Document Lo4qdYvbZ9gYVv1mRpy3yx0dQ
aory committees and public meetings and by encouraging officials to be accessftde to outsiders. This has increased the burden of CPA officials directly involved in the endless round of meetings and memos which move forward the rule making process. A hard-working group of bureaucrats, these officials have been lashed to the mast for nearly a year
working long hours, often 7-day weeks; many have had no vacations since the
push began. A source ofrestraint among .the critics is the awareness that the regu lators must contend constantly with am biguity. As Muskie said in the recent hearings, "the Agency will be required to develop a program and a set of regula tions based on many 'unknowns.' "
In dealing with toxic substances, EPA must administer a law which Congress
left unspecific on many points. The agen cy's line of authority is often less than
dear and the science uncertain, nek and other EPA officials ha reaching a decision on unreason: will be to some extent subjective
If the regulators must live wii guity, the goals are clear enough assistant administrator put it, " mate test of success is whether cut down the number of aftercalamities, and the sad jokes al chemical of the week/'--John
would become obsolete In 5 to li
Nonetheless, the government
Industry Council Challenges HEW
gators took NOHS data for the i ofworkers exposed to earcinoger. liplied that number by a risk r.
' on Cancer in the Workplace
dieating an increased risk oftumo dated with exposure to the care
and multiplied again by the incidt
the type oftumors caused by the c
Health, Education,and Welfare Secre tary Joseph A. Califfino made headlines in September when he released a report
that projects a massive increase in can cer due to occupational exposure during the next two decades. Last week the American Industrial Health Council
(AIHC), an industry group organized to combat stiff new rules proposed by the Occupational Safety and Health Admin istration <OSHA) to govern carcinogens, released a counterreport suggesting that the first report wits little more than a figment of the collective imaginations of
ernment report grossly exaggerates both gen. Chromium, for example, cat
the risk associated with exposure to vari mors ofthe respiratory tract. The
ous carcinogens and the number ofwork data suggest that 1.5 million '
ers who have been exposed to them.
were exposed to chromium coir
The dispute can be divided Into two during the period of the study. T
major categories: projections about as mal incidence of respiratory tu:
bestos exposure and projections about the general population is 131 per
exposure to other carcinogens. The gov males over the age of 20. And sti
ernment investigators used different workers at chromate-producing
methodologies in the two cases, and the -during.the 1930's indicated ths
AIHC report thus attacks them on dif workers were five to nine time
ferent grounds. AIHC investigators have likely to develop respiratory turn,
placed much of their emphasis on as the population at large. Multiplybestos, but-their most telling arguments government investigators predic
the-government investigators. At least Involve other carcinogens, including ar
one -of the authors of the HEW report, senic, chromium,-nickel, and petroleum
David P.- Rail, director of the National distillates. --V
. .- -'rrr
-Institute of Environmental Health Sci 7 For -carcinogens other than asbestos,
ences (N1EHS), dismissed the rebuttal the government-^investigators ^-relied
as "what-might be expected ofindustry." heavily on a 1974 study known as the Na
Nonetheless,-the AZHC report appears tional Occupational - Hazard: Survey
to ^demonstrate - some father serious XNOHS). This 2-yearstudy was commte-
.errorein'tbeHEWsepori. -. *
Lsioned by the National Institute ofOccu
?*Califai>o*s motives forplacing the re pational Safety and Health to determine,
port in tite record of the hearings on the among other thtngt^*`th* extent ofwork-
proposed -OSHA regulations have been .-er exposure to-chemical and physical
impugned by industry representatives - agents/*: The NOH5 tnvestigators^is-
because the report does not seem ger .ited a representative-group, statistically
mane.- It-does not address -conditions selected, of business establishments and
bating in industry now orthat may ex - noted any exposure (without noting the
ist in the Aiture. lt argues, instead, that degree of exposure) to any of 198 specif
there will be 7,900 to 16,000 *\ respiratory remora m the future suit of exposure to chromium. In lar fashion* they computed tbi would be 3,900 to 14,000 excess of the respiratory tract resulting f. posure toarsenic, 350 to 1,400 exces of leukemia resulting from e> to benzene, 7,300 to 16,500 exo piratoryxumora resulting from e; to nickd'compounds. and 9.100 lung tumors resulting from expc carcinogenic components of pelr * These estimates are clearly infl each caser the investigators hav the highest risk ratio available obtained for workers exposed to:
because of conditions that have existed ic chemical and physical hazards. The concentrations of the carcinoget
in industry during the past 30 years or more, the proportion of cancer in the United Stales attributable to occupation al exposure will shortly elrfnb from the present range of Ho 5 percent to a much more alarming range of 20 to 40 percent, industry thinks tins is simply a scare tac tic designed to buttress support for the rigid proposed guidelines. The AIHC re
NOHS report -concluded that 38.2 mil lion employees had nearly 4.38 billion ex posures, or an average of 115 exposures per worker. The NOHS authors dearly warn that the majority of those ex posures are only potential exposures or exposures to minute quantities of materi al, and that rapid improvements in the workplace would sharply reduce the
multiplied that by the total nur workers who might have been < to the carcinogen, even though : all of the workers have never b posed to the concentrations upo the risk ratios are based. In a analogy, one might find that the the driver dying in an automobile one in ten Ifthe automobile is cor
port argues, furthermore, that the gov number of exposures so that the study .ly driven at speeds in excess of L
-sc e36-807V7&'mO-OM2SOO^VO CopyrigM e> 1978 AAAS SCIENCE, VOL. 302, 10 NOVEM'
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-^erhour, and that there are currently 100
entUioD automobiles on American higb&<ways. Using the logic of the government ^.report, one would conclude that there
w' ill be 10 million excess deaths as a reofdriving at high speeds. Thisanalois not as farfetched as it might aeem, the risk of developing a tumor y decreases with decreasing ex
posure to a carcinogen, just as the risk of
dying in an automobile accident dearly aaes with decreasing speed.
The investigators have also rather ily equated deaths with incideece, though the number ofdeaths result-
from a tumor is dearly only eome of the Incidence, depending on
Ohe tumor, hi short, the HEW projections dearly exaggerated.
bike dispute about deaths resulting tn asbestos exposure is more difficult resolve. Fairly good data indicate that 4.5 miliioa people were exposed to in shipyards during World War and that another 3.5 million to 6-5 m3-
3km people in other occupations have :becn exposed. Some 4 million of that to tal are believed to have had heavy ex posure. Epidemiological studies ofheav ily exposed workers who have already !*died indicate that 20 to 25 percent died 'from lung cancer, 7 to 10 percent from mesothelioma, and 8 to 9 percent from gastrointestinal cancers.
-Ofthe 4 million heavily exposed workre, the investigators thus expect at least .6 million to die from asbestos-related
rs, or about five times the number it would be predicted from the normal ^incidence. They predict that those exreposed to lesser amounts would have at one-quinsr-of tins -risk. That
d bring the-total number of asutos-related -cancers to a range of 2.0 tor2;i3 million. Since most asbestos-inneed tumors are manifested over a peti <bd?30 te 31 years after exposure, the
iber ofexcess cancer deaths assedatwith exposure to asbestos would be
n .56,000 and 75,000 per year, uch numbers, 4he Investigators aay.
Id-amount to 13 to 16 pereent.of all cer deatiis in the United States.v
AIHC report disagrees with the government report cm several specifics,
government investigators, for ex.assume that about 1 milfoilofthe (.million exposed workers would be by now. The AIHC investigators standard mortality rates would pre dict that some 2.5 million ofthe shipyard Workers would have died by now ami a /substantial number ofthe other exposed
workers also would have died. Ifthe in-creased risk of asbestos-induced cancer
uy the government investigators
v?>;
CE, VOl_ a, 10 NOVEMBER 197S
Regulators Defend Their Turf
Environmental and health and safety regulation has been on the defensive
ever since last winter when the Council of Economic Advisers (CEA) and
the CoubcO on Wage and Price Stabilization (CWPS) first zeroed in on it as a
contributor to inflation. Thus far, however, the regulatory agencies, which
include the Environmental Protection Agency (EPA), the Occupational
Health and Safety Administration (OSHA), and the National Highway Traf
fic Safety Administration (NHTSA), have held their own fairly well against
proposals that could have sharply reduced their authority to issue regula
tions imposing new costs on industry. This was again evident on 24 October `
fas President Carter's special message to the nation on inflation. The new
.Regulatory Council announced by the President for the coordination and
.review of proposed new regulations is mild medicine compared to what
some White House advisers had first proposed.
Observing that regulation should not be allowed to place unnecessary bur
dens on the economy, the President noted thatearlier this year be had called
for review of existing regulations from that standpoint and thorough costbenefit analysis of proposals for major new regulations (Science, 14 July).
Now, be said, the new Regulatory Council, to be made up of representatives
of the regulatory agencies themselves, will "coordinate regulations to pre
vent overlapping and duplication" and maintain a "unified calendar of
planned new regulations."
All ofthe relevant units within foe Executive Office ofthe President, such
as the CEA, CWPS, the domestic policy staff, the Office of Science and
'Technology, and the Office of Management and Budget (OMB), will have a
chance to review the regulatory calendar and to seek to modify any pro
posed regulations seen as needlessly burdensome. But, significant as this
may be, it is a far cry from what Charles L. Schult2e, chairman ofthe CEA,
had proposed. Schultze advocated having the regulatory agencies submit
proposed regulations to the OMB each year for a centralized process of
review and clearance.
This was a watered-down version of the "regulatory budget" concept
which Schultze and others have been suggesting for some time as a desir able, if admittedly difficult, goal to work toward in the future. In its purest
form, this concept calls for a process of review and approval for regulations
that is closely analogous to the fiscal budget process. That is, the OMB
would establish limits agency by agency as to the regulatory costs to be
- imposed in any given yearand the agencies would have to stay within them.
This "budget," like the conventional budget, would ultimately be submitted
by the White House to Congress for its review and approval. > (As Schultze has acknowledged, the difficulties -of carrying out so am
bitious a process or anything approaching it would be formidable. For one -
thing, -predicting foe costs that proposed new regulations would place on .
industry and the economy-would not be easy.) - /,
; ..
Eariy-ra October, the.-Council on Environmental Quality'Organized a
meeting of leaders of theregulatory agencies to stiseuss what was perceived
as a vigorous campaign being waged from a number ofindustry and govern
mental quarters to constrain the regulatory process in the name of com
bating inflation. Subsequently, as these leaders began working closely with
the White House staffers who were preparing the President's forthcoming
inflation message, they found the Schultze proposal to befront and center.
Alarmed at this, the agency leaders, with Deputy Administrator Barbara
Blum ofthe EPA taking the lead, put their minds to work preparing a coun
terproposal. The result was the Regulatory Council proposal which ulti
mately carried the day. According to sources attbe CEA, this proposal was
agreed to by Schultze himself as an acceptable compromise.
The Regulatory Council is regarded by Blum and others as a kind of"reg
ulatory clearinghouse," andjust what this will mean fai practice is sufficient
ly uncertain as to cause some uneasiness in the environmental community.
Nevertheless, leaders of the regulatory agencies are taking comfort in the
fret that the review of proposed regulations his been entrusted largely to a
body which they will make up and run themselves.--Luther J. Carter
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were valid for the shipyard workers, fact, data from the National Cancer Insti
moreover, that population would be ex* tute's Surveillance Epidemiology and
tinct by now, they argue.
End Results Program indicate that the in
If all the risks and exposure figures cidence of mesothelioma has been
used by the government investigators are rather stable at about 1000 eases per
valid, the AIHC report argues, the can* year. Even if the AIHC assumptions are
cer epidemic should have already begun. completely wrong, the investigators say,
Using the government figures, and as there should be an upward trend in meso
suming that both the 1 million'who have thelioma incidence if the government
already died and the 4 million most heav predictions are correct. There is dearly
ily exposed were among the World War. no such trend, AIHC argues, and there
II shipyard workers (a rather dubious as fore the government predictions must be
sumption), the AIHC investigators pre much too high.
dict that there should be between 7,000 AIHC representatives criticized the
aad 10,000 cases ofmesothelioma (which original report on several other grounds
is considered a marker for asbestos-in- including its hurried preparation, its
-duced cancers) occurring each year. In lack of submission to peer review, and
a the absence ofthe authors* names onth, 4
original summary that was released (iv. names did appear on the complete p*. per). These criticisms lose some nine however, in that the AIHC rebuttal wd prepared in about 1 month, it was not subjected to pear review, and no authors are listed on it.
Nonetheless, the rebuttal points oui some severe deficiencies of the original report and necessitates the conclusion
that its predictions are invalid. A con clusion about whether the incidence of occupationally induced cancer is as lot as AIHC says it is, however, will await a more thoroughly prepared report or the last of time.--Thomas H. Maugh II
anthropology, and finally the Harvard
Corporation,'which is the ultimate arbi
ter. The Fogg vetoed the idea of sellint
Peabody Museum Contemplates
the Bingham and several other paintings, which werejudged too valuable as an to
Sales to Reserve Collections
be sold. Paintings in the Bushnell collec tion depicting Indian life were also elimi
nated from consideration, leaving rooslly
landscapes that do not contain Indians.
The Peabody Museum of Harvard ovation and half to augment the muse What remains is a group of works rang
University, founded in 1866. is one ofthe um's $4.5 million endowment.
ing in estimated value from $1,000 to
world's first museums of anthropology The items earmarked for possible sale more than $300,000 apiece.
and ethnology. If houses one of the come from two collections. One is a ' The Harvard Corporation has ap
country's half-dozen major anthropolog group of 106 oil paintings by 19th-cen proved the tale pending the preparation
ical collections.
tury portraitist Henry Inman. These are ofdocuments that spell out the legal su
Like all museums, h does not have copies of a famous group of portraits of ms ofthe paintings, indicate the strictures
enough money. It needs money so badly Indians by Charles Bird King that were on any transaction, specify the mode of
that it is thinking about selling, or "deac- destroyed by fire. The other is agroup of sale and detail the reasons for It. Mean
eessioning" some of ha paintings. De&c- 387 watercolors, oils, and drawings re while, Harvard has been hearing from a
cesstoning is a very touchy matter. You lated to North American Indians, part of small but vocal constituency, activated
sever can be sure that you are selling the a collection donated by David I. Bush through the efforts of a Smithsonian In
right thing or getting the right price for k. nell, Jr., who worked at foe Peabody at stitution -anthropologist, who emphat
Every item In a museum has its own his the turn ofthe century. Thetotal value of ically disapprove of the proposed deac-
tory and constituency, its lovers and both collections has been estimated by cesskming. --
scholars. There is bound to be a hue and New York dealers Hirschl and Adler at r The Smithsonian curator is William C.
ay from somewhere when people find $7million.
............
Stunevant, an -ethnologist whose spe
out that a museum has sold something.
Lamberg-Kariovsky explaini that the cialty is eastern North American In-
Thus it can be seen why -former Peabody paintings are of minimal anthropological dians. Wben Stunevant heard of the pro
director Stephen Williams said that "the value and have not been used at all for posed sale, be sent letters to 150 anthro
curatorwho deacccssions is either a fool research and teaching, which are the pri pologists throughout the land and abroad
ora knave or probably both."
mary function* of the museum. He say* -warning font Harvard was in danger of
However, there may -come a time they have been 'stashed away for 40 precipitating "another famous deacees*
when the well-being of an. entire collec years where nobody looks at them.`A sioning scandal.'*' Stunevant claimed
tion Is in such jeopardy--through lack of few have been loaned -out to an muse that Harvard did not have the benefit of
proper maintenance, preservation, and ums--including the most famous piece in expert knowledge on ethnographic illus
safety measures--that it seems better to the Bushnell collection, a painting by tration, and foe feet that the paintings
jettison some of the cargo before the ves George Caleb Bingham valued at SI mil had not been used by scholars did not
sel founders.
lion--but none has been analyzed for an mean they would not be used in the fu
So thinks C. C. Lamberg-Kariovsky, thropological purposes.
ture. He claimed that it would be impos
the director of the Peabody, who ever The items proposed for tale, says sible to make completely accurate repro
since he took office in July 1977 has been Lamberg-Kariovsky, have been filtered ductions of foe paintings and that these
trying to figure out how to get money to through innumerable groups--the muse in any case would not yield information
initiate a thorough program of preserva um's governing board, Ha visiting com on potentially important pictorial details
tion, conservation, and security. He mittee, a committee from the Fogg art or for "iconographtc, stylistic, or phjv
wants to raise S3 million, halffor the ren- museum at Harvard, the department of ical-chemical research."
tot OM*OM/?Vm604SOO.?M Copyright 9 Wt AAAS SCIENCE. VOL. t<e. 10 NOVEMBER tff
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Occupations Health & Safety LftttovApril 8,1979
However the numbers turn out, the episode is certain to stimulate a major intensification of research
' h|l
effects of low-level radiation. It could well be that this will have a major impact on occupa-
\ hwlth programs as the need for health physicists and others with specialized information on radia-
he:lih effects becomes more evident.
\ofc: We spent a full day in Middletown,Pa., nearest town to the Three Mile Island facility. We
h*am very much from either the facility or the Government about the occupational exposure levels.
|nii we did get an objective lesson about occupational health and the "problem" of informing workers
;ilm t health hazards they face in a conversation in a bar with one of the workers at the reactor. We asked
him if he knew about the health risks he might be facing in his job. He fixed us with a tolerant smile and
tnid: "Hell, man, I get S15 an hour in that reactor. For that kind of money I expect to take risks, and I
don't want to hear about 'em." Then he returned to his beer.
STUDY OF BRAIN TUMORS IN CHEMICAL WORKERS EXPANDED FOLLOWING NEW REPORTS:
New reports of brain tumors, otherwise unclassified, in two additional chemical plants in Galveston County, Tex., have spurred an intensified epidemiological investigation by Government and industry researchers into the incidence of glioblastoma multiforme in former chemical workers in and around Texas City (OCCUPA TIONAL HEALTH &. SAFETY LETTER, March 8).
It had been previously disclosed that 11 brain tumors had been experienced by former employees at Union Carbide's plant in Texas City and that an unknown number had been reported at the nearby Mon santo plant.
Now a Government source told OCCUPATIONAL HEALTH & SAFETY LETTER that two additional chemical plants in the same county--Galveston County--are being studied following reports that one plant had three brain tumors and another had one or two brain tumors. They have not been classified as glioblas toma multiforme, said the source, who refused to name the companies.
Meanwhile, the long-range study of glioblastoma multiforme and other brain tumors at the Union Car bide plant was scheduled to begin March 9 between NIOSH and the company, which will be represented by Dr. Michael Utidjian. It will consist of a case of control study of the 11 known brain tumors, of which eight are believed to be glioblastoma multiforme-a considerably higher percentage than would normally be expected in the population. That is expected to take about one year. A second part of the investigation is a mortality study to define the risk more precisely.
The original theory was that glioblastoma multiforme might be linked to exposure to vinyl chloride. However, in the view of some epidemiologists (not all, by any means), the connection with vinyl chloride . is getting less plausible.
Among this group, it was noted that the 11 Carbide employees with brain1 mors since i41 (all of whom have died, the 11th death occurring two weeks ago) had minimal contat ith vinyl r mde. t should also be noted that Equitable Environmental Health conducted a study for the Manufacturing Chem ists Association in 1976 among 431 vinyl chloride workers (including the Carbide employees in Texas City) and found 12 cases of glioblastoma multiforme, as opposed to an expected incidence of six cases. But it said that no association between exposure to vinyl chloride and the tumors could be made on the basis of its study.
DR. STALLONES SEEKS TO SUMMARIZE AIHC'S POSITION, AND TO EXPLAIN HIS OWN:
Dr. Reuel Stallones, dean of the University of Texas School of Public Health, has sent a second docu ment to the American Industrial Health Council, which hired him as a consultant, summarizing what he believed should be AIHC's position on the HEW Estimates report on the extent of cancer related to occu pation-plus a letter designed to explain his own views, which are apparently basically unchanged..
It was reported exclusively in OCCUPATIONAL HEALTH & SAFETY LETTER of March 22 that Dr. Stallones, along with Dr. Thomas Downs of the University of Texas, had sent to AIHC an analysis of the HEW estimates which criticized the methodology used In the Government study but placing the extent of occupationally-related cancer between 15 and 33 percent (possibly higher than HEW's estimate of 20 percent over the next 30 years).
As a result of conversations with Dr. Robert Morgan, an epidemiologist at the Univeislty of Toronto,
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I liis own view that his critique might be considered too technical. Dr. Stallones then prepared a sum-
* Jlinry of what he believed AIHC's position on the analysis should be.
AIHC chose not to accept the Stallones summary, preferring instead to file its own statement with
OSFIA after the cancer policy hearing. Dr. Morgan and Dr. Maury Johnson, medical director of Goodrich,
ihcn called Dr. Stallones to discuss what they believed to be "discrepancies" between Dr. Stallones* critique
of the HEW Estimates paper and his summary position for AIHC.
-
So Dr. Stallones then sent a letter, dated March 5, to Robert C. Barnard of the Washington law firm
of Cleary, Gottlieb, Steen & Hamilton, representing AIHC, in which he sought to clarify the misunderstand*
ing.
"Dr. Downs and I collaborated on our critique, and we still believe that this represents our views," Dr.
Stallones wrote Barnard. "The authors of the Estimates paper made several assumptions that had the effect
of overstating the risk of cancer associated with occupational exposure. Dr. Downs recomputed the esti
mates using the data in the original paper and obtained modestly lower figures, which we reported.
"We believe that the allocation of cancer deaths to multiple causes is justifiable, but that to do so cre
ates new problems in dealing with the concepts of causality. The data presently available are not adequate
to permit us to make reliable estimates of the risk of cancer in industrial environments in the presence of
complex interactions. The only position I see to this problem is to acquire better information.
"I prepared the proposal for a Summary Statement after discussing the AIHC response with Dr.
Robert Morgan. It was not intended to supplant nor to supplement our previous critique, but rather con
tained suggestions for summarizing the AIHC Reply to the Estimates paper. I thought that some of Dr.
Morgan's ideas about the useful applications of epidemiology in answering questions raised by the Estimates
paper and the AIHC reply deserved emphasis. For the rest, I was summarizing the AIHC reply, not reflect
ing in any detail my own views. Nevertheless, after reviewing these statements carefully, I am unable to
find as much disagreement as has been suggested.
"The most important point in all of this discussion is, I think, agreed to by all parties: that cancer
resulting from exposure to toxic substances in occupational settings is a serious problem, and that serious
and continuing study is needed to find w* ays toreduce* these *risks." #
In the summary, which Dr. Stallones prepared in language which AIHC could adopt for its own authorship, he criticized the Government's uses of multiple causes as the basis for estimating occupational
exposures and said that epidemiology could best answer the question of what fraction of cancer incidence or deaths could be prevented by reduction or elimination of occupational exposure. In the summary, Dr. Stallones explained:
"Many epidemiologists agree that in the past, a portion of lung cancer deaths among smokers has been falsely attributed to smoking alone. There would be considerable value in undertaking the epidemio logic exercise to define that portion of smokers' cancers that should be attributed to the combination of smoking and industrial exposure rather than to smoking alone. The preventive implications for this, how ever, are not entirely clear since we appreciate the fact that protection of smoking workers from asbestos '
particles or radon daughters, while reducing cancer risk, will grant no immunity from the effects of cigar ettes alone."
Meanwhile, the executive director of AIHC expressed "serious concern over apparent misconcep tions" about the Stallones analyses which he said could "undermine the ongoing cooperative effort" among industry, government and the scientific community to identify potential carcinogens in the workplace and to find effective means for protecting employees from their hazards.
Ronald A. Lang, executive director of AIHC, told a press luncheon in New York that the StallonesDowns paper, along with three other comments on the Estimates paper by outside experts contacted by AIHC, were all used by AIHC's Scientific Committee in development of the Council's comments on the Government study and none of the four were published separately.
"AIHC very much regrets that the present tempest over estimates of how much cancer in the future may be attribi table to what causes is diverting attention from the pressing need for a sound, sdentificallybased national cancer policy," Lang said.
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