Document G6Q1GBrD0rnQxYkVOJ26arqYN

R&S 113081 A " 'x bio-medical research DOCUMENT DESCRIPTION FORM 63 68 69 76 Duplicate in all cards: --> 0000407 year as-1961- File number [Right justify [Numeric only] 77_______ 78 Sub-Index Code Author(s)f as Last Name FS (No Punctuation) and coden for journal as JAMA preceeded by one blank space 1 20 21 _________ 40 4160 61 62 Title of Report; end with space-hyphen-hyphen-space. Follow with Index Terms, separated from each other with comma-space. Avoid other punctuation; do not abbreviate. i2 61 62 21 22 23 24 Source (Journal, Vol., Number, Pages, Date) 12 61 62 31 32 Brief Summary 12 10 SUMMARY: 61 62 61 62 63 64 j-lt /SYC~-'? - DOW CHEMICAL U.S.A. October 29, 1980 MIDLAND, MICHIGAN 48640 30 t/> Fred Hoerger wo 2030 Dow Center 00 NO I saw this manuscript by Charles R. Perry some time ago. It is cleverly written for business/management type people. 1. I have no comment on his estimated costs; I don't understand them. 2. I don't know where he got his figures on angiosarcoma deaths. The last confirmed death in the U. S. was not in 1976 but as shown in Table 8 compiled by Dr...John Stafford of ICI in' England, there were 4 deaths in 1976, 2 in 1977, 2 in 1978 and apparently none in 1979. Although not yet in John's table at least one death has occurred in the U. S. in 1980. These numbers are too small to determine any trends. All that can be said is that as of now, the predicted deluge of deaths have fortunately not occurred. Europe, particularly Great Britain has had several bad years since 1976. I don't know the total but Great Britain had more than one death already in 1980. Why the apparent increase, is not clear. 3. I wish Dr. Perry had indicated in his reports that the cost of additional regulations, engineering, etc. will be disproportionatelyhigh as increasingly restrict standards are set. If no lives are saved but additional money is spent, the cost per life saved is infinity (X dollars/ 0 = ) Sincerely, T. R. Torkelson Health and Environmental Sciences 1803 Building ebg Enclosures (Tables 5 & 8 from Dr. John Staffords Compilation of 1 May 1980). AN OPERATING UNIT OP THE DOW CHEMICAL COMPANY * SAFE AND HEALTHFUL WORKING CONDITIONS: THE CASE OF VINYL CHLORIDE. I \wm# DA.I&- /MilU 4/15/80 - Charles R. Perry, O000407 University of Pennsylvania ,Cj^' 3hi0ppeu(K (licerctf Ml/c Tr'a L /CdJcbrcA Cl KIT Tkt k/k&bTtK School, The Occupational Safety and Health Act was passed less that, fen years ago*. with an apparent ease and unanimity uncharacteristic of major labor legislation in this country. The Occupational Safety and I-Tealth Administra tion created by the Act, however, has not enjoyed the blessings of its noble birthright. Indeed, OSEA, almost from its inception, has bean the target R&S 113083 ef public criticism and private conspiracy typically reserved for the mad or illegitimate progeny of royalty. The fall from grace of the highborn is fascinating to observe and intriguing to explain. The ''downfall" of OSEA began with the requirement cf "inflation impact statements" for major regulatory actions and has been carried on in the "regulatory reform" and "regulator)' analysis" movements. These movements are the product cf a perception that CSKA, like ar. unwise ' monarch, is imposing substantial and oppressive new taxes to support personal adventures which provide or promise little tangible benefit to an already overtaxed populace which, per force, must indulge the king's whims. There can be no doubc that OSEA regulations impose a tax on the producers and consumers of American-cace goods and services. There is, however, consid erable latitude for debate over the magnitude of that tax both in absolute terms anc in relation to the benefits purchased by the tax. This debate over Cr.a absolute and relative impact of OS'dA regulation on productivity and cost nay never be subject to definitive resolution, but it should be possible to gain sona perspective on the issue by analysis of the results of specific -a-