ar. in favor of Letting our employees die. * A television executive in Minneapolis described this new breed of reporter as being "so intent on demolishing the establishment that they would blindly dsstruy the credibility of th. media in th. bargain." o t h e r TV executive, this time in Chicago, stated "they want to mate moral and political an social judgments on their assigroent, and then tale sidas. .never mind getting the facts straight." - 13 - M a result of this -industry is a monster- philosophy, asbestos will remain a hot news item only so long as the newt is bad. The -good- that asbestos does in protecting lives and property is of no concern to the press. Likewise, industry efforts to protect workmen and the general public from asbestos exposure will always be given minimal coverage, since such information.is directly contrary to the portrait of an irresponsible industry producing a - k i l l " product, t & t is the ,, l a element of news worthiness in the asbestos story. . The press relations battle will therefore be won, not When the media starts to print positive or balanced articles about asbestos, but when the press c a s e s to print anything about asbestos at all. is long a. negative news on asbestos-health oontinues to he generated, the media will continue to eat it up. The media will cnly cease to carry such stories when the 'generation of negative news ceases. It is a. siiple as that. Positive or balanced stories are a chimera, since they are, . by definition, not newsworthy. Let me give you a very specific example of this last principle in action. As most of you already know, the Association is currently engaged in an extensive campaign to interest the trade press in articles on the benefits of asbestos and on industry accomplishments in the environmental control area. The trade press, unlike the national or public media, is much A 195 68 - 14 more receptive to articles of this nature and we expect to be seeing a number of positive stories in the trade press in the next few months. In any case, we also from tine to time put out press releases on various subjects relating to asbestos-health. A few weeks .ago, we issued a release on the report of the advisory committee on asbestos cancers of the World Health organization. In brief, the report concluded that the general public is not in danger from asbestos in the environment. Thus far, we have received nearly two dozen press clippings from trade publications that carried the story. To the best of our knowledge, not a 1 single newspaper, news magazine, radio or TV station, or any other segment of the public media ran the story, with the solitary exception of a French language paper in Toronto. As I said . before, if the news is good, the press simply isn't interested. ` Nonetheless, the Association has no intention of abandoning our efforts vis-a-vis the national media. We will continue to issue appropriate press releases, cooperate with feature writers doing stories on asbestos, write letters to the editor when those stories appear, and in short, do all we can , * * to present the press with a balanced view of the asbestos-health situation. Our most recent effort in this regard has been the preparation and printing of an Asbestos and Health Information ft 1 3 5 8 3 - 15 - File which we have nailed t o s o n e 3,000 newspapers, magazines -trade publications, radio and TV stations, science writers etc. across the United States. . . Basically, the file contains copies of five industry position papers on asbestos and asbestos-health, as well as a number of important medical papers and a pair of photographs illustrating the benefits of asbestos and industry efforts at environmental control. While we don't expect our information file to change the whole attitude of the press toward asbestos, we are hoping that the media will mahe use of it to accurately report the industry's position when doing stories on the subject. And now, having heard the bad side of the jmblie relations problem, it's time for stane good news. And the good news is that despite all the negative articles on asbestos-health that have appeared in the press over the past half-dozen years, very few people have been paying attention. Let me explain. In February, th Association undertook a personal interview research survey of the American public to determine its attitude toward asbestos and its awareness of the health issue. The survey wasconducted by the Opinion Research Corporation during March and April. More than 2,000 . demographically selected Americans were interviewed. Without going into enormous, detail, the results show that only 22 per cent of the American public are aware of the 16 health hazards of asbestos, and that 80 per cent of these consider it a hazard only to those who are occupationally exposed. A mere three percent of those interviewed stated that they considered asbestos a health hazard to the general public, and less than one quarter of one percent.considered it the most dangerous material on the list they were given to choose from. Surprisingly, the college age youths of America are no more aware of the hazards of asbestos than their parents and grandparents. These results should be reassuring to those industry customers who fear that the general public will stop buying their products because they contain asbestos. ' 8 Before going on to describe our activities in the government relations area, 1 think it might be interesting at this point to take a very brief look at the manner in which Dr. Selikoff and his supporters have used his research results to dramatize and exaggerate the seriousness of the asbestos'health problem. I have two charts which point this .out rather conclusively. The first chart shows the actual results of Dr. Selikoff"s four mortality studies of asbestos workers. The numbers in parenthesis beside the figures for total number of workers indicate those who have so far died from all causes. The percentage figures alongside the total number of deaths from esbestosis, lung cancer and mesothelioma are based on the total number of deaths from all causes, not on the number of workers in the study. A 1050 1 CHART HUMBER I fot. X. 3. SEL.IKOFF ~ RESEARCH DATA HO. OF WORKERS DESCRIPTION OF COHORT TOTAL DEATHS FROM ASBESTOSIS. LUNG CANCER & MESOTHELIOMA MORTALITY STUDY OF TWO LOCALS OF INSULATION WORKERS UNION 62S (423) THOSE WITH A MINIMUM OF 20 YEARS EXPOSURE 149 (35%) MORTALITY STUDY OF ALL MEMBERS OF INSULATION WORKERS UNION 17,800 (1092) ALL WORKERS ON ROLLS 1/1/67 368 * (34%) MORTALITY STUDY OF WORKERS IE A WORLD WAR II AMOSITE INSULATION PLANT 933 (494) EXPOSED ONLY TO AMOSITE ASBESTOS 107 (22.1%) .MORTALITY STUDY OF WORKERS 689 (199) THOSE WITH A 66 (33%) | AT JOHNS-MAHVILLR COST. MINIMUM GF 20 H MANVIIXE, M.J., PLANT YEARS EXPOSURE si * t * * _ __ * 340 OF THESE DEATHS WERE AMONG THE 5,119 EMPLOYEES WITH GREATER THKH 20 TEARS SXFOSOW *< ywwmr.TBMBn OATA TAfcEN FROM ARTXCUB IS THE NEW YORK POST, MAT 1972 A 1953 M . t - is . Th. sost important .tody Of the 9 TM p is the ..eoed f the top, showing the deaths from asbestos-related disease among ail members of the insulatioi workers union, regardless of length of exposure. You will note that 34 percent of those workers who have died thus far haw. died fro on. of th. three asbestos-related diseases. These, then, are the tacts Dr. Selikoff works fro. This is What he knows fro his own investigations. Sow let US take a look at what he has don. with these figure, in order to dramatize the problem. . chart nunher II show. Dr. selikoff`s prediction, about asbestos-related deaths in the United States. Without going into details. Dr. Selikoff has arrived at his projections by the simple procedure of nultiplying the percentage of deaths fro asbestos-related disease aeng his insulation workers by the total number of employees in the entire industry. You will also note that he has raised his projected death eatinate to enormous height, over the pest year by .imply -increasing the b e figure of employees exposed, -while.a t t U retaining the percentage multiplier of 34 percent being experienced by the insulation workers. A 19503 CHART BOMBER II DR. 1. J. SELIK O F F ----PREDICTIONS WO. OF WORKERS ARTICLE IN HALL STREET JOURNAL -- 6/8/72 "STUDIES BY DR. IRVING SELIKOFF ... LEAD HIM TO PREDICT ..." 250,000 ARTICLE IN THE NEW YORK TIMES --- 6/13/72 (FIVE DAYS LATER} "IF OUR EXPERIENCES ... ARB A GUIDE ..." 500,000 TESTIMONY AT TOXIC SUBSTANCES HEARING ~* 2/21/73 "OUR STUDIES INDICATE.,." 1,000,000 AP STORY ON TOXIC SUBSTANCES HEARING 1,000,000 DESCRIPTION OP COHORT ALL WORKERS CURRENTLY EMPLOYED IN THE " ASBESTOS INDUSTRY TOTAL DEATHS FROM ASBESTOSIS. LONG CANCER 6 MESOTHELIOMA 85,000 * ALL WORKERS CURRENTLY AND PREVIOUSLY EMPLOYED IN TUB ASBESTOS INDUSTRY 170.000 ALL WORKERS CURRENTLY, PREVIOUSLY, AND WHO WILL BE EMPLOYED IN THE ASBESTOS INDUSTRY IN THIS CENTURY (AS ABOVE) 340.000 1,000,000 (MIS-QUOTB) * ACTUAL QUOTED FREE*XCTXON WAS 95,000, BOX THIS INCLUDED DEATHS FROM GI CANCER, H & C H I HAVE SUBTRACTED FROM THE TOTAL. - 20 - I night point out that this tactic, however deceptive, has been an enormous success since each raising of the estimate has earned Dr. Selikoff correspondingly greater coverage by the media. No finer example exists of the total gullibility of the press than the manner in which it allowed its prejudices to be manipulated and played upon in this situation. . Please don't get me wrong. 1 have no doubt that the insulation workers are in fact dying as rapidly as Dr. Selikoff says they are. The problem is that he has translated their mortality experience to the rest of the entire industry, which is completely erroneous. in the first place, the estimated number of employees in the industry is too high -- - five times too high to be precise Even more important, according to an analysis by the Association of more than a dozen mortality studies, including those of Dr. Selikoff, our.prediction is that approximately 25,000 past * and present employees in the asbestos industry have died or will eventually die of asbestos-related disease. This is less than one-thirteenth of Dr. Selikoffs most recent estimate. In addition, our figures show that 20 of the 25,000 deaths -- or 80 percent -- will occur among those in the insulation trades. While these estimates should be reassuring to those in the mining and manufacturing areas of the industry, we should not forget that 5,000 of our workmen are still going to die of asbestos-related disease and that, all things, considered, there A 1959b is absolutely nothing that we oan do to prevent it. The only thing we can do Is to clean up our plant, to .aura that those entering the industry in the future ill not have the s u n experience. Within the past year and a half, the main thrust of Association effort has shifted to the government affair, front. She principal agencies in- Washington with which have been ^ . n - g are the occupational Safety and Health Administration, the Environmental Protection Agency, the Pood and Drug Adminis tration, the Bureau of Mines, and, to a lesser degree, the , National Institute of occupational Safety and Health, and the National Institute, of Health,' both of which are maihly involved in research efforts. . In addition, a few weeks ago we were contacted by the Federal Trade Commission, which had received a petition from the Center for Science in the Public Interest requesting an investigation of consumer .uses of asbestos for the purpose of dm*___.whether certain products-eught to be labeled as . hazardous'and whether warning, should be required on all advertisement, for those products. On the basis of a preliminary meeting with an investigator from the PTC it would appear that we have little to worry about in this particular area The Occupational safety and Health Adminiatration ha. been of enormous concern to the. industry over the past 18 months. As most of you slraady know, the Association expanded . A '9503 - 22 - tremendous efforts during the si* month period leading to the promulgation of last June's 0 8 standards on asbestos. I think it is gauge of the effectiveness of the total industry involveM n t in this most crucial m a t t that of eleven main requirements in the standards, the industry position as accepted totally by OSH& on nine of the eleven, about fifty pareent on a tenth, and totally rejected on. only one. 0 8 is now planning to redo the standard package and e are working closely ith them on this project. The first step will be the formation of a 15 man advisory committee to Teviaw the current standards and any additional medical and technical data that has become available in the year since the'standards were promulgated in cooperation with nine other trade associations we have selected four individuals as industry-wide recommendations to 0 8 for the four so-called -employ' spots on the advisory committee. ' ' In discussing .the formation -of the adviwory committee with John O'Neill of the OSHA Standards Development Section, we were asked to add a couple of names to the list so that OSHA would have more of a selection to choose from. This we have agreed to do. The committee will be given up to nine months to complete Its deliberations and prepare for 0 8 a revised standard paekaga. This will be followed by public hearings, approximately a y e . from now. We do not expect to see e new standard prfflsulgatad before the Pall of 1974 23 - It Is .of course impossible to determine at this time what the new standards will look like, however, I would venture to say that they will certainly not be less strict than the ones we have today, although they will probably be less confusing and leave less room for employer interpretation. Something will unquestionably be don to improve the current difficulties with the monitoring requirements. ' ' The main function of the National Institute-for Occupational Safety and Health is to conduct research and to prepare so.-callsd Criteria Packages, which are essentially recommendations to OSHA for standards on various materials, # chemicals and activities. Such a package on asbestos was prepared by NXOSH at the time of the OSHA' proceedings last year. NIOSH will not be preparing a new or revised criteria package for the upcoming review of the asbestos standards. I do not believe it would be unfair to. say that of * all the agencies in Washington dealing with asbestos. Dr. Selikoff h m had his greatest influence on the young idealistic scientists and doctors at NIOSH.. Consequently, ,,industry .influence is weakest in this agency. It was NIOSH, after all, that made the original recommendation for a two fiber standard in the tJnited States asbestos industry. Next to OSHA, the Environmental Protection Agency has the greatest potential of any federal agency fox adversely affecting the future of the asbestos industry in this country. ft \ 9 5 0 8 4 \ I - 24 - * . Hot only is the EPA responsible for developing and enforcing air nr* water pollution standards, but the Toxic Substances Control Act, now pending in Congress, will also become an EPA function after passage. Por this reason, X am pleased to be able to say that the asbestos industry has an excellent relationship with the SfAa Ho finer proof of this exists than the fact that there was not a single major industry recommendation made to the EPA at the public hearings on the proposed asbestos emission regulations that was not accepted either in toto or in principle in the final standards, which were published in early April of this year. ' '. . He are presently working with the EPA on the development of waste water effluent standards for asbestos manufacturing plants. We certainly hope that these standards will turn.out to be as reasonable as the. air pollution regulations. The proposed effluent standards are scheduled to be published in the Federal Realster sometime this Summer, to be followed .by public hearings, with the final standards being promulgated in the Fall, perhaps as early as October. We are also planning, in the near future, to meet in Washington with representatives from the standards development and enforcement branches of the EPA to discuss with them questions of interpretation and compliance policy with regard to the new air pollution regulations. . . A 19503 as - We have already resolved one interpretation question that is of special interest to the asbestos textile industry. Approximately two weeks ago I was asked by a member company of the Association to find out whether the SPA was planning to require the manufacturers of asbestos safety clothing to register as potential emission sources under the law. In discussing the situation over the phone with SPA compliance officials, I argued that the producers of asbestos safety clothing were not manufacturers as defined in the regulations but were instead only fabricators of an asbestos pxoducti and as such, should not have to register as potential! emission sources. After our phone conversation ended, a brief meeting was held among the EPA compliance people. I was then called back and informed that they agreed with me that the safety clothing producers should not be required to register. .. While this rather minor problem took approximately an hour and a half and two or three phone calls to resolve, is indicative of the type of day-to-day services that the Association provides for its member companies. Over the past year the Food and Drug Administration has shown an increasing interest in asbestos as a possible hazardous contaminant in various foods, beverages and drugs. Late in 1972 they set up an asbestos task force to review the situation and to propose regulations and guidelines where appropriate . A1960C- ' - 26 - Thus far they have concentrated their efforts in two areas -- on the use of asbestos-contaminated talc in food packaging and in cosmetics, and secondly, on the use of asbestos eelulose filter pads in the beverage and drug industries. Xn our first meeting with the FDA task force last ' November on the filter problem, they demonstrated and admitted to an appalling ignorance about the health hazards of asbestos. Since then, they have gotten one heck of a lot smarter, due at least in part to the tremendous amount of data and information which the Association has been supplying to them. As a consequence, the FDA is today less panicky about asbestos and therefore le^s likely to propose foolish, unsupportable regulations. Spokesmen from the FDA have, in fact, defended the filter industry against environmentalist attacks in the press and elsewhere in recent months. This is, quite obviously, a healthy sign. Our activities in the area of Congressional relations ' have been quite minimal to date, although we are preparing for the upcoming struggle in Congress over workmen's compensation reform, at which time asbestos is unquestionably going to be racked over the coals by Dr. Selikoff and by representatives of organized labor. - Unfortunately, the Association has neither the manpower nbr the time to embark on a full-scale legislative information program. We have met on occasion with the legislative and A 19601 27 - assistants to various Senators who have attacked asbestos however much more needs to be done in this area and I am afraid individual member companies are going to have to be the prime ball carriers and not the Association* For essentially the same reason our government activities at the state and local level have declined to essentially zero over the. past year and a half* This has not been too serious a deficiency as most of the authority of the cities and states in asbestos control has been usurped by various Federal regulatory agencies* Nonetheless more individual 6 company activity is required at these levels of government. In conclusion# 1 think we can all be justifiably pleased with What we have been able to accomplish in the past few years in resolving the cornucopia of interrelated problems that constitute the asbestos-health situation. ' Our plants are cleaner and our workmen better protected. The general public has been shown to be in no danger from asbestos# if ever was. While we have been regulated extensively# for the most part the standards that have been developed have not been as bad as we feared they might be and in some cases they turned out far better than wa ever dared hope. In addition while we are still taking our lumps in the public press the net effect of all this adverse publicity has been shown to be surprisingly small. - 28 - ' He have sweated a lot and we have groaned & lot but we are still standing and we are still viable. 1 sense today within the industry a greater feeling of confidence in the future than at any time in the past few years. But we wist not rest contented. He must remember that Dr* Selikoff has to date been far less successful than our industry has in influencing the decisions of the various governmental regulatory agencies. This will make him try harder. Just last week I saw a speech of his in which he misinterpreted acme data by a distinguished British scientist so as to "prove* that even two fibers is not f a sufficiently safe level for occupational exposure to asbestos. The struggle is far from over. We must not only continue but indeed expand our activities in the various areas of concern if we are to assure the future well-being of the asbestos industry in the United States. A19Q03