Document N2w1BJxEgaJ17dgoqkdVMZDZR

Bommarito Cs^js Cancer Stud} Summary of Testimony T nfrfir Pt|iai1rr 'nf Hruring on Carcinogens Standard ByURWPreSdi Peter Bommarito f SepteaAanll, 1973 J Washington, D.C. IV f*. ' 7 Superficial &L(J My awareness of' the ntXeflTTal health hazards related to die use and handling of certain carcinogens did not stem from OSHA's promulgation of the May 3, 1973 Emergency Tempo rary Standard of Certain Carcinogens. This awareness goes back at least a decade, and became the prime mover in our 1970 negotiations which estab lished our current involvement in our Joint Occupational Health Program. On April 28, 1972, Floyd Smith, International President of the IAM, members of my Staff and the IUD Staff, and I met with the Secretaries of Labor and HEW' to express our grave concern regarding the lack of specific standards on certain carcino gens. My opening remark at a press conference later that day was as fol lows: "Half-hearted enforcement poli cies of the Department of Labor in the field of Occupational Safety and Health are subjecting an unknown mimacr of workers to needless and highly dangerous contact with cancer producing substances." This statement was made one year after OSHA's effective date. 2Vi Years Late Today, nearly two and one half years after the effective date, wc arc, in reality, just a little beyond the talk ing stage of a formal standard on some of the carcinogens which may or al ready have endangered the health of our workers. I will not attempt to ra tionalize the reasons for this obvious delay by the Departmentof-Labor. Our interest is of a direct nature. Wc are involved in the manufacture of rubber, plastic, linoleum type prod ucts, chemicals and even organic dyes. Our membership has a greater poten tial exposure to certain of the carcino gens than any other AFL^CIO, CLC National or International affiliate. Epidemiological studies con ducted during the late '40's and dur ing the '50's in Great Britain and Lite United Stales, produced salient evi- dcnce of the increased incidence of bladder cancer among rubber workers. These data have led to the prohibition of the use and manufacture of betanaphthylaminc in the State of Penn sylvania in 1960, and were also re sponsible for the 1968 Factory Inspec torate Act on Carcinogenic Substances in Great Britain. Chemicals other than beta-naphthylaminc were added, to various other, lists including the A.C.G.I.H. TLV's for 1972 and 1973 and fourteen sub stances were enumerated in the May 3, 1973 Emergency Temporary Stand ard. Of the fourteen listed carcino gens, nine present a potential hazard to our membersmp. OSHA Study Su terikial At this point. I must comment on OSHA's most recent study, "Some Economic Aspic*> of an Occupational Safe.y and Heal.h Standard for the use of Fourteen Carcinogenic Com pounds.": 1. The study is very superficial and docs not relate to the true picture of the users potential exposure and the number exposed. 2. Some of the information is not factual. 3. The information is misleading, and provides a sense of false security. OSHA's, "Economic Aspects" re port of August 10, 1973, bv admis sion, not only docs not reflect the po tential worker exposure of URW mem bership, but only allows an imaginative approach to the total, "user" worker exposure in this country to the fourteen listed carcinogens. The report vaguely reflects economics of control for the large manufacturers, but docs not reflect the cost to the worker. An approach to our population "at risk" would start with the assump tion that a least 125.000 of our mem bers may be involved in the production or manufacture of rubber products. Of this group, a conservative estimate of the potential exposure group may number 10,000 workers. Our involve ment in the urethane industry could URW Pres. Bommarito conceivably result in another "at risk" group of about 1.500 men or women. Thousands At Risk In considering operations and processes involving heated milling, calendering, molding, and curing procedures and the potential evolution of dusts, fumes, and vapors to general work areas, perhaps the "at risk" group is considerably higher. The esti mate for our present membership could approach 18 to 20 thousand po tentially exposed workers. But how can we make a retro spective estimate of workers having had potential exposures in the early 1920's or 1930's. Tins number couid easily be many hundreds of thousands. Perhaps the mortality and mor bidity studies being conducted by Har vard's and the University of North Carolina's Schools of Public Health may provide more objective data. How can any of us then dismiss the significance and need of a Stand ard on Certain Carcinogens? How can I be less than adamant in my stand when I know that now--today--the vital organs of some of my Brother and Sister Union members have al ready been seeded and are respond ing to deadly cancer? During the testimony to be pre sented here within the next few days, will the real voice of the people, the voice of the worker be equally repre sented--or will the major testimony (continued on page five) 4 BOR 011562 'O i Bommarit Testim ny... (continued from page four) ^Jtcrvcd as a memher of the Advisory ^Committee. T authorized Mr, Bclic- zky's participation not only as a rep t further in-put to the proposed standard seems to be a breach of "good faith" and could lead to the question be from large corporate entities and trade and business associations which will attempt to present a**rwhelmmg data to discredit a Standaf^ on Car cinogens as economically' unreason able, impractical, and that the con tinued risking of workers' lives is justified strictly on the basis of eco nomics? Human Experimentation Perhaps attempts will be made to justify exploiting an uninformed work force by the capricious use of workers as experimental subjects. No qualified professional can honestly and unequivocally state with surety that humans are not "at risk" when ex posed to chemicals which to date have only produced cancer in animals. Arc our medical and clinical sur"eillance programs in this country so total, com plete and sophisticated that no unde tected case has slipped by: Arc all observations of this nature based on only "controlled" human subjects ex posures in large corporations? Have we been able to relate to the small user, who knowingly or unknowingly risks workers by indiscriminate ex posures which are never environmen tally, clinically, or medically moni tored? Or will we hear testimony pre pared by legal advisors for clients, em ployers, or employer representatives who will attempt to rationalize risk of health and life to the dollars and cents of dividends paid to stockholders who wou'd not rest easily if they knew or were aware of the "taint" on that profit dollar. No doubt testimony will be pre sented that some of the chemicals in their pure state are not carcinogenic, without emphasizing thafc, this par ticular chemical, as it is ud today is, in reality, a mixture containing a known potent carcinogen. Will some expert play God and tell us how much of a carcinogen in a mixture is not carcinogenic?! I have read with interest pub lished comments regarding the activi ties of the Advisory Committee ap pointed by the Secretary of Labor, I have listened to progress reports which were periodically presented to me by the URW's Director of Industrial Hy giene. Louis S. Bcliczkv, who has resentative of Labor, but also as a representative of the Union which I serve as International President. Stormy Sessions Transcripts of the Advisory Com mittee meetings certainly indicated some stormy sessions, and at times there was a serious question as to whether or not the committee would or could ever fulfill its prescribed re sponsibility to the Assistant Secretary of Labor, Mr. John Stender, The Committee's responsibilities seemed overwhelming and nearly im possible in the time framework pro vided. Some serious issues which were deferred by committee action were never reconsidered. Mr. Stcnder's cancellation of the approved meetings for the 9th and 10th of September 1973 is considered as a serious deter-ent to any final ac tion by the committee to provide the necessary in-put for the proposed standard. The stage was set, the first two acts were completed, and the cur tain was brought down before the third act finale v'as staged. Unless the finale is presented,, the critics will never be able to judge the full action of the cast in light of their contribu tion to a reasonable, effective and en forceable standard on carcinogens. It is especially important now to set the proper protocol pattern, since future considerations of other carcino gens not currently listed is imminent! To disband the committee with- New Yorker Cites On-Job Hazards The New Yorker Magazine, voice of silk stocking New York and sophisticates everywhere, has completed the publication of a series of articles of unprece dented length: five articles on oc cupational health. Written by Paul Brodeur and called "Annals of Industry," the scries began on Oct. 29 and focuses on the asbestos hazard. It demonstrates how the med ical-industrial complex hides the facts, prevents real action and makes the key decisions in OSHA and NIOSH. |j ing of sound judgement on the part of the Office of Standards and its ad ministrators. This action could destroy the credibility of current or future standards advisory committees. In the time remaining. I must emphasize the need of specific refer ence in the proposed stand on carcino gens of the following essentials:________ URW Demands I. The absolute need of a permit system for the effective implementa-, tion of an enforceable standard. I must emphasize the Standards Advis ory Committee's recommendation: "A, use permit system shall be initiated as an integral part of the permanent standard to provide for effective regu lation of conditions and practices con cerning carcinogens to enhance the implementation of the standard." II. The need of a National Regis try of exposures to carcinogens. NIOSH's assistance in this ttca is en visioned. (N.B.: Items I and II are also the strong recommendations in Report VIT of the ILO's 58th Session regarding the, "Control and Provention of Occupational Cancer.") Jj III. The need of specific continu ing scientific and technical assistance in providing reliable information on:. Jnalyfical and monitoring procedures. B. Medical survciljanee^rograms and more ^information regard ing: arcinogynic responses^ 2. Non-carcinogenic systemic responses'^ /' 3. Ficsfaiid procedures (L-Worker and) management training and/undoctrination programs.^ \ D. Decontamination procedures. EASpgcific protective clothing and other protective'devices. ' F. Data /cgprdfng the^effcct of t these/Carcinogens" related to j j>rdispo<iing'' synergistic re- | 'spbpseST 'I G. ^Research in-ptU,^.-regarding | ^'tolerance-dose-fime responses, j (_ IV. The"'istablislnnent of an AcT/v Hoc Review Committee of effective / j size and representation which would*' J act in an objective advisory capacity ' to assist the Secretary. BOR 0X1563 5