Document MJEzJn5wbJ6xkZ4RR99G3E4mV

i C e iul VJKY ASBESTOS ? A Presentation Before the ' Asbestos Textile Institute Arlington, Virginia -.June 7, 1973 By: Matthew M. Swetonic, Executive Secretary Asbestos Information Association/Morth America mmpm I ara sure that many of you have asked yourselves, as I hava asked myself, why has the asbestos industry seemingly been singled out as the prime target for sa many assaults by government, labor, the press, certain segments of the medical profession, and by various environmental and consumer activist groups? Why us? Can asbestos really be all that bad? Ara the products we produce truly going to kill millions of Americans, as seme experts have predicted? Or is there some sort of nefarious conspiracy afoot to destroy -the asbestos industry? The answer to the question of "Why us" Complex because it is a combination or separate factors'. Simple because each considered, by itself, quite obvious. is both complex and simple. three interrelated but of the factors is, when The three factors are (1) asbestos can causa disease, (2) a spokes man arose to champion the need for asbestos control, and (3) a cornucopia of new government agencies were set up to control materials and products that can cause disease. Let us look at each of these factors in turn. ' First, there is no doubt that the inhalation of substantial amounts of asbestos can lead to increased rates of various types of lung disease, including two forms of cancer. These are facts which can not be denied, even if they do not apply in all circumstances and under all conditions. The medical literature is full of solid evi dence linking asbestos tc disease. In my office, I have on file more than 2,QG0 medical papers dealing with the health risks of asbestos and hundreds more are published every year. Secondly, the spreading of concern over the health risks of asbes tos has as its prime spokesman one of the most talented medical publicists of the age -- Dr. Irving J. Selikoff o'f Hew York's Mount Sinai Hospital. Hot only is Dr. Selikoff capable of arousing the ^ira^and mora3--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, unquestionably painted a fax darker picture than the facts warrant, we should always remember . in his defense that the insulation workers ho has br^n studying for ^PLA1>^5? - Pago 2--.Xlhy Asbestos?, by U. M. Swetonic, AIA/ITA . Presented to the ATI at Arlington, Virginia - 6/7/73 mors than, a decade were and still are dying free asbestos related disease at an appalling rate. Such a situation would be sufficient to make a crusader out of the most conservative of scientists. Finally, in the past 'de'eade' there has been a tremendous growth in public-' and -gove-r?im^n^i^-inteir2s1f";in "environmental and occupational health matters. This interest has been translated into a series of far-reaching laws affecting industry in a manner hitherto unknown irr this or any other country. I believe it is accurate to a say that these new laws, such as the Occupational Safety and Health Act, the Clean Air Act, the Consumer Product Safety Act, and others, have forever altered the concept of the free enterprise system as it was known in this country for a hundred and fifty years. Thus, in combination, these three factors created a situation in which a cadre of freshly created federal agencies, with strong statutory authority, were prodded into assigning priority status to . asbestos by Dr. Selikoff trid'his~ followers, who achieved'thesa 'ends through skillful-use-of the great wealth of negative asbestos-health .. data cpn.ta.incd in' the medical literature. ' . In short," the" asbestos, industry was singled out because it was vulnerable to attack, because there was someone willing to lead that c attack, and because Congress had graciously provided the vehicles for such an assault. - The background of industry efforts to deal with the asbestos-health problem as a national issue goes back nearly a decade, to Dr. Selikoff1s now famous 1964 seminar on asbestos disease at the hew York Academy of Sciences. IThile this seminar did much to prick the industry's conscience about asbestos and health, the problem still remained one of limited public and 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 acid for the health and safety of its workmen and the American public. The asbestos-health problem was - found to be tailor-made for such stories. As a result, starting with Paul Drcdeur's infamous hew Yorker article of March 1963, asbestos has since grown into an item of major press'interest. In those years, industry efforts to combat the spate of negative press articles on asbestos were carried on primarily by the Johns- ilanyille Corporation, which set up a task force of specialists in -----------various- fields-to-do-what-it could:'to portray the'problem in``lfs proper perspective. IThile 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 late 1970, eight companies gathered in New York City . to launch the Asbestos Information Association of North America,' . ~ Page 3`~ Pfhv Asbestos?# by M. M. Swetonic, AIA/UA Presented to the ATI at Arlington , Virginia - 6/7/73 which was patterned after the British Asbestos Information Ccmmit.tee, which had been established seme three years earlier. In our original concept# the Association would limit its activities to providing accurate# unbiased information on asbestos`and health to the press# to the public and to interested politicians and ether government officials. It must be remembered that at this particu lar time# the enormous problems that would later develop with regard to OSHA and other Federal regulatory agencies wera as yet cr. 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 manufac turing 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 years 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# and Government Affairs. To take these activities one at a time, let us start with medical affairs. It is an obvious fact that if an organization is to speak authori tatively on a medical matter# it must not only be steeped in the literature of that particular medical subject, but it must also keep itself constantly informed of new discoveries and developments This we have accomplished in a number of ways. For example# by sending representatives to important medical nestings, such as the 1972 Lyon# France# international conference on the biological effects of asbestos# which was sponsored by the florid Health Organi zation. V7e also meet on an irregular basis with various medical experts in the field, both from the United States and abroad# to review and discuss recent developments and discoveries. Our literature research is eased considerably by receiving the monthly medical 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 has elected to sponsor medical research of its 'own. Currently underway is a completely AIA/UA funded study of chest sounds# which is being conducted by Dr. Raymond Murphy of the Harvard School of Public Health. The purpose of the study is to find a new method of determining anindividual's potential susceptibility to asbestos disease, . Page 4 - Why Asbestos?, by li. M. Swetonic, AIA/NA Presented to the ATI at Arlington, Virginia - 6,-7/73 ' -&dLEXH13n > The Association has also recently decided to contribute to seme ve: exciting research into a possible cure for mesothelioma through electromotive treatment. This study is being conducted at Somers-. Hospital in New Jersey. - In the legal affairs area, the Association participated in an amicus curiae capacity in the lav/ suit brought by the Industrial Union Department of the AFL/CIO against the Occupational Safety ar.c Health Administration on the asbestos standards. In our brief the Association supported GSHA against the IUD, somewhat of a unique position for an industry to find itself in vis-a-vis a governmental regulator*/ agency. Oral argument on the case was held April 4 in Washington. While a. decision has yet to be handed down by the Ccur of Appeals, we are confident that the case will be decided in cur favor. The Association, has retained the services of a special technical consultant cn environmental control affairs. At the present time, he is working with the ATA/NA Environmental Control Sub-Committee oh the development of a series of five Association compliance 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 ceruai variables on the overall accuracy of the method. 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 sen to both OSHA and to the National Institute for Occupational Safety and Health. A number of the recommendations contained in the study for improving the accuracy" of the method have beer, incorporated int a soon-to-be-released revised N1CSH operations manual on fiber counting. In the customer relations area, the total effect of negative press publicity ar.d government regulations cn industry customers is still today rather poorly defined. Seme 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 mako it non-competitive with non-asbestos containing substitutes. . Second, the customer has not thoroughly investigated his situation and only thinks that he can no longer afford to continue using ' .asbestos.~ i ' . .. ..................... .~ . . ( -A 4 -* Page 5.- Why Asbestos?, by M. M. Gwetonic, AIA/UA Presented to the ATI at Arlington, Virginia - 6/7/73 Third, the customer has raad one or more negative articles cn asbestos in the public press and has mads the snap decision that "we ought to get that dangerous stuff out of our plant." Often, decisions of this nature are forced on top management by illinformed medical advisors or safety and health directors. ' Fourth, the customer has neither a control problem nor is he parti cularly afraid of using asbestos in his own plant. However*, ha is fearful that those of his competitors whose finished products do rx' contain asbestos will stress the adverse health effects cf asbestos in trying to take business away from him. Customer fears cf this nature arc essentially "cut" reactions and am hence extremely difficult ta deal with. - Fifth, the customer has none of these problems or fears but he has been advised by a government official cr inspector that he would bo better off if he quit using asbestos or asbestos-containing product.in his plant. Whila this problem does not appear to be widespread, we have learned of -a number of situations where it has occurred. 'Actions, of this nature by government cfficials are totally uncalled for and should be dealt with promptly and decisively. The best solution is to obtain complete details on`the incident and.then to register a formal complaint with the offending official's immediate superior or with the government agency involved. The Association's first reaction to the overall customer relations problem was to approve funds for a series of four regional seminars at which industry customers would be given a number of,basic presen tatiens on the various aspects of the asbestos-health problem. The seminars were tentatively scheduled for the Spring of 1973. However, the experiences of a number cf our member companies shewed that general "catchall" type seminars of the type originally contemplated would not be effective in dealing with the majority cf customer relations problems. In order to do the job properly, it was found that customer presentations have to be tailored to the needs and problems-of the individual customer. As a result, the Association cancelled its scheduled series of seminars and instead elected' to develop a number of packaged slide presentations on such topics as "The Faces About Asbestos and Health," and "Understanding the QSHA Regulations," which could be used by member companies as part of a tailored presentation to individual customers. _____________* As with customer relations, the Association feels that employee relations is a problems best handled by the individual member . companies. Thus far, the AIA's sole contribution in this area of industry concern has been tc prepare the draft of an Employee Hafet and Health Guide on Asbestos-Health. The draft was made available to the member companies for their ovm use and at least one has - produced it in booklet form for distribution to all its employees.' Pago 6'-- Why Asbestos?, by M. M. Swetonic, AIA/bA Presented to the ATI at Arlington, Virginia -- 6/7/72 I personally believe that the employes 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. V7e knew that various organized laber groups are planning a full scale campaign to bring their interpre tation cf the asbestos-health problem to the attention of asbestos industry employees throughout the nation. If the industry permits this interpretation to be disseminated without rebuttal, the consequences could be grave indeed. -1 Inter-industry relations are best defined as keeping the industry informed about important new developments on the governmental, medical and press relations fronts that affect asbestos. This is accomplished within the AIA by periodic distributions of documents and information to the member companies and to others on our mailing list. /The value of this activity can be gauged by the fact that cur overall mailing list increased from approximately a dozen names in 1971 to more than 60 a year later. T/hile we have had to trim the list somewhat this year for logistical reasons, we assume from the frequent requests we still receive to be placed cn the list than the material we send out is being read and is of considerable value to thosa receiving it. Next to government affairs, our public relations and publicity activities constitute the single largest consumer of time, effort -and money within the Association. Those of you who are familiar with the treatment that asbestos has been receiving in the public press over the years can readily unde rs why this activity ranks so high on our priority list. {That you aav not understand are the reasons why cur extensive _ efforts in dealing with the nation's press have been so unsuccess ful to date in producing the theoretical "balanced" or "positive" story on asbestos and health. The 'simple fact is that f rcry the standpoint cf today's young activist reporter, industry is the bad guy, and nothing we do, say or achieve can ever change this impression. If we spend $100 million dollars on environmental control, tho press either says we ought to have done it ten years ago or that wo should have spent ,._.?.2Q0 million* _..If we sponsor medical research, they say we are -- trying to buy favorable results. If we are opposed tc ridiculously stringent standards, they say wo arc in favor of lettiag our employees die. s .* ^ television executive in Minneapolis described this nc-w breed of reporter as being "so intent on demolishing the establishment that L they would blindly destroy the credibility of the media in the bar .. gain." Another TV executive, this tine in Chicago, stated "they . Page 7.~ Why Asbestos?/ by M. M. Svetor.ic, AIA/'TA Presented to the ATX at Arlington/ Virginia - 6/7/73 want to make moral and political and sccia.1 judgments on their assignments and then take sices. Never mind getting the facts straight." As a result of this "industry is a monster" philosophy, asbestos will remain a hot news item only so long as the news 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 diracciy contrary to the portrait of an irresponsible industry producing a "killer" product that is the sole element of news worthiness in the asbestos story. The press relations battle will therefore he won, not when the media starts to print positive or balanced articles about asbestos, but when the press ceases to print anything about asbestos at all. As long as negative news on asbestos-health continues to be ^generated, the media will continue to eat it up. The media will only cease to carry such stories when the generation of negative news ceases. It is as simple 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 knew, the Association is currently engaged in an extensive campaign to interest the trade press in articles on the benefits of asbestos and on industry accomplish ments in the environmental control area. The trade press, unlike the national or public media, is much 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 frem time to time put out press releases cn various subjects relating tc asbestos-health. A few weeks ago, we issued a release on the report of the advisory committee cn asbestos cancers of the World Health Organization. In brief, the report concluded that the general public is net 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 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 jiews is coed, "the press simply' isn^t' interested. ' "' Nonetheless, tho Association has no intention of abandoning cur efforts. vis-a-vis the national media. I7e 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 tc present the press with a balanced view of the asbestos-health situation. - Page 8' - VThy Asbestos?, by M. fl. Swetonic, AIA/tTA Presented to the ATI at Arlington, Virginia - 6/7/73 SJfePl^MTIFr'S - * NO.-*'-' Our most recent effort in this regard has been the preparation and printing of an Asbestos and Health Xnfcmaticn File, which v/e have .mailed to some 3,QQQ 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 can't expect our information file to change the whole attitude of the press toward asbestos, we are hoping that the media will make 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 public relations problem, it's time for some good naws* ' /And the good news is that despite all the negative articles on asbestos-health that have appeared in tha press over the past half dozen years, very fevj people have been paying attention. Lac me explain. In February, the 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 was conducted by tha Opinion Research Corporation during March and April. More than 2,000 dsnographicaliy selected Americans were interviewed* Without going into enormous detail, the results shew that only 22 per cent of the American -public are aware of the health hazards of asbestos, and that 80 por cent of these consider it a hazard only to these who are occupationally exposed. A mere three per cent of those interviewed stated that they considered asbestos a health hazard to the general public, and less than one quarter of one per cent considered it the most dangerous material on the list they were given to choose from. Surprisingly, the college age youths of America are no mere 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.___ _______________. ._________ Before going on to describe our activities in the government relations area, I think it might be interesting at this point to take a very brief look at the manner in which 5r. Selikoff and his supporters have used his research results tc dramatize and exaggerate the seriousness of the asbestos-health problem. I have two charts which point this out rather conclusively. . . . - * .Page 9' - TTiy Asbestos?, by ?i. It. Swetor.ic, AIA/U1 -Presented to the ATX at Arlington/ Virginia - J5/7/73 f ^exhibits? 2 The first chart shows the actual results of Dr. SeliKoff'5 four mentality studies of asbestos workers. The numbers in parentheses beside the figures for total number of workers indicate those who have so far died fron all causes. The percentage figures .alongside the total number of deaths from asbestosis, lung cancer and nescthelioma are based on the total number of deaths from all causes, not cn the number of workers in the study. The most important study of the group is the second from the top, -.1 shewing the deaths fron asbestos-related disease among all members of the insulation workers union, regardless of length of exposure. You will note that 34 per cent of those workers who have died thus far have, died from one of the throe asbestos-related diseases. These, then, are the facts Dr. Solikoff works fren. This is what ho knows from his own investigations, ttew let us take a look at what he has done with these figures in order to dramatize the problem. - ............... ' Chart number IX shews Dr. Gelikcff's predictions about asbestosrelated deaths in the United States. Without going into details, Dr. Seiikofi has arrived at his projections hv the simple procedure of"multiplying the percentage of deaths from asbestos-related disease among his insulation workers by the total number of employees in the entire industry. You v/ill also note that he has raised his projected death estimate to enormous heights over the past year by simply increasing the base figure of employees exposed, while still retaining the percentage multiplier cf 34 per cent heing experienced by the insulation workers. I night point out that this tactic, however deceptive, has been an enormous success sines each raising of the estimate has earned Dr, Sclikoff correspondingly greater coverage by the media. do finer example exists of the total gullibility of the press than the manner in \jhi.ch it alleged its prejudices to bo manipulated and played upon in this situation. ' Please don't get mo wrong. . I have no doubt that the insulation workers are in fact dying ao rapidly as Dr. Selikoff says they are. The problem is that ha has translated their mortality experience to the* rest cf 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 bo precise. Even mere important, according to an analysis by the Association of more than a dozen mortality studies, including those of Dr. Selfkoff, cur prediction is that approximately 25,000 past .and present employees in the asbestos industry have died or will eventually dra Of asbestos--related disease. This is loss than ona-thirte^nt-h n Page 10 - Why Asbestos? by f!o II. Swctonic, AIA/>AA Presented tc the ATX at Ar1ing ton ? Vir: rjini a - 6/7/73 of Dr. Gelikcff' s most recent estimate* In addition, our figures shovr that 20 of the 25,000 deaths ~~s or 805 will occur among those in the insulation trad.es* * While these estimates should be reassuring tc those in the mining and nonufacturing areas cf the industry, ve should not forget that 5,000 of our workmen are still going tc die of asbestos-relatad disease and that, all things considered, there is absolutely nothing that we car. do to prevent it. The only thing we can do is to clean up cur plants to assure that those entering the industry in the future will not have the snice experience. Within the past year and a half, the nain thrust of Association effort has shifted to the government affairs front. The principal agencies in Washington with which we have been dealing are the Occupational Safety and Health Administration? the Environmental Protection Agency? the Food-and Drug Administration; the Bureau of nines? and, to a lesser degree, the national Institute of Occupational Safety and Health, and the national Institutes of Health, both of which are nainiv involved in research efforts. In addition, a fevr weeks ago we were contacted by the Federal Trade Commission, which had received a petition from the Center for Science in tha Public Interest requesting an investigation of consumer usas cf asbestos for the purpose of determining whether certain products ought to be labeled as hazardous and whether warnings should be required on all advertisements for these pro ducts. On the basis cf a preliminary meeting with an investigator from the FTC it would appear that ve hove little to worry about in this particular area. The Occupational Safety and Health Administration has been cf enormous concern to the industry ever the past 12 months. .As nest of you already know, tha .Association expended tremendous efforts during tha six month period leading to tha promulgation of last June's OGILA standards on asbestos. I think it is a gauge of tha effectiveness of the total industry involvement in this most crucial matter that of eleven main requirements in the standards, the industry position was accepted totally by OSHA on nine cf the eleven, about fifty per cent on a tenth, and totally rejected on only one. OSIIA is new planning to redo the standard' package and we are. work ing closely--with-them. on this project. -mThe _first~stap .will be the formation of a 15 nan advisory committee to review the current standards and any additional medical and technical data that has become available in the year since the standards '.'ore promulgated. - Forking in cooperation with nine ether trade associations we have selected four individuals as industry-wide recommendations to OS HA for the four _ so-called "employer*' spots cn the advisory committee. 'Pago !! -- Uhy Asbestos?, by El. Et* Ewetenic, "Presented "to the ATX -at 'Arlington, Virginia In discussing the formation. c the advisory ccrmittas with, John O'tTeill* cf the OSIITi Standards Development Section, we ware ashed to add a couple of nar.es tc the list sc that CSZIA would have more of a selection to choose from. This wc have acreed to do* The committee will be given up to nine months to complete its deliberations and prepare for C3HA a revised standard package. This will be followed by public hearings, approximately a year from now* T?e do not expect to see a new standard promulgated before the Fall of 1974. It is of course impossible to determine at this time what the row - -- standards will look like, however, I would venture to say that they will certainly net he less strict than the ones wa have today, although they will prcoably be less confusing and leave less rocn for employer interpretation. Something will unques tionably be done to improve the current difficulties .with the . monitoring requirements. i?he main function of the national Institute for Occupational Safety and Health is to conduct research and to prepare sc-calied Criteria Packages, which ara essentially, reccmandations to OSHA for stan dards on various materialschemicals and activities. Such a package on asbestos was prepared by UIOSH at the time of the OSEA proceedings last year. iTICSE will not he preparing a new cr 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 agon- cios in Washington dealing with asbestos. Dr. Selikoff has had his greatest influence on the young idealistic scientists and doctors at niOSII. Consequently, industry influence is weakest in this agency. It was niOSII, after all, that made the original rGconr.cn- dation for a two fiber standard, in the United States . asbestos industry. ' Next to OSHA, the Environmental Protection Agency has the greatest potential cf any federal agency fer adversely affecting the future of the asbestos industry ir. this country. dot only is the HP A responsible for developing and enforcing air and water pollution standards, but the Toxic Substances Control Act, now pending in Congress, will also became an UPA function after passage. For this reason, I an pleased to he able to say that the asbestos industry has an excellent relationship with the E?A._ Uc finer _ _ "'proof 'of 'this exists than the 'fact that `there was not a single major industry recommendation node to the E?A at the`public hear ings on tiie proposed asbestos cnission regulations that was not - accepted either in toto or in principle in the final standards, which ware published in early April of this year. _ We are presently working with the EP?v cn the development of waste watar effluent standards for asbestos manufacturing plants. Vq . "j* ' . 4 Page. 12 *- UZ%y riVshfrj>t'-CiS? DwetOUiu r BrdscmtcSd ta lrt 'A*2i . aimh:r.LA'ig\.crA . Virginia' certainly* hope "that, theca stemAaxdlfc will turrr out to be as reason able as the air pollution' r aginations* ~hc proposed effluent ' standards are scheduled to ,be published in the federal Register sorr.atino this Sumer,' to he followed by public hearings, with the final standards being promulgated in the Fall, perhaps as early as October. ~~ Ha are also planning, in the near future, to meet in Hashingtcn with representatives from the standards development ar.d enforcement branches of the F?A to discuss with them questions of interpretation, and compliance policy with regard to the new air pollution regulations. He have already resolved one interpretation question that is of special interest to the asbestos textile industry- Approximately two weeks age I was asked by a member company of*the Association to find out whether the EPA was planning to require the oanurac- -- turers of asbestos safety clothing to register as potential emission sources under the law. In discussing the situation over the phone with E?A compliance officials, I argued that the producers of asbestos safety clothing were net manufacturers as defined in the regulations but were instead only fabricators of an asbestos product, and as such, should net have to register as potential emission sources. After our phono conversation ended, a brief meeting was held among the CPA compliance people. I was then called hack and informed that they agreed with no that the safety clothing producers should not be required to register. Uhile this rather minor problem toe]: approximately an hour and a half and two or three phone call s to resolve, it is indicative of the type of day-to-day services that the dissociation nrevices icr its member companies. Over the past year the Feed and tor ug ?dministrnticn has shcr-m an increased interest in asbestos as a possible hazardous contaminant drugs. Lata in 1972' they set up an asbestos task force to review the situation and to propose regula tions and guidelines where appropriate. Thus far they have concentrated their efforts in two areas ---on _.tiie .use of asbestos-contaminated talc in food packaging and in cosmetics, and secondly, on the use of asbestos celulose filter pads in the beverage ar\d drug industries. In our first moating with' the FDA task force last Hcvembcr on the .falter problem, they demonstrated and admitted to an appalling ignorance about thn health hazards of asbestos. Since then, they have gotten one heck of a lot smarter, due at least in part tc the tremendous amount of data and information which the Assnointjon Page: 13 Vfhy Asbestos?s by tS. t:; 'sW^cjuXc> ATA/lTA Presented to the AID Ariinyh un, vlry:luia -* 6/7/ has been supplying to theuu As o. cmaice, the FDA is today lass panicky about asbestos' and therefore less likely to propose ' foolish, unsupportoble regulations ,, Spokesmen from the FDA have, in. fact, defended the filter industry against, ouvirotanen talist attacks in the press and cli-ewhere 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/ d:' compensation reform, at which time asbestes is unquestionably going to be racked over the coals by Dr. Salikoff and by representatives of organized labor. Unfortunately, the Association, has neither the manpower ncr the time to embark on a full-scale legislative information program., We have met on occasion with the* legislative and legal assistants to various Senators who have attacked asbestos, however much, more needs to be done in this area and I^an afraid individual member Companies are going tc have to be the prime ball carriers and not the Association* - For essentially the 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 con trol has been usurped by various Federal regulatory agencies. Nonetheless, more individual company activity is required at these levels of government. In conclusion, I think ve 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 workman better protected; The gene ral public has been shown to be in no danger from asbestos, if it ever was. V7hile we have been regulated extensively, for the ir.est part the standards that have been developed have net been as bad as we feared they might be, and in some cases they turned out far bet ter than we ever dared hope. In addition, while wc are still taking our lumps in the public press, the not effect of all this adverse publicity has been shown to be surprisingly small. Ue have sweated a lot and we"have groaned-a lot, but we are still' standing and ve are still viable. I sense today within the indus try a greater feeling ofxconfidence in the future than at any tine in the past few years. But.v/e must not rest contented. . .. ............. Ue must remember that Dr. Selikoff has to date been far less sue- " cessful than our industry has in influencing the decisions of the _ various governmental regulatory agencies. This will make him try . ' />;>35Y- t 8 April 1975 Docket Officer Docket H-033 '" ' . U.S. Department of Labor . Room N-3S2Q ' -200 Constitution Avenue Washington, D. C. 20210 .. . . ...... ' ' . '. ..... .. ' ` .. .. ' ' .. . . Dear Sir: - . '. The 120-day extension for comment on the proposed revision, to the OSHA asbestos standard; from. December 8, 1975 to April' 9r ISIS, has permitted this Association the time necessary to sponsor an in dustry-wide review of the proposal and its effect on the asbestos using industry within the United States. . ' . The analysis, comments, and recommendations pertaining to the pro posal are respectfully submitted- in an industry effort to cooperate fully with the Department of Labor in xthe^development of a reasonable and practicable standard for the protection of workers in thousands of work places, where asbestos productsAare manufactured or other--_ wise processed- The task force effdrfcAreached out to all sectors of the asbestos industry, excepting ^construction- The results of this work are contained in the two volumes, appended hereto. The first volume contains ` summary comment's and recommendations prepared by the task force chairman, Guy G. Gabrielson, Jr. ; a statement on the scientific-medical issues raised in the proposal prepared by Hans Weill, M.D. ? and detailed comments Oh the proposed standard, prepared by the Standards and Technical Committee of the Association under the chairmanship of Harrison B. Rhodes, Ph.D. The second volume is the technological feasibility and economic impact study . ` prepared by the independent consultant firm, Roy Weston, Inc. We shall be pleased to further communicate or meet with any officials within OSHA to discuss the findings and recommendations presented ' herewith. - . . '. We believe a public hearing on this matter will best serve the in- . t'erests of asbestos workers, the employers within the industry, and the general public. We request a public hearing at the soonest practicable date. . . ' Sincerely yours, ' rv . . Executive Director Enclosures: (in quadruplicate RHM: v CRMC-M&S-000737